United States Department of Agriculture 

Forest Service

Malheur National Forest Site-Specific 

Invasive Plants Treatment Project

Draft Environmental Impact Statement

Grant, Baker, Harney, Malheur and Crook Counties, Oregon

October 2013
The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers, employees, and 

applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, 

religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual 

orientation, or all or part of an individual's income is derived from any public assistance program, or protected 

genetic information in employment or in any program or activity conducted or funded by the Department. (Not 

all prohibited bases will apply to all programs and/or employment activities.)

To File an Employment Complaint

If you wish to file an employment complaint, you must contact your agency's EEO Counselor within 45 days of 

the date of the alleged discriminatory act, event, or in the case of a personnel action. Additional information can 

be found online at www.ascr.usda.gov/complaint_filing_file.html.

To File a Program Complaint

If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program 

Discrimination Complaint Form (PDF), found online at www.ascr.usda.gov/ complaint_filing_cust.html, or at 

any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the 

information requested in the form. Send your completed complaint form or letter to us by mail at U.S. 

Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, 

D.C. 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov.

Persons with Disabilities

Individuals who are deaf, hard of hearing or have speech disabilities and you wish to file either an EEO or 

program complaint please contact USDA through the Federal Relay Service at (800) 877-8339 or (800) 845-

6136 (in Spanish).

Persons with disabilities who wish to file a program complaint, please see information above on how to contact 

us by mail directly or by email. If you require alternative means of communication for program information 

(e.g., Braille, large print, audiotape, etc.) please contact USDA's TARGET Center at (202) 720-2600 (voice and 

TDD).
i

Malheur National Forest Site-Specific Invasive Plants

Treatment Project Draft Environmental Impact Statement

Grant, Baker, Harney, Malheur and Crook Counties, Oregon

Lead Agency: USDA Forest Service

Malheur National Forest

Responsible Official: Teresa Raaf, Forest Supervisor

Malheur National Forest

431 Patterson Bridge Road

PO Box 909

John Day, OR 97845

Information Contact: Joseph H. Rausch

Malheur National Forest

431 Patterson Bridge Road

PO Box 909

John Day, OR 97845

Phone: 541-575-3141

Email: jhrausch@fs.fed.us

The DEIS can be viewed and downloaded from the internet at 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=35614 In addition, an electronic copy on a CD 

or a hard copy is available upon request from Joseph H. Rausch using the contact information provided 

previously.

Abstract

This draft environmental impact statement (DEIS) discloses the effects of treating invasive plants in the 

Malheur National Forest. Invasive species were identified by the Chief of the Forest Service as one of the 

four threats to forest health (for more information see http://www.fs.fed.us/project/four-threats). Invasive 

plants are displacing native plants, potentially destabilizing streams, reducing the quality of fish and 

wildlife habitat; and degrading natural areas. 

We propose to treat invasive plants using integrated treatment methods in cooperation with our neighbors, 

and in accordance with the R6 2005 ROD and other relevant management direction, to reduce the extent 

and impact of invasive plants. The underlying purpose of treating invasive plant infestations is to maintain 

or improve the diversity, function, and sustainability of desired native plant communities and other natural 

resources that can be adversely impacted by invasive plant species. 

The project area encompasses the entire 1,459,422-acre Malheur National Forest and 240,000 acres of the 

Ochoco National Forest that are managed by the Malheur Forest (previously known as the Snow 

Mountain Ranger District, now managed as part of the Emigrant Creek Ranger District.) for a total of 

nearly 1.7 million acres located in eastern Oregon. These 1.7 million acres is the acreage considered as 

the Malheur National Forest for purposes of this analysis. We estimate at this time (using our updated 

inventory), approximately 2,124 acres of invasive plants need to be suppressed, contained, controlled or 

eradicated.

Invasive plant spread is unpredictable and actual locations of target species may change abruptly over 

time. Accordingly, we need the flexibility to adapt to changing conditions, and rapidly respond to invasive 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

ii

plant threats that may currently be unknown. Timeliness of action is an important factor because the cost, 

difficulty, and potential adverse effects of controlling invasive plants increases with the size and extent of 

the population. The smaller the population when treated, the more likely the treatment will be effective. 

The proposed action includes a decision process and design features to ensure that treatments used for 

rapid response to new detections are within the scope of this analysis. This DEIS includes detailed 

consideration of four alternatives:

Alternative A, the no-action alternative would not approve any invasive plant treatments. 

Alternative B, the proposed action, is our proposal as the most cost-effective approach to invasive 

plant treatment while minimizing the adverse effects of treatment. Alternative B responds to the 

purpose and need for action by authorizing several herbicide and other integrated treatment methods 

to be implemented on the Forest over the next 5 to 15 years. These options are intended to effectively 

reduce the size and density of invasive sites and abate the adverse effects of invasive plants. The 

project would continue to be implemented each year until the treatments were no longer needed or 

conditions substantially change on the ground to such a degree that the analysis in this EIS is no 

longer valid. The annual implementation planning process discusses how changed conditions would 

be evaluated for this project over time. This alternative would comply with standards and guidelines 

associated with invasive plant management and allow use of any of the 10 herbicides authorized for 

use in the R6 2005 ROD. It would also amend the Malheur National Forest Land and Resource 

Management Plan (LRMP) to allow the use of a new herbicide ingredient, aminopyralid.

Two action alternatives were developed in response to public issues related to herbicide use:

Alternative C was developed in response to some public concerns about herbicide use on the Malheur 

National Forest. Alternative C would impose strict limitations on our ability to use herbicides to treat 

invasive plants. Compared to alternative B, alternative C responds to public issues about herbicide 

impacts to human health, non-target vegetation and pollinators, soils, water, aquatic organisms, and 

wildlife, while still allowing for some limited herbicide use. Under alternative C, all of the alternative 

components for alternative B would be followed (including a Malheur National Forest LRMP

amendment to allow use of aminopyralid), however, no broadcasting of herbicide would be allowed. 

No boom spraying would be allowed. Maximum herbicide application rates per acre would be 

reduced by about 30 percent across the board. No herbicide use would be allowed within the 

boundaries of any mapped infested area that at any point is within 100 feet of creeks, lakes, ponds and 

wetlands. Picloram would be eliminated from the list of available herbicides. 

Alternative D, no Land and Resource Plan amendment and no aminopyralid, was developed to 

evaluate the tradeoffs involved with adding aminopyralid to the list of available herbicides in standard 

16. Some members of the public have expressed doubt about whether or not this herbicide should be 

approved, mainly because it is new and effectively kills broadleaf plants. Alternative D would be 

similar to alternative B, except a Forest Land and Resource Management Plan amendment would not 

be completed and aminopyralid would not be approved for use on the Malheur National Forest. 

Aminopyralid would not be used to treat known sites or new detections. All of the components of 

alternative B would apply, except those that refer to aminopyralid would not be included. 
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement

iii

Figure 1. Vicinity Map
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

iv

Table of Contents

List of Acronyms _____________________________________________________________ ix

Summary __________________________________________________________________S-1

Introduction ______________________________________________________________S-1

Extent of the Primary Target Species and Management Objectives ___________________S-1

Integrated Control Measures _________________________________________________S-3

Alternatives ____________________________________________________________S-8

Alternative Comparison __________________________________________________S-10

Chapter 1. Purpose and Need for Action ___________________________________________ 1

1.1 Introduction ____________________________________________________________ 1

1.2 Background ____________________________________________________________ 2

1.3 Project Area ____________________________________________________________ 3

1.4 Desired Future Conditions _________________________________________________ 5

1.5 Purpose and Need________________________________________________________ 5

1.6 Proposed Action_________________________________________________________ 6

1.7 Management Direction____________________________________________________ 6

1.7.1 Land and Resource Management Plan ____________________________________ 7

1.7.2 Additional Guidance _________________________________________________ 10

1.8 Decision to be Made ____________________________________________________ 11

1.9 Public Involvement and Scoping ___________________________________________ 11

1.10 Issues _______________________________________________________________ 12

1.10.1 Treatment Cost-Effectiveness _________________________________________ 12

1.10.2 Herbicide Impacts to Human Health ____________________________________ 12

1.10.3 Herbicide Impacts on Nontarget Vegetation and Pollinators _________________ 13

1.10.4 Delivery to Water and Potential Herbicide Impacts on Fish __________________ 13

1.10.5 Herbicide Impacts on Wildlife ________________________________________ 14

1.10.6 Other Issues _______________________________________________________ 14

1.11 What this Proposal Does Not Include ______________________________________ 15

Chapter 2. Alternatives, Including the Proposed Action ______________________________ 17

2.1 Introduction ___________________________________________________________ 17

2.2 Extent of the Primary Target Species and Management Objectives ________________ 17

2.3 Alternatives Considered in Detail __________________________________________ 19

2.3.1 Alternative A – No Action ____________________________________________ 19

2.3.2 Alternative B – Proposed Action________________________________________ 21

2.3.3 Alternative C – Strict Limitations on Herbicide Use_________________________ 51

2.3.4 Alternative D – No Forest Plan Amendment, No Aminopyralid _______________ 53

2.4 Alternatives Considered but Eliminated from Detailed Study_____________________ 54

2.4.1 Alternative to Evaluate Effectiveness of Past Treatments by a Third Party _______ 54

2.4.2 Limitations on Herbicide-use Rates for All Herbicides ______________________ 54

2.4.3 Mandatory Decline on Herbicide Use Over Time___________________________ 55

2.4.4 Use of Herbicides As a Last Resort______________________________________ 55

2.4.5 Use of Herbicides for Only the Highest Priority Target Species________________ 55

2.4.6 No Herbicide Use in a Variety of Areas __________________________________ 55

2.4.7 No Early Detection and Rapid Response _________________________________ 56

2.5 Alternatives Compared___________________________________________________ 57

Chapter 3. Affected Environment and Environmental Consequences ____________________ 65

3.1. Introduction___________________________________________________________ 65

3.1.1 The Effects Analysis _________________________________________________ 65

3.1.2 Herbicide Risk Assessments ___________________________________________ 66

3.1.3 Site Types _________________________________________________________ 68
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement

v

3.1.4 Treatment Costs and Effectiveness ______________________________________ 68

3.1.5 Introduction to the Cumulative Effects Analysis____________________________ 75

3.2 Human Health _________________________________________________________ 89

3.2.1 Introduction ________________________________________________________ 89

3.2.2 Affected Environment ________________________________________________ 90

3.2.3 Environmental Consequences __________________________________________ 91

3.3 Botany _______________________________________________________________ 99

3.3.1 Introduction ________________________________________________________ 99

3.3.2 Affected Environment _______________________________________________ 100

3.3.3 Environmental Consequences _________________________________________ 106

3.4 Soils ________________________________________________________________ 118

3.4.1 Introduction _______________________________________________________ 118

3.4.2 Affected Environment _______________________________________________ 118

3.4.3 Environmental Consequences _________________________________________ 123

3.5 Water Quality _________________________________________________________ 131

3.5.1 Introduction _______________________________________________________ 131

3.5.2 Affected Environment _______________________________________________ 132

3.5.3 Environmental Consequences _________________________________________ 137

3.6 Fisheries _____________________________________________________________ 146

3.6.1 Introduction _______________________________________________________ 146

3.6.2 Affected Environment _______________________________________________ 149

3.6.3 Environmental Consequences _________________________________________ 154

3.7 Wildlife _____________________________________________________________ 170

3.7.1 Introduction _______________________________________________________ 170

3.7.2 Affected Environment _______________________________________________ 171

3.7.3 Environmental Consequences _________________________________________ 199

3.8 Range _______________________________________________________________ 240

3.8.1 Introduction _______________________________________________________ 240

3.8.2 Affected Environment _______________________________________________ 242

3.8.3 Environmental Consequences _________________________________________ 246

3.9 Recreation and Special Places ____________________________________________ 253

3.9.1 Introduction _______________________________________________________ 253

3.9.2 Affected Environment _______________________________________________ 254

3.9.3 Environmental Consequences _________________________________________ 256

3.10 Archeological Resources _______________________________________________ 260

3.10.1 Introduction ______________________________________________________ 260

3.10.2 Affected Environment ______________________________________________ 261

3.10.3 Environmental Consequences ________________________________________ 261

3.11 Specifically Required Disclosures ________________________________________ 262

3.11 1 Irreversible or Irretrievable Impacts ___________________________________ 262

3.11.2 Long-term Productivity _____________________________________________ 262

3.11.3 Energy Requirements and Conservation Potential ________________________ 262

3.11.4 Non-significant Land and Resource Management Plan (LRMP) Amendment ___ 262

3.11.5 Floodplains and Wetlands ___________________________________________ 263

3.11.6 Prime Farmlands __________________________________________________ 264

Chapter 4. Consultation and Coordination ________________________________________ 265

List of Preparers and Consultation ____________________________________________ 265

List of People to Whom This EIS has been Sent _________________________________ 265

Individuals ____________________________________________________________ 265

Organizations, Industry, and Local Agencies__________________________________ 265

Oregon State Agencies ___________________________________________________ 266

Tribal Contacts _________________________________________________________ 266
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

vi

Federal Agencies _______________________________________________________ 266

Local Officials _________________________________________________________ 266

References ______________________________________________________________ 267

Glossary ________________________________________________________________ 290

Index __________________________________________________________________ 304

Appendix A – Invasive Plant Inventory Watershed Analysis for the Malheur National Forest 307

Summary of Invasive Plant Infestations by Watershed ____________________________ 309

North Fork John Day Sub-basin (17070202)____________________________________ 311

Cottonwood Creek (1707020209) __________________________________________ 312

Lower North Fork John Day River (1707020210) ______________________________ 313

Middle Fork John Day Sub-basin (17070203)___________________________________ 314

Bridge Creek- Middle Fork John Day River (1707020301)_______________________ 315

Camp Creek- Middle Fork John Day River (1707020302) _______________________ 316

Big Creek- Middle Fork John Day River (1707020303) _________________________ 317

Long Creek (1707020304) ________________________________________________ 319

Upper John Day Sub-basin – Main Stem Portion (17070201)_______________________ 320

Reynolds Creek-John Day River (1707020105) _______________________________ 321

Grub Creek-John Day River (1707020106) ___________________________________ 322

Canyon Creek (1707020107) ______________________________________________ 323

Beech Creek (1707020108) _______________________________________________ 324

Laycock Creek-John Day River (1707020109) ________________________________ 325

Fields Creek-John Day River (1707020110) __________________________________ 326

Upper John Day Sub-basin – South Fork Portion (17070201) ______________________ 327

Upper South Fork John Day River (1707020101) ______________________________ 328

Middle South Fork John Day River (1707020102) _____________________________ 329

Murderers Creek (1707020103) ____________________________________________ 330

Upper Malheur Sub-basin – North Fork Portion (17050116) _______________________ 331

Upper North Fork Malheur River (1705011611) _______________________________ 332

Little Malheur River (1705011612) _________________________________________ 333

Upper Malheur Sub-basin – Main Stem Portion (17050116) _______________________ 334

Headwaters Malheur River (1705011601) ____________________________________ 335

Wolf Creek (1705011602) ________________________________________________ 336

Pine Creek (1705011603)_________________________________________________ 337

Griffin Creek-Upper Malheur River (1705011605) _____________________________ 338

Otis Creek (1705011606) _________________________________________________ 339

Silvies River Sub-basin (17120002) __________________________________________ 340

Headwaters Silvies River (1712000201) _____________________________________ 341

Bear Creek (1712000202) ________________________________________________ 342

Upper Silvies River (1712000203)__________________________________________ 343

Middle Silvies River (1712000204) _________________________________________ 344

Emigrant Creek (1712000205)_____________________________________________ 345

Sage Hen Creek (1712000206) ____________________________________________ 346

Silver Creek Sub-basin (17120004)___________________________________________ 347

Claw Creek (1712000401) ________________________________________________ 348

Upper Silver Creek (1712000402) __________________________________________ 349

Middle Silver Creek (1712000403) _________________________________________ 350

Harney-Malheur Lakes Sub-basin (17120001) __________________________________ 351

North Basin (1712000101)________________________________________________ 352

Malheur Slough (1712000102)_____________________________________________ 353

Deschutes River Basin (170703) _____________________________________________ 354

South Fork Beaver Creek (1707030305) _____________________________________ 355
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement

vii

List of Tables

Table S- 1. Current treatment objectives for mapped, primary invasive plant species_______ S-2

Table S- 2. Common control measures___________________________________________ S-4

Table S- 3. Alternative comparison by activity ___________________________________ S-11

Table S- 4. Comparison of first year/first choice herbicide by alternative_______________ S-12

Table S- 5. Alternative comparison relative to significant issues______________________ S-13

Table 1. R6 2005 Standards and Project Compliance _________________________________ 7

Table 2. Infested acres _________________________________________________________ 9

Table 3. Current treatment objectives for mapped, primary invasive plant species__________ 18

Table 4. Biological agents released on neighboring lands _____________________________ 20

Table 5. Proposed treatment methods descriptions __________________________________ 23

Table 6. Summary of herbicide use under alternative B_______________________________ 24

Table 7. Herbicide descriptions _________________________________________________ 26

Table 8. Common control measures ______________________________________________ 28

Table 9. Project Design Features ________________________________________________ 32

Table 10. Herbicide-use buffers (in feet) for streams, wetlands, lakes and ponds with water 

present at the time of treatment. Measured in feet from the edge of surface water.______ 43

Table 11. Herbicide-use buffers (in feet) for stream channels that are dry at the time of treatment. 

Measured in feet from the edge of the channel as defined by the high water (bankfull) mark

______________________________________________________________________ 43

Table 12. Management objectives under early detection and rapid response_______________ 47

Table 13. Summary of herbicide and non-herbicide use under alternative C_______________ 53

Table 14. Summary of herbicide use under alternative D _____________________________ 53

Table 15. Alternative comparison by activity_______________________________________ 57

Table 16. Comparison of first year/first choice herbicide by alternative __________________ 58

Table 17. Alternative comparison relative to significant issues _________________________ 60

Table 18. Herbicide risk comparison table_________________________________________ 67

Table 19. Site type criteria and acres _____________________________________________ 68

Table 20. Most ambitious treatment scenario and costs for alternative B _________________ 72

Table 21. Most ambitious treatment scenario and costs for alternative C _________________ 73

Table 22. Most ambitious treatment scenario and costs for alternative D _________________ 74

Table 23. Results of the cost-effectiveness analysis for alternatives _____________________ 74

Table 24. Potential disturbance frequency for invasive plants spread ____________________ 82

Table 25. Foreseeable future projects on the Forest with project details, vectors for invasive plant 

spread, watershed(s) affected and implementation schedule _______________________ 83

Table 26. Watersheds containing planned future activities and invasive plant treatments_____ 88

Table 27. Project design features in alternative b that address human health concerns _______ 97

Table 28. Potential Vegetation Groups on the Malheur National Forest’s 1.7 million acres and 

their susceptibility to invasive plants ________________________________________ 100

Table 29. Sensitive plant populations within 100 feet of proposed invasive treatment areas _ 101

Table 30. Sensitive plant species documented (D), suspected (S), or having a historical record 

(H) on the Malheur National Forest _________________________________________ 102

Table 31. Summary of effects to sensitive plants and special forest products _____________ 117

Table 32. Most common soil types from SSURGO mapping-sort is from dry to mesic vegetation 

types _________________________________________________________________ 122

Table 33. Soil properties of prevalent soil series ___________________________________ 123

Table 34. Beneficial uses of major streams on the Malheur National Forest______________ 135

Table 35. Drinking water sources_______________________________________________ 135

Table 36. Acres of occurrence of invasive plants near roads and streams ________________ 136

Table 37. Herbicides physical/chemical properties _________________________________ 138

Table 38. GLEAMS model runs results. All values in ppm. __________________________ 140
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

viii

Table 39. GLEAMS model results for alternative C ________________________________ 144

Table 40. Aquatic species of conservation concern _________________________________ 149

Table 41. Special Status Fish in John Day River Watersheds _________________________ 150

Table 42. Invasive Plants and Fish Species in 5th field watersheds_____________________ 153

Table 43. Levels of concern for fish from project herbicides based on the R6 2005 FEIS and 

2007 SERA Risk Assessment for aminopyralid________________________________ 156

Table 44. Bull trout PCEs and MPI habitat indicators _______________________________ 159

Table 45. Invasive Plants and Fish Species in 5th field watersheds_____________________ 162

Table 46. Draft Determinations for Fish Species of Conservation Concern ______________ 167

Table 47. Cumulative effects, qualitative estimates within focus watersheds for fisheries ___ 169

Table 48. ESA species (listed, proposed, candidate, delisted) _________________________ 172

Table 49. Acres of Lynx habitat in the project area _________________________________ 174

Table 50. Forest Service sensitive species in the project area _________________________ 177

Table 51. Management Indicator Species on the Malheur NF and Ochoco NF____________ 190

Table 52. Habitat for Cavity Nesters (MIS) _______________________________________ 193

Table 53. Habitat for Featured Species __________________________________________ 194

Table 54. Northern Rocky Mountain Habitat Types - Landbird Focal Species and Their Habitats

_____________________________________________________________________ 196

Table 55. Columbia Plateau Habitat Types - Landbird Focal Species and Their Habitats ___ 197

Table 56.Birds of Conservation Concern _________________________________________ 198

Table 57. Gamebirds below desired condition _____________________________________ 198

Table 58. Toxicity indices for birds _____________________________________________ 203

Table 59. Toxicity indices for mammals _________________________________________ 204

Table 60. Exposure scenario results from FS risk assessments for mammals, birds, and 

honeybees, using the typical and highest application rates and assuming upper residue rates

_____________________________________________________________________ 206

Table 61. First year/first choice treatments by habitat type and action alternative _________ 208

Table 62. Watersheds containing planned future activities and invasive plant treatments ___ 213

Table 63. Draft findings and determinations for ESA-listed wildlife species in the project area

_____________________________________________________________________ 215

Table 64. Sensitive Species determinations and rationale ____________________________ 216

Table 65. Treatment effects determinations for management indicator species (MIS) ______ 231

Table 66. Exposure groups, habitat and species included in each group _________________ 238

Table 67. Standards from the R6 2005 ROD and the relationship to Range Management ___ 241

Table 68. Invasive plant species information by allotment ___________________________ 243

Table 69. Allotment use and invasive plants ______________________________________ 245

Table 70. Herbicide label restrictions relevant to range______________________________ 247

Table 71. Acres of Inventoried Roadless Areas ____________________________________ 255

Table 72. Number of invasive plants by Recreation Resource Area and Alternative _______ 256

List of Figures

Figure 1. Vicinity Map ..................................................................................................................iii

Figure 2. Malheur National Forest project area map with infestations.......................................... 4

Figure 3. Herbicide-use buffers.................................................................................................... 42

Figure 4. Questions that facilitate the decision for using herbicides............................................ 50

Figure 5. One sample area showing treatment distribution .......................................................... 59

Figure 6. Target invasive plant sites by elevation ...................................................................... 120

Figure 7. Modeled soil concentrations (ppm) on Wonder Series soils in the Clear Creek 

watershed............................................................................................................................ 125

Figure 8. Disturbance from ongoing forest activities................................................................. 130
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement

ix

Figure 9. Precipitation pattern at Austin weather station............................................................133

Figure 10. Stream flow at selected gages and precipitation at John Day ...................................134

Figure 11. Location in Middle Fork John Day River of GLEAMS model sites.........................143

Figure 12. Focus watersheds for fisheries analysis.....................................................................163

Figure A- 1. Watershed Groups..................................................................................................308

Figure A- 2. Invasive plants infestation summary......................................................................310

Figure A- 3. North Fork John Day Sub-basin (17070202).........................................................311

Figure A- 4. Middle Fork John Day Sub-basin (17070203).......................................................314

Figure A- 5. Upper John Day Sub-basin – Main Stem Portion (17070201) ..............................320

Figure A- 6. Upper John Day Sub-basin - South Fork Portion (17070201)...............................327

Figure A- 7. Upper Malheur Sub-basin – North Fork Portion (17050116)................................331

Figure A- 8. Upper Malheur Sub-basin – Main Stem Portion (17050116)................................334

Figure A- 9. Silvies River Sub-basin – 17120002......................................................................340

Figure A- 10. Silver Creek Sub-basin (17120004).....................................................................347

Figure A- 11. Harney-Malheur Lakes Sub-basin (17120001)....................................................351

Figure A- 12. Deschutes River Basin (170703), South Fork Beaver Creek (1707030305) .......354

List of Acronyms

APHIS Animal and Plant Health Inspection Service

ATV All-terrain vehicle

AUM Animal Unit Month

BA Biological Assessment

BCC Birds of Conservation Concern

BCR Bird Conservation Region

BE Biological Evaluation

BLM Bureau of Land Management

BMP Best Management Practices

BO Biological Opinion

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CWA Clean Water Act

d.b.h. Diameter Breast Height

DEIS Draft Environmental Impact Statement

DOG Dedicated Old Growth

DN Decision Notice

DPS Distinct Population Segments

DWD Down Woody Debris

EA Environmental Assessment

EDRR Early detection rapid response

EFH Essential fish habitat

EIS Environmental Impact Statement

EPA Environmental Protection Agency

ESA Endangered Species Act

FACTS Forest Service Activity Tracking System

FEIS Final Environmental Impact Statement

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FOSS Federal OSHA Safety Standard

FP Forest Plan

FS Forest Service

FSH Forest Service Handbook

FSM Forest Service Manual

FWS Fish and Wildlife Service

GIS Geographical information system

GLEAMS Groundwater Loading Effects of Agricultural Management Systems

GPS Global positioning system

HEI Habitat Effectiveness Index
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

x

HCB hexachlorobenzene

HQ Hazard quotient

HUC Hydrologic Unit Codes

IDT Interdisciplinary Team

INFISH Inland Native Fish Strategy

IRA Inventoried Roadless Areas

IWM Integrated weed management

LAU Lynx analysis units

LCAS Lynx Conservation Assessment and Strategy

LOAEL Lowest observed adverse effect level

LRMP Land and Resources Management Plan

LWD Large Woody Debris

MCR Middle Colombia River

MIS Management Indicator Species

MPG Major Population Group

MPI Matrix of Pathways and Indicators

MSA Magnuson Stevens Act

NEPA National Environmental Policy Act

NF National Forest

NFMA National Forest Management Act

NFS National Forest System 

NMFS National Marine Fisheries Service

NOA Notice of Availability

NOAEL No observed adverse effect level

NOI Notice of Intent

NPE Nonylphenol Polyethoxylate

NSA National Scenic Areas

NST National Scenic Trails

NVUM National Visitors Use Monitoring

ODFW Oregon Department of Fish and Wildlife

OHV Off-highway vehicles

ONF Ochoco National Forest

OR Oregon

ORV Outstanding Remarkable Values

OSU Oregon State University

PA Proposed Action

PACFISH Pacific Native Fish Strategy

PCE Primary Constituent Elements

pdf Project design feature

PIF Partner in Flight

PFA Post Fledgling Area

PNW Pacific Northwest

POEA Polyoxyethylene alkylamine

PPE Personal Protective Equipment

R6 Forest Service Pacific Northwest Region Six

RHCA Riparian Habitat Conservation Area

RMO Riparian Management Objectives

RNA Research Natural Areas

ROD Record of Decision

ROG Replacement Old Growth

ROS Recreation Opportunity Spectrum

ROW Right of Way

SERA Syracuse Environmental Research Associates, Inc.

SHPO State Historic Preservation Office

SMU Species Management Units

SOLI Species of local interest

TES Threatened, Endangered and Sensitive

TMDL Total maximum daily load

TNC The Nature Conservancy

USDA United States Department of Agriculture

USDI United States Department of Interior

USFS United States Forest Service

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement

xi

WA Washington

WEPP Water Erosion Prediction Project

WSR Wild and Scenic River
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

xii

This page left blank intentionally
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-1

Summary

Introduction

Invasive species were identified by the Chief of the Forest Service as one of the four threats to forest 

health (for more information see http://www.fs.fed.us/project/four-threats). Invasive plants are 

currently damaging the ecological integrity of lands. They are displacing native plants, increasing the 

potential for soil erosion and potentially destabilizing streams, reducing water quality and the quality 

of fish and wildlife habitat, and degrading natural areas. Invasive plants can have adverse effects on 

rare or endemic species, which could result in listing under state or federal endangered species laws. 

Land managers for the Malheur National Forest (Forest) propose to suppress, contain, control, and 

eradicate invasive plants using an integrated approach to treatment methods that includes herbicide 

mechanical, manual, cultural and biological agents1

. Currently, we estimate that invasive plants 

occupy approximately 2,124 acres on the Malheur National Forest. The infestations are broadly 

distributed, often occurring in areas of high spread-potential (e.g., along roads). It is expected that 

additional invasive plant sites exist but have not yet been identified, so new invasive plants are likely 

to be introduced over time.

This DEIS focuses on treatment of invasive plants and restoration of treated sites. It is tiered to the 

broader scale Pacific Northwest Region Invasive Plant Program Preventing and Managing Invasive 

Plants FEIS (USDA Forest Service 2005a) along with the accompanying Record of Decision for 

Invasive Plant Program Management (USDA Forest Service 2005b), herein referred to as R6 2005 

FEIS and R6 2005ROD.

Extent of the Primary Target Species and Management 

Objectives

As of November 2012, we estimate that 2,124 acres currently need to be treated within the Malheur 

National Forest. There are 18 primary target invasive species within 3,070 mapped infested sites 

(GIS polygons). Site-specific integrated treatment objectives and methods (also referred to as 

common control measures) vary depending on the size and density of the infestation, its location and 

the target species, and the design features associated with each action alternative. Invasive plants are 

scattered throughout the infested areas with density ranging from less than 10 percent to 100 percent 

primary target species.2

We assigned preliminary treatment objectives to each of the primary target species depending on its

potential negative impacts, the size of infestations, and the values or sensitivity of the infested sites

(or adjacent lands). These objectives are subject to change as site conditions change over time. Table 

S- 1 displays our current treatment objectives for the 18 primary invasive species mapped on the 

Malheur National Forest. “Eradication” is our highest priority, and “tolerate” represents the lowest 

 1 This project-level EIS responds to the need for suppression, containment, control and eradication of 18 

primary invasive species currently found on the Malheur National Forest. It also responds to the need to 

rapidly treat new detections of these or other invasive species found in the future. Our invasive plant 

management program is comprised of several interrelated aspects, including preventing the introduction, 

establishment, and spread of invasive plants on and adjacent to the Forest, and working with other agencies and 

groups to increase program effectiveness. This EIS is tiered to the R6 2005 FEIS, which analyzes other aspects 

of the invasive plant management program.

2 This analysis assumes all sites are 100% occupied by invasive species because this variable is subject to rapid 

change.
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-2

priority for integrated treatment and restoration. All other things being equal, we treat highest 

priorities first. However, many other variables factor into our annual program of work. Below are 

definitions of our invasive plant treatment objectives. R6 2005 Standards 12 and 13 require that we 

identify the desired future condition and objectives before implementing integrated treatments.

Eradicate: Eliminate an invasive plant species from a site. This objective generally applies to 

species that are difficult to control and cover small areas. Some occurrences may be on roadsides 

(Russian knapweed, squarrose knapweed) and others may occur in intact native vegetation (yellow 

starthistle, small occurrences of thistles or knapweed, new invaders). This is generally our first 

priority for treatment.

Control: Reduce the size of the infestation over time; some level of infestation may be acceptable. 

This objective applies to most of the target species (houndstongue, leafy spurge, perennial 

pepperweed, St. Johnswort, sulfur cinquefoil, whitetop) and large infestations of thistles and 

knapweeds. This is generally our second priority for treatment.

Contain: Prevent the spread of the weed beyond the perimeter of patches or infestation areas 

mapped from current inventories. This objective applies to target species such as reed canary grass 

and St. Johnswort. This is generally our third priority for treatment.

Suppress: Prevent seed production throughout the target patch and reduce the area coverage. Prevent 

the invasive species from dominating the vegetation of the area; low levels may be acceptable. This 

objective applies to target species such as toadflax that would be treated mainly with biocontrol 

agents. This is generally our fourth priority for treatment.

Tolerate: Accept the continued presence of established infestations and the probable spread to 

ecological limits for certain species. This category is for species that are so widespread and abundant 

that other objectives would be extremely difficult to meet. This category includes species such as 

cheatgrass, medusahead North Africa grass, dandelion, mullein, and bulbous bluegrass. These 

invasive plants have low priority for treatment and would likely only be treated if they happen to be 

near one of the primary target species.

Table S- 1. Current treatment objectives for mapped, primary invasive plant species

Target 

Species

Category

Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Knapweeds 

Spotted knapweed 171 82

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Diffuse knapweed 213 74

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Russian knapweed 43 4 Eradicate
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-3

Target 

Species

Category

Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Squarrose knapweed 3 <1

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Meadow knapweed 2 <1

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Starthistle Yellow star-thistle 3 1 Eradicate

Thistles

Canada thistle 1,277 1,021 Control

Bull thistle* 0 0

Eradicate small infestations in 

ecologically-sensitive areas

Control roadside infestations, large 

open sites and forested sites

Scotch Thistle 61 23

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Musk thistle 13 11

Eradicate small infestations in 

ecologically-sensitive areas

Control roadside infestations, large 

open sites and forested sites

Roadside 

Species

Common St. Johnswort 185 120 Contain

Houndstongue 171 340 Control

Sulphur cinquefoil 61 186 Control

Toadflax

Dalmatian toadflax 666 155 Suppress

Yellow toadflax 27 9 Suppress

Mustards Whitetop 148 85 Control

Perennial pepperweed 12 2 Control

Spurge Leafy spurge 14 10 Control

Total 3,070 2,124

*Bull thistle and Canada thistle were cataloged together in our November 2012 invasive plant inventory. However, the precise 

species would be identified to determine the specific treatment objective for a given site.

The underlying purpose of treating invasive plant infestations is to maintain or improve the diversity, 

function, and sustainability of desired native plant communities and other natural resources that can 

be adversely impacted by invasive plant species.

Integrated Control Measures

Table S- 2 lists the integrated control measures effective for the 18 primary target species currently 

mapped on the Malheur National Forest. The first-choice herbicide is the one that is considered most 

effective for each target species. Other effective herbicides and integrated treatment methods may 

also be used, depending on the location of the infestation and the design of each action alternative.
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-4

Table S- 2. Common control measures

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

Yellow star-thistle

Centaurea solstitialis

(CESO3)

Annual

aminopyralid

clopyralid

glyphosate

picloram

Early detection and treatment increase the 

chances of control. 

Treatment of small infestations in otherwise 

healthy sites should be a priority Biological 

control agents are available. 

Hand pull when soil is moist and remove all 

roots and flower and seed heads.

Common St. Johnswort

Hypericum perforatum

(HYPE)

Perennial with stolons and 

rhizomes

aminopyralid

glyphosate

metsulfuron 

methyl

picloram

Biological agents are available. 

Small infestations may be controlled by 

pulling or digging. Repeated treatments will 

be necessary because lateral roots can 

give rise to new plants. Bag and remove all 

plant parts from site.

Sulphur cinquefoil

Potentilla recta

(PORE5)

Taprooted perennial that 

may have several shallow, 

spreading branch roots 

but not rhizomes

metsulfuron 

methyl

glyphosate 

picloram

triclopyr

Cultural treatments such as seeding of 

native plants may be effective.

There are no approved biocontrols.

Small infestations may be controlled by 

hand digging if the entire root crown is 

removed.

For large infestations, selective herbicides 

are likely the only method of effective 

control (TNC 2004).

Repeated treatments are needed for the 

first couple of years to ensure reestablishment does not occur.

Russian knapweed

Acroptilon repens

(ACRE3)

Long-lived creeping 

perennial

aminopyralid

clopyralid

chlorsulfuron

glyphosate

imazapyr

metsulfuron 

methyl

picloram

Hand pulling is effective only in the 

establishment year. 

Reproduces mainly by vegetative 

propagation from buds on creeping roots.

Biocontrol agents being developed.

Cutting or mowing several times per year 

will control top growth and seed production; 

re-emerging plants will have less vigor.

Lasting control requires an integrated 

approach; using mechanical or cultural 

measures with herbicide application, 

especially in late fall, is most effective.

Small, isolated infestations should be 

eradicated first. Then larger infestations 

should be controlled from the perimeter 

and eradicated when possible.
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-5

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

Spotted knapweed

Centaurea stoebe ssp. 

Micranthos

(CESTM)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

triclopyr

picloram

Treatment would focus on reducing seed 

production and preventing germination.

Biological agents are available.

Repeated manual pulling and digging may 

eliminate small infestations (2-4 times per 

year for multiple years). Pull prior to seed 

set. Bag and remove flower and seed 

heads.

Diffuse knapweed

Centaurea diffusa

(CEDI)

Short-lived perennial, 

biennial or annual. Often 

with a long, stout taproot

aminopyralid

clopyralid

glyphosate

picloram

triclopyr

Squarrose knapweed

Centaurea ulfome ssp. 

Squarrosa

(CEVIS2)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

picloram

triclopyr

Meadow knapweed

Centaurea jacea 

sensulato

(CEJA)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

picloram

triclopyr

Canada thistle

Cirsium arvense

(CIAR4)

Rhizomatous perennial

aminopyralid

clopyralid

chlorsulfuron

picloram

Combining mechanical, cultural, biological, 

and chemical methods is best for effective 

control Biological agents are available, but 

use may affect native thistles. 

Mowing, cutting or pulling can be an 

effective control if repeated at about 1-

month intervals throughout the growing 

season for several years. Combining 

mowing/cutting with herbicides (in the fall) 

will further enhance control of Canada 

thistle. Covering with plastic tarp 

(solarization) may be effective for small 

infestations.
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-6

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

Bull thistle*

Cirsium vulgare

(CIVU)

Taprooted biennial

aminopyralid

clopyralid

chlorsulfuron

glyphosate

picloram

triclopyr Prioritize small infestations in otherwise 

healthy sites. Prioritize prevention of 

establishment and eliminating plants as 

soon as they are found.

Biological agents are available, but use 

may affect native thistles

Manually pulling rosettes or cutting stems 

2”-4” below the soil surface before flower 

heads develop kills plants and prevents 

seed development. Roots may be left on 

site to dry; all flower and seed heads 

should be removed.

Covering disturbed sites, particularly small 

burn areas, with fine to medium sized 

organic matter may prevent or reduce the 

size of infestations.

Scotch Thistle

Onopordum acanthium

(ONAC)

Taprooted biennial or 

short-lived perennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

picloram

triclopyr

Musk thistle

Carduus nutans

(CANU4)

Taprooted biennial or 

occasional annual

aminopyralid

chlorsulfuron

clopyralid

glyphosate

picloram

triclopyr

Leafy spurge

Euphorbia esula

(EUES)

Rhizomatous perennial

aminopyralid

glyphosate 

imazapic 

picloram

Early detection and rapid eradication is 

important since plant spreads rapidly by 

seeds and rhizomes.

Continuous aggressive management is 

necessary to keep infestations under 

control (5 – 10 years).

Prioritizing treatment of small infestations, 

then treating large infestations from the 

outside edges is most effective. 

Biological control agents may reduce 

aboveground stems but do not kill root 

systems. 

Mechanical, cultural, or herbicide methods 

alone are rarely effective. Combinations of 

several herbicide treatments and planting 

grass seed may provide the best chance of 

controlling the species. 

Hand pulling and grubbing are not effective 
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-7

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

because of the extensive root system. 

Cutting and mowing reduce seed 

production and the plant’s competitive 

ability.

Covering with weed cloth, plastic, or thick 

mulch may kill plants. Site can then be 

planted with native seed.

If manual methods are used all plant parts 

should be bagged and removed since new 

plants may form from roots and rhizomes 

as well as from seeds.

Plant’s milky sap may be irritating to skin, 

eyes, and digestive tract of humans and 

other animals.

Houndstongue

Cynoglossum officinale

(CYOF)

Taprooted biennial or 

short-lived perennial

chlorsulfuron

metsulfuron 

methyl 

imazapic

Mowing/cutting second year plants during 

flowering, but before seed maturation 

reduces seed production and may kill the 

plant. 

Pulling plants or cutting 1 – 2 inches below 

the soil surface have the best chance of 

eliminating plants. Cutting produces less 

ground disturbance than pulling.

Bag and remove all flower and seed heads.

Dalmatian toadflax

Linaria dalmatica

(LIDA)

Perennial with taproot and 

extensive system of lateral 

roots

chlorsulfuron

metsulfuron 

methyl 

imazapic 

picloram

Dalmatian toadflax reproduces primarily by 

seed and partly by adventitious root buds. 

Yellow toadflax reproduces primarily by 

adventitious root buds on lateral roots.

Biological agents are available and may be 

very effective. 

Manual pulling and digging may not be 

effective because of the deep (4-10 feet) 

and laterally extensive root systems (to 10 

feet from plant). If manually removed, all 

roots and flower and seed heads should be 

bagged and removed. 

Cutting stems in spring or early summer 

would eliminate seed production, but not 

the root system.

If biocontrol agents continue to be effective, 

herbicide application may not be needed. 

Yellow toadflax

Linaria vulgare

(LIVU2)

Perennial with taproot and 

extensive system of 

vertical and creeping 

lateral roots

chlorsulfuron

metsulfuron 

methyl 

imazapic 

picloram

Whitetop

Cardaria draba

(CADR)

chlorsulfuron

metsulfuron 

methyl

glyphosate

imazapic

These species are difficult to control 

because of its deep taproots (9 ft.) and 

ability to sprout from root fragments.

Early detection and proactive management 
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-8

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

Rhizomatous perennial imazapyr is most effective since established 

infestations are difficult to control.

Frequent monitoring for new sites and 

prioritizing small infestations in otherwise 

healthy sites is important.. Next priority 

would be for corridors such as waterways 

and irrigations structures that have a high 

likelihood of spread. Biological controls are 

not available.

Repeated pulling may control small, young 

infestations. Established plants are likely to 

resprout from deep roots. All roots and 

flower and seed heads should be removed. 

Mowing does not eliminate plants but 

removes thatch.

Perennial pepperweed

Lepidium latifolium

(LELA2)

Perennial with rhizome 

like creeping roots

Alternatives

This EIS discloses the direct, indirect, and cumulative environmental impacts that would result from 

the proposed action and alternatives.

Four alternatives are considered: 

Alternative A, the no-action alternative —If alternative A is selected, no invasive plant treatments 

would be authorized under this environmental impact statement. Invasive plant treatments would 

likely continue on state road rights-of-way and easements within the Malheur National Forest

because they are not subject to Forest Service control. 

Prevention measures, continued to be applied during land uses, would slow (but not stop) the spread 

of invasive plants on the Forest and surrounding lands given the propagule pressure and type of 

expected disturbance associated with surrounding land uses and activities. 

Alternative A addresses some public concerns by eliminating most herbicide use on the Forest. There 

would continue to be low or no risks or impacts from herbicides on human health, nontarget 

vegetation and pollinators, soils, water, aquatic organisms, or wildlife. However, the threats to the 

environment from invasive plants would continue unabated. Neighbors would continue to be 

frustrated in their attempts to enlist the Forest Service to help with partnerships to implement 

effective integrated treatments within and outside Forest boundaries. 

Alternative B, the proposed action—This alternative is the most cost-effective approach to 

invasive plant treatment while minimizing the adverse effects of treatment. Alternative B responds to 

the purpose and need for action by authorizing several herbicide and other integrated treatment 

methods to be implemented on the Forest over the next 5 to 15 years. These options are intended to 

effectively reduce the size and density of invasive sites and abate the adverse effects of invasive 

plants. The project would continue to be implemented each year until the treatments were no longer 

needed or conditions substantially change on the ground to such a degree that the analysis in this EIS 

is no longer valid. The annual implementation planning process discusses how changed conditions 

would be evaluated for this project over time.
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-9

Under alternative B, the herbicide ingredient considered most effective (table S- 2) would be applied 

the first year of treatment. Over time, other effective herbicides may also be used depending on 

treatment results. 

We are proposing a Land and Resource Management Plan (LRMP) amendment to add aminopyralid 

to the list of acceptable herbicides for use as part of the integrated treatment toolbox for invasive 

plants on the Malheur National Forest. Aminopyralid (also known by the trade name: milestone®) 

was not available during the analysis process for the R6 2005 FEIS. A risk assessment completed in 

2007 indicates that this herbicide will increase treatment effectiveness and decrease risk of adverse 

effects as compared to other herbicides authorized in the R6 2005 ROD. Thus, we propose to add 

aminopyralid to the list of approved ingredients in invasive plant standard 16 for the Forest (nonsignificant LRMP amendment). All other standards and guidelines for invasive plant management 

would remain the same.

We propose to apply aminopyralid to about 64 percent of the infested acreage for the first treatment 

entry (about 1,350 acres). We would use aminopyralid for the first year of treatment because it is 

considered the most effective of the proposed herbicides for 13 of the 18 primary target species (all 

except houndstongue, toadflax, pepperweed and whitetop, which have chlorsulfuron as the firstchoice herbicide; and sulphur cinquefoil, that has metsulfuron methyl as the first-choice herbicide) 

(table 8). Aminopyralid has low toxicity to aquatic organisms and is labeled for use up to the edge of 

surface waters. Alternative B would allow broadcasting (boom spraying) of this herbicide to the edge 

of streams and other water bodies.

We are also proposing to use chlorsulfuron for the first treatment entry on 28 percent of the acres 

(about 591 acres), and metsulfuron methyl for one target species: sulphur cinquefoil that covers an 

estimated 8 percent of the acres (about 186 acres). 

Under alternative B, biological control agents would be deliberately redistributed to suppress or 

contain established populations of invasive plants on the Forest. Redistribution or release of 

biological control agents would be done as part of the Oregon Department of Agriculture Biological 

Control Program and meet the requirements of R6 2005 ROD Standard 14. The treated areas would 

continue to be inventoried and monitored to determine the success of the treatments, and when the 

released biological control agents have reached equilibrium with the target species. This EIS is tiered 

to the R6 2005 FEIS and various and ongoing Animal and Plant Health Inspection Service (APHIS)

National Environmental Policy Act (NEPA) documents for the release of biological control agents. 

Alternative B provides for treatment flexibility and early detection and rapid response by providing a 

method for us to adapt to changes on the ground over time. We expect some populations to increase 

and others to decrease over the life of this project, depending on many unpredictable factors such as 

weather (droughts and wet periods), funding, and the location of wildland fires or other uncontrolled 

disturbances. Under alternative B we will tailor the prescription to ground conditions at the time of 

treatment. 

In addition, new or previously undiscovered infestations could be treated using the range of methods 

described in this EIS. An EDRR approach is needed because (1) the precise location of individual 

target plants, including those mapped in the current inventory, are subject to rapid and/or 

unpredictable change, and (2) the typical NEPA process does not allow for rapid response to new 

detections; infestations may grow and spread into new areas during the time it usually takes to 

prepare NEPA documentation. The intent of the project early detection and rapid response approach 

is to treat new infestations when they are small so that the likelihood of adverse treatment effects is 

minimized. If alternative B is selected, integrated treatments would be authorized for new 

infestations detected over the next 5 to 15 years, using the treatment methods and project design 
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-10

features evaluated in this EIS. The analysis of alternative B assumes that all of the current 

infestations are treated in a single year and all pdfs are properly applied. 

Alternative B responds to public concerns about treatment effectiveness by authorizing a wide range 

of integrated treatment methods that would be prioritized, planned and implemented in cooperation 

with our neighbors. We would start to use herbicides and redistribute biological control agents on the 

Malheur National Forest as soon as practicable after the NEPA decision. Alternative B is, by 

definition, the most cost-effective alternative.

Alternative B favorably responds to issues about effects of herbicides on human health, non-target 

vegetation and pollinators, soils, water, aquatic organisms, and wildlife because treatments would be 

implemented according to design features and herbicide-use buffers that minimize the risk of adverse 

effects.

Two action alternatives were developed in response to public issues related to herbicide use:

Alternative C, strict limitations on herbicide use—This alternative was developed in response to 

some public concerns about herbicide use on the Malheur National Forest. Alternative C would 

impose strict limitations on our ability to use herbicides to treat invasive plants. Compared to 

alternative B, alternative C would further address public issues about herbicide impacts to human 

health, non-target vegetation and pollinators, soils, water, aquatic organisms, and wildlife, while still 

allowing for some limited herbicide use. Under alternative C, all of the alternative components for 

alternative B would be followed, however, no broadcasting of (boom spraying) would be allowed. 

No herbicide use would be allowed within the boundaries of any mapped infested area that at any 

point is within 100 feet of creeks, lakes, ponds and wetlands; or 200 feet of well-source areas. Nonherbicide methods would continue to be used within these areas. Picloram would be eliminated from 

the list of available herbicides. About 735 acres would be approved for spot/selective herbicide use 

and on the remaining 1,389 acres, no herbicide would be used. 

Alternative D, no forest plan amendment and no aminopyralid—This alternative was developed 

to evaluate the tradeoffs involved with amending the LRMP to add aminopyralid to the list of 

available herbicides. Some members of the public have expressed doubt about whether or not this 

herbicide should be approved. Alternative D would be similar to alternative B, except a Forest Plan

amendment would not be completed and aminopyralid would not be approved for use on the 

Malheur National Forest. Aminopyralid would not be used to treat known sites or new detections. 

Compared to alternative B, more chlorsulfuron, glyphosate, metsulfuron methyl, and picloram would 

be used in lieu of aminopyralid. As a result, infested sites close to streams and other water bodies 

would be spot treated rather than broadcast. 

Alternative Comparison

Project Design Features and Herbicide-use Buffers

The project design features (pdfs) (table 9) minimize the potential impacts of invasive plant 

treatment. These pdfs provide sideboards for treatment of known sites, along with new detections. 

The pdfs were developed to respond to the site-specific resource conditions within the infested areas, 

including (but not limited to) botanical areas; habitat and presence of botanical, wildlife and/or fish 

species of conservation concern; the potential for herbicide delivery to water, and proximity other 

areas of interest (roads and trails, recreation sites, Wilderness/Wild and Scenic Rivers, wildland fire 

areas). The analysis assumes pdfs are properly implemented. Herbicide-use buffers (table 10 and 

table 11 restrict the method of application for most of the proposed herbicides depending on their

persistence, mobility and toxicity to aquatic organisms and label advisories.
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-11

Implementation of pdfs and herbicide-use buffers would be mandatory for all action alternatives, 

where applicable. Alternative C would not allow broadcasting, so pdfs associated with broadcast 

treatments would not be applicable. In addition, alternative C would not allow any herbicide use 

within 100 feet of streams and other water bodies, so the variations in method of application of the 

different herbicides would not be applicable. Alternative C would eliminate use of picloram so pdfs

and herbicide-use buffers associated with picloram would not be applicable. 

Alternative D would not amend the Malheur National Forest LRMP so pdfs associated with 

aminopyralid would not apply. 

The following table displays the main differences between the alternatives.

Table S- 3. Alternative comparison by activity

Activity Alt A

(No Action)

Alt B

(Proposed Action) Alt C Alt D

Authorizes EDRR No Yes Yes Yes

Non-herbicide 

treatments None3

Non-herbicide 

treatments would 

be integrated with 

herbicide 

treatments

Same as Alternative 

B , except only nonherbicide treatments 

would be approved 

within 100 feet of 

water bodies 

Same as 

Alternative B 

Maximum acres of 

proposed herbicide 

treatments during 

any year of 

implementation

0 2,124 735 Same as 

Alternative B 

Total Invasive Plant 

Treatment Acres 

Over the Life of the 

Project (includes all 

treatments and retreatments)

0

30,000 over 15 

years (including 

herbicide use)

11,025 herbicide

30,000 total all 

treatments

Same as 

Alternative B 

Number of 

herbicides available 

for use

0 11 10 (no picloram) 10 (no 

aminopyralid)

Forest LRMP

amendment to 

include aminopyralid

No Yes Yes No

Herbicide 

Application Rate and 

Method

None

Lowest effective 

rate, broadcast

sprayers may be 

used where 

needed according 

to pdfs

Application rate 

would not exceed 

70% of typical 

broadcast rate, no 

boom or broadcast 

sprayers

Same as 

Alternative B , no 

aminopyralid

 3 The analysis in chapter 3 assumes that no action means no invasive plant treatments will occur. Prevention 

would continue, and biological agents distributed in adjacent lands would naturally distribute to host species 

within the Malheur National Forest.
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-12

Table S- 4 displays a comparison of the first year/first choice treatment for each alternative. All action 

alternatives (B-D) would approve a range of treatments on all 2,124 currently infested acres. Alternative 

C is the only action alternative that would disallow herbicide use in specific areas to the degree that nonherbicide treatments would be the only methods allowed for a substantial portion of these sites. Under 

alternative A (no action), no treatments would be approved. Under all alternatives (A-D), approved 

biological controls will continue to be released adjacent to the project area, and would help suppress 

toadflax, St Johnswort and other common invasive species. Biological controls would be redistributed to 

host species within the project area in the action alternatives.

Table S- 4. Comparison of first year/first choice herbicide by alternative

First Year/First Choice Treatment Alternative A

Acres

Alternative B

Acres

Alternative C

Acres

Alternative D

Acres

Broadcast Herbicide Application 0 1,281 0 0

Aminopyralid 0 1,179 0 0

Chlorsulfuron 0 71 0 435

Glyphosate 0 0 0 3

Metsulfuron methyl 0 30 0 69

Picloram 0 0 0 36

Spot/Selective Herbicide 

Application 0 843 735 1,581

Aminopyralid 0 168 560 0

Chlorsulfuron 0 519 142 595

Glyphosate 0 0 0 722

Metsulfuronmethyl 0 156 33 238

Picloram 0 0 0 27

Non-herbicide Only 0 0 1,389 0

Table S- 5 provides a comparison of the alternatives relative to the issue measures described in chapter 1.
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-13

Table S- 5. Alternative comparison relative to significant issues

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

1 – Treatment Effectiveness

Unnecessary restrictions 

on herbicide use reduce 

treatment effectiveness 

and increase treatment 

costs.

Average Cost per Acre of 

Effective Treatment 

(includes re-treatments and 

restoration)

0 $544 $722 $598

Total Cost of Most 

Ambitious Treatment 

Scenario

0 $1,154,000 $1,472,900 $1,270,500

Maximum Cost over the 

Life of the Project

(assuming maximum 

treatment caps multiplied 

by average per acre cost) 

0 $16,320,000 $21,660,000 $17,940,000

Number of Years to 

Achieve Objectives (most 

ambitious treatment 

scenario)

Objectives not 

achieved 4 years 6 years 5 years

2 – Herbicide Impacts to Human Health

Human health may be 

harmed by herbicide 

exposure.

Type (rate, method, 

chemical properties) and 

extent of herbicide use that 

could result in harmful 

exposure scenarios to 

people.

None

None of the herbicides

proposed for use are 

associated with any 

harmful scenarios to the 

public. Where 

necessary, pdfs

minimize or eliminate 

potential for harmful 

Same as Alternative 

B, except that far less 

herbicide would likely 

be sprayed annually. 

The minimal risks 

associated with 

herbicide use under 

Alternative B would be 

Same as Alternative B.

Where necessary, pdfs

minimize or eliminate 

potential for harmful 

exposure scenarios.
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-14

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

exposure scenarios by 

limiting the herbicide 

ingredient, rate, or 

method of application in 

specific areas. Workers 

need to take specific 

precautions to avoid 

harmful herbicide and 

NPE exposure. 

eliminated. 

Qualitative assessment 

about the effectiveness of 

herbicide-use buffers and 

other project design 

features to prevent harmful 

herbicide exposure 

scenarios

None

Risk assessments 

demonstrate that 

aminopyralid poses very 

low risk to human 

health. The likelihood of 

harmful exposures is 

low, thus the design 

features have high 

likelihood of eliminating 

all potential adverse 

impacts from herbicide 

use. 

Alternative C would 

have less risk of 

herbicide exposure 

overall, especially to 

fish and water, due to 

restrictions on 

herbicide use near 

water. The buffers 

would eliminate all 

potential herbicide 

exposure near 

streams. While this 

alternative includes 

some additional 

design features that 

would comparatively 

reduce risk of harmful 

herbicide exposure, 

the risk is already low.

Same as Alternative B, 

except opportunities to 

use aminopyralid would 

be foregone and in some 

cases, higher risk 

herbicides would be used. 

However, more spot 

treatment and less 

broadcasting would occur, 

which could result in less 

herbicide exposure, partly 

because less herbicide 

can be applied per day so 

the daily treatment extent 

would likely be less. For 

the project as a whole, the 

design features minimize 

adverse impacts to human 

health from herbicide use. 

Potential for Herbicides to 

Affect Drinking Water None

Drinking water quality 

would not be adversely 

affected. Restrictions on 

herbicide use near 

drinking water and well 

intakes further minimize 

risk. Herbicide 

transportation and 

handling safety plan 

would minimize potential 

Same as Alternative B Same as Alternative B
Malheur National Forest Site-Specific Invasive PlantsTreatment Draft Environmental Impact Statement-Summary

S-15

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

for an herbicide spill.

3 – Herbicide Impacts on Non-target Vegetation and Pollinators

Proposed herbicide use 

may harm non-target 

plants and/or pollinators, 

specifically sensitive and 

other species of 

conservation concern, 

cultural use plants, and 

special forest products.

Type and extent of 

herbicide use within 100 

feet of botanical special 

species of conservation 

concern, cultural use 

plants, and special forest 

products.

None

Project design features

prohibit broadcast 

herbicide use within100 

feet of sensitive plant 

populations. Spot

applications will be used 

within 100 feet of 

sensitive plant 

populations. Project 

design features for use 

of blue dye will alert 

special forest product 

gatherers of herbicide 

spray areas.

Same as Alternative 

B, less overall 

herbicide use

Same as Alternative B

4 - Herbicide Delivery to Water and Potential Impacts to Fish

Proposed herbicide use 

may result in chemicals 

reaching streams and 

other water bodies 

(through drift, leaching 

and/or run off) and may 

adversely fish and their 

habitat. 

Type and extent of 

herbicide use within 100 

feet of streams and other 

water bodies.

None

Aminopyralid could be 

broadcast up to the 

water’s edge; however 

no adverse impacts on 

fish are expected

because the amount of 

herbicide that could 

reach streams is below 

a level that could harm 

fish. Herbicide-use 

buffers and other pdfs

reduce the rate, extent, 

or frequency of 

herbicide use that pose 

potential risks to fish.

Same as Alternative 

B, except no 

herbicides would be 

used within 100 feet of 

streams and other 

water bodies. There 

potentially could be 

more sediment from 

non-herbicide 

methods required near 

streams. 

Same as Alternative B, 

except comparatively 

more use of higher-risk 

herbicides relative to fish.

Project design features 

minimize risks and 

differences between 

alternatives.

Qualitative Assessment 

about whether or not, and 

how fisheries might be 

affected

No impacts

Water concentrations 

from site-specific model 

runs at highest risk sites 

demonstrate that levels 

Same as Alternative B Same as Alternative B
Summary-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

S-16

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

of herbicide that could 

reach streams and 

aquatic organisms are 

at least 3 orders of 

magnitude less than 

levels of concern for fish 

and their habitat. All 

treatment methods may 

result in minor amounts 

of sediment reaching 

streams.

6- Herbicide Impacts on Wildlife

Proposed herbicide use may 

result in harmful exposure to 

terrestrial wildlife (specifically 

species of conservation 

concern).

Type and extent of herbicide 

use within specific wildlife 

habitats for wildlife of 

conservation concern

None

This alternative has the 

most broadcasting, but the 

first-choice herbicides that 

would be used pose low 

risk to wildlife.

Spot application of 

herbicides would occur 

on 735 acres and the 

first-choice herbicides 

pose low risk to wildlife.

First-choice herbicides that 

pose a low risk to wildlife 

would be applied on 1,337 

acres, whereas moderate to 

risk first-choice herbicides 

would be used on 787 acres. 

Less broadcasting than 

Alternative B, which reduces 

risk of drift.

Risk of HCB 

(hexachlorobenzene) 

contamination and effects on 

raptor eggs

None

No PCBs in first-choice

herbicides. Project design 

features minimize risk to 

raptors to extremely low 

level. 

Same as alternative B. 

No picloram eliminates 

risk. 

Picloram is the first-choice

herbicide on 63 acres, posing 

low risk of PCB’s; pdfs

minimize risk to raptors to 

extremely low level.

Narrative assessment about 

whether or not, and how 

species of conservation 

concern and amphibians might 

be affected

None

First-choice herbicides 

pose a low risk to wildlife. 

Project design features 

restrict timing or application 

in sensitive habitats and

minimize or eliminate 

likelihood for any species to 

receive harmful exposure 

to herbicide or disturbance.

Same as Alternative B, 

except greater risk of 

disturbance from nonherbicide treatments. 

Same as Alternative B, 

except less broadcasting and 

more use of herbicides that 

pose a comparatively greater 

risk to wildlife. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

1

Chapter 1. Purpose and Need for Action

1.1 Introduction

Land managers for the Malheur National Forest (Forest) propose to suppress, contain, control, 

and eradicate invasive plants using an integrated approach to treatment methods that includes 

herbicides, mechanical, manual, cultural and biological agents4

. Currently, we estimate that 

invasive plants occupy approximately 2,124 acres on the Forest. The infestations are broadly 

distributed, often occurring in areas of high spread-potential (e.g., along roads). It is expected 

that additional invasive plant sites exist but have not yet been identified, so new invasive plants 

are likely to be introduced over time.

Invasive plants are defined as “nonnative plants” whose introduction does or is likely to cause 

economic or environmental harm or harm to human health (Executive Order 13112). Invasive 

plants are distinguished from other nonnative plants by their ability to spread (invade) into native 

ecosystems. They spread between National Forest System lands and neighboring areas, affecting 

all land ownerships.

Invasive plants are currently damaging the ecological integrity of National Forest System (NFS) 

lands. They are displacing native plants, increasing the potential for soil erosion and potentially 

destabilizing streams, reducing water quality and the quality of fish and wildlife habitat, and 

degrading natural areas. Invasive plants can have adverse effects on rare or endemic species, 

which could result in listing under state or federal endangered species laws. 

The Forest Service has prepared this environmental impact statement (EIS) in compliance with 

the National Environmental Policy Act (NEPA) and other relevant federal and state laws and 

regulations. This EIS discloses the direct, indirect, and cumulative environmental impacts that 

would result from the proposed action and alternatives. The document is organized into the 

following chapters:

♦ Chapter 1. Purpose and Need for Action: This chapter includes information on the 

background, and purpose of and need for the project. This section also details how the 

Forest Service informed the public of the proposal and the issues identified through 

public scoping.

♦ Chapter 2: Alternatives, including the Proposed Action: This chapter provides a more 

detailed description of the proposed action as well as alternative methods for meeting the 

need for action. These alternatives were developed based on issues raised by the public 

and other agencies. This section also provides a summary table of the design 

components that compares the relative risks and benefits of each alternative.

♦ Chapter 3: Affected Environment and Environmental Consequences: This chapter 

describes the current condition and the resources that are at risk from invasive plants on 

the Malheur National Forest. It also details the environmental effects of implementing 

the proposed action and other alternatives.

 4 This project-level EIS responds to the need for suppression, containment, control and eradication of 18 

primary invasive species currently found on the Malheur National Forest. It also responds to the need to 

rapidly treat new detections of these or other invasive species found in the future. Our invasive plant 

management program is comprised of several interrelated aspects, including preventing the introduction, 

establishment, and spread of invasive plants on and adjacent to the Forest, and working with other 

agencies and groups to increase program effectiveness. This EIS is tiered to the R6 2005 FEIS, which 

analyzes other aspects of the invasive plant management program.
Chapter 1-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

2

♦ Chapter 4: Consultation and Coordination: This chapter provides a list of preparers and 

agencies and people consulted during the development of the environmental impact 

statement. 

♦ Chapter 5: Literature Cited and Glossary: This chapter provides a list of references 

cited in the document and a list of definitions for technical terms and acronyms.

♦ Appendices: The appendices provide more detailed information to support the analyses 

presented in the environmental impact statement. A report discussing the distribution and 

extent of invasive plants across Malheur National Forest watersheds is in Appendix A.

This report is available for review online at 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=35614 Site-specific reports addressing 

botany, soils, hydrology, wildlife, fisheries, range, recreation and archeology; and detailed maps 

for the project may be found in the project record located at the Malheur National Forest 

Headquarters located in John Day, Oregon. 

1.2 Background

This 2013 project-level DEIS documents the environmental analysis of a proposal to effectively 

treat invasive plants on the Malheur National Forest. On June 26, 2000, the Forest first decided 

to treat weeds using herbicides and other methods according to regional direction developed 

during the 1980s. However, later that year, the Decision Notice and Finding of No Significant 

Impact for the Noxious Weed Control Project on the Malheur National Forest were litigated.

In December 2002, U.S. District Court (Blue Mountain Biodiversity Project v. US Forest Service, 

CV 01-703-HA) concluded that the noxious weed control environmental assessment was 

insufficient under NEPA because it was tiered to earlier documents that the court deemed to be 

outdated. Thus, we were: “...enjoined from implementing ... the use or application of herbicides 

and biological controls until and unless it considers, evaluates and discloses in an environmental 

impact statement or supplemental environmental impact statement the individual and cumulative 

impacts of herbicide use...” (ibid.). Although that court decision applied exclusively to the 

Malheur National Forest, in 2005 the Pacific Northwest Region 6 Regional Forester decided to 

amend all of the Forest Plans in the Region based on new herbicide risk assessments and 

information about preventing invasive plant introduction, establishment and spread, and 

restoring treated sites.

Management direction for invasive plant prevention, treatment and restoration, and monitoring 

was added to the Malheur Forest Plan as a result of the Record of Decision for the Pacific 

Northwest Region Invasive Plant Program: Preventing and Managing Invasive Plants (USDA 

Forest Service 2005b). This document, referred to herein as the R6 2005 ROD, described the 

reasons why specific management direction was adopted and why alternative strategies (to 

increase herbicide use or increase emphasis on prevention) were not adopted. These discussions 

are summarized and incorporated where relevant; however the decisions made in 2005 are not 

being reconsidered here. The action alternatives considered in this EIS are intentionally limited 

in scope to options for implementing updated, effective invasive plant treatments in accordance 

with the R6 2005 ROD.

The R6 2005 FEIS satisfied the intent of the 2002 court order. On March 31, 2006, the Malheur 

National Forest published a Notice of Intent (NOI) to prepare an Environmental Impact 

Statement (EIS) for an invasive plant treatment project (Federal Register Vol. 72, No. 62, pp.

16281 -1628). The Forest Service considered public scoping input and initiated an analysis. 

However, there was a delay in completing the NEPA process, so the proposed action was updated 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

3

and a new NOI was published in the Federal Register on April 5, 2011, (Federal Register Vol. 76, 

No.65, pp. 18713-18715) initiating new scoping input. Scoping input from both 2006 and 2011 

was used to develop issues and alternatives analyzed for this DEIS. We have continued to 

collect, update and analyze site-specific information during the time since the court injunction.

In accordance with the injunction, we have been treating invasive plants exclusively using 

manual or mechanical methods on the Malheur National Forest.5 Manual and mechanical 

treatments are labor intensive and tend to be costly, and in some cases are not effective (see 

common control measures table 8 in chapter 2 for more information). 

1.3 Project Area

The project area encompasses the entire 1,459,422-acre Malheur National Forest and 240,000 

acres of the Ochoco National Forest that are managed by the Malheur Forest (previously known 

as the Snow Mountain Ranger District, now managed as part of the Emigrant Creek Ranger 

District.) for a total of nearly 1.7 million acres located in eastern Oregon (figure 2). These 1.7 

million acres is the acreage considered as the Malheur National Forest for purposes of this 

analysis. The main counties included in the analysis area are Grant, Baker and Harney. Small 

portions of Crook and Malheur Counties are also included in the analysis. The Malheur National 

Forest shares boundaries with the Umatilla, Wallowa-Whitman and Ochoco National Forests, 

Bureau of Land Management (BLM), State, county and private lands.

The following map shows the current extent and distribution of invasive species mapped across 

the project area. The acreage within each 5th field watershed is color-coded; the darker the color 

indicates more acreage in that watershed.

 5 Herbicides have been used in spot treatments totaling 10-20 acres/year along roads on the Snow 

Mountain Ranger District portion of the Emigrant Creek Ranger District – Ochoco National Forest, as 

authorized under the Ochoco National Forest Plan Amendment # 16, which is outside the area covered by 

the injunction. Biological agents have been released by county and state agencies adjacent to the Malheur 

National Forest boundaries and are active on widespread host species such as toadflax and St Johnswort 

within the Forest. 
Chapter 1-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

4

Figure 2. Malheur National Forest project area map with infestations
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

5

1.4 Desired Future Conditions

The R6 2005 ROD added the following desired future condition statement to the Malheur 

National Forest Plan:

“....healthy native plant communities remain diverse and resilient, and damaged 

ecosystems are being restored. High quality habitat is provided for native organisms 

throughout the [Forest]. Invasive plants do not jeopardize the ability of the [Malheur] 

National Forest to provide goods and services communities expect. The need for 

invasive plant treatment is reduced due to the effectiveness and habitual nature of 

preventative actions, and the success of restoration efforts.”

The R6 2005 ROD provided management direction intended to help forests reach this desired 

condition. All projects must include invasive plant prevention measures to meet the R6 2005 

ROD standards that amend the Malheur National Forest Land and Resource Management Plan

(LRMP). Invasive plant treatments must be timely and may require several years of effort to be 

effective. Restoration of native plant communities through mulching, seeding or planting may be 

needed to discourage reinvasion. The Forest needs the ability to implement treatment actions to 

more effectively contain and reduce the extent of invasive plants at existing inventoried sites, 

and rapidly responds to new or expanded invasive plant sites as they may occur in the future.

Each of the resource areas addressed in chapter 3 is associated with specific Forest Land and 

Resource Management Plan management direction, including desired conditions.

1.5 Purpose and Need

The Forest estimates at this time (using our updated inventory), approximately 2,124 acres of 

invasive plants need to be suppressed, contained, controlled or eradicated. We propose to treat 

invasive plants using integrated treatment methods in cooperation with our neighbors and in 

accordance with current management direction, to reduce the extent and impact of invasive 

plants. The underlying purpose of treating invasive plant infestations is to maintain or improve 

the diversity, function, and sustainability of desired native plant communities and other natural 

resources that can be adversely impacted by invasive plant species.

As discussed previously, invasive plants are occupying many special places on the Forest, 

including dispersed and developed recreation sites, wilderness areas and wild and scenic river 

corridors, fish habitat, and grazing allotments. The quality of native plant and wildlife habitats 

are being degraded across many watersheds on the Malheur National Forest (figure 2).

The lack of sufficient herbicides approved by the R6 2005 ROD for treating invasive plants is 

hampering the Forest’s ability to meet the desired condition described previously. A Malheur 

National Forest Land and Resource Management Plan Amendment is needed to add 

aminopyralid to the list of herbicides available for use on the Forest.

Our ability to prevent or minimize adverse impacts of invasive plants is greatest when 

populations are treated while still small and in early stages of invasion. Treatment options and 

the likelihood of their success are also greater in small or new invasive populations. Additional 

benefits of timely treatments include reduced treatment costs and less ground and habitat 

disturbance.

Invasive plants are estimated to be spreading at an average rate of 8-12 percent; emphasis on 

prevention may be reducing this rate (potentially to as low as 4 percent per year), but new 
Chapter 1-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

6

infestations are inevitable (R6 2005 FEIS and ROD). Chapter 3.1.5 includes further discussion

about vectors for invasive plant spread. 

Invasive plant spread is unpredictable and actual locations of target species may change abruptly 

over time. Accordingly, the Forest needs the flexibility to adapt to changing conditions, and 

rapidly respond to invasive plant threats that may currently be unknown. Timeliness of action is 

an important factor because the cost, difficulty, and potential adverse effects of controlling 

invasive plants increases with the size and extent of the population. The smaller the population 

when treated, the more likely the treatment will be effective. The Forest needs a way to 

effectively treat invasive plants as soon as possible after they are detected. 

1.6 Proposed Action

The Forest Service proposes an integrated approach to treatments to suppress contain, control, or 

eradicate invasive plants. That is, treatments would be a combination of herbicides, biological 

agents, mechanical and manual techniques. Cultural/restoration treatments such as mulching, 

competitive seeding, or planting with native species would be implemented when needed to 

facilitate natural plant recovery. Existing and new infestations would be treated, including 

potential new target invasive plant species that currently are not found on the Forest. The Forest 

Plan would be amended to provide for the use of the herbicide aminopyralid that was not 

available when the R6 2005 ROD was signed in 2005. For a full description of the proposed 

action (alternative B), please see chapter 2.

1.7 Management Direction

This EIS process and documentation has been completed according to direction contained in the 

National Forest Management Act (NFMA), the National Environmental Policy Act (NEPA), the 

Council on Environmental Quality (CEQ) regulations, and the Clean Water Act and Endangered 

Species Act. The project is consistent with all applicable Federal, State and local laws. This EIS 

tiers to the Malheur National Forest Land and Resource Management Plan Final Environmental 

Impact Statement and Record of Decision (1990) and incorporates by reference the 

accompanying Land and Resource Management Plan (LRMP, Forest Plan) (1990), as amended 

by the Inland Native Fish Strategy (INFISH 1995a) and the Interim Strategies for Managing 

Anadromous Fish Producing Watersheds (PACFISH 1995), where appropriate, also the Pacific 

Northwest Region Invasive Plant Program: Preventing and Managing Invasive Plants Final 

Environmental Impact Statement and Record of Decision for the Pacific Northwest Region 

Invasive Plant Program: Preventing and Managing Invasive Plants (USDA Forest Service 2005a, 

USDA Forest Service 2005b).

The Federal Noxious Weed Act of 1974, as amended (7 U.S.C. 2810 et seq.) requires 

cooperation with State, local and other Federal agencies in the application and enforcement of all 

laws and regulations relating to management and control of noxious weeds (a summary of this 

act can be viewed at: http://ipl.unm.edu/cwl/fedbook/fedweed.html\). This Act directs the 

Secretary of Agriculture to develop and coordinate a management program for control of 

undesirable plants which are noxious, harmful, injurious, poisonous, or toxic on Federal lands 

under the agency’s jurisdiction, to establish and adequately fund the program, to complete and 

implement the cooperative agreements and/or memorandums, and to establish Integrated Weed 

Management to control or contain species identified and targeted under cooperative agreements 

and/or memorandums.

In 2011, the Chief of the Forest Service authorized Forest Service Manual 2900 (FSM 2900) for 

invasive species management. This project is consistent with this manual direction, which 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

7

emphasizes integrated weed management (IWM) concepts and early detection and rapid 

response (EDRR). 

1.7.1 Land and Resource Management Plan

Management direction for the treatment of invasive plants on the Malheur National Forest is 

specifically provided by the Malheur National Forest Land and Resource Management Plan

(LRMP) (1990) as amended by the R6 2005 ROD. The R6 2005 ROD provided management 

direction for (1) public education and coordination, (2) prevention of the spread of invasive 

plants during land uses and activities, (3) treatment of target species, (4) reducing reliance on 

herbicides over time, and (5) site restoration.

The standards that apply to invasive plant treatment/restoration are shown in table 1. Standards 

related to invasive plant prevention are not duplicated here; all projects on the Malheur National 

Forest include measures to prevent or slow the spread of invasive plants, such as:

♦ Timber sale and other contracts require washing heavy equipment

♦ Weed-free feed requirements in wilderness, later throughout national forests

♦ Weed-free rock source requirements 

♦ Coordination between road maintenance and invasive plant staff to ensure prevention 

practices are incorporated into road work

♦ All project plans require invasive plant prevention measures to be included

♦ Invasive plant prevention measures are included in special use permits and grazing 

allotment management plans

Table 1. R6 2005 Standards and Project Compliance

Standard # R6 2005 Standard (LRMP) Project Implementation Notes

11

Prioritize infestations of invasive plants for 

treatment at the landscape, watershed or 

larger multiple forest/multiple owner scale. 

The highest priority infestations are those 

we can eradicate. Treatments to contain 

larger, well established populations are 

lowest priority. Areas where we can reduce 

the density of invasive plant populations but 

not entirely eradicate them have medium 

priority. 

12

Develop a long-term site strategy for 

restoring/revegetating invasive plant sites 

prior to treatment.

The long-term strategy for restoration 

depends on the type of site infested, the 

target species, and location.

13

Native plant materials are the first choice in 

revegetation for restoration and 

rehabilitation where timely natural 

regeneration of the native plant community 

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

of the following situations: 1) when needed 

in emergency conditions to protect basic 

resource values (e.g., soil stability, water 

quality and to help prevent the 

establishment of invasive species), 2) as an 

interim, non-persistent measure designed to 

aid in the re-establishment of native plants, 

3) if native plant materials are not available, 

or 4) in permanently altered plant 

communities. Under no circumstances will 

Revegetation (competitive seeding and 

planting) would occur as needed to replace 

invasive plants with native plant 

communities. Non-native, non-persistent 

species may be used infrequently as an 

interim measure to control erosion or 

prevent target species from returning on 

treated sites. Restoration of native plant 

communities through mulching, seeding or 

planting would be considered as a follow up 

to invasive plant treatment.
Chapter 1-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

8

Standard # R6 2005 Standard (LRMP) Project Implementation Notes

non-native invasive plant species be used 

for revegetation.

14

Use only USDA Animal and Plant Health 

Inspection Service (APHIS) and stateapproved biological control agents. Agents 

demonstrated to have direct negative 

impacts on non-target organisms would not 

be released.

Agents found to have negative impacts may 

not be distributed on the Forest. The R6 

Regional Office updates the list regularly. 

15

Application of any herbicides to treat 

invasive plants will be performed or directly 

supervised by a state or federally licensed 

applicator.

All treatment projects that involve the use of 

herbicides will develop and implement 

herbicide transportation and handling safety 

plans.

The elements of herbicide transportation 

and handling safety plans discussed in the 

project design feature section of chapter 2.

16

Select from herbicide formulations 

containing one or more of the following 10 

active ingredients: chlorsulfuron, clopyralid, 

glyphosate, imazapic, imazapyr, 

metsulfuron methyl, picloram, sethoxydim, 

sulfometuron methyl, and triclopyr. Mixtures 

of herbicide formulations containing 3 or 

less of these active ingredients may be 

applied where the sum of all individual 

Hazard Quotients for the relevant 

application scenarios is less than 1.0.

All herbicide application methods are 

allowed including wicking, wiping, injection, 

spot, broadcast and aerial, as permitted by 

the product label. Chlorsulfuron, 

metsulfuron methyl, and sulfometuron 

methyl will not be applied aerially. The use 

of triclopyr is limited to selective application 

techniques only (e.g., spot spraying, wiping, 

basal bark, cut stump, injection).

Additional herbicides and herbicide mixtures 

may be added in the future at either the 

LRMP or project level through appropriate 

risk analysis and NEPA/ESA procedures.

No aerial treatment is proposed in any 

alternative. A Forest Plan amendment would 

accompany a decision to add aminopyralid 

to the list of available herbicides. 

18

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

and inert ingredients reviewed in Forest 

Service hazard and risk assessment 

documents such as SERA, 1997a, 1997b; 

Bakke, 2002.

Adjuvants and inert ingredients would be 

from approved lists (see chapter 3.1 for 

more information on adjuvants).

19

To minimize or eliminate direct or indirect 

negative effects to non-target plants, 

terrestrial animals, water quality and aquatic 

biota (including amphibians) from the 

application of herbicide, use site-specific 

soil characteristics, proximity to surface 

water and local water table depth to 

determine herbicide formulation, size of 

buffers needed, if any, and application 

method and timing. Consider herbicides 

Chapter 3 discusses how risks from 

herbicide use are abated by project design 

features, including buffers and restrictions 

on herbicide use and method of application 

near botanical species of local interest, 

certain wildlife habitats, streams and other 

water bodies.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

9

Standard # R6 2005 Standard (LRMP) Project Implementation Notes

registered for aquatic use where herbicide 

is likely to be delivered to surface waters.

20

Design invasive plant treatments to 

minimize or eliminate adverse effects to 

species and critical habitats proposed 

and/or listed under the Endangered Species 

Act. This may involve surveying for listed or 

proposed plants prior to implementing 

actions within unsurveyed habitat if the 

action has a reasonable potential to 

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

and method, timing, wind speed and 

direction, nozzle type and size, buffers, etc.) 

to mitigate the potential for adverse 

disturbance and/or contaminant exposure.

Chapter 3 discusses how potential adverse 

effects to Endangered Species and critical 

habitats from herbicide use are minimized.

21

Provide a minimum buffer of 300 feet for 

aerial application of herbicides near 

developed campgrounds, recreation 

residences and private land (unless 

otherwise authorized by adjacent private 

landowners).

No aerial application is proposed.

22

Prohibit aerial application of herbicides 

within legally designated municipal 

watersheds.

No aerial application is proposed.

23

Prior to implementation of herbicide 

treatment projects, National Forest staff will 

ensure timely public notification. Treatment 

areas will be posted to inform the public and 

forest workers of herbicide application dates 

and herbicides used. If requested, 

individuals may be notified in advance of 

spray dates.

Chapter 2 lists Project Design Features,

including public notification requirements.

The Malheur National Forest LRMP outlines various management areas across the Forest and 

specific environmental standards and guidelines for each area. Table 2 displays the infested 

acreage within each management area. In some cases, there is management direction specifically 

related to invasive plant treatments. Please note that our GIS (Geographical Information System) 

queries take in more riparian acres than is allocated to this management area. Specific guidance 

for this management area applies whether or not the acres show up in this database layer.

Table 2. Infested acres

Forest Plan Management Area (MA) Infested Acres MA Guidance Related to 

This Project

Big Game Winter Range Maintenance 172.3

General Forest 6.4

General Forest-Rangeland 720.3

Long Creek Municipal Supply Watershed 0.1

R6 2005 ROD (Forest LRMP)

standards do not allow aerial 

spraying in municipal 

watersheds. The low level of 

current infestation likely will 

not require any use of 

herbicides.
Chapter 1-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

10

Forest Plan Management Area (MA) Infested Acres MA Guidance Related to 

This Project

Monument Rock Wilderness 1.1 No mechanical equipment or 

motorized access allowed

Old Growth 342.1

Old Growth-District 4-18 0.0

Research Natural Area 0.1

The Forest Supervisor is 

responsible to “protect 

research natural areas” (FSM 

4063.04b). FSM 4063.3 

requires remove exotic plants 

or animals to the extent 

practicable.” Treatments 

within RNAs are coordinated 

with the Pacific Northwest 

Research Station.

Riparian Areas (Anadromous and NonAnadromous) 239.9

PACFISH-INFISH S&Gs: 

Treatments in riparian 

habitats designed to follow 

riparian management 

objectives.

Scenic Area 0.5

Semi-Primitive Non-Motorized Recreation Areas 4.1

Strawberry Mountain Wilderness 420.0 No mechanical equipment or 

motorized access allowed.

Visual Corridors (Foreground) 194.4

Visual Corridors (Middleground) 1.5

Visual Corridors (Partial Retention) 2.7

Visual Corridors (Retention) 1.0

Wild and Scenic River 1.1

Wildlife Emphasis Area (With Non-Scheduled 

Timber Harvest) 0.3

Wildlife Emphasis Area (With Scheduled Timber 

Harvest) 16.0

Winter Range 172.3

1.7.2 Additional Guidance

Wilderness Act

Invasive plant treatment within wilderness areas must be aimed at preserving or protecting 

wilderness character. Treatments using mechanized equipment are not generally compatible with

wilderness status.

Endangered Species Act

The Forest Service is consulting with the U.S. Fish and Wildlife Service (USFWS) and National 

Marine Fisheries Service (NMFS) to ensure the project would not jeopardize the continued 

existence of federally listed species (or species proposed or considered candidates for listing).

Clean Water Act

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

required for herbicide use that may directly enter streams. Treatments on small portions of 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

11

riparian infestations (currently mapped or detected in the future) may meet the criteria; however 

the type of infestations currently found on the Malheur National Forest are not riparian 

dependent. The current mapping is not refined enough to determine whether a permit will 

ultimately be needed; however, NPDES Pesticide General Permits would be obtained prior to 

implementing any treatments in which herbicide could be directly introduced into surface waters.

Clean Water Act compliance includes use of best management practices (BMPs). Specific BMPs 

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

Forest Service 2012). The project design features in chapter 2 integrate the national BMPs. Core 

objectives for chemical uses on National Forests are provided in the technical guide. These 

include:

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

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

♦ Avoid or minimize the risk of soil and surface water or groundwater contamination by 

complying with all label instructions and restrictions required for legal use.

♦ Avoid or minimize the risk of chemical delivery to surface water or groundwater when 

treating areas near waterbodies.

1.8 Decision to be Made

The Malheur National Forest Supervisor is the responsible official for this EIS and will make the 

following decision:

♦ Whether or not to authorize site-specific invasive plant treatments using herbicides and 

other methods

♦ Whether or not to amend the Malheur National Forest LRMP

♦ Whether or not to implement an early detection and rapid response process for 

infestations that are detected over the next 5-15 years

♦ What project design features are required

♦ What monitoring will occur

1.9 Public Involvement and Scoping 

Ongoing public involvement has occurred throughout this NEPA process. Tribes have been 

consulted and input from federal and state agencies has been sought. The proposed action was 

circulated for scoping input in 2006 and again in 2011.

Scoping Respondents in 2011 included: Dick Artley, Karen Coulter, Blue Mountains 

Biodiversity Project (BMBP), Doug Heiken (Oregon Wild), the Grant Soil and Water District 

(GSWD), and the National Park Service (NPS).

Scoping Respondents in 2006 included: Karen Coulter (BMBP); Oregon Natural Desert 

Association (ONDA); Center for Tribal Water Advocacy (CTWA); U.S. Environmental 

Protection Agency (EPA); Doug Heiken with others Oregon Natural Resource Council (ONRC); 

Matt Carter; Walt Gentis, Nancy Hafer; Phil Turrell (RMEF); Dan Bishop; Assante Riverwind 

(Sierra Club); John Day RAC, Jean Public; and Gregg Smith.

The Forest Service reviewed scoping responses and identified issues—points of discussion, 

debate or dispute about environmental effects—related to the proposed action. Public issues 
Chapter 1-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

12

revolve around the cost-effectiveness of the treatments proposed and the potential adverse effects 

of herbicide use. The focus on herbicide use is prevalent because other treatments such as 

manual and mechanical have been authorized for many consecutive years on the Forest, while 

herbicides have not been applied. Thus, herbicide application is the part of the program that is 

the focus of alternatives considered herein.

1.10 Issues

The following significant issues influenced the analysis of alternatives in this EIS: 

♦ Treatment cost-effectiveness 

♦ Herbicide impacts to human health

♦ Herbicide impacts on non-target vegetation and pollinators

♦ Herbicide delivery to water and impacts on fish

♦ Herbicide impacts on wildlife

1.10.1 Treatment Cost-Effectiveness

Issue Statement: Unnecessary restrictions on herbicide use reduce treatment effectiveness and 

increase treatment costs.

Background: Integrated invasive plant treatments need to be timely and cost-effective to be able 

to result in suppression, containment, control, or eradication of invasive plants. Restrictions on 

herbicide type, timing, extent, rate, and application method (beyond label restrictions and R6 

standards) limit our ability to effectively treat known and new sites. Treatment costs and need for 

re-treatment are directly affected by the range of effective treatments available in the toolbox for 

any given site. Increased costs and reduced effectiveness reduce the acreage that can be 

effectively treated with limited funding. This issue is directly addressed in chapter 3.1.4.

Issue Measures: 

Average cost per acre of effective treatment (includes re-treatments and restoration)

Total cost of the most ambitious treatment scenario6

Maximum cost over the life of the project (assuming maximum treatment caps multiplied by 

average per acre cost)

Years to achieve objectives

1.10.2 Herbicide Impacts to Human Health

Issue Statement: Human health may be harmed by herbicide exposure.

Background: This issue speaks to general concern about herbicides and the risks to workers and 

the general public from proposed herbicide use. For the most part, by following the management 

direction for herbicide use from the R6 2005 ROD, which amended the Malheur National Forest

LRMP, herbicide use would not result in exposures above conservative thresholds of concern for 

human health. The risk assessment for aminopyralid demonstrates that this herbicide does not 

pose additional risks to human health. At the project level, risks are further minimized through 

 6 The most ambitious treatment scenario assumes all of the areas that are currently infested with invasive 

plants are treated the first year after a decision is made for this project, and re-treated as needed to achieve 

control objectives.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

13

project design features (table 9) and herbicide-use buffers (table 10 and table 11) that avoid 

certain types of exposures. This issue is addressed in chapter 3.2. Additional information about 

drinking water sources is in chapter 3.5.

Issue Measures: 

Type (rate, method, chemical properties) and extent of herbicide use that could result in toxic 

herbicide exposure to people

Qualitative assessment about the effectiveness of herbicide-use buffers7 and other project 

design features to prevent toxic herbicide exposure to people

Potential for herbicides to affect drinking water

1.10.3 Herbicide Impacts on Nontarget Vegetation and Pollinators

Issue Statement: Proposed herbicide use may harm nontarget plants and/or pollinators, 

specifically sensitive and other special status species, cultural use plants, and special forest 

products. 

Background: Herbicides are designed to kill plants and there is always a risk that herbicide will 

affect nontarget botanical species (vascular and non-vascular plants, fungi, algae, lichens, 

bryophytes, liverworts). The presence of special-status species, treatment extent, rate and method 

of application and the properties of the chemicals proposed influence the degree of risk. This 

issue is addressed in chapter 3.3.

Issue Measures: 

Type and extent of herbicide use within 100 feet of botanical species of conservation 

concern, cultural use plants, and special forest products

Qualitative assessment about the effectiveness of herbicide-use buffers and other project 

design features to prevent herbicide from harming nontarget botanical species and 

pollinators

1.10.4 Delivery to Water and Potential Herbicide Impacts on Fish

Issue Statement: Proposed herbicide use may result in chemicals reaching streams and other 

water bodies (through drift, leaching and/or run off) and adversely affect fish and their habitat.

Background: The proposed action will minimize potential for herbicide delivery to streams and 

other water bodies. However, the risk that some chemicals may reach surface waters cannot be 

eliminated. Treatment extent, rate and method of application and the properties of the chemicals 

proposed influence the degree of risk. Specific concern about picloram use has been expressed 

due to its potential mobility and persistence in the soil. The main focus of this issue is the 

potential for aquatic species of conservation concern. This issue is addressed in chapter 3.5. and 

3.6.

Type and extent of herbicide use within 100 feet of streams and other water bodies

Qualitative assessment about whether fisheries might be affected and in what way

 7 Herbicide-use buffers are areas near streams and other water bodies where some types of herbicide use 

are restricted.
Chapter 1-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

14

1.10.5 Herbicide Impacts on Wildlife

Issue Statement: Proposed herbicide use may result in harmful exposure to terrestrial wildlife 

(specifically species of conservation concern). 

Background: Most of the herbicides proposed for use pose no risk to terrestrial wildlife and 

amphibians. The focus of this issue is on the herbicides that pose a small risk, meaning that there 

are some plausible exposure scenarios that exceed the no-effect level. There is limited 

information about effects on amphibians, so pdfs are in place to add an extra layer of caution to 

protect these species. Hexachlorobenzene (HCB), an industrial contaminant within picloram, and 

to a lesser extent, clopyralid, poses potential risks to raptor eggs. This is one reason aminopyralid 

is the first-choice herbicide between the three, as no HCBs are present in aminopyralid. This 

issue is addressed in chapter 3.7.

Issue Measures: 

Type and extent of herbicide use within wildlife habitats for wildlife species of conservation 

concern 

Risk of HCB contamination and effects on raptor eggs 

Narrative assessment about whether, and how wildlife species of conservation concern and 

amphibians might be affected

1.10.6 Other Issues

Some public concerns expressed in scoping responses are not considered significant issues 

because they are addressed through routine compliance with management direction, are 

addressed through tiering to the R6 2005 FEIS, or are addressed by best available science.

Issues Addressed by Compliance with Management Direction 

Some public concerns are not considered significant issues for analysis but are routinely 

addressed in the course of environmental analysis. Compliance with existing management 

direction, permits and other requirements associated with the action, and disclosure of findings 

and determinations associated with endangered species act consultation are some of the topics 

that are covered in this EIS, but are not considered significant issues. 

The proposed action will be designed to follow relevant management direction (an LRMP

amendment is proposed to allow use of aminopyralid, which is intended to meet other standards 

requiring that impacts be minimized through site-specific selection of chemicals and other 

measures). In addition, we are working with tribal governments and others to ensure 

environmental justice and protection of heritage resources and treaty rights.

Impacts to soils have been resolved through adherence to the R6 2005 ROD standards and 

additional project design features. None of the alternatives pose significant threats to soils given 

the nature of the types of treatments proposed. The approach to soils in this document is to 

analyze how herbicides are filtered through various soil types and their eventual environmental 

fate, with the main issue ultimately being potential effects on fish. 

In addition, we are working with tribal governments and others to ensure environmental justice 

and protection of heritage resources and treaty rights. The sections on human health, botany and 

archeology offer more information about these topics.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Chapter 1

15

Issues Addressed by Tiering to the R6 2005 FEIS

Some commenters remarked that changes in land uses and other measures should be applied to 

forest activities to prevent or slow the spread of invasive plants. Prevention applied to land uses 

is not a connected action to this project. The R6 2005 FEIS discussed the programmatic 

relationship between prevention, the spread of weeds, and the eventual need for treatment 

(chapter 4.1.3). Causes and vectors of invasive plant spread are specifically addressed in the R6 

2005 FEIS (chapter 3 and appendices). 

This treatment project EIS is tiered to the R6 2005 FEIS and relies on these discussions where 

necessary to address the relationship between land uses and invasive plant spread. However, at 

the project level, the need for suppression, eradication, control, and containment of invasive 

plants will still exist regardless of how the prevention standards from the R6 2005 ROD, along 

with other management direction, are implemented. The R6 2005 FEIS acknowledges that 

invasive plants will continue to spread, and treatment will continue to be needed; even with 

prevention measures applied to land uses (R6 2005 FEIS 4.1.3).

Issues Addressed by Best Available Science 

Issues about herbicide toxicity are addressed through peer-reviewed risk assessments and sitespecific risk models, which constitute best available science. Some people do not accept the 

dose-exposure relationship that is part of the risk assessment process, nor do they believe that 

information supplied by chemical manufacturers is valid. These beliefs are not resolvable in this 

EIS.

Current science is insufficient to precisely determine a cause-and-effect relationship between 

climate change and the proposed action for the project area. A general conclusion, based on the 

preponderance of current literature, suggests that “most of the important elements of global 

climate change are likely to increase the prevalence of biological invaders” (Bautista 2008). All 

action alternatives include an early detection/rapid response component to address uncertainties 

regarding effects of climate change at any specific location over the life of this project.

1.11 What this Proposal Does Not Include

♦ This action does not include experimental trials of herbicides conducted by the U.S. 

Environmental Protection Agency (EPA) to test new products.

♦ This action does not include activities that could influence invasive plant populations but 

are covered under other programs. Such programs include transportation planning, 

timber management, livestock grazing, etc. Invasive plant prevention and treatment 

activities are incorporated into individual projects carried out under regulation and 

guidance of these programs.

♦ No treatment of aquatic invasive plants is proposed. 

♦ No aerial herbicide application is proposed. 

♦ No mechanical restoration treatments such as scarification are proposed. 
Chapter 1 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

16

This page left blank intentionally
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

17

Chapter 2. Alternatives, Including the Proposed Action

2.1 Introduction

This chapter summarizes and compares four alternatives for invasive plant treatments including the no-action

alternative. No action for this environmental impact statement (EIS) is defined as not using integrated treatment 

methods and not following updated management direction for invasive plants.

Under alternative A-no action, invasive plant treatments would not be authorized as part of a decision on this 

project-level EIS; projects similar to the current program would likely be authorized under categorical exclusions

or connected actions associated with other project decisions. Please see the glossary for a definition of 

categorical exclusions and connected actions. Biological agents would also continue to find their way onto the 

Malheur National Forest, but none would be deliberately released by Forest personnel.

8 More information about 

the no-action alternative can be found later in this chapter. 

Alternative B-proposed action is the most ambitious and effective conceivable approach to invasive plant 

treatment. Integrated treatment prescriptions were developed to effectively suppress, eradicate, control, and 

contain the 18 target species currently found within 2,124 acres (3,070 mapped sites) on the Malheur National 

Forest. Project design features minimize the possible adverse effects of treatment in accordance with the LRMP

for the Malheur National Forest (chapter 1, management direction).

2.2 Extent of the Primary Target Species and Management Objectives

As of November 2012, approximately 2,124 acres containing target invasive plant species have been mapped

within the project area (figure 2). There are 18 primary target invasive species within 3,070 mapped infested sites 

(GIS polygons). Site-specific integrated treatment objectives and methods (also referred to as common control 

measures) vary depending on the size and density of the infestation, its location and the target species, and the 

design features associated with each action alternative. Invasive plants are scattered throughout the infested areas 

with density ranging from less than 10 percent to 100 percent primary target species.9

Preliminary treatment objectives were assigned to each of the primary target species depending on its potential 

negative impacts, the size of infestations, and the values or sensitivity of the infested sites (or adjacent lands). 

These objectives are subject to change as site conditions change over time. Table 3 displays our current treatment 

objectives for the 18 primary invasive species mapped on the Malheur National Forest. “Eradication” is our

highest priority, and “tolerate” represents the lowest priority for integrated treatment and restoration. All other 

things being equal, we would treat highest priorities first. However, many other variables factor into the annual 

program of work. Below are definitions of our invasive plant treatment objectives. R6 2005 Standards 12 and 13 

require that we identify the desired future condition and objectives before implementing integrated treatments.

Eradicate: Eliminate an invasive plant species from a site. This objective generally applies to species that are 

difficult to control and cover small areas. Some occurrences may be on roadsides (Russian knapweed, squarrose 

knapweed) and others may occur in intact native vegetation (yellow starthistle, small occurrences of thistles or 

knapweed, new invaders). This is generally the first priority for treatment.

Control: Reduce the size of the infestation over time; some level of infestation may be acceptable. This objective 

applies to most of the target species (houndstongue, leafy spurge, perennial pepperweed, sulfur cinquefoil, 

whitetop) and large infestations of thistles and knapweeds. This is generally the second priority for treatment.

 8 Invasive plant treatments would likely continue on state road rights-of-way and easements within the Malheur National 

Forest because they are not subject to Forest Service control. 

9 This analysis assumes all sites are 100% occupied by invasive species because this variable is subject to rapid change.
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

18

Contain: Prevent the spread of the weed beyond the perimeter of patches or infestation areas mapped from 

current inventories. This objective applies to target species such as and common St. Johnswort. This is generally 

the third priority for treatment.

Suppress: Prevent seed production throughout the target patch and reduce the area coverage. Prevent the 

invasive species from dominating the vegetation of the area; low levels may be acceptable. This objective applies 

to target species such as toadflax that would be treated mainly with biocontrol agents. This is generally the fourth 

priority for treatment.

Tolerate: Accept the continued presence of established infestations and the probable spread to ecological limits 

for certain species. This category is for species that are so widespread and abundant that other objectives would 

be extremely difficult to meet. This category includes species such as cheatgrass, medusahead North Africa grass, 

dandelion, mullein, and bulbous bluegrass. These invasive plants have low priority for treatment and would 

likely only be treated if they happen to be near one of the primary target species.

Table 3. Current treatment objectives for mapped, primary invasive plant species

Target 

Species

Category

Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Knapweeds 

Spotted knapweed 171 82

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Diffuse knapweed 213 74

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Russian knapweed 43 4 Eradicate

Squarrose knapweed 3 <1

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Meadow knapweed 2 <1

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations

Starthistle Yellow star-thistle 3 1 Eradicate

Thistles

Canada thistle 1,277 1,021 Control

Bull thistle* 0* 0*

Eradicate small infestations in 

ecologically-sensitive areas

Control roadside infestations, large 

open sites and forested sites

Scotch Thistle 61 23

Eradicate small isolated sites in 

ecologically-sensitive areas

Control large open sites and linear 

roadside populations
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

19

Target 

Species

Category

Common Name

Spatial Extent 

(November 2012) Treatment Objective

Sites Acres

Musk thistle 13 11

Eradicate small infestations in 

ecologically-sensitive areas

Control roadside infestations, large 

open sites and forested sites

Roadside 

Species

Common St. Johnswort 185 120 Contain

Houndstongue 171 340 Control

Sulphur cinquefoil 61 186 Control

Toadflax

Dalmatian toadflax 666 155 Suppress

Yellow toadflax 27 9 Suppress

Mustards Whitetop 148 85 Control

Perennial pepperweed 12 2 Control

Spurge Leafy spurge 14 10 Control

Total 3,070 2,124

*Bull thistle and Canada thistle were cataloged together in our November 2012 invasive plant inventory. However, the precise species would 

be identified to determine the specific treatment objective for a given site.

2.3 Alternatives Considered in Detail

2.3.1 Alternative A – No Action

The no-action alternative is required by NEPA (36 CFR 220) to provide a baseline for comparison of effects of 

action alternatives. If the no-action alternative is selected for this project, no invasive plant treatments would be 

authorized. The Malheur National Forest invasive plants treatment program would not follow current invasive 

plant management direction.

Since 2002, when use of biological agents and chemicals for invasive plant control was enjoined by the court on 

the Malheur National Forest, most treatments have been manual (primarily hand pulling and digging) with 

limited mechanical treatment (primarily mowing). 

In 2010, the Malheur National Forest treated about 375 acres with manual and mechanical treatments using 

“Forest Service personnel, County cooperators, and Nature Conservancy volunteers” (R6 2010 accomplishment 

report). In 2011, the Malheur National Forest treated 203 acres in essentially the same manner (R6 2011

accomplishment report). 2012 saw a drop in manual and mechanical acres accomplished to 39 (R6 2012 

accomplishment report). Partners and cooperators in 2012 were the Confederated Tribes of the Warm Springs, 

Harney County, the Nature Conservancy, Oregon Department of Agriculture, and Oregon Department of 

Transportation. Our focus in 2012 was working on this Draft EIS. 

If alternative A-no action is selected, the Forest Service would not treat invasive plants as proposed in the action 

alternatives. Invasive plant treatments would likely continue on state road right of ways and easements within the 

Malheur National Forest because they are not subject to Forest Service control. Any future treatments would 

require a separate environmental analysis. For example categorical exclusions may be completed to authorize 

manual and limited mechanical treatments in site specific areas. Prevention measures applied during land uses 

would continue to slow (but not stop) the spread of invasive plants on the Forest and surrounding lands (see 

chapter 3.1.5 for more information about the potential for spread of invasive plants over time within the Forest) 

given the propagule pressure and type of expected disturbance associated with surrounding land uses and 

activities. 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

20

Alternative A addresses some public concerns by eliminating most herbicide use on the Forest. There would 

continue to be low or no risks or impacts from herbicides on human health, nontarget vegetation and pollinators, 

soils, water, aquatic organisms, or wildlife. However, the threats to the environment from invasive plants would 

continue unabated. Neighbors would continue to be frustrated in their attempts to enlist the Forest Service to help 

with partnerships to implement effective integrated treatments within and outside Forest boundaries. 

No biological agents were deliberately released within the Malheur National Forest boundaries, because the 2002 

Court Order enjoined the Forest Service from releasing these agents. However, biological agents that have been 

released in surrounding National Forests and lands of other ownerships disperse to new areas on their own. The 

analyses of the environmental effects of biological control agents have already been completed under documents 

developed by Agricultural Plant Health and Insect Service (APHIS) for approval of their use. The completed 

environmental impact statements are available at: http://www.aphis.usda.gov/ppq/enviro_docs/index.html. These 

analyses assume the agent may occur throughout the range of its host invasive species.

Therefore, although they have not been released by the Malheur National Forest, biological control agents are 

helping to suppress or contain established populations of invasive plants here. Common biological agents 

released on neighboring Forests and adjacent counties and likely already distributed on the Malheur National 

Forest are displayed in the following table. 

Table 4. Biological agents released on neighboring lands

Target Species Agent Mode of Action

Canada Thistle Ceutorhunchus litura Larvae mine pith in stems of flowering plants, increasing 

susceptibility to pathogens. Adults feed on leaves.

Canada Thistle Urophora cardui Larvae cause galls on the stems that act as nutrient sinks, 

stressing plants and reducing seed production and growth.

Dalmation Toadflax Mecinus janthinus Larvae are stem miners; adults can cause damage to flowers 

and young leaves.

Leafy Spurge

Aphthona cyparissiae, 

Aphthona flava, 

Apthona nigriscutis

Adults feed on foliage reducing the plant's production of sugars; 

larvae feed on root hairs and young roots reducing the plant's 

ability to take up water and nutrients.

Leafy Spurge Aphthona czwalinae, Apthona 

lacertosa

Adults feed on foliage reducing the plant's production of sugars; 

larvae feed on root hairs and young roots reducing the plant's 

ability to take up water and nutrients.

Leafy Spurge Oberea erythrocephala Larvae bore in the stems and roots of larger plants. Adults girdle 

the top of the stalk before laying eggs in the stem.

Mediterranean Sage Phrydiuchus tau Adults feed on the leaves, and larvae feed in the root crown and 

petioles of large leaves.

Musk Thistle Rhinocyllus conicus Larvae eat seeds in primary heads, lateral heads still produce 

seed

Musk Thistle Trichosirocalus horridus

Larvae feed on the root crown, damaging the primary shoot, and 

adults feed on the leaves. Large numbers of larvae can kill 

rosettes.

Musk Thistle Urophora solstitialis Larvae cause galls in the seed heads that interfere with seed 

production and dissemination.

Spotted Knapweed Cyphocleonus achates Larvae are root borers and adults feed on the leaves
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

21

Target Species Agent Mode of Action

Spotted Knapweed Metzneria paucipunctella Larvae consume seeds in infested heads.

Spotted Knapweed, 

Diffuse Knapweed Bangasternus fausti

Attacks the project EISrly buds, and appears to contribute to the 

impacts of Larinus minutus. Larvae consume most of the seeds 

in infested heads.

Spotted Knapweed, 

Diffuse Knapweed Larinus minutus

Larvae feed in the flower head destroying most of the seeds.

Heavy attack by adults can stunt or kill plants and delay 

flowering.

St Johnswort Chrysolina quadrigemina Adults and larvae are foliage feeders.

Yellow Starthistle Bangasternus orientalis Larvae feed on seeds and seed heads, reducing the number of 

seeds by 40-60%

Yellow Starthistle Chaetorellia australis Larvae tunnel into the center of the head, where they feed on 

the ovaries and developing seeds.

Yellow Starthistle Chaetorellia succinia Larvae tunnel into the center of the head, where they feed on 

the ovaries and developing seeds.

Yellow Starthistle Eustenophus villosus Adults feed on developing buds, causing the buds to die. Larvae 

feed on the seed head and developing seeds.

Yellow Starthistle Larinus curtus Adults feed on the flowers and larvae feed on the seed head, 

reducing seed production.

Yellow Starthistle Urophora sirunaseva Larvae feed on flowers and seed heads and cause formation of 

galls.

2.3.2 Alternative B – Proposed Action

Introduction

Alternative B, the proposed action, is our proposal as the most cost-effective approach to invasive plant treatment 

while minimizing the adverse effects of treatment according to the Malheur National Forest LRMP as amended 

R6 2005 ROD. We inventoried the invasive plants across the Malheur National Forest and identified common 

control measures for the 18 primary target species found. 

The common control measures include a range of integrated treatment/restoration methods that could be 

implemented across a range of infested sites. We will identify the specific manual, mechanical, biological, 

herbicide and cultural/restoration treatments to be implemented at the time of treatment (see common control 

measures table below). 

In addition to the common control measures (table 8), we developed project design features (table 9) and 

herbicide-use buffers (table 10 and table 11) for alternative B. The project design features and herbicide-use 

buffers are intended to minimize adverse effects of treatment and follow national Best Management Practice 

guidelines for chemical uses on national forests (USDA Forest Service 2012). 

To develop the common control measures, project design features, and herbicide-use buffers, we considered the 

best available scientific information about invasive plant management. Our primary sources come from the R6 

2005 FEIS, the most current herbicide and adjuvant risk assessments (SERA and Bakke), professional journal 

articles and other information published since 2005. The literature cited section of chapter 4 documents our 

commitment to using best available science and high quality data. 

Alternative B responds to the purpose and need for action by authorizing several herbicide and other integrated 

treatment methods to be implemented on the Malheur National Forest over the next 5 to 15 years. These options 

are intended to effectively reduce the size and density of invasive sites and abate the adverse effects of invasive 

plants. The project would continue to be implemented each year until the treatments were no longer needed or 

conditions substantially change on the ground to such a degree that the analysis in this EIS is no longer valid. 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

22

The annual implementation planning process later in this chapter (section 2.4.2) discusses how changed 

conditions would be evaluated for this project over time. 

Aminopyralid would be used for the first year or so of treatment for about 1,350 acres (64 percent of the total 

infested acreage). This herbicide is likely to be the most effective of the 11 available herbicides for 13 of the 18 

primary target species (all except houndstongue, toadflax, pepperweed and whitetop, which have chlorsulfuron as 

the first-choice herbicide; and sulphur cinquefoil, that has metsulfuron methyl as the first-choice herbicide). 

Other effective herbicides could be used as needed over time, depending on whether the first year’s choice 

proved effective. 

Under alternative B, biological control agents would be deliberately redistributed to suppress or contain 

established populations of invasive plants on the Forest. Redistribution or release of biological control agents 

would be done as part of the Oregon Department of Agriculture Biological Control Program and meet the 

requirements of R6 2005 ROD standard 14. The treated areas would continue to be inventoried and monitored to 

determine the success of the treatments and when the released biological control agents have reached equilibrium 

with the target species. This EIS is tiered to the R6 2005 FEIS and various and ongoing APHIS NEPA documents 

for the release of biological control agents. By definition, only agents that have been approved by APHIS would 

meet the R6 2005 ROD Standard 14. See table 4 for the list of approved biological agents for target species that 

are currently found on the Forest.

Alternative B responds to public concerns about treatment effectiveness by authorizing a wide range of 

integrated treatment methods that would be prioritized, planned and implemented in cooperation with our 

neighbors. We would start to use herbicides and redistribute biological control agents on the Forest as soon as 

practicable after the NEPA decision. Alternative B is, by definition, the most cost-effective alternative.

Alternative B favorably responds to issues about effects of herbicides on human health, non-target vegetation and 

pollinators, soils, water, aquatic organisms, and wildlife because treatments would be implemented according to 

design features and herbicide-use buffers that minimize the risk of adverse effects.

Land and Resource Management Plan Amendment

We are proposing a Land and Resource Management Plan amendment to add aminopyralid to the list of 

acceptable herbicides for use as part of the integrated treatment toolbox for invasive plants on the Malheur 

National Forest. Aminopyralid (also known by the trade name: Milestone®) was not available during the analysis 

process for the R6 2005 FEIS. The risk assessment completed in 2007 (table 7) indicates that this herbicide will 

increase treatment effectiveness and decrease risk of adverse effects as compared to other herbicides authorized 

in the R6 2005 ROD. Thus, we propose to add aminopyralid to the list of approved ingredients in invasive plant 

standard 16 for the Forest (non-significant LRMP amendment). All other standards and guidelines for invasive 

plant management would remain the same (see chapter 1).

U.S. EPA (2005) has concluded that the use of aminopyralid as a replacement for other herbicides will decrease 

risk to some non-target species (SERA 2007):

“Aminopyralid is a Reduced Risk herbicide that provides reliable control of a broad spectrum of 

difficult-to control noxious weeds and invasive plants on rangeland and pastures, rights-of-way, and 

wildlife habitat areas. Aminopyralid is particularly effective for the control of tropical soda apple, musk 

thistle, Canada thistle, spotted knapweed, diffuse knapweed, yellow starthistle and Russian knapweed. 

Aminopyralid has a favorable human health toxicity profile when compared to the registered alternatives 

for these use sites and will be applied at a lower rate. Its residual action should alleviate the need for 

repeat applications, resulting in a reduction in the amount of herbicides applied to the environment for 

the control of these weeds. Aminopyralid has been determined to be practically non-toxic to non-target 

animals at the registered application rates, compared to the alternatives, and is less likely to impact both 

terrestrial and aquatic plants.” 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

23

Currently Standard 16 reads: 

Select from herbicide formulations containing one or more of the following 10 active ingredients: 

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

sulfometuron methyl, and triclopyr...Additional herbicides and herbicide mixtures may be added in the 

future at either the Malheur National Forest LRMP or project level through appropriate risk analysis and 

NEPA/ESA procedures.

We propose to amend Standard 16 to read: 

Select from herbicide formulations containing one or more of the following 11 active ingredients: 

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

sethoxydim, sulfometuron methyl, and triclopyr...Additional herbicides and herbicide mixtures may be 

added in the future at either the Malheur National Forest LRMP or project level through appropriate risk 

analysis and NEPA/ESA procedures.

Invasive Plant Treatment Methods Authorized Under Alternative B

The following description summarizes important information about the treatment methods that are proposed for 

alternative B.

Table 5. Proposed treatment methods descriptions

Treatment Method Description

Manual

Includes hand pulling or using hand tools (e.g., grubbing), to remove plants or cut off seed heads. 

Manual treatments are labor intensive, effective only for relatively small accessible areas, and would 

be repeated several times throughout the growing season depending on the species. Handsaws, 

axes, shovel, rakes, machetes, grubbing hoes, mattocks, brush hooks, and hand clippers may all be 

used to manually remove invasive plant species. Other manual methods could include mulching, hot 

water steaming, or solarization techniques such as using black plastic to cover invasive plants to 

shade out and kill pieces of roots (i.e. rhizomes). These techniques could be used where minimizing 

herbicide use is desirable such as streambanks or near sensitive plant populations.

Mechanical

Mechanical methods use power tools and include such actions as mowing, weed whipping, road 

brushing, and root tilling. These activities would typically occur along roadsides, rock sources, or 

other confined disturbed areas and dispersed use areas. Mowing and cutting would be used to 

reduce or remove above ground biomass. Seed heads and cut fragments of species capable of resprouting from stem or root segments would be collected and properly disposed of to prevent them 

from spreading into non-infested areas.

Biological Agents

Biological agents are parasitic insects, mites, nematodes, and pathogens that feed on specific parts 

of invasive plants and inhibit their growth and spread. In some situations, a suite of biological control 

agents is needed to reduce weed density to a desirable level. For instance, a mixture of five or more 

biological control agents may be needed to attack flower or seed heads, foliage, stems, crowns and 

roots all at the same time or during the plant’s life cycle. Typically 15 to 20 years are needed to 

suppress or contain an established population of invasive plants. Agents approved by the Animal 

and Plant Health Inspection Service (APHIS) that are proven natural control agents of specific 

invasive species but do not harm other species may be released.

Cultural Methods/

Restoration

Cultural controls are defined in the R6 2005 FEIS as: “The establishment or maintenance of 

competitive vegetation, use of fertilizing, mulching, prescribed burning, or grazing animals to control 

or eliminate invasive plants” (page 10). In this project, the following cultural treatments are not 

included: livestock grazing1

, burning, tilling, plowing and mechanical seed drilling. Mulching, 

seeding, planting would be used to encourage native plant survival and re-establishment, speed 

reoccupation of a site by native vegetation, and provide erosion protection. Restoration of native 

plant communities through mulching, seeding or planting would be likely to occur as a follow up to 

invasive plant treatment in areas where passive restoration is not sufficient. This will be determined 

as a part of each treatment prescription. The 1,281 acres that are of a size and configuration to 

potentially warrant broadcast spraying are assumed to need some sort of restoration in this analysis.

Please not that passive restoration could be sufficient in many of these areas, or restoration could 

be needed elsewhere.
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

24

Treatment Method Description

Herbicide 

Application: General 

Herbicides would be used to contain, control and eradicate invasive plants that are not costeffectively treated by other methods. When herbicide use is proposed to occur in or near sensitive 

areas, specific design features would be used to insure that vegetation treatments do not have an 

adverse impact on non- target plants or animals. Herbicide treatments, chemical mixing, spill 

prevention, and clean up would be done in accordance with Forest Service policies, plans and 

product label requirements.

Herbicide 

Application: 

Broadcast Spraying

Broadcast application means that herbicide is applied to a continuous population of invasive plants. 

This method is used when the weed is dense enough that it is difficult to discern individual plants 

and the area to be treated makes spot spraying impractical. Larger and denser infestations may 

require a broadcast spray. In cases where the invasive plant covers more than 70 percent of an area 

that is bigger than 0.1 acre, broadcasting may be the most cost-efficient method. The most 

ambitious conceivable situation would be all currently infested areas become 100 percent covered 

with invasive plants, which would require the full amount of herbicide to be broadcast on each acre 

at a typical rate. Using this assumption for this analysis, about 1,281 acres are assumed to be 

broadcast in this analysis under alternative B. Many project design features are proposed to avoid 

drift and other risks sometimes associated with broadcast spraying. Broadcast spraying using most 

of the 11 herbicides is not allowed near streams (with the exception of aminopyralid which poses 

little to no risk to the aquatic environment).

Herbicide

Application: Spot

and Selective 

Spraying 

Selective application targets individual plants. Herbicide is usually applied by hand. Spot spraying 

targets clumps of plants. Herbicide is usually applied with a backpack sprayer or other hand pump 

system. Spot spraying is also done using a hose off a truck-mounted or ATV-mounted tank. The 

most ambitious conceivable situation would be that all currently infested areas become 100 percent 

covered with invasive plants; however, the size of these infestations would not require broadcast 

treatment. Therefore under this scenario about 843 acres would be treated using selective or spot 

application methods.

1 Grazing would be managed to prevent invasive plant introduction, establishment and spread and may reduce existing populations. These 

actions would be managed under appropriate grazing management plans. Prescribed burning would also address prevention of the spread of 

invasive plants and could reduce the size of target populations. However, no grazing or burning is proposed for this project.

The herbicide active ingredients listed in table 6 are likely to be most effective on the currently mapped 

infestations using the herbicide application methods described above. The assumption that currently infested 

areas are 100 percent covered with invasive plants, which would require even herbicide application across each 

acre, overestimates the amount of broadcast that would actually occur during implementation because many of 

the infested areas are sparsely covered with invasive plants, so only a portion of each acre would actually be 

treated with herbicide, regardless of application tool. However, the assumption of 100 percent coverage allows 

for analysis of maximum possible herbicide exposure and potential effects on people and the environment (see 

chapter 3 for effects analysis). Spot or hand treatments would be preferred and used wherever they would be 

effective. Some mapped infestations are so small or so inaccessible that broadcast treatment would not be likely 

to occur there, even if they became 100 percent covered with invasive plants. 

Table 6. Summary of herbicide use under alternative B

First Year/First Choice Activity Acres Assuming 100 Percent 

Coverage with Invasive Plants

Potential Broadcast Herbicide

Aminopyralid 1,180

Chlorsulfuron 71

Metsulfuron methyl 30

Total Potential Broadcast Application Method 1,281

Potential Spot/Selective Herbicide 

Aminopyralid 168

Chlorsulfuron 519

Metsulfuron methyl 156

Total Potential Spot/Selective 843
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

25

The following table shows, for each herbicide, the active ingredient, the SERA risk assessment reference, the 

typical and maximum label rates, and some remarks about the herbicide. Maximum application rates may be used 

if necessary in small areas, but in general, spot and broadcast treatments will use typical or lower application 

rates. The SERA risk assessment reference and year is also given. 

Adjuvants are compounds added to the formulation to improve its performance. They can either enhance the 

activity of an herbicide’s active ingredient (activator adjuvant) or offset any problems associated with its 

application (special purpose or utility modifiers). Surfactants are one type of adjuvant that makes the herbicide 

more effective by increasing absorption into the plant. Many of the inert ingredients are proprietary in nature and 

have not been tested on laboratory species. However, confidential business information (i.e. the identity of 

proprietary ingredients) was considered in the preparation of the herbicide risk assessments completed prior to 

2004.

Inert compounds are those that are intentionally added to a formulation, but have no herbicidal activity and do 

not affect the herbicidal activity. Inerts are added to the formulation to facilitate its handling, stability, or mixing. 

Impurities are inadvertent contaminants in the herbicide, usually present as a result of the manufacturing process. 

The risk assessments describe the impurities and their risks: in this project, hexachlorobenzene is a by-product of 

manufacturing picloram and clopyralid and is factored into the toxicity analysis for these chemicals. 

The following table describes the herbicides authorized for use on the Forest. Most of these herbicides are not 

proposed for use during the first year of treatment, but could be used if the first year’s choice is not effective or 

on newly detected infestations. More information on herbicide toxicity is in chapter 3. 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

26

Table 7. Herbicide descriptions

Active 

Ingredient

Risk Assessment Year and 

Reference

Typical

Application 

Rate 

(lb. per ac) 

Highest 

Application 

Rate 

(lb. per ac)

Remarks

Aminopyralid 2007 – SERA TR-052-04-04a 0.078 0.11

This herbicide poses a very low risk to the aquatic environments. We will 

avoid ground water contamination as per label instructions. Aquatic 

formulations are not available but we can use this herbicide up to the water’s 

edge in most situations. It is the first-choice herbicide for about 64% of the 

currently infested acreage (about 1,346 acres). 

Chlorsulfuron 2004 – SERA TR 04-43-18-01c 0.056 0.25

This herbicide poses a moderate risk to the aquatic environments and there 

are no aquatic formulations. We will not use this herbicide next to streams or 

on certain soils or near certain non-target plants as per project design 

features. It is the first-choice herbicide for about 28% of the currently infested 

acreage (about 591 acres).

Clopyralid 2004 – SERA TR 04 43-17-03c 0.35 0.5

This herbicide poses a low risk to aquatic environments. We will implement 

some soil restrictions due to its increased mobility in some soil types and we 

will avoid ground water contamination as per label instructions. It is one of 

the most target-species selective herbicides proposed for use.

Glyphosate 2011 – SERA_TR-052-22-03b 2 7

This is one of the most common herbicides used in Oregon and has the 

advantage of being effective on a very wide range of target species. Aquatic 

formulations are available; however some formulations of glyphosate have

ingredients that may pose higher risk to aquatic environments. It is nonselective and quickly taken up by target plants. Many people have expressed 

concern about “round up” or “round up ready GMO crops” and its effect on 

human health. However, the studies that underpin the concerns are not 

applicable to the proposed project. The glyphosate risk assessment was 

updated recently and all current science was considered. 

Imazapic 2004 – SERA TR 04-43-17-04b 0.13 0.19

This herbicide poses a moderate risk to aquatic environments and there is 

no aquatic formulation. This herbicide is associated with a concern for nontarget plants and we will protect botanical species of conservation concern.

Imazapyr 2004 – SERA TR 04-43-17-05b 0.45 1.25

This herbicide poses a low risk to aquatic environments and an aquatic 

formulation is available. This herbicide is also associated with a concern for 

non-target plants and we will buffer botanical species of conservation 

concern.

Metsulfuron 

Methyl 2003 – SERA TR 04-43-17-01b 0.03 0.15

This herbicide poses a moderate risk to aquatic environments and no 

aquatic formulations are available. We will buffer streams when using this 

herbicide. This herbicide is also associated with a concern for non-target 

plants and we will protect botanical species of conservation concern. It is the 

first-choice herbicide for about 8% of the currently infested acreage (about 

186 acres).
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

27

Active 

Ingredient

Risk Assessment Year and 

Reference

Typical

Application 

Rate 

(lb. per ac) 

Highest 

Application 

Rate 

(lb. per ac)

Remarks

Picloram 2003 – SERA TR 03-43-16-01b 0.35 1.0

This herbicide poses higher risk to aquatic environments and there is no 

aquatic label. We will not use this herbicide near streams, especially 

because it is toxic to certain aquatic species and it can be very mobile. It is 

valued for its persistence in the soil; we will not use it on certain soils and we 

will use it infrequently to protect soil biology.

Sethoxydim 2001 – SERA TR 01-43-01-01c 0.3 0.38

This herbicide poses a moderate risk to aquatic environments and there is 

no aquatic label. We will not use it near streams. It is very selective (only kills 

grasses). 

Sulfometuron 

Methyl 2004 – SERA TR 03-43-17-02c 0.045 0.38

This herbicide poses a moderate risk to aquatic environments and no 

aquatic formulations are available. We will buffer streams when using this 

herbicide. This herbicide is also associated with a concern for non-target 

plants and we will protect botanical species of conservation concern.

Triclopyr 2003 – SERA TR 02-43-13-03b 1.0 10

This herbicide poses higher risk to aquatic environments, however there is 

an aquatic label that reduces (but does not eliminate) the risk. We will not 

use this herbicide near streams. This herbicide poses some risk to herbicide 

applicators and will not be broadcast as per R6 2005 ROD Standard 16. It 

may only be spot or selectively applied and only in limited cases. 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

28

Integrated Treatment Prescriptions (Common Control Measures) For 18 Primary Target 

Species

The following table lists the 18 primary target species; common and scientific names, (scientific code), 

and growth habit; spatial extent (no. of sites and acres); first-choice and other herbicides known to be 

effective on each species (or group of species) and detailed integrated prescription notes. The order 

species are presented is for the convenience of display and no other meaning should be ascribed. The 

order of other effective herbicides is alphabetical and no other meaning should be ascribed. 

We propose to apply aminopyralid to about 64 percent of the infested acreage for the first treatment entry 

(about 1,350 acres) and chlorsulfuron for the first treatment entry on 28 percent of the acres (about 591 

acres), and metsulfuron methyl for one target species: sulphur cinquefoil that covers an estimated 8 

percent of the acres (about 186 acres). We may use other effective herbicides in future re-treatments 

depending on the effectiveness of the first-choice herbicide. 

Table 8. Common control measures

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

Yellow star-thistle

Centaurea solstitialis

(CESO3)

Annual

aminopyralid

clopyralid

glyphosate

picloram

Early detection and treatment increase the 

chances of control. 

Treatment of small infestations in otherwise 

healthy sites should be a priority Biological 

control agents are available. 

Hand pull when soil is moist and remove all 

roots and flower and seed heads.

Common St. Johnswort

Hypericum perforatum

(HYPE)

Perennial with stolons and 

rhizomes

aminopyralid

glyphosate

metsulfuron 

methyl

picloram

Biological agents are available. 

Small infestations may be controlled by 

pulling or digging. Repeated treatments will 

be necessary because lateral roots can give 

rise to new plants. Bag and remove all plant 

parts from site.

Sulphur cinquefoil

Potentilla recta

(PORE5)

Taprooted perennial that 

may have several shallow, 

spreading branch roots but 

not rhizomes

metsulfuron 

methyl

glyphosate 

picloram

triclopyr

Cultural treatments such as seeding of native 

plants may be effective.

There are no approved biocontrols.

Small infestations may be controlled by hand 

digging if the entire root crown is removed.

For large infestations, selective herbicides 

are likely the only method of effective control 

(TNC 2004).

Repeated treatments are needed for the first 

couple of years to ensure re-establishment 

does not occur.

Russian knapweed

Acroptilon repens

(ACRE3)

aminopyralid

clopyralid

chlorsulfuron

glyphosate

imazapyr

metsulfuron 

methyl

picloram

Hand pulling is effective only in the 

establishment year. 

Reproduces mainly by vegetative 

propagation from buds on creeping roots.

Biocontrol agents being developed.

Cutting or mowing several times per year will 

control top growth and seed production; re-
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

29

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

Long-lived creeping 

perennial

emerging plants will have less vigor.

Lasting control requires an integrated 

approach; using mechanical or cultural 

measures with herbicide application, 

especially in late fall, is most effective.

Small, isolated infestations should be 

eradicated first. Then larger infestations 

should be controlled from the perimeter and 

eradicated when possible.

Spotted knapweed

Centaurea stoebe ssp. 

Micranthos

(CESTM)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

triclopyr

picloram

Treatment would focus on reducing seed 

production and preventing germination.

Biological agents are available.

Repeated manual pulling and digging may 

eliminate small infestations (2-4 times per 

year for multiple years). Pull prior to seed set. 

Bag and remove flower and seed heads.

Diffuse knapweed

Centaurea diffusa

(CEDI)

Short-lived perennial, 

biennial or annual. Often 

with a long, stout taproot

aminopyralid

clopyralid

glyphosate

picloram

triclopyr

Squarrose knapweed

Centaurea ulfome ssp. 

Squarrosa

(CEVIS2)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

picloram

triclopyr

Meadow knapweed

Centaurea jacea sensulato

(CEJA)

Taprooted perennial

aminopyralid

clopyralid

glyphosate

picloram

triclopyr
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

30

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

Canada thistle

Cirsium arvense

(CIAR4)

Rhizomatous perennial

aminopyralid

clopyralid

chlorsulfuron

picloram

Combining mechanical, cultural, biological, 

and chemical methods is best for effective 

control Biological agents are available, but 

use may affect native thistles. 

Mowing, cutting or pulling can be an effective 

control if repeated at about 1-month intervals 

throughout the growing season for several 

years. Combining mowing/cutting with 

herbicides (in the fall) will further enhance 

control of Canada thistle. Covering with 

plastic tarp (solarization) may be effective for 

small infestations.

Bull thistle*

Cirsium vulgare

(CIVU)

Taprooted biennial

aminopyralid

clopyralid

chlorsulfuron

glyphosate

picloram

triclopyr Prioritize small infestations in otherwise 

healthy sites. Prioritize prevention of 

establishment and eliminating plants as soon 

as they are found.

Biological agents are available, but use may 

affect native thistles

Manually pulling rosettes or cutting stems 2”-

4” below the soil surface before flower heads 

develop kills plants and prevents seed 

development. Roots may be left on site to 

dry; all flower and seed heads should be 

removed.

Covering disturbed sites, particularly small 

burn areas, with fine to medium sized organic 

matter may prevent or reduce the size of 

infestations.

Scotch Thistle

Onopordum acanthium

(ONAC)

Taprooted biennial or shortlived perennial

aminopyralid

chlorsulfuron

clopyralid

glyphosate

picloram

triclopyr

Musk thistle

Carduus nutans

(CANU4)

Taprooted biennial or 

occasional annual

aminopyralid

chlorsulfuron

clopyralid

glyphosate

picloram

triclopyr

Leafy spurge

Euphorbia esula

(EUES)

Rhizomatous perennial

aminopyralid glyphosate 

imazapic picloram

Early detection and rapid eradication is 

important since plant spreads rapidly by 

seeds and rhizomes.

Continuous aggressive management is 

necessary to keep infestations under control 

(5 – 10 years).

Prioritizing treatment of small infestations, 

then treating large infestations from the 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

31

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

outside edges is most effective. 

Biological control agents may reduce 

aboveground stems but do not kill root 

systems. 

Mechanical, cultural, or herbicide methods 

alone are rarely effective. Combinations of 

several herbicide treatments and planting 

grass seed may provide the best chance of 

controlling the species. 

Hand pulling and grubbing are not effective 

because of the extensive root system. 

Cutting and mowing reduce seed production 

and the plant’s competitive ability.

Covering with weed cloth, plastic, or thick 

mulch may kill plants. Site can then be 

planted with native seed.

If manual methods are used all plant parts 

should be bagged and removed since new 

plants may form from roots and rhizomes as 

well as from seeds.

Plant’s milky sap may be irritating to skin, 

eyes, and digestive tract of humans and other 

animals.

Houndstongue

Cynoglossum officinale

(CYOF)

Taprooted biennial or shortlived perennial

chlorsulfuron

metsulfuron 

methyl 

imazapic

Mowing/cutting second year plants during 

flowering, but before seed maturation 

reduces seed production and may kill the 

plant. 

Pulling plants or cutting 1 – 2 inches below 

the soil surface have the best chance of 

eliminating plants. Cutting produces less 

ground disturbance than pulling.

Bag and remove all flower and seed heads.

Dalmatian toadflax

Linaria dalmatica

(LIDA)

Perennial with taproot and 

extensive system of lateral 

roots

chlorsulfuron

metsulfuron 

methyl 

imazapic 

picloram

Dalmatian toadflax reproduces primarily by 

seed and partly by adventitious root buds. 

Yellow toadflax reproduces primarily by 

adventitious root buds on lateral roots.

Biological agents are available and may be 

very effective. 

Manual pulling and digging may not be 

effective because of the deep (4-10 feet) and 

laterally extensive root systems (to 10 feet 

from plant). If manually removed, all roots 

and flower and seed heads should be bagged 

and removed. 

Yellow toadflax

Linaria vulgare

(LIVU2)

Perennial with taproot and 

chlorsulfuron

metsulfuron 

methyl 

imazapic 

picloram
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

32

Primary Target Species First-Choice 

Herbicide

Other Effective 

Herbicides Integrated Treatment Notes

extensive system of vertical 

and creeping lateral roots Cutting stems in spring or early summer 

would eliminate seed production, but not the 

root system.

If biocontrol agents continue to be effective, 

herbicide application may not be needed. 

Whitetop

Cardaria draba

(CADR)

Rhizomatous perennial

chlorsulfuron

metsulfuron 

methyl

glyphosate

imazapic

imazapyr

These species are difficult to control because 

of its deep taproots (9 ft.) and ability to sprout 

from root fragments.

Early detection and proactive management is 

most effective since established infestations 

are difficult to control.

Frequent monitoring for new sites and 

prioritizing small infestations in otherwise 

healthy sites is important.. Next priority would 

be for corridors such as waterways and 

irrigations structures that have a high 

likelihood of spread. Biological controls are 

not available.

Repeated pulling may control small, young 

infestations. Established plants are likely to 

resprout from deep roots. All roots and flower 

and seed heads should be removed. 

Mowing does not eliminate plants but 

removes thatch.

Perennial pepperweed

Lepidium latifolium

(LELA2)

Perennial with rhizome like 

creeping roots

*Bull thistle and Canada thistle were cataloged together in our November 2012 invasive plant inventory. However, the precise 

species would be identified before an integrated treatment prescription would be applied.

Project Design Features

The following project design features (pdfs) minimize the potential impacts of invasive plant treatment. 

These pdfs provide sideboards for treatment of known sites, along with new detections. The pdfs were 

developed to respond to the site-specific resource conditions within the infested areas, including (but not 

limited to) botanical areas; habitat and presence of botanical, wildlife and/or fish species of conservation 

concern; the potential for herbicide delivery to water, and proximity other areas of interest (roads and 

trails, recreation sites, Wilderness/Wild and Scenic Rivers, wildland fire areas). Implementation of the 

pdfs would be mandatory. The analysis assumes pdfs are properly implemented. The herbicide-use buffers

apply horizontal (map) distances. The pdfs and herbicide-use buffers follow national Best Management 

Practice guidelines for chemical uses on national forests (USDA Forest Service2012). The project design 

features associated with alternative B are summarized in the following table.

Table 9. Project Design Features

pdf

Reference Design Features Purpose of pdf Source of pdf

B – Coordination with Other Landowners/Agencies

B1

Work with owners and managers of 

neighboring lands to respond to invasive 

plants that straddle multiple ownerships. 

To ensure that neighbors 

are fully informed about 

nearby herbicide use and to 

A variable distance 

based on site and 

species specific 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

33

pdf

Reference Design Features Purpose of pdf Source of pdf

Coordinate treatments within appropriate 

distances based on invasive species 

reproductive characteristics, and current 

use of area.

increase the effectiveness 

of treatments on multiple 

ownerships. 

characteristics was 

chosen because it 

adjusts for various 

conditions that exist in 

these areas. All pdfs

related to riparian areas 

and buffer distances will 

be followed.

C – To Prevent the Spread of Invasive Plants During Treatment Activities

C1

Ensure vehicles and equipment 

(including personal protective clothing) 

does not transport invasive plant 

materials. 

To prevent the spread of 

invasive plants during 

treatment activities

Common measure.

D – Wilderness Areas 10

D1

No solarization, mechanical or motorized 

treatments will occur in wilderness areas. 

Herbicide use would be approved by the 

Regional Forester via a pesticide use 

proposal.

To maintain wilderness 

values, e.g., solitude, 

unimpeded natural 

processes—and comply 

with environmental laws 

and policies.

Wilderness Act, 1990 

Malheur National Forest 

Plan

E – Non-herbicide Treatment Methods

E1

Treatments implemented below the 

ordinary high water mark will be applied

from the bank and workers will not walk 

in flowing streams regardless of 

treatment method. 

To reduce the likelihood of 

causing negative impacts to 

fish and fish habitat.

Memorandum of 

Understanding between 

WDFW and USDA 

Forest Service, January 

2005. 

E2

Fueling of gas-powered equipment with 

tanks larger than 5 gallons would 

generally not occur within 150 feet of 

surface waters. Fueling of gas-powered 

machines with tanks smaller than 5 

gallons may occur up to 25 feet of 

surface waters.

To protect riparian and 

aquatic habitats. Common Measure

F – Herbicide Applications

F1

POEA surfactants, urea ammonium 

nitrate or ammonium sulfate would not 

be used in applications within 100 feet of 

surface water, wetlands or on roadside 

treatment areas having high potential to 

deliver herbicide.

To protect aquatic 

organisms.

SERA and Bakke risk 

assessments

F2

The least amount of a given herbicide 

would be applied as necessary to meet 

control objectives. 

NPE surfactant would not be broadcast 

at a rate greater than 0.5 lbs. a.i./ac 

(pounds of active ingredient per acre). 

Favor other classes of surfactants 

wherever they are expected to be 

effective.

In no case will imazapyr use exceed 0.70 

To eliminate possible 

herbicide or surfactant 

exposures of concern to 

human health.

SERA and Bakke risk 

assessments

 10 Invasive plant eradication within Wilderness meets the “no impact” intent of the Wilderness Act and associated 

land use policies. 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

34

pdf

Reference Design Features Purpose of pdf Source of pdf

lbs. a.i./ac. Broadcast application of 

Clopyralid, Glyphosate, Picloram, 

Sethoxydim, or Sulfometuron methyl will 

not exceed typical application rates.

F3

Broadcast herbicide applications would 

occur when wind velocity is between two 

and eight miles per hour to reduce the 

chance of drift. During application, 

weather conditions would be monitored 

periodically by trained personnel.

To ensure proper 

application of herbicide and 

reduce drift. 

These restrictions are 

typical so that herbicide 

use is avoided during 

inversions or windy 

conditions. 

F4

To minimize herbicide application drift 

during broadcast operations, use low 

nozzle pressure; apply as a coarse 

spray, and use nozzles that minimize fine 

droplet spray, e.g., nozzle diameter to 

produce a median droplet diameter of 

500-800 microns. 

To ensure proper 

application of herbicide and 

reduce drift. 

These are typical 

measures to reduce 

drift. The minimum 

droplet size of 500 

microns was selected 

because this size is 

modeled to eliminate 

adverse effects to nontarget vegetation 100 

feet or further from 

broadcast sites (see 

chapter 3 for details).

F5

No use of sulfonylurea herbicides 

(chlorsulfuron, sulfometuron methyl and 

metsulfuron methyl) on dust-laden bare 

soils. Avoid bare areas >100 sq. ft. with 

powdery, ashy dry soil, or light sandy 

soil.

To avoid potential for 

herbicide drift. Label advisory

F6

When herbicides are applied, a non-toxic

blue dye will be used to mark treated 

areas. 

To ensure treated areas are 

obvious to people and 

prevent accidental ingestion 

by plant collectors.

Common measure

G Herbicide Transportation and Handling Safety/Spill 

Prevention and Containment

§ An Herbicide Transportation and Handling Safety/Spill 

Response Plan would be the responsibility of the 

herbicide applicator. At a minimum the plan would:

§ Address spill prevention and containment.

§ Estimate and limit the daily quantity of herbicides to be 

transported to treatment sites.

§ Require that impervious material be placed beneath 

mixing areas in such a manner as to contain small 

spills associated with mixing/refilling.

§ Require a spill cleanup kit be readily available for 

herbicide transportation, storage and application 

(minimum FOSS Spill Tote Universal or equivalent).

§ Outline reporting procedures, including reporting spills 

to the appropriate regulatory agency.

§ Ensure applicators are trained in safe handling and 

transportation procedures and spill cleanup.

§ Require that equipment used in herbicide storage, 

transportation and handling are maintained in a leak 

proof condition.

§ Address transportation routes so that traffic, domestic 

water sources, and blind curves are avoided to the 

extent possible.

§ Specify conditions under which guide vehicles would 

To reduce likelihood of 

spills and contain any spills. FSH 2109.14
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

35

pdf

Reference Design Features Purpose of pdf Source of pdf

be required.

§ Specify mixing and loading locations away from water 

bodies so that accidental spills do not contaminate 

surface waters.

§ Require that spray tanks be mixed or washed further 

than 150 feet of surface water.

§ Ensure safe disposal of herbicide containers.

§ Identify sites that may only be reached by water travel 

and limit the amount of herbicide that may be 

transported by watercraft.

H - Soils, Water and Aquatic Ecosystems

H1

Follow herbicide-use buffers shown 

below. Tank mixtures would apply the 

largest buffer as indicated for any of the 

herbicides in the mixture. 

To reduce likelihood that 

herbicides would enter 

surface waters in 

concentrations of concern

and ensure that the project 

does not hamper 

attainment of riparian 

management objectives. 

Herbicide-use buffers 

are based on label 

advisories; SERA risk 

assessments and Berg’s 

2004 study of broadcast 

drift and run off to 

streams. Herbicide-use 

buffers are intended to 

demonstrate compliance 

with R6 2005 ROD 

Standards 19 and 20.

H2

In riparian and aquatic settings, vehicles 

(including all-terrain vehicles) used to 

access invasive plant sites, or for 

broadcast spraying will not travel off 

roadways, trails and parking areas if 

damage to riparian vegetation, soil and 

water quality, and aquatic habitat is 

likely.

To protect riparian and 

aquatic habitats.

Common protection 

measure

H3

Avoid using picloram and/or metsulfuron

methyl on bare or compact soils, and 

inherently poor productivity soils that are 

highly disturbed. Poor soils include 

shallow soils less than 20 inch depth that 

lack topsoil and serpentine soils.

To preserve site recovery 

after disturbance, lessen 

offsite runoff and leaching.

Poor soils will have longer 

residence times with these 

persistent herbicides.

Label advisory

H4

Do not use more than one application of 

picloram or metsulfuron methyl on a 

given area in a calendar year, except to 

treat areas missed during the initial 

application.

Reduce potential for 

accumulation in soil.

SERA Risk 

Assessments. Based on 

quantitative estimate of 

risk from a maximum 

level of exposure.

H5

Limit herbicide offsite transport on sites 

with high runoff potential including sites 

with: shallow seasonal water tables,

saturated soils (wet muck and peat 

soils), steep erosive slopes with shallow 

soils and rock outcrop, or bare 

compacted and disturbed soils.

Limit runoff by applying herbicide during 

the dry season with the lowest soil 

moisture conditions, where > 50% 

groundcover exists on shallow slope 

sites, and > 70% on steep slope sites, 

and/or at reduced rates.

Reduce potential offsite 

runoff transport of 

herbicides.

SERA Risk 

Assessments and Label.

Based on quantitative 

risk for erosion and 

runoff.

H6 For soils with seasonally high water 

tables, do not use picloram or triclopyr 

Reduce the risk for 

contamination of Label advisory
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

36

pdf

Reference Design Features Purpose of pdf Source of pdf

BEE and limit glyphosate use to aquatic 

label only.

groundwater and offsite 

runoff to aquatic habitat and 

fish.

H7

Lakes and Ponds – No more than half 

the perimeter or 50 percent of the 

vegetative cover within established 

buffers or 10 contiguous acres around a 

lake or pond would be treated with 

herbicides in any 30-day period. This 

limits area treated within riparian areas to 

keep refugia habitat for reptiles and 

amphibians.

To reduce exposure to 

herbicides by providing 

some untreated areas for 

organisms to use. 

SERA Risk 

Assessments. Based on 

quantitative estimate of 

risk from maximum 

herbicide exposure 

scenario and uncertainty 

regarding effects to 

reptiles and amphibians.

H8

Wetlands would be treated when soils 

are driest. If herbicide treatment is 

necessary when soils are wet, use 

aquatic labeled herbicides. Favor 

hand/selective treatment methods where 

effective and practical. No more than 10 

contiguous acres or fifty percent 

individual wetland areas would be 

treated in any 30-day period.

To reduce exposure to 

herbicides by providing 

some untreated areas for 

some organisms to use.

SERA Risk 

Assessments. Based on 

quantitative estimate of 

risk from maximum 

herbicide exposure 

scenario and uncertainty 

in effects to some 

organisms, and label 

advisories.

H9

Herbicide use would not occur within 100 

feet of wells or 200 feet of spring 

developments. For stock tanks located 

outside of riparian areas, use wicking, 

wiping or spot treatments within 100 feet 

of the watering source. 

To reduce the potential for 

herbicide delivery to wells 

and springs that provide 

drinking water, and to 

protect watering systems 

used for grazing animals.

Label advisories and 

state drinking water 

regulations.

H10

Use of Triclopyr BEE is not allowed 

except in dry upland areas that are not 

hydrologically connected to streams or 

ponds with water present.

Reduce the risk for 

contamination of 

groundwater and offsite 

runoff to aquatic habitat and 

fish.

Label and quantitative 

assessment for risk to 

aquatic organisms.

H11

Do not spray when local weather 

forecast calls for a ≥ 50% chance of rain, 

or when wind speed at the site is in 

excess of 8 mph.

Reduce potential offsite 

runoff transport of 

herbicides.

SERA Risk 

Assessments and Label.

Based on quantitative 

risk for erosion and 

runoff.

I - Vascular and Non-Vascular Plant and Fungi Species of Concern

I1

A USDA Forest Service botanist would 

use monitoring results/adaptive 

management to refine herbicide-use 

buffers in order to adequately protect 

botanical species on the Regional 

Forester’s Sensitive List.

To prevent any repeated 

effects to sensitive 

botanical populations, 

thereby mitigating any longterm effects. Uncertainty 

about effects on 

nonvascular plants would 

be addressed through 

monitoring.

Herbicide-use buffer 

sizes for broadcast of 

most herbicides are 

based on Marrs 1989 

based on tests on 

vascular plants. Spot

and hand/select buffer 

distances are based on 

reports from 

experienced applicators.

I2

Botanical surveys will be conducted to 

document locations of sensitive plants if 

suitable habitat is within 100 feet of 

planned herbicide treatments

To ensure sensitive 

botanical species are 

protected and botanical 

surveys are conducted 

when appropriate

Forest Service Manual

2670 and applicable 

federally listed recovery 

plans

I3

Sensitive plants located within 100 feet 

of planned ground-based broadcast 

applications would be covered by 

protective barrier, or broadcast 

To ensure sensitive 

botanical species are 

protected

Forest Service Manual

2670 and applicable 

federally listed recovery 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

37

pdf

Reference Design Features Purpose of pdf Source of pdf

application would be avoided in these 

areas (spot or hand herbicide treatment, 

or non-herbicide methods may be used 

without covering sensitive plants)

plans

I4

When sensitive plants are within 10 feet 

of saturated or wet soils at the time of 

herbicide application, only hand methods 

(wiping, stem injection,) would be used. 

Avoid the use of picloram and imazapyr 

in this situation, and use aquatic triclopyr 

with caution as typical application rates 

can result in concentrations greater than 

estimated or measured “no observable 

effect concentration” to aquatic plants 

(R6 2005 FEIS, Table 4-47).

To ensure sensitive 

botanical species are 

protected

Forest Service Manual

2670 and applicable 

federally listed recovery 

plans

I6

Monitoring prework review would occur 

before implementation to ensure that 

prescriptions, contracts and agreements 

integrate appropriate project design 

features.

To ensure sensitive 

botanical species are 

protected

Forest Service Manual

2670 and applicable 

federally listed recovery 

plans

I7

Implementation monitoring would occur 

during implementation to ensure project 

design features are implemented as 

planned. An implementation monitoring 

form will be used to document daily field 

conditions, activities, accomplishments 

and/or difficulties. Contract 

administration mechanisms would be 

used to correct deficiencies. Herbicide 

use will be reported as required by the 

Forest Service Health Pesticide Use 

Handbook.

To ensure sensitive 

botanical species are 

protected

Forest Service Manual

2670 and applicable 

federally listed recovery 

plans

I8

Effectiveness monitoring would occur 

during and after treatment to determine 

whether invasive plants are being 

effectively controlled and to ensure nontarget vegetation, especially sensitive

species are adequately protected. 

To ensure sensitive 

botanical species are 

protected

Forest Service Manual

2670 and applicable 

federally listed recovery 

plans

I9

The impacts of herbicide use on some 

sensitive botanical species are uncertain, 

especially non-vascular species. To 

manage this uncertainty, representative 

samples of herbicide treatment sites 

adjacent to sensitive botanical species 

would be monitored. Non-target 

vegetation within 100 feet of herbicide 

broadcast treatment sites and 20 feet of 

herbicide spot and hand treatment sites 

would be evaluated before treatment, 

immediately after treatment, and two to 

three months later as appropriate. 

Herbicide-use buffers would be 

expanded if damage is found as 

indicated by: 

•Decrease in the population of the 

species of conservation concern

•Leaf discoloration or chlorophyll change

To ensure SOLI are 

protected and survey are 

conducted when 

appropriate

Forest Service Manual

2670 and applicable 

federally listed recovery 

plans
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

38

pdf

Reference Design Features Purpose of pdf Source of pdf

•Mortality 

Monitoring would continue until three 

post-treatment visits (at one or more 

sites near each sensitive botanical 

species) confirm a lack of adverse 

effects.

J - Wildlife Species of Local Interest

J1 Gray Wolf

J1-a

Treatments within 1 mile of active wolf 

dens or rendezvous sites would only 

occur outside the season of occupancy 

(April 1 through June 30).

Reduce impacts to active 

dens or rendezvous sites

Federal Register (USDI 

FWS 2003)

J2 Bald eagle

J2-a

Noise-producing activity above ambient 

levels would not occur near known winter 

roosts and concentrated foraging areas 

between October 31 and March 31 

during the early morning or late 

afternoon. Disturbance to daytime winter 

foraging areas would be avoided.

Minimize disturbance and 

energy demands during the 

winter.

Bald Eagle Management 

Guidelines for OR-WA 

(Dillon 1981); USDI 

FWS 2007, No, 62 4(d)

J2-b

Treatment of areas within 0.25 mile, or 

0.50 mile line-of-sight, of bald eagle 

nests would be timed to occur outside 

the nesting/fledging season of January 1 

to August 31, unless treatment activity is 

within ambient levels of noise and human 

presence (as determined by a local 

specialist). Occupancy of nest sites (i.e. 

whether it is active or not) would be 

determined each year prior to 

treatments.

Reduce impacts to eagle 

nests and reproduction.

Bald Eagle Management 

Guidelines for OR-WA 

(Dillon 1981) and, USDA 

Forest Service 2005a

J3 Peregrine Falcon

J3-a

Seasonal restrictions shall apply to all 

known peregrine falcon nest sites for the 

periods and elevations listed below:

a. Low elevation sites (1000-2000 ft.) –

Jan 1st to July 1st 

b. Medium elevation sites (2001-4000 ft.) 

– Jan 15th to July 31st 

c. Upper elevation sites (greater than 

4000 ft.) – Feb 1st to Aug 15th 

These restrictions may be waived if the 

site is unoccupied or if nesting efforts fail 

and monitoring indicates no further 

nesting behavior. Seasonal restrictions 

shall be extended if monitoring indicates 

late season nesting, asynchronous 

hatching leading to late fledging, or 

recycle behavior which indicates that late 

nesting and fledging will occur. 

Protection would be provided until at 

least two weeks after all young have 

fledged.

Reduce disturbance to 

nesting birds and protect 

eggs and nestlings.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J3-b All invasive plant treatments would be 

restricted within 0.5 miles of peregrine Reduce disturbance to Pagel 2006
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

39

pdf

Reference Design Features Purpose of pdf Source of pdf

falcon nests (primary nest zone) during 

the nesting season (described above).

nesting birds and young. Peregrine falcon nest 

site data, 1983-2006.

J3-c

Invasive plant treatments involving 

motorized equipment and/or vehicles 

would be seasonally prohibited within the 

secondary nest zone (0.5 miles to 1.5 

miles of known nest sites) during the 

nesting season. This may include 

activities such as mulching, chainsaws, 

vehicles (with or without boom spray 

equipment) or other mechanically-based 

invasive plant treatment.

Reduce disturbance to 

nesting birds and young.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J3-d

Non-mechanized or low disturbance 

invasive plant activities (such as spot 

spray, hand pull, etc.) may occur within 

the secondary nest zone (0.5 miles to 1.5 

miles of known nests) during the nesting 

season, but would be coordinated with 

the wildlife biologist on a case-by-case 

basis to determine potential disturbance 

to nesting falcons and identify mitigating 

measures, if necessary.

Reduce disturbance to 

nesting birds and young.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J3-e

Picloram and Clopyralid would not be 

used within 1.5 miles of a peregrine nest 

more than once per year.

Reduce herbicide exposure 

to eggs.

Pagel 2006

Peregrine falcon nest 

site data, 1983-2006.

J4 Greater Sage Grouse

J4-a

Do not use NPE-based surfactants in 

areas where sage grouse may forage, as 

determined by the district wildlife 

biologist. Glyphosate would be limited to 

the typical application rate.

Minimize exposure to 

herbicides and surfactants 

that could pose a risk.

Biological Evaluation for 

Malheur Invasive Plant 

EIS, USDA Forest 

Service 2000.

J4-b

Human activities within 0.3 mile of leks 

will be prohibited from the period of one 

hour before sunrise until four hours after 

sunrise and one hour before sunset until 

one hour after sunset from February 15 –

May 15.

Minimize disturbance to 

breeding grouse

Connelly et al. 2000, 

USDI FWS 2003.

J4-c

Do not conduct any vegetation 

treatments or improvement projects in 

breeding habitats from February 15 –

June 30.

Minimize disturbance to 

breeding grouse Connelly et al 2000

J5 Columbia Spotted Frog

J5-a

Avoid broadcast spraying of herbicides, 

and spot spraying of glyphosate with 

POEA surfactant, sulfometuron methyl, 

and NPE-based surfactants within 100 

feet of occupied or suitable spotted frog 

habitat. Follow herbicide-use buffers in 

wetlands. Treatment methods, timing 

and location will be coordinated with a 

local biologist prior to implementation.

Reduce impacts to the 

Columbia spotted frog.

Appendix P of the R6 

2005 FEIS; SERA 2003, 

2004; Bakke 2003

J6 Silver bordered fritillary

J6-a

Within occupied sites, follow pdfs

identified under vascular plants of 

concern to protect host/nectar plant 

Reduce the likelihood 

host/nectar plants would be 

affected.

Malheur Invasive Plant 

BE.
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

40

pdf

Reference Design Features Purpose of pdf Source of pdf

species.

J6-b

Within occupied habitat proposed for 

treatment, use of ester formulations of 

herbicide and NPE-based surfactants 

would be prohibited.

Minimize exposure of 

herbicides and surfactants 

that could pose a risk to the 

silver bordered fritillary.

Malheur Invasive Plant 

BE.

J7 Pygmy Rabbit

J7-a

Within suspected burrow areas, activities 

will be restricted to manual techniques. 

Treatment methods, timing and location 

will be coordinated with a local biologist.

Minimize chances a burrow 

would collapse.

Malheur Invasive Plant 

BE.

J8 Upland Sandpiper

J8-a

In order to avoid disturbance or potential 

trampling of nesting upland sandpipers, 

no treatment would occur on sites that 

have historic or recent documentation of 

upland sandpipers during the nesting 

season (April 1st to August 1st), unless 

the site has been surveyed and no 

nesting is occurring.

Minimize likelihood that 

nests would be disturbed 

during treatment.

Malheur Invasive Plant 

BE.

J9 Grasshopper Sparrow

J9-a

In order to avoid disturbance or potential 

trampling of nesting birds during the 

nesting season (May 1st to August 1st), 

no treatment would occur on sites where 

grasshopper sparrows have been 

documented.

Minimize likelihood that 

nests would be disturbed 

during treatment.

Malheur Invasive Plant 

BE.

J10 Harney Basin Duskysnail

J10-a

If an occupied site is proposed for 

treatment, a local biologist would be 

consulted to determine protection 

measures, if necessary. These measures 

may include limitations on vehicle entry, 

modifications to treatment type or timing, 

or implementation of buffers.

Minimize likelihood that 

snails would be harmed 

from treatment

Malheur Invasive Plant 

BE

J11 Featured Species: Raptors and Osprey

J11-a

Active raptor nest sites will be protected 

during implementation. If a raptor nest is 

found within 0.50 mile of a site proposed 

for treatment, a wildlife biologist will be 

consulted to determine appropriate 

seasonal restriction dates and buffer 

distances, if necessary.

Reduce impacts to raptor 

nesting and reproduction.

Malheur Forest Plan

Ochoco Forest Plan

J12 Big game

J12-a

Restrict off-highway vehicle use within 

MA 41 (big game winter range) between 

December 1 and April 1.

Reduce disturbance to 

wintering elk and deer. Malheur Forest Plan

J12-b

To prevent harassment in designated 

calving areas, restrict off-highway 

vehicles and other motorized traffic use 

to designated roads and trails from May 

1 to June 31.

Reduce impacts during elk 

calving. Malheur Forest Plan
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

41

pdf

Reference Design Features Purpose of pdf Source of pdf

K Public Notification

K1

High use areas, including administrative 

sites, developed campgrounds, visitor 

centers, and trailheads would be posted 

in advance of herbicide application or 

closed.

Postings would indicate the date of 

treatments, the herbicide used, and 

when the areas are expected to be clear 

of herbicide residue.

See also L2 for special products and M1 

for cultural plants.

To ensure that no 

inadvertent public contact 

with herbicide occurs.

These are common 

measures to reduce 

conflicts. 

K2

The public would be notified about 

upcoming herbicide treatments via the 

local newspaper or individual notification, 

fliers, and posting signs. Forest Service 

and other websites may also be used for 

public notification. 

To ensure applicators know 

what area has been treated

and to ensure no 

inadvertent public contact 

with herbicide occurs.

R6 2005 ROD Standard 

23 (see table 1). 

L Special Forest Products

L2

Special forest product gathering areas 

may be closed for a period of time to 

ensure that no inadvertent public contact 

with herbicide occurs.

To eliminate any scenario 

where people might be 

exposed to herbicide.

R6 2005 ROD Standard 

23

L3

Popular berry and mushroom picking 

areas would be posted prominently, 

marked on the ground or otherwise 

posted.

To eliminate any scenario 

where people might be 

exposed to herbicide.

R6 2005 ROD Standard 

23

L4

Special forest product gatherers would 

be notified about herbicide treatment 

areas when applying for their permits.

Flyers indicating treatment areas and 

explaining the use of blue dye may be 

included with the permits, in multi-lingual 

formats if necessary. See section K.

To ensure that no 

inadvertent public contact 

with herbicide occurs.

R6 2005 ROD Standard 

23

M American Indian Tribal and Treaty Rights and Archaeology

M1

American Indian tribes would be notified 

annually as treatments are scheduled so 

that tribal members may provide input 

and/or be notified prior to gathering 

cultural plants. Cultural plants identified 

by tribes would be buffered as above for 

botanical species of concern; see section 

I2, I3, and I4).

To ensure that no 

inadvertent public contact 

with herbicide occurs and 

that cultural plants are fully 

protected. 

Government to 

government agreements 

between American 

Indian tribes and the 

Malheur National Forest.

N Range Resources

N2

Permittees will be notified of annual 

treatment actions at the annual permittee 

operating plan meeting, and/or notified 

within 2 weeks of planned treatments of 

infestations > 1 acre in size.

To ensure permittee has 

knowledge of activities 

occurring within the 

allotment

Common Practice 

N3 Follow most current EPA herbicide label 

for grazing restrictions. 

To ensure grazing animals are 

not exposed to chemicals

EPA labeling 

requirements
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

42

Herbicide-use buffers

Herbicide treatments would become more restrictive as they occur close to water. Project design features 

and herbicide-use buffers within the aquatic influence zone were developed based on label advisories,

SERA risk assessments, and various studies of drift and runoff to streams such as Berg 2004. Figure 3

shows the water’s edge and bankfull (i.e., high water mark). The further away from these areas, the 

greater the number of options available. 

In general, aquatic labeled herbicides and aminopyralid may be used to the water’s edge, with potential 

additional restrictions, depending on soils or other factors such as herbicide effectiveness on the target 

species and sensitivity and susceptibility of non-target species.

The assumption under this project is that if any part of an infested area falls within an herbicide use 

buffer, the buffer restrictions apply to the entire infestation. This assumption is reasonable because of the 

nature of herbicide application; fine distinctions are often difficult to discern on the ground and 

applicators would likely use one tankful to do an entire job rather than switching between tanks during 

treatment.

Figure 3. Herbicide-use buffers
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

43

Table 10. Herbicide-use buffers (in feet) for streams, wetlands, lakes and ponds with water present at the 

time of treatment. Measured in feet from the edge of surface water.

Herbicide

Streams, wetlands, lakes and ponds 

with surface water

Broadcast Spot/Hand/Select

Aquatic Glyphosate 50 Water’s edge

Aquatic Imazapyr 50 Water’s edge

Aquatic Triclopyr-TEA Not Allowed 15

Aminopyralid Water’s edge Water’s edge

Clopyralid 100 15

Imazapic 100 15

Metsulfuron Methyl 100 15

Imazapyr 100 50

Sulfometuron Methyl 100 50

Chlorsulfuron 100 50

Picloram 100 50

Sethoxydim 100 50

Glyphosate 100 50

Table 11. Herbicide-use buffers (in feet) for stream channels that are dry at the time of treatment. Measured in 

feet from the edge of the channel as defined by the high water (bankfull) mark

Herbicide

Intermittent and Ephemeral Streams (Dry at time of 

treatment) 

Broadcast Spot/Hand/Select

Aquatic Glyphosate Bankfull No buffer

Aquatic Imazapyr Bankfull No buffer 

Aquatic Triclopyr-TEA Not Allowed Bankfull

Aminopyralid No Buffer No Buffer

Imazapic 50 Bankfull

Metsulfuron Methyl 50 Bankfull

Clopyralid 50 Bankfull

Imazapyr 50 15

Sulfometuron Methyl 50 15

Chlorsulfuron 50 15

Picloram 100 50

Sethoxydim 100 50

Glyphosate 100 50

Triclopyr-BEE Not Allowed 150
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

44

Passive and Active Restoration

Recovery of native vegetation after invasive plant treatment cannot be precisely predicted. Restoration

would be considered following repeated herbicide and other treatment methods, especially in areas where 

recovery to native vegetation may not be possible such as campgrounds and other highly disturbed areas. 

It is likely that due to the nature of repeated disturbance activities in some areas on the Forest, such as 

roadsides, long-term site objectives may be focused on containment to prevent future spread into other 

areas of the Forest but not full restoration of these areas to native vegetation.

Mulching, seeding and planting may be needed to ensure native plant communities can reoccupy treated 

sites. Restoration and competitive plantings of native flora is essential to long term control of invasive 

plants. Restoration can be accomplished in some areas by removing competition from invasive plants and 

allowing native flora to occupy a site. Other areas would require active restoration, which would include 

mulching, competitive seeding, or planting desirable vegetation. Meadows and forested areas are most 

likely to respond favorably to passive restoration, while roadsides and other highly disturbed areas may 

require active assistance through mulching and/or competitive seeding/planting with desirable vegetation. 

The intent is to re-establish competitive local, native vegetation post-treatment to promote resilient habitat 

conditions that are less susceptible to invasive plants.

Appendix M of the R6 2005 FEIS emphasizes the role of competitive seeding in restoration:

“Plan ahead for revegetation. First assess the need for revegetation. It may not always be 

necessary if a healthy native population is already in place. Not every inch of bare ground needs to 

be revegetated. If revegetation is needed, make sure you have materials available to seed or plant 

treated sites as soon after treatment as possible...The planting of competitive desirable species can 

sometimes be the most effective method of control available for an invasive species.”

The Malheur National Forest LRMP (as amended by the R6 2005 ROD) Invasive Plant Standard 13 (table 

1) requires that native species be the first choice for revegetation. No noxious weed or invasive plant 

species would be used for revegetation. A combination of native and desirable non-natives could be an 

initial mix for revegetation. A fast-growing desirable nonnative such as sterile wheatgrass can germinate 

quickly and start filling in bare ground until a slower to germinate native species can start competing 

effectively.

Evaluation for site restoration will occur before, during and after herbicide, manual and mechanical 

treatments. Passive site restoration would be favored in areas having a stable, diverse, native plant 

community and sufficient organics in the soil to sustain natural revegetation. If the soils lack sufficient 

organics, mulch and/or mycorrhizae could be added. Deep-rooted shrubs may also be seeded or planted to 

more fully utilize resources from the lower soil profile, especially late in the growing season. Shrubs 

allow for easier establishment of understory species by increasing water availability and reducing 

understory temperatures and evapo-transpiration.

The degree of disturbance, as indicated by the proportion of the existing plant cover that consists of 

desirable native species, will also affect revegetation outcome. Ten to twenty percent native cover is 

considered a minimum required to facilitate natural recovery of a site (James 1992, Sheley et al. 1996, 

Goodwin and Sheley 2003). The diversity, abundance, and viability of plant propagules of desirable 

species in the seed bank or within the immediate vicinity are additional important determinants in natural 

recruitment and recovery. 

Draft Guidelines for Revegetation of Invasive plant Sites and Other Disturbed Areas on National Forests 

and Grasslands in the Pacific Northwest (Erickson et al. 2003) provides information on methods and 

guidelines for revegetation of invasive plant sites and disturbed areas. Steps are outlined for assessing 

existing and potential site conditions, and for developing long-term revegetation strategies that are 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

45

effective, affordable, and consistent with the ecological context and land management objectives of the 

site and surrounding landscape. This document promotes the use of local native plant materials to 

establish competitive plant cover and meet the long-term objective to restore ecosystem functioning.

For this project, active restoration is assumed to be a connected action as needed. We estimate that the 

1,281 acres of a size and configuration that might require broadcasting would be the most likely places 

active restoration could be needed.

Treatment Flexibility and Early Detection and Rapid Response

Alternative B provides for treatment flexibility and early detection and rapid response by providing a 

method for us to adapt to changes on the ground over time. We expect some populations to increase and 

others to decrease over the life of this project, depending on many unpredictable factors such as weather 

(droughts and wet periods), funding, and the location of wildland fires or other uncontrolled disturbances. 

Under alternative B we will tailor the prescription to ground conditions at the time of treatment.

In addition, new or previously undiscovered infestations could be treated using the range of methods 

described in this EIS. An EDRR approach is needed because (1) the precise location of individual target 

plants, including those mapped in the current inventory, are subject to rapid and/or unpredictable change, 

and (2) the typical NEPA process does not allow for rapid response to new detections; infestations may 

grow and spread into new areas during the time it usually takes to prepare NEPA documentation. The 

intent of the project early detection and rapid response approach is to treat new infestations when they are 

small so that the likelihood of successful treatment is maximized and adverse effects are minimized.

If alternative B is selected, integrated treatments would be authorized for new infestations detected over 

the next 5 to 15 years, using the treatment methods and project design features evaluated in this EIS. The 

analysis of alternative B assumes that all of the current infestations are treated in a single year and all pdfs

are properly applied. 

We expect herbicide use would steadily increase the first few years of implementation of this project;

however, we would also reduce reliance on herbicides over time as target invasive plant populations are 

reduced and desirable vegetation is restored. Newly detected invasive plants are high priority for 

treatment and herbicides may be used, however we do not expect EDRR to require extensive herbicide 

treatments. Our intention is to rapidly respond to new detections and treat them while they are small, 

increasing our chances of success and minimizing the amount of herbicide needed.

Chapter 3.1.5 discusses how the spread of invasive plants is influenced by the intensity and frequency of 

soil disturbance at a given site, along with the invasive plant propagule pressure associated with nearby 

vectors (pathway).

The approach is based on the premise that the impacts of similar treatments are predictable, even though 

the precise location or timing of the treatment may be unpredictable. The project early detection and rapid 

response approach would allow the Forest Service to treat new infestations using approved methods 

anywhere on the Forest that the need exists. The implementation planning process detailed in the 

following section is intended to ensure that pdfs and herbicide-use buffers are appropriately applied and 

that effects are within the scope of those disclosed in this EIS. FSH 1909.15, chapter 1.8.1 provides 

guidance of review of ongoing projects to determine if the environmental analysis and documentation 

should be corrected, supplemented, or revised.

Project “Caps” 

These caps provide further sideboards to minimize adverse effects and ensure that the effects of 

treatments authorized under this EIS are consistent with the analysis disclosed in this EIS. Under 

alternative B:
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

46

♦ In no case would more than 2,124 discrete acres be treated using herbicides in a single year 

(based on our existing, site-specific inventory).

♦ No more than 30,000 acres (including initial and repeat treatments) would be treated using any 

method over the life of the project. The 30,000-acre cap is based on the current inventory of 

invasive plants spreading by 10 percent per year over a 15-year period, without any slowing of 

spread from prevention or treatment. This is an extreme scenario that is unlikely to actually occur. 

♦ No more than 10 percent of the total acres of any 6th field watershed, and no more than 10 acres 

within 100 feet of any water body in a 6th field watershed would be treated with herbicide in a 

single year.11

The following table shows management objectives for additional target species that may be found under 

the project early detection and rapid response portion of the project. These include: (1) new invasive plant 

species that may invade the Forest in the future, (2) invasive species that are known to occur on the 

Forest, but are not mapped due to their ubiquity, (3) noxious weeds that are not invasive, dominating, or 

persistent on the Forest, and (4) non-native species that may be treated only when co-occurring with the 

18 primary target species we have currently mapped.

 11 Currently, a total of 470 acres of invasive plants lie within 100 feet of a water body. This acreage is scattered 

mainly along roads within several 6th field sub-watersheds. When the entire infested site acreage is included if any 

part of the infested area is within 100 feet of a water body, this acreage rises to 1,389. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

47

Table 12. Management objectives under early detection and rapid response

Species Category Examples Treatment Objective Notes

New invasive species/noxious weeds on 

the Forest.

Class A or B noxious weeds as 

designated by the State of Oregon or 

species that are new to the state or North 

America

Eradicate New sites will be inventoried and eradicated using Early 

Detection Rapid Response (EDRR).

Invasive species/noxious weeds/ nonnative species that are ubiquitous 

across landscape

Cheatgrass, medusahead, Ventenata,

intermediate wheatgrass, Poa bulbosa,

dandelion, mullein

Tolerate

These species are not inventoried. Some species may be treated 

if they co-occur with the 18 primary target species, especially 

where active restoration is prescribed. Additionally, some of these 

species may be indirectly suppressed with cultural methods on a 

site specific basis. For example, permitted livestock grazing may 

occur in cheatgrass-dominated areas in an attempt to suppress 

the vigor of the infestation. However, this would be dealt with 

during Allotment Management Plan revision or the Annual 

Operating Instructions.

Non-native species/noxious weeds that 

occur sporadically on the Forest, but are 

not invasive and have not been 

observed to dominate or persist at sites

Tansy ragwort, rush skeletonweed, 

oxeye daisy Tolerate & Monitor

These species are either not inventoried or the existing inventory 

is incomplete and inaccurate. Adjust treatment objectives through 

adaptive management if species are becoming invasive (e.g. 

spreading, displacing native species, disrupting ecosystem 

processes). Some may be treated if they co-occur with the 18 

primary target species. Manual treatments may occur if sites are 

encountered during other related fieldwork.
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

48

Implementation Planning

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

implemented. The methodology follows integrated weed management principles (R6 2005 FEIS, 3-3) and 

satisfies pesticide use planning requirements at FSH 2109.14. It applies to currently known infestations 

and new sites found within or outside currently mapped treatment areas during ongoing inventory. 

Appropriate Forest Service staff would develop annual treatment prescriptions to ensure that project 

design features are appropriately incorporated. This process applies to invasive plant treatments planned 

as a part of other projects (such as a mitigation measure associated with a thinning or road 

decommissioning) or on a stand-alone basis. The priority, strategy and timing of treatment are influenced 

by the potential for disturbance, especially where seed beds are in the soil and invasive plant growth may 

be triggered by the disturbance. See chapter 3.1.5 for more information about the spread of invasive 

plants along identified vectors. The range of treatment methods considered herein are based on effective 

treatments (common control measures, see table 8) needed for the current inventory of 18 primary target 

species across the Malheur National Forest. New situations could lead to the need for additional 

integrated treatment methods. Treatments outside the scope of this alternative would not be authorized 

under this decision.

1. Characterize invasive plant infestations to be treated

1. Identify target species, location, density, and extent. 

2. Identify adjacent land uses and vectors for invasive plant spread 

3. Determine treatment objective and priority. 

2. Develop site-specific prescriptions 

Consider whether active restoration may be necessary 

Review the common control measures and update as needed using Integrated Weed Management

principles. Identify effective integrated treatment method depending on the target species and 

surrounding environment. 

Determine whether herbicides are needed and which application method is needed based on the 

biology of the target species and size and distribution of the infestations. See figure 4 below 

showing how the decision to use herbicides would be made on a case by case basis. 

Apply appropriate pdfs based on:

Past treatment history and response to past treatment 

Proximity to species of local interest or their habitats

Proximity to streams, lakes, wetlands

Proximity to vectors and potential for persistent disturbance;

Surrounding National Forest land uses and activities 

Soil conditions

Municipal watersheds and/or domestic water intakes

Recreation areas, special forest product and special use areas

First-choice or other effective herbicide

Application rate and method 

Once the treatment prescription has been refined, we will: 

Complete Form FS-2100-2 Pesticide Use Proposal. This form lists treatment objectives, specific 

herbicide(s) that would be used, the rate and method of application, and pdfs that apply. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

49

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

Coordinate with adjacent landowners, water users, agencies, partners, and tribal governments.

Initiate public notification 

3. Accomplishment and Compliance Monitoring

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

organizational and operational details including the precise treatment objectives, equipment, 

materials, and supplies needed; the herbicide application method and rate; field crew organization 

and lines of responsibility; and interagency coordination.

Ensure contracts and agreements include appropriate prescriptions and that herbicide ingredients 

and application rates meet label requirements, R6 2005 ROD, and site-specific pdfs. Contracts 

and agreements will include the appropriate PDFS, herbicide-use buffers, including herbicide and 

additive limitations.

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

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

extracts data from FACTS.

4. Post-treatment Monitoring and Recurring Treatments

Monitoring would occur during implementation to ensure Project Design Features are executed as 

planned. Post-treatment reviews would occur to determine whether treatments are effective and 

whether or not passive/active restoration is occurring as expected.

Contract administration and other existing mechanisms would be used to correct deficiencies. 

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

Post-treatment monitoring would also be used to detect whether pdfs were appropriately applied, 

and whether non-target vegetation impacts were within tolerable levels. 

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

remain within the scope of the EIS. For instance, an invasive plant population treated with a 

broadcast herbicide may be retreated with a spot spray, or later manually pulled, once the size of 

the infestation is sufficiently reduced following the initial treatment. Another example would be 

the use of another herbicide if the first choice is not effective. 

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

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

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

The findings would be applied to herbicide-use buffers for waterbodies. Herbicide-use buffers

may be adjusted for certain herbicides/application methods and not others, depending on results.

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

The Decision to Use Herbicides

The following figure displays a series of questions to be answered during implementation show situations 

where herbicide would be applied and how in general, pdfs would be considered in the prescription 

process. This figure applies to currently known infestations and new sites found within or outside 

currently mapped treatment areas during ongoing inventory. If the target invasive species population is 

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

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

(considering the availability of volunteers if needed), then non-herbicide methods would be favored. 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

50

Figure 4. Questions that facilitate the decision for using herbicides

The Decision to Use Herbicides 

Is the target invasive species population associated with a size, phenology, density or 

distribution that warrants herbicide use (alone or in combination with other methods)?

Yes: To determine appropriate herbicide, review common control measures coupled with local 

experience. Use first choice or other effective herbicides based on their properties, risks, label 

directions and project design features. Consider non-target vegetation surrounding treatment sites 

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

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

herbicide or combination of methods be more effective? Consider wildlife habitats in the area 

and implement seasonal restrictions if required. Consider proximity to water and fish species of 

conservation concern.

No: Would use of herbicides substantially increase cost-effectiveness of treatment? Consider 

whether volunteers may be available to reduce the cost of manual treatments.

Yes: To determine appropriate herbicide, review common control measures coupled with 

local experience. Use first choice or other effective herbicides based on their properties, 

risks, label directions and project design features. Consider non-target vegetation 

surrounding treatment sites and use more selective herbicides as appropriate. Consider soil 

conditions at the treatment site. Consider previous treatments that have occurred on the site. 

Were they effective? Would another herbicide or combination of methods be more 

effective? Consider wildlife habitats in the area and implement seasonal restrictions if 

required. Consider proximity to water and fish species of conservation concern.

No: Use non-herbicide (manual, mechanical biological or cultural) methods.

Process for Prescribing Broadcast Herbicide Application Method 

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

No: Use application methods other than broadcasting

Yes: Is the Site within 100 feet of streams and water bodies? Does the area provide habitat for 

fish species of conservation concern?

Yes: Apply buffers and other pdfs as appropriate. If broadcast is no longer an 

acceptable method given pdfs, choose an application method other than 

broadcasting. 

No: Are there botanical species of conservation concern within 100 feet of the 

proposed broadcast site? If yes, survey as needed within suitable habitats. Apply 

botanical buffers as appropriate. Broadcast may still be acceptable if botanical 

species of conservation concern are covered by barrier. Apply remaining project 

design features. If broadcast is no longer an acceptable method, choose an 

application method other than broadcasting.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

51

Monitoring

Under alternative B, we would continue to monitor invasive plants and treatments according to 

national and regional Forest Service policy. Monitoring is very important because this is an 

adaptive management project that is expected to last 5 to 15 years. Our monitoring approach is 

described in the bullets below: 

♦ We would continue to inventory (catalog and map) invasive plant presence using 

established Forest Service protocols ((NRM 2013);

♦ We would ensure that higher-risk projects with potential to impact species of 

conservation concern are properly implemented, and that adverse effects are minimized 

according to the R6 2005 invasive plant monitoring framework and subsequent 

monitoring plans (a copy of the current R6 Invasive Plant Monitoring Plan is in the 

project record); 

♦ We would assess the potential for chemicals and sediment to reach streams and impact 

water quality according to the R6 2005 Monitoring Framework and subsequent 

monitoring plans along with monitoring associated with National Water Quality Best 

Management Practice (BMPs). We would follow established monitoring protocols for 

chemical use and other projects that may impact streams, water or riparian habitats. We 

would increase herbicide-use buffers, reduce herbicide application rate, or change 

treatment method should we find unexpected adverse effects. 

♦ We would monitor treatment effectiveness as part of our annual accomplishment 

reporting. In accordance with national policy, at least 50 percent of all invasive plant 

treatments are monitored on the ground to determine treatment effectiveness. We would 

likely revisit most if not all treatment sites to determine need for follow up until the site 

is fully restored to its desired condition (depending on the capability of the site, the 

surrounding land uses, the nature of the infestation, and other factors – please see our 

implementation planning process outlined later in this chapter).

♦ We would ensure that herbicide-use buffers and design features are being properly 

implemented. If not, we would immediately adjust treatments to ensure proper 

implementation. In addition, if we find unexpected adverse effects despite proper 

implementation, we would adjust the herbicide-use buffers and design features until the 

effects are no longer occurring.

2.3.3 Alternative C – Strict Limitations on Herbicide Use

Introduction

We developed alternative C in response to some public concerns about herbicide use on the 

Malheur National Forest. Alternative C would impose strict limitations on our ability to use 

herbicides to treat invasive plants. Compared to alternative B, alternative C would address public 

concerns about herbicide impacts to human health, non-target vegetation, pollinators, potential 

water contamination, and herbicide effects on fish and wildlife while still allowing for some 

herbicide use. About 735 acres would be approved for spot/selective herbicide use and on the 

remaining 1,389 acres, no herbicide would be used.

12

 12 This assumes that no herbicide would be used within the entire infested area if any part of the area is 

within 100 feet of a stream or water body, or 200 feet of a well-source area.
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

52

Forest Plan Amendment

Alternative C would include the same Forest Plan amendment as alternative B. 

Integrated Treatment Methods

Alternative C would include all of the integrated treatment methods listed for alternative B 

except broadcast treatment would not be authorized. 

Integrated Treatment Prescriptions

♦ Alternative C would include greater reliance on non-herbicide methods. Picloram would 

be eliminated from the list of available herbicides based on public concerns about

persistence and mobility in soils. 

Project Design Features

Under alternative C, all of the alternative components project design features for alternative B 

would be followed, except that pdfs related to broadcast spraying and picloram use would 

become non-applicable.

Herbicide-Use Buffers

No herbicide use would be allowed within the boundaries of any mapped infested area that at 

any point is within 100 feet of creeks, lakes, ponds and wetlands; or 200 feet of well source 

areas. Non-herbicide methods would continue to be used within of these areas. The buffer tables 

associated with alternative B would become non-applicable since no herbicide use would be 

allowed within 100 feet of streams.

Passive and Active Restoration

Restoration would be the same as described for alternative B. 

Treatment Flexibility and Early Detection Rapid Response

Alternative C would provide for treatment flexibility through the life of the project. Newly 

detected infestations could be treated according to the pdfs associated with this alternative. No 

broadcast treatments, use of herbicides within 100 feet of streams, or use of picloram would be 

authorized for future year treatments. Selective and spot treatment of herbicide would be limited 

to no more than 735 acres per year, or total 11,025 acres over the life of the project.13 The total of 

non-herbicide and herbicide methods would not exceed 30,000 acres over a 15-year period.

These restrictions would apply to known sites as they change over time, as well as new 

detections. The implementation planning process would be similar to alternative B, however the 

range of treatments that would be allowed and the places, types and amounts of herbicide that 

may be used would be more restrictive. Table 13 summarizes the herbicides ingredients that are 

likely most effective in alternative C, based on the target species within the mapped infested 

areas and the restrictions on herbicide use in this alternative.

 13 This acreage is based on total acres in any infested site for which any portion is within 100 feet of a 

stream. There are additional waterbodies that would be buffered (approximately 63 acres fall within 100 

feet of a lake, pond or wetland and are more than 100 feet from a stream). These are not included in the no 

herbicide acreage. Any ponds or wetlands that are found during implementation would be buffered 

appropriately.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

53

Implementation Planning and Monitoring

The implementation planning process and monitoring requirements would be similar to 

alternative B. Questions to facilitate the use of herbicides would not include questions leading to 

decisions about whether or not to use the broadcast application method.

Table 13. Summary of herbicide and non-herbicide use under alternative C

First Year/First Choice Activity Acres

Herbicide Active Ingredient

Aminopyralid 560

Chlorsulfuron 142

Metsulfuron methyl 33

Total Spot/Selective Herbicide Application 735

Total Non-herbicide Treatment 1,389

2.3.4 Alternative D – No Forest Plan Amendment, No Aminopyralid

Introduction

Alternative D was developed to evaluate the tradeoffs involved with adding aminopyralid to the 

list of available herbicides for use on the Malheur National Forest. 

LRMP Amendment

No LRMP amendment is proposed for this alternative.

Integrated Treatment Methods

All treatment methods listed for alternative B would be approved.

Integrated Treatment Prescriptions

Integrated treatment prescriptions would be similar to those listed for alternative B except that no

aminopyralid would be used to treat known sites or new detections. Compared to alternative B, 

more chlorsulfuron, glyphosate, metsulfuron methyl, and picloram would be used in lieu of 

aminopyralid.

Project Design Features

All of the project design features and herbicide-use buffers associated with alternative B would 

apply, except for those that refer to use of aminopyralid.

The herbicide-use rates, pdfs and herbicide-use buffers associated with aminopyralid would 

become non-applicable. Much of the infested sites near streams and other water bodies would be 

spot treated rather than broadcast as directed by the herbicide-use buffers associated with 

herbicides other than aminopyralid. 

Table 14. Summary of herbicide use under alternative D

First Year/First Choice Activity Acres

Broadcast Herbicide

Chlorsulfuron 435

Glyphosate 3

Metsulfuron methyl 69
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

54

First Year/First Choice Activity Acres

Picloram 36

Total Broadcast 543

Selective/Spot by First-choice Herbicide 

Aminopyralid 0

Chlorsulfuron 595

Glyphosate 721

Metsulfuron methyl 238

Picloram 27

Total Selective/Spot 1581

Passive and Active Restoration

This component of alternative D would be the same as alternative B.

Treatment Flexibility and EDRR

This component of alternative D would be the same as alternative B, except aminopyralid would 

not be authorized for use.

Implementation Planning and Monitoring

This component of alternative D would be the same as alternative B, except aminopyralid would 

not be authorized for use.

2.4 Alternatives Considered but Eliminated from Detailed 

Study

During scoping, some people suggested alternatives that were considered but eliminated from 

detailed study because they either did not meet the purpose and need for action or were similar to 

an alternative considered in this document. 

2.4.1 Alternative to Evaluate Effectiveness of Past Treatments by a 

Third Party

One commenter suggests that effectiveness of past treatments must be evaluated by a 

disinterested party before new treatments would be implemented. This is an opinion not 

supported by law or policy and is outside the scope of the analysis in the EIS. It would not 

address the need for treatment flexibility or rapid response to newly detected infestations. It 

would not expand the treatment toolbox or bring the program into alignment with Malheur 

National Forest LRMP guidance. Therefore, this alternative was not developed for detailed 

study.

2.4.2 Limitations on Herbicide-use Rates for All Herbicides

Some people suggested that maximum rates of any herbicide should not be used in any 

circumstances. Limitations on certain herbicide ingredients, rates, and application methods are 

already part of the action alternatives to ensure that the adverse impacts of treatments are 

minimized. For instance, the lowest amount of herbicide necessary to meet treatment objectives 

is part of the design of all action alternatives and in some cases rates have been specifically 

limited to address a specific human health or environmental concern. However, in some 

situations, maximum label rates could be needed for timely and effective treatment. Thus, a 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

55

general limit on application rates was not considered for detailed study because it would not 

further minimize adverse effects but could impede treatment effectiveness. 

2.4.3 Mandatory Decline on Herbicide Use Over Time

Some people suggested an alternative requiring a mandatory decline in herbicide use over time.

An R6 2005 ROD objective is to reduce reliance on herbicides over time. This would be 

accomplished through effective treatment and restoration at any given treatment site. Our intent 

is to effectively treat invasive plants across the Forest until target populations are at a level that 

can be maintained with little or no herbicide (see chapter 3.1.4). However, due to uncertainty in 

funding and workforce capacity, the pattern of herbicide use over time cannot be precisely 

predicted. Thus, a mandatory decline on herbicide use each year at the project level is not 

possible and would not meet the purpose and need for timely and effective treatments. Annual 

and life of the project caps would ensure that herbicide use does not increase over time. 

2.4.4 Use of Herbicides as a Last Resort

Use of herbicides as a last resort was considered as an alternative in the R6 2005 FEIS and was 

rejected in the R6 2005 ROD (p. 27). This decision need not be reconsidered at the project scale. 

The Pacific Northwest Regional Forester decided to include use of herbicides as part of an 

integrated weed management approach to allow for the most effective possible treatment 

outcome. The common control measures (table 8) display the integrated treatment methods most 

likely to be effective on the target invasive species currently found on the Forest. Use of nonherbicide methods have not resulted in eradication, control, or containment of the current 

infestations. 

2.4.5 Use of Herbicides for Only the Highest Priority Target Species

Priority for treatment is a function of the invasive plant species as well as its size and location. 

Site-specific integrated treatment objectives and methods vary depending on the location, size 

and density of a given infestation. Thus, a prohibition on use of herbicides depending solely on 

target species would not allow effective treatment in all high priority situations. All action 

alternatives would only utilize herbicides as necessary to meet treatment objectives. Herbicides 

would not likely be used in any alternative where target species are widespread, and are 

effectively suppressed by non-herbicide methods such as biological agents. Thus, this alternative 

was not developed for detailed study. 

2.4.6 No Herbicide Use in a Variety of Areas

One comment letter included a number of suggestions about prohibiting herbicide use in a 

variety of areas including fish habitat, riparian areas, municipal watersheds, wildlife habitat, 

areas of wild edible plants, in cultural plant gathering areas, in roadless or other undeveloped 

areas, and in developed areas like campsites and along trails. When all of the areas are added 

together, this becomes an alternative very similar to eliminating herbicides from the treatment 

toolbox and would not meet the purpose and need for timely and effective treatment. Use of nonherbicide methods have not resulted in eradication, control, or containment of the current 

infestations. For fish and wildlife habitats, disturbance from non-herbicide methods that require 

more repeated entries would have greater effects than the herbicide use proposed.

Alternative C minimizes use of herbicides and would require non-herbicide methods across the 

majority of currently infested sites. It includes an annual cap on herbicide use that is much lower 

than the other action alternatives and addresses many of the suggestions expressed in the scoping 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

56

comment letters. Thus, another alternative strictly limiting herbicide use was not developed for 

detailed study because of its similarity to alternative C.

2.4.7 No Early Detection and Rapid Response

One commenter suggested that new detections should be subject to additional NEPA analysis. 

This alternative would not meet the purpose and need for timely treatment of new infestations. 

Thus, this alternative was not developed for detailed study.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

57

2.5 Alternatives Compared

Table 15. Alternative comparison by activity

Activity Alternative A

(No Action)

Alternative B

(Proposed Action) Alternative C Alternative D

Authorizes EDRR No Yes Yes Yes

Non-herbicide treatments None14 Non-herbicide treatments 

would be integrated with 

herbicide treatments

Same as Alternative B , except 

only non-herbicide treatments 

would be approved within 100 

feet of water bodies 

Same as Alternative B 

Maximum acres of proposed 

herbicide treatments during 

any year of implementation

0 2,124 735 Same as Alternative B 

Total invasive plant treatment 

acres over the life of the 

project (includes all treatments 

and re-treatments)

0 30,000 over 15 years 

(including herbicide use)

11,025 herbicide

30,000 total all treatments Same as Alternative B 

Number of herbicides available 

for use 0 11 10 (no picloram) 10 (no aminopyralid)

Forest LRMP amendment to 

include aminopyralid No Yes Yes No

Herbicide application rate and 

method None

Lowest effective rate, 

broadcast sprayers may be 

used where needed 

according to pdfs

Application rate would not 

exceed 70% of typical 

broadcast rate, no boom or 

broadcast sprayers

Same as Alternative B , no 

aminopyralid

 14 The analysis in chapter 3 assumes that no action means no invasive plant treatments will occur. Prevention would continue, and biological agents distributed in 

adjacent lands would naturally distribute to host species within the Malheur National Forest.
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

58

Table 16 displays a comparison of the first year/first choice herbicide for each alternative. All action 

alternatives (B-D) would approve a range of treatments on all 2,124 currently infested acres. Alternative 

C is the only action alternative that would disallow herbicide use in specific areas to the degree that nonherbicide treatments would be the only methods allowed for these sites. Under alternative A (no action), 

no treatments would be approved. Under all alternatives (A-D), approved biological controls will 

continue to be released adjacent to the project area, and would help suppress toadflax, St Johnswort and 

other common invasive species. Biological controls would be redistributed to host species within the 

project area in the action alternatives.

Table 16. Comparison of first year/first choice herbicide by alternative

First Year/First Choice Treatment Alternative A

Acres

Alternative B

Acres

Alternative C

Acres

Alternative D

Acres

Broadcast Herbicide Application 0 1,281 0 0

Aminopyralid 0 1,179 0 0

Chlorsulfuron 0 71 0 435

Glyphosate 0 0 0 3

Metsulfuron methyl 0 30 0 69

Picloram 0 0 0 36

Spot/Selective Herbicide Application 0 843 735 1,581

Aminopyralid 0 168 560 0

Chlorsulfuron 0 519 142 595

Glyphosate 0 0 0 722

Metsulfuronmethyl 0 156 33 238

Picloram 0 0 0 27

Non-herbicide Only 0 0 1,389 0

Figure 5 displays how these treatments are distributed within one sample area. 

Table 17 provides a comparison of the alternatives relative to the issue measures described in chapter 1. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

59

Figure 5. One sample area showing treatment distribution
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

60

Table 17. Alternative comparison relative to significant issues

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

1 – Treatment Effectiveness

Unnecessary restrictions 

on herbicide use reduce 

treatment effectiveness 

and increase treatment 

costs.

Average Cost per Acre of 

Effective Treatment 

(includes re-treatments 

and restoration)

0 $544 $722 $598

Total Cost of Most 

Ambitious Treatment 

Scenario

0 $1,154,000 $1,472,900 $1,270,500

Maximum Cost over the 

Life of the Project

(assuming maximum 

treatment caps multiplied 

by average per acre cost) 

0 $16,320,000 $21,660,000 $17,940,000

Number of Years to 

Achieve Objectives (most 

ambitious treatment 

scenario)

Objectives not 

achieved 4 years 6 years 5 years

2 – Herbicide Impacts to Human Health

Human health may be 

harmed by herbicide 

exposure.

Type (rate, method, 

chemical properties) and 

extent of herbicide use 

that could result in harmful 

exposure scenarios to 

people.

None

None of the herbicides

proposed for use are 

associated with any 

harmful scenarios to 

the public. Where 

necessary, pdfs

minimize or eliminate 

potential for harmful 

exposure scenarios by 

limiting the herbicide 

ingredient, rate, or 

method of application in 

specific areas. Workers 

Same as Alternative 

B, except that far less 

herbicide would likely 

be sprayed annually. 

The minimal risks 

associated with 

herbicide use under 

Alternative B would 

be eliminated. 

Same as Alternative B.

Where necessary, pdfs

minimize or eliminate 

potential for harmful 

exposure scenarios.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

61

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

need to take specific 

precautions to avoid 

harmful herbicide and 

NPE exposure. 

Qualitative assessment 

about the effectiveness of 

herbicide-use buffers and 

other project design 

features to prevent harmful 

herbicide exposure 

scenarios

None

Risk assessments 

demonstrate that 

aminopyralid poses 

very low risk to human 

health. The likelihood of 

harmful exposures is 

low, thus the design 

features have high 

likelihood of eliminating 

all potential adverse 

impacts from herbicide 

use. 

Alternative C would 

have less risk of 

herbicide exposure 

overall, especially to 

fish and water, due to 

restrictions on 

herbicide use near 

water. The buffers 

would eliminate all 

potential herbicide 

exposure near 

streams. While this 

alternative includes 

some additional 

design features that 

would comparatively 

reduce risk of harmful 

herbicide exposure, 

the risk is already low.

Same as Alternative B, 

except opportunities to 

use aminopyralid would 

be foregone and in some 

cases, higher risk 

herbicides would be 

used. However, more 

spot treatment and less 

broadcasting would 

occur, which could result 

in less herbicide 

exposure, partly because 

less herbicide can be 

applied per day so the 

daily treatment extent 

would likely be less. For 

the project as a whole, 

the design features 

minimize adverse impacts

to human health from 

herbicide use. 

Potential for herbicides to 

affect drinking water None

Drinking water quality 

would not be adversely 

affected. Restrictions 

on herbicide use near 

drinking water and well 

intakes further minimize 

risk. Herbicide 

transportation and 

handling safety plan 

would minimize 

potential for an 

herbicide spill.

Same as Alternative B Same as Alternative B

3 – Herbicide Impacts on Non-target Vegetation and Pollinators

Proposed herbicide use 

may harm non-target 

plants and/or pollinators, 

specifically sensitive and 

Type and extent of 

herbicide use within 100 

feet of botanical special 

species of conservation 

None

Project design features

prohibit broadcast 

herbicide use within100 

feet of sensitive plant 

Same as Alternative 

B, less overall 

herbicide use

Same as Alternative B
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

62

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

other species of 

conservation concern, 

cultural use plants, and 

special forest products.

concern, cultural use 

plants, and special forest 

products.

populations. Spot

applications will be 

used within 100 feet of 

sensitive plant 

populations. Project 

design features for use 

of blue dye will alert 

special forest product 

gatherers of herbicide 

spray areas.

4 - Herbicide Delivery to Water and Potential Impacts to Fish

Proposed herbicide use 

may result in chemicals 

reaching streams and 

other water bodies 

(through drift, leaching 

and/or run off) and may 

adversely fish and their 

habitat. 

Type and extent of 

herbicide use within 100 

feet of streams and other 

water bodies.

none

Aminopyralid could be 

broadcast up to the 

water’s edge; however 

no adverse impacts on 

fish are expected

because the amount of 

herbicide that could 

reach streams is below 

a level that could harm 

fish. Herbicide-use 

buffers and other pdfs

reduce the rate, extent, 

or frequency of 

herbicide use that pose 

potential risks to fish.

Same as Alternative 

B, except no 

herbicides would be 

used within 100 feet 

of streams and other 

water bodies. There 

potentially could be 

more sediment from 

non-herbicide 

methods required 

near streams. 

Same as Alternative B, 

except comparatively 

more use of higher-risk 

herbicides relative to fish.

Project design features 

minimize risks and 

differences between 

alternatives.

Qualitative Assessment 

about whether or not, and 

how fisheries might be 

affected

No impacts

Water concentrations 

from site-specific model 

runs at highest risk 

sites demonstrate that 

levels of herbicide that 

could reach streams 

and aquatic organisms 

are at least 3 orders of 

magnitude less than 

levels of concern for 

fish and their habitat. 

All treatment methods 

may result in minor 

amounts of sediment 

reaching streams.

Same as Alternative B Same as Alternative B

6- Herbicide Impacts on Wildlife
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 2

63

Issue Component Unit of Measurement (No Action)

Alternative A

(Proposed Action)

Alternative B Alternative C Alternative D

Proposed herbicide 

use may result in 

harmful exposure to 

terrestrial wildlife 

(specifically species of 

conservation concern).

Type and extent of 

herbicide use within 

specific wildlife habitats for 

wildlife of conservation 

concern

None

This alternative has the 

most broadcasting, but 

the first-choice

herbicides that would 

be used pose low risk 

to wildlife.

Spot application of 

herbicides would 

occur on 735 acres 

and the first-choice

herbicides pose low 

risk to wildlife.

First-choice herbicides 

that pose a low risk to 

wildlife would be applied 

on 1,337 acres, whereas 

moderate to risk firstchoice herbicides would 

be used on 787 acres. 

Less broadcasting than 

Alternative B, which 

reduces risk of drift.

Risk of HCB 

(hexachlorobenzene) 

contamination and effects 

on raptor eggs

None

No PCBs in first-choice

herbicides. Project 

design features 

minimize risk to raptors 

to extremely low level. 

Same as alternative 

B. No picloram 

eliminates risk. 

Picloram is the firstchoice herbicide on 63 

acres, posing low risk of 

PCB’s; pdfs minimize risk 

to raptors to extremely 

low level. . 

Narrative assessment 

about whether or not, and 

how species of 

conservation concern and 

amphibians might be 

affected

None

All first-choice

herbicides pose a low 

risk to wildlife. Project 

design features that 

restrict timing and 

application of 

herbicides in sensitive 

habitats will minimize or 

eliminate the likelihood 

for any species to 

receive a harmful 

exposure to herbicides 

or disturbance.

Same as Alternative 

B, except greater risk 

of disturbance from 

non-herbicide 

treatments. 

Same as Alternative B, 

except less broadcasting 

and more use of 

herbicides that pose a 

comparatively greater risk 

to wildlife. 
Chapter 2 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

64

This page left blank intentionally
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

65

Chapter 3. Affected Environment and Environmental 

Consequences

3.1. Introduction 

3.1.1 The Effects Analysis

Chapter 3 discusses the existing condition within the project area and the direct, indirect and cumulative 

environmental effects of the alternatives. 

Direct effects are effects that occur at the same time and in the same general location as the activity 

causing the effects. An example of direct effects is the potential for herbicides to harm non-target 

plants during applications.

Indirect effects are those that occur at a different time or location from the activity causing the effects. 

An example of indirect effects is herbicide that is unintentionally delivered to streams through 

leaching or overland runoff following one or more storms after treatment (see chapter 3.4 Soils and 

3.5 Water Quality).

Cumulative Effects result from the incremental impacts of the proposed actions/alternatives when 

added to other past, present, and reasonably foreseeable actions, on the Forest and adjacent lands 

within 5th field watersheds in the project area. Chapter 3.1.5 provides an introduction to the 

cumulative effect analysis found throughout chapter 3.

The project area is the 1.7 million-acre Malheur National Forest (Forest), including 240,000 acres of the 

Ochoco National Forest (previously known as the Snow Mountain Ranger District, now managed as part 

of the Emigrant Creek Ranger District.) The Strawberry Mountain Range, part of the Blue Mountains, 

extends east to west through the center of the Malheur National Forest. This range splits the Forest into 

two geologic provinces, the Columbia Basin to the north and the Great Basin to the south. The Malheur 

National Forest is bordered by the Wallowa-Whitman National Forest on the east, the Umatilla National 

Forest on the north, and the Ochoco National Forest on the west. Elevations on the Malheur National 

Forest vary from less than 4,000 feet to 9,038 feet on Strawberry Mountain. The result is a diverse and 

productive landscape of grasslands, sage, and juniper; forests of pine, fir, and other tree species and 

mountain lakes and meadows. The northern part of the Malheur National Forest is drained by the John 

Day River System into the Columbia River Basin. The southern part is drained, principally, by the Silvies 

River System into the Great Basin, and by the Malheur River System into the Snake River. There are 

several lakes and reservoirs on the Malheur National Forest ranging in size from 1 acre to greater than 50 

acres. 

The project area lies in Grant (1,128,930 acres), Harney (523,066 acres), Baker (46,357 acres), Crook 

(9,726 acres) and Malheur (605 acres) counties. The Malheur National Forest is within a day’s drive from 

Portland, Oregon. Principal access routes are U.S. Road 26 and U.S. Road 395, winding two-lane, rural 

routes. Two main population centers are within the area: the John Day Valley from Dayville to Prairie 

City, and Burns/Hines.

Invasive plants need to be treated on 2,124 acres within the Malheur National Forest. If the Malheur 

National Forest Supervisor selects an action alternative, invasive plant treatments would be implemented 

over several years as funding allows, until no more treatments were needed or until conditions otherwise 

changed sufficiently to warrant this EIS outdated. Site-specific conditions are expected to change within 

the life of the project; treated infestations would be reduced in size, untreated infestations would continue 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

66

to spread, specific non-target plant or animal species of local interest could change, and/or new invasive 

plants could become established within the project area.

Chapter 3 discloses the effects of a range of treatment options applied to a range of site conditions to 

accommodate the uncertainty associated with project implementation. The most ambitious treatment 

scenario assumes that all 2,124 acres of currently mapped infestations are treated for a period of 4-6 years 

until control objectives are met. In reality, we are likely to treat fewer acres each year, and treatments are 

likely to be needed for more than 6 years. Our assumption reflects an ambitious level of treatment that 

and allows for analysis consistency. Each specialist considers how unpredictable implementation might 

influence the expected effects. 

Assuming full and immediate treatment of all existing infestations, early detection/rapid response 

(EDRR) would likely be a very small part of the project. However, because the funding level will likely 

be too low to treat all existing acres, and because some of the primary target species are likely to spread 

along existing vectors (mainly roads), some of the lower priority existing infestations will not be treated 

in the near future. Treatment of new detections is one of our highest priorities in all action alternatives.

The common control measures (table 8), project design features (table 9) and herbicide-use buffers (table 

10 and table 11), and the implementation planning process (figure 4) provide sideboards that minimize 

and bound the potential for effects even though the suite of integrated treatments would vary each year.

Figure 2 in chapter 2 shows the current extent of invasive plants and their distribution through the 5th field 

HUC watersheds on the Malheur National Forest. Appendix A contains a report showing specific 

locations and descriptions of invasive plants within the 5th field HUC watersheds.

3.1.2 Herbicide Risk Assessments

The effects from the use of any herbicide depend on the toxic properties (hazards) of that herbicide, the 

level of exposure to that herbicide at any given time, and the duration of that exposure. Herbicide risk 

assessments were the basis for analysis in the R6 2005 FEIS, disclosing the potential for effects on nontarget plants, wildlife, human health, soils and aquatic organisms. Risk assessments were done by 

Syracuse Environmental Research Associates, Inc. (SERA) using peer-reviewed articles from the open 

scientific literature and current Environmental Protection Agency (EPA) documents, including 

Confidential Business Information. Information from laboratory and field studies of herbicide toxicity, 

exposure, and environmental fate was used to estimate the risk of adverse effects to non-target organisms. 

See table 7 in chapter 2 for the list of current SERA risk assessments.

In addition to the analysis of potential hazards to human health from every herbicide active ingredient, 

Forest Service/SERA Risk Assessments evaluated available scientific studies of potential hazards of other 

substances associated with herbicide applications: impurities, metabolites, inert ingredients, and 

adjuvants. There is usually less toxicity data available for these substances (compared to the herbicide 

active ingredient) because they are not subject to the extensive testing that is required for the herbicide 

active ingredients under FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act).

In some cases, toxicity data on inerts and adjuvants is produced to comply with other federal laws that 

regulate non-herbicide uses of these chemicals, such as the Federal Food, Drug, and Cosmetic Act.

The risk assessments considered maximum exposure scenarios including accidental exposures and 

application at maximum label rates. The project design features described in chapter 2 were developed to 

abate hazards indicated by the assessments. Although the risk assessments have limitations (see R6 2005 

FEIS pages 3-95 through 3-97), they represent the best science available. The risk assessment 

methodologies and detailed analysis is incorporated into references of conclusions about herbicide 

toxicology in this document.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

67

Herbicide Toxicity Terminology 

The following terminology is used throughout this chapter to describe relative toxicity of herbicides 

proposed for use in the alternatives.

Hazard Quotient (HQ)

The ratio of the estimated level of exposure to a substance from a specific pesticide application, to the 

level of the acceptable exposure or toxicity. A HQ less than or equal to one is presumed to indicate an 

acceptably low level of risk for that specific application.

Exposure Scenario

Exposure scenarios consider both the toxicity of a given chemical and the mechanism by which an 

organism may encounter it. The application rate and method influences whether a person, animal or nontarget plant could be adversely affected by exposure to a particular herbicide.

Plausible Effects

The analysis in chapter 3 focuses on whether effects that are possible based on risk assessments are 

plausible, given site conditions, life history of organisms in an area, herbicide application methods and 

other project design features. Project design features (table 9) are often used to minimize or eliminate the 

plausibility of effects indicated as possible in the risk assessments.

Herbicide Comparison Table

The following table was prepared by Bautista and Bulkin in 2008. It provides a simple comparison of the 

relative risk of the 11 herbicides that could be used in this project. This shows how favorably 

aminopyralid stacks up in comparison. However, the R6 2005 ROD already approved the other 

herbicides, due to their effectiveness on invasive plants known in the region, the relatively low risks 

associated with these herbicides, and our ability to mitigate risks to people and the environment (R6 2005 

ROD). In this project, exposure scenarios that could be associated with the higher risk ranking for some 

herbicides have been eliminated through the project design features, herbicide-use buffers, and adaptive 

implementation planning process described in chapter 2. Each of the action alternatives would utilize 

different herbicides and application methods as first choice for the first year of treatment, depending on 

the design of that alternative. First-choice herbicides are indicated in bold.

Table 18. Herbicide risk comparison table

Comparative

Risk Level Public Health Worker Health Non Target Plants

Aquatic 

Organisms Wildlife

Low

chlorsulfuron; 

metsulfuron 

methyl; 

sulfometuron 

methyl;

aminopyralid

chlorsulfuron; 

clopyralid;

glyphosate; 

imazapic; 

imazapyr; 

metsulfuron 

methyl; 

aminopyralid

clopyralid; 

picloram; 

sethoxydim, 

triclopyr

clopyralid; 

imazapic; 

metsulfuron 

methyl;

aminopyralid,

chlorsulfuron; 

clopyralid; 

imazapic; 

imazapyr; 

metsulfuron 

methyl;

aminopyralid

Moderate

clopyralid; 

glyphosate; 

imazapic; 

imazapyr; 

picloram; 

sethoxydim; 

triclopyr

picloram; 

triclopyr

chlorsulfuron; 

aminopyralid;

metsulfuron 

methyl; 

sulfometuron 

methyl; imazapic, 

imazapyr 

(somewhat 

selective)

chlorsulfuron;

imazapyr; 

sulfometuron 

methyl

glyphosate; 

picloram
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

68

Comparative

Risk Level Public Health Worker Health Non Target Plants

Aquatic 

Organisms Wildlife

Higher -- -- glyphosate

sethoxydim; 

glyphosate;

picloram; triclopyr

triclopyr

3.1.3 Site Types

We stratified the existing invasive plant sites into “site types” to help characterize the pattern of 

infestation and make predictions about future spread (see section 3.1.5 for a discussion about vectors of 

invasive plant spread in the context of cumulative effects analysis). The majority of mapped invasive 

plant sites are within 50 feet of roads. This is due to two primary factors: 1) we often look for invasive 

plants along roads; funding for surveys off roads is limited, and 2) roads are a major vector for the spread 

of invasive plants. In the following table, if any part of an invasive plant site (polygon) meets the criteria, 

then that site falls within the given site type. The table also shows the number of actual acres that meet the 

criteria (portions of invasive plant sites that do not meet the criteria are excluded). Most of the infestations 

near streams are also along roads.

Table 19. Site type criteria and acres

Site 

Type 

ID

Criteria

Number of 

Infested 

Sites 

Total Number Of 

Infested Acres If 

Entire Infested 

Acreage is 

Included 

(within and outside 

criteria)

Number of infested 

Acres that Meet 

Criteria 

(portions of 

infested sites)

1 Within 50 ft. of existing, not 

decommissioned roads 2,252 1,868 1,178

2 Within 100 ft. of existing, not 

decommissioned roads 2,495 1,950 1,491

3 Within 50 ft. of all roads including 

decommissioned roads 2,301 1,904 1,244

4 Within 100 ft. of all roads including 

decommissioned roads 2,552 1,983 1,572

5 Within 25 ft. of trails 91 94 21

6 Within 25 ft. from all streams and ditches 589 1,199 117

7 Within 100 ft. from all streams and ditches 1,045 1,389 462

8 Within wildfire boundaries < 30 years old 409 451 246

9 BAER Inventory (outside wildfire 

boundaries) 93 38 39

10 Within timber harvest boundaries less 

than 30 years old 1,467 1,419 729

11 Within 100 ft. of a recreation site 7 20 < 1

3.1.4 Treatment Costs and Effectiveness

This section addresses the cost and effectiveness of treatment under the action alternatives over a 5-year 

period. While the life of the project is expected to last more than 5 years (5 to 15 years given anticipated 

budgets), the most ambitious conceivable project, should funding be available, would result in treatment 

and restoration of all currently known infestations. Assessing this most ambitious conceivable project for 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

69

each alternative allows us to derive an average cost per acre that can be applied to the life of the project 

and annual caps, thus accounting for new detections found over time.

The design of each alternative influences the cost of eradicating, controlling, and containing invasive 

plants on the Malheur National Forest. For acres where the first-choice herbicide or application method 

are not allowed due to a particular design feature (such as no broadcasting in alternative C and no 

aminopyralid use in alternative D), a loss of effectiveness and economic efficiency is predicted. This 

would increase costs and could compromise our ability to control or eradicate populations of certain 

aggressive target species, such as thistles and knapweeds (especially near streams).

This analysis demonstrates that a consistent budget over a series of years is needed to meet our invasive 

plant treatment and restoration objectives. Far less treatment has historically occurred on an annual basis 

than would be needed to reach objectives in the compressed time frame shown below.

Each treatment entry would reduce the size or density of treated populations. The effectiveness of each 

treatment is influenced by the tools available for use; the more tools available, the greater the potential 

effectiveness of the treatment. If the toolbox is restricted and some situations cannot be effectively 

treated, the percentage of target population killed each year can be dramatically decreased. On page 4-18, 

the R6 2005 FEIS notes that “In general, alternatives that have the widest variety of herbicides and 

herbicide families available for use have the greatest potential to result in effective treatments.” In 

contrast, when herbicide use is more restricted, “...fewer acres would likely be achieved at a constant 

budget, and the years to control increases proportionally” (ibid. page 4-21). Thus, a loss of effectiveness 

is likely if the most effective choice is not available for a given site.

Botanists and invasive species specialists across the region have estimated that each treatment entry, 80 

percent of the existing target plants would be removed; assuming fully effective integrated weed 

management methods are available (Desser 2007). Thus, the model assumes population size would 

decrease by an average of 80 percent on any effectively treated acre. Although the density of target plants 

would be reduced, the gross number of infested acres could decrease or stay the same. However, we 

express the 80 percent effectiveness concept as a decrease in the number of acres estimated to need 

treatment each year.

For instance, a 100-acre infestation effectively treated in year 1 would result in 20 acres needing 

treatment in year 2. These 20 acres treated in year 2 would result in 4 acres still needing treatment in year 

3, and so on until the area needing retreatment is so small as to be uncountable. While we apply this 

assumption to acres, we are not likely to change any polygon (infested site) boundaries until we are 

certain we have met our invasive plant treatment objectives for the site. In many cases, there would more 

likely be 80 percent less density of invasive plants within the infested area than 80 percent fewer acres.

For this analysis, we assume all infested sites are covered with 100 percent invasive plants, because 

density is a variable that changes rapidly and is unpredictable. Each year, effective treatments are 

assumed to reduce the treated acreage 80 percent. 

The 80 percent estimate is not precise and the range of results varies widely depending on the target, how 

long the invasive population has been established, the objectives of treatment, and other conditions 

(monitoring results, funding, topography, soils, weather during time of treatment, and many other 

variables). Robin Dobson, Ecologist for the Columbia River Gorge National Scenic Area confirmed the 

80 percent estimate based on his personal experience in the field (ibid.). Dobson noted that some 

retreatment was necessary for at least 3 to 5 years to eradicate or control established invasive plant sites.

Remnant target plants and seed banks can remain for several years but after four consecutive entries, 

invasive plants at any given site would be drastically reduced. 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

70

This analysis assumes that all known infestations are treated the first year following a decision on this 

project, and then treated in three to five subsequent entries over a total of 3-5 years. Active restoration is 

also modeled (year 4, 5, or 6 depending on alternative) to help protect bare areas from reinfestation.

Assuming the most effective treatment tools are available, populations could be reduced from the current 

2,124 acres to approximately 23 acres after 4 years (see alternative B). The financial efficiency model 

adds one more calculation to account for the spread of invasive plants during the life of the project, using 

a fixed rate of 10 percent per year (based on the R6 2005 FEIS, spread rate estimates range from 4 to 12 

percent per year). The rate of spread would not be influenced by the alternatives, but the remnant 

population subject to spread would vary depending on the effectiveness of each year’s treatments.

A consistent cost of $200 per acre was used regardless of treatment method. The site-specific combination 

of methods and their juxtaposition vary depending on many factors that a more specific estimate is not 

available. For this analysis, the difference in cost of the project for each action alternative is a function of 

the effectiveness of each alternative (and the amount of repeated treatments needed) rather than the base 

cost per acre of a given treatment method. 

Alternative Comparison

The alternatives vary as to the first year/first choice herbicides, and these differences influence cost and 

effectiveness over time. The more effective the first year/first choice herbicide, the less retreatment would 

be needed. The design of alternatives C and D require that non-herbicide, spot or hand treatments may be 

required for areas that could more efficiently be broadcast, which would increase the cost of treatment in 

that alternative.15 The primary differences between the alternatives and the influence on cost-effectiveness 

are: 

1) Whether or not aminopyralid may be used as the first-choice herbicide. Aminopyralid is the firstchoice herbicide to treat 1,350 acres (64 percent) of the primary target species found on the 

Forest. In alternative B, we could broadcast this herbicide almost everywhere needed on the 

Forest, including to the water’s edge. In alternative C, we would spot apply this herbicide to 560 

acres, except within 100 feet of stream or other water bodies.

We would not use this herbicide in alternative D. This increases the amount of spot or hard 

treatment required in alternative D due to the herbicide-use buffers associated with all herbicides 

except aminopyralid. The requirement to spot or hand treat, rather than have the broadcast tool, 

is estimated to decrease the effectiveness of each year’s entry from 80 percent to 40 percent.16

2) Restrictions on herbicide use and method. The herbicide application rates and methods approved 

influence our ability to effectively treat invasive plants. Alternatives B and D approve broadcast 

spraying and some use of herbicide near streams. Alternative C does not approve any broadcast 

spraying and does not allow more than 70 percent of the maximum herbicide label rate to be 

sprayed on a given acre. It also excludes herbicide use over much of the infested area. This is 

estimated to reduce effectiveness to 40 percent from 80 percent, in effect doubling the time and 

cost for this alternative.

 15 This assumption leads to the greatest differences between alternatives compounded over time and provides a 

reasonable alterantive comparison, but there are too many variables to more precisely predict the costs and 

effectiveness of treating invasive plants on the Forest over time. 

16 Broadcast methods accomplish many more acres a day than spot or hand methods. Spot and hand treatments tend 

to require more labor as applicators must walk from spot to spot and then return to accommodate skips and gaps that 

are common with this type of treatment. 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

71

Also the effectiveness would decrease by half on the portion of alternative D that requires spot 

or hand treatment rather than allowing broadcast, due to the elimination of aminopyralid

(explained previously). This reflects the need for repeated entries to accommodate skips and 

gaps and the increased amount of labor needed to accomplish the manual, mechanical and spot 

herbicide work. This is especially true for large infestations with high densities of invasive 

plants. 

3) Whether or not picloram may be used. Alternatives B and D allow picloram and alternative C 

does not. Alternative D includes the use of picloram as the first-choice herbicide on 63 acres (or 

about 3 percent of the total infested acreage). Because alternative C does not approve the use of 

picloram, there will be an unquantifiable loss of effectiveness for those acres where picloram is 

one of the effective herbicides. About 1,697 (80%) of the existing infested acres are occupied by 

target species where picloram is listed as an effective choice (table 8, chapter 2); however, 

picloram would likely be the “second choice” herbicide on a small portion of these acres.

Alternative A 

Under alternative A, no invasive plant treatments would occur so no funds would be expended. However, 

invasive plants would continue to spread at a rate from 4 to 12 percent per year (R6 2005 FEIS and 

ROD). Prevention measures would be applied to new projects and ongoing activities and would be 

expected to slow the rate of spread over time (ibid.); however, existing infestations would not be treated 

under this decision. The purpose and need for action would not be met and the degrading impacts of 

invasive plants, explained in all of the resource sections of chapter 3 would continue unabated. 

Isolated populations of invasive plants, particularly the knapweeds, Dalmatian toadflax, and sulphur 

cinquefoil, can quickly spread into adjoining forest lands if the Forest canopy is opened up. Seeds of 

invasive plants can be carried some distance by passing traffic, equipment, wind, and animals. Alternative 

A continues the current the risk for invasive plant propagules to spread. Chapter 3.1.5 lists associated 

activities, intensity and frequency of disturbance and level of noxious weed propagule pressure. Since 

most of the current weed sites occur near roads, the risk for increased spread from lack of treatment is 

highest along these routes. Roads and recreation areas have perpetual disturbance, a non-natural habitat 

that favors opportunistic invasive species and a high rate of propagule pressure.

Alternative B 

Alternative B allows for the most effective, available treatment methods to occur on the existing 

infestations and future detections, thus the first year/first choice treatment for each infested area under 

alternative B is assumed to be 80 percent effective.

The most ambitious treatment scenario would treat all 2,124 acres within a year of this decision being 

signed (2014-2015 or year 1). The following year 20 percent of the acreage would need to be retreated 

(425 acres 2015-2016 or year 2). These remaining acres would be subject to spread, so a rate of 10

percent spread per year was applied on the remaining acres. Thus, about 468 acres would be treated in the 

years 2015-2016 and given the 80 percent effectiveness on these acres; about 94 acres would need to be 

treated in 2016-2017 (year 3). Thus, about 103 acres would be treated in year 3 once 10 percent spread 

rate is applied. Under the most ambitious treatment scenario, these 103 acres would be reduced to about 

21 acres by 2018 (year 4). This would be considered a nominal level, so the treatment cost-effectiveness 

analysis is not carried out further, except to accommodate the cost of active restoration. 

Passive restoration would be adequate on most of the treated sites; however some areas will need to be 

seeded, mulched or planted once invasive species are removed. For the most ambitious treatment 

scenario, I estimated that the 1,231 acres that are of a size and configuration that could require broadcast 

treatment would need some sort of active restoration (mulching, seeding, planting), at a rate of $500 per 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

72

acre17 applied year 4 (2018). This is a high estimate and likely passive restoration would suffice for many 

of these areas. However, this estimate accurately characterizes the potential for high costs of repeat 

treatments and restoration of invasive species over time. The surrounding vector of spread and propagule

pressure would influence the need and extent of active restoration. Perpetual disturbance associated with 

recreation, livestock grazing, and roads could complicate restoration. 

In some cases, restoration of native vegetation would be part of another ongoing or planned project, such 

as road decommissioning, stream restoration, and restoration of yarding corridors associated with timber. 

Road closures could make restoration and long-term maintenance of invasive plants more difficult. 

Cooperative treatments between neighboring land owners and agencies involved with invasive plant 

management would increase the effectiveness of alternative B and ensure weed spread between land 

ownerships is properly abated. 

Table 20 shows the costs per year, total cost over a 4-year period, and average cost per acre to be applied 

to unpredictable new infestations that could be discovered and treated over the life of the project 

according to common control measures, pdfs, and subject to treatment caps. 

Table 20. Most ambitious treatment scenario and costs for alternative B

Acres 

Treated 

Acres Remaining 

to Be Treated

Add 10% spread 

rate Cost Year 1

Year 1 2,124 425 468 $424,800

Year 2 468 94 103 $93,600

Year 3 103 21 23 $20,600

Year 4 – restoration 1,231 Maintenance level NA $615,500

Total $1,154,500

Average Cost per 

Acre with all activities 

included 

$544

Applied to 30,000 

acre life of the Project 

Cap For EDRR

Maximum of $16,320,000 

over a fifteen year period 

Alternative C 

Alternative C restricts available treatment methods for both the existing infestations and future detections 

and thus reduces its effectiveness. The loss of the ability to use herbicides/broadcast spray in this 

alternative is estimated to reduce the effectiveness of treating all existing infestations to half of alternative

B based on these restrictions. In addition, the potential effectiveness would be reduced due to the lack of 

picloram in the toolbox. The loss of the use of picloram would reduce our ability to effectively adapt to 

areas that do not effectively respond to aminopyralid or another first year/first choice herbicide.

The most ambitious treatment scenario would treat all 2,124 acres within a year of this decision being 

signed (2014-2015 or year 1). The following year, half of this acreage would still need to be treated and 

would be subject to annual spread. Table 21 shows how this would compound over time and increase the 

life of the project cost. Restoration costs are the same across the action alternatives.

Cooperative treatments between neighboring land owners and agencies involved with invasive plant 

management would increase the effectiveness of alternative C.

 17 Restoration cost based on estimates in the GPNF EIS, Gifford Pinchot National Forest, 2008
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

73

Table 21 below shows the costs per year, total cost over a 6-year period, and average cost per acre to be 

applied to unpredictable new infestations that could be discovered and treated over the life of the project 

according to common control measures, pdfs and subject to treatment caps associated with alternative C. 

Table 21. Most ambitious treatment scenario and costs for alternative C

Acres 

Treated 

Acres Remaining 

to Be Treated

Add 10% spread 

rate Cost Year 1

Year 1 2124 1062 1168 $424,800

Year 2 1168 584 642 $233,600 

Year 3 642 321 353 $128,400

Year 4 353 177 195 $70,600 

Year 5 195 98 108 $39,000

Year 5 108 54 59 $21,600

Year 6 - restoration 1,231 Maintenance level NA $615,500

Total $1,533,500

Average Cost per 

Acre with all activities 

included 

$722

Applied to 30,000 

acre life of the Project 

Cap For EDRR 

Maximum of $21,660,000 

over a fifteen year period 

Alternative D 

Alternative D restricts available treatment methods for both the existing infestations and future detections 

and thus reduces its effectiveness. The loss of the ability to use aminopyralid in this alternative is 

estimated to reduce the effectiveness of treating about 1,347 acres. Because aminopyralid can be 

broadcast to the water’s edge, and other herbicides cannot, about 738 acres would have to be spot applied 

in alternative D, rather than broadcast. This would increase the time and thus the cost of treating these 

acres. The loss of aminopyralid itself would also have an effect on making alternative D less effective but 

this was not included in the economic analysis. The main effect of alternative D that was modeled is the 

difference in spot versus broadcast acreage. Restoration costs would remain the same as alternative B and 

C. 

The economic analysis assumes equal effectiveness between alternatives B and D for 1,386 acres (80% 

effective per year). However, it reduces the effectiveness by half for those 738 acres that must be spot or 

hand treated in alternative D (rather than broadcast sprayed) due to the herbicide-use buffers on 

herbicides other than aminopyralid that restrict broadcast spraying near streams. Spot treatment is 

considered half as effective as broadcast because of the greater amount of time spent by workers walking 

from invasive plant to invasive plant, rather than a uniform application. Where spot treatment is required 

for areas that are 100 percent covered by invasive plants (our analysis assumption for the currently 

mapped infestations), there will also likely be a need for increased entries due to the potential for skips 

and gaps when spot treating (Desser 2008). This reduces the overall effectiveness ranking for alternative 

D to 66 percent meaning that about one-third of the acreage would have to be retreated each year until 

target populations reach a maintenance level and can be restored. 

The most ambitious treatment scenario would treat all 2,124 acres within a year of this decision being 

signed (2014-2015 or year 1). The following year 34 percent of this acreage would still need to be treated 

and would be subject to annual spread. Table 22 shows how this would compound over time and increase 

the life of the project cost and average cost per acre. Restoration costs are the same across the action 

alternatives. Cooperative treatments between neighboring land owners and agencies involved with 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

74

invasive plant management would increase the effectiveness of alternative D to ensure weed spread 

between land ownerships is properly abated. 

Table 22 below shows the costs per year, total cost over a 5-year period, and average cost per acre to be 

applied to unpredictable new infestations that could be discovered and treated over the life of the project 

according to common control measures, pdfs and subject to treatment caps associated with alternative D.

Table 22. Most ambitious treatment scenario and costs for alternative D

Acres 

Treated 

Acres Remaining to 

Be Treated

Add 10% spread 

rate Cost Year 1

Year 1 2124 701 771 $424,800

Year 2 771 254 279 $154,200

Year 3 279 92 101 $55,800

Year 4 101 34 37 $20,200 

Year 5 - restoration 1,231 Maintenance level NA $615,500

Total $1,270,500

Average Cost per Acre 

with all activities 

included 

$598

Applied to 30,000 acre 

life of the Project Cap 

For EDRR 

Maximum of $15,930,000 

over a fifteen year period 

Alternative Comparison

Table 23. Results of the cost-effectiveness analysis for alternatives 

Issue Indicator Alternative A Alternative B Alternative C Alternative D

Average Cost per Acre of Fully Effective 

Treatment (includes 4-6 years of retreatments and restoration)0 $544 $722 $598

Total Cost of Most Ambitious Treatment 

Scenario 0 $1,154,000 $1,472,900 $1,270,500

Maximum Cost over the Life of the Project

(assuming maximum treatment caps

multiplied by average per acre cost) 

0 $16,320,000 $21,660,000 $17,940,000

Number of Years to Achieve Objectives 

(most ambitious treatment scenario)

More than 

10-15 years 4 years 6 years 5 years

The Life of the Project

It is unlikely that the Malheur National Forest will be funded to implement the most ambitious treatment 

scenarios analyzed. Only a portion of the 2,124 acres currently needing treatment will likely be treated in 

year 1 regardless of action alternative selected. The economic analysis allows a consistent basis to see the 

impact of differences in alternatives and provides an estimate of the cost of fully treating and restoring an 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

75

acre, based on the metrics of existing infestations. The 30,000-acre cap is based on all existing 

infestations spreading over a 15-year period at a rate of 10 percent per year, without any reduction in 

acreage from treatment. The sooner treatment of existing infestations occurs; the less likely large numbers 

of acres will need to be treated in the future. The most ambitious conceivable scenarios described above 

demonstrate that the purpose and need for this project could be met in a compressed time frame, if 

funding and workforce were available.

Funding and workforce capacity will dictate how many acres are treated under the auspices of this 

project. The more acres that get treated immediately, the less cost and better effectiveness over time. 

However, it is more likely that the project will take 10 to 15 years to reach the maintenance level modeled 

in a compressed timeframe above.

3.1.5 Introduction to the Cumulative Effects Analysis 

Introduction

Cumulative effects are the result of incremental impacts of the proposed actions/alternatives when added 

to other past, present, and reasonably foreseeable actions, both on National Forest System lands and 

adjacent federal, state, or private lands (40 CFR 1508.7). The baseline for cumulative effects analysis is 

the current condition as described in the affected environment sections throughout chapter 3.

Management activities and actions on neighboring lands contribute to spread or management of invasive 

plants on National Forest system lands, and vice versa. The effectiveness of the proposed invasive plants 

treatment project would be increased if coordination with adjacent landowners treats invasive infestation 

across land ownerships. The cumulative effects analysis assumes that this cooperative, coordinated effort 

will continue, and the release of biological control agents on lands adjacent lands by the Oregon 

Department of Agriculture, as analyzed by Animal Plant Health Inspection Service (APHIS), will 

continue, regardless of alternative.

Herbicides are commonly applied on lands other than National Forest System lands for a variety of 

agricultural, landscaping and invasive plant management purposes. Herbicide use occurs on tribal lands, 

state and county lands, private forestry lands, rangelands, utility corridors, road rights-of-way, and private 

property. No requirement or central reporting system exists to compile invasive plant management 

information on or off national forests in Oregon. Accurate accounting of the total acreage of invasive 

plant treatment for all land ownerships is unavailable. The estimates provided in this section are not 

precise and are uncertain given the long project life.

All invasive plant treatment methods have the potential to damage individual non-target plants, including 

sensitive species. Noise and worker activity can disturb wildlife and removal of vegetation can affect their 

habitat. If manual, mechanical or herbicide treatments create bare soil, erosion can be accelerated. Small 

amounts of herbicide or sediment could reach surface water and impact water quality or aquatic 

organisms. All treatments have the potential to injure a worker or result in other accidents; and all 

treatments would create jobs and cost money. There is little disagreement that the potential adverse 

impacts of non-herbicide invasive plant treatments are minor, small scale, and of short duration. The 

potential for non-herbicide treatments to result in effects of concern to the public is very low. The 

potential for cumulative effects from such treatments were discussed in the R6 2005 FEIS (chapter 4-39, 

4-50, 4-61 to 62, 4-89 to 4-90, and 4-122 to 123) and are incorporated by reference.

The issues for this project center on the effects of herbicide use or restrictions of herbicide use in the

alternatives. Some people have expressed concern that herbicide use from this project could combine with 

herbicide use elsewhere and have an additive, synergistic, or other cumulative effect; specifically the 

effects on wildlife, fish or people exposed to repeated doses of herbicides. The focus of the following 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

76

section is on herbicide use, however potential cumulative effects of non-herbicide treatment methods and 

other projects and land uses across and adjacent to the Malheur National Forest are discussed throughout 

chapter 3.

The relative scale of this project is so small that it is unlikely to contribute to measurable, detectable 

herbicide concentrations in downstream waters. Multiple herbicide exposures are unlikely to occur in 

close enough proximity in time or space with other applications to trigger cumulative effects. The small, 

scattered nature of the infestations, the relatively low toxicity and potential to cause adverse effects 

associated with the herbicides proposed for use, the pdfs, herbicide-use buffers and treatment caps that 

limit the extent, intensity and duration of potential adverse effects, and treating invasive plants

cooperatively across administrative boundaries, all serve to minimize the potential for adverse effects to 

accumulate and amount to a measurable impact on people or the environment.

Counties are responsible for controlling noxious weeds along county roads and other county property 

outside of and within the Malheur National Forest. They also work with conservation districts, weed 

management areas, and watershed councils to control noxious weeds on private property. Additive 

herbicide exposures are possible if herbicide is used on neighboring lands during the same day as planned 

on the Forest. Treatments occurring on National Forest System land, lands of other federal agencies, 

states, and counties would be coordinated so treatment overlaps are unlikely. Any molecules of herbicide 

that leave a treatment site will have time to dilute and degrade before mixing with another contaminant. 

The R6 2005 FEIS (p. 4-10) estimated 3 percent of the herbicide use within Oregon and Washington is on 

National Forest System land.

The Bureau of Land Management has proposed invasive plant treatments using herbicides on BLM lands 

in Oregon; however their proposals are not site-specific enough to model cumulative effects at the 

watershed scale. The BLM contribution to cumulative effects would also be relatively low compared to 

other herbicide use in Oregon (USDI Bureau of Land Management 2010).

Herbicides are commonly applied for a variety of agricultural, landscaping and invasive plant 

management purposes. Herbicide use occurs on tribal lands, state and county lands, private forestry lands, 

rangelands, utility corridors, road rights-of-way, and private property. Studies (listed in this section) have 

shown that pesticides are commonly found in surface waters in Oregon and throughout the United States. 

However, the studies indicate that herbicide use similar to the type proposed in this project will not result 

in harmful concentrations of herbicide in water.

The R6 2005 FEIS (pages 4-1 to 4-3) and SERA Risk Assessments discussed effects of chronic exposure 

to low levels of herbicides used to treat invasive plants on National Forest System land. Chronic 

exposures do not result in cumulative effects because the herbicides are more rapidly excreted from 

organisms (people, animals and fish) than would be absorbed from predicted levels of exposure. Thus, an 

animal could encounter herbicide in more than one location over time; however there would be no 

possibility for this project to result in exposures that could cause a cumulative effect.

Statewide Herbicide Use

In 2007, approximately 284,984 reports of pesticide use were reported in Oregon. The top five active 

ingredients, by pounds, for the entire state were:

Metam-sodium (42%) [soil fumigant]

Glyphosate (9%) [herbicide]

Copper naphthenate (7%) [wood preservative]

1,3-dichloropropene (5%) [soil fumigant]
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

77

Aliphatic petroleum hydrocarbons (4%) [insecticide]

Of these, glyphosate is the only herbicide. It was the second most-used active ingredient and accounted 

for 9 percent of all pesticide use reported statewide. The vast majority was agricultural use. Statewide 

reported glyphosate use was over 3.5 million pounds. In the John Day Basins alone nearly 153,000 

pounds of glyphosate were reportedly applied. Glyphosate is quickly taken up by plants or bound up with 

soils so that it is not mobile in the environment soon after application. Effects of glyphosate from invasive 

plant treatments are very limited in time and space to the immediate area of the treatment. If vegetation 

adjacent to or emergent from flowing water is treated, glyphosate may be detected downstream from the 

treatment. However, it is very likely bound to organic matter and not biologically active and very unlikely 

to cause any effect. Therefore, glyphosate use from other lands in the water basins is not likely to cause 

cumulative effects when added to the direct and indirect effects of this project. Many of the proposed 

herbicides have limited mobility in the environment so effects would be limited to areas immediately 

adjacent to the treatment sites; others, though mobile to some extent, have properties that bind them to 

soil particles or ensure rapid degradation, so do not pose a level of concern. Most of the herbicides 

proposed for use would not persist in the environment for more than a few weeks or months, and those 

that remain longer have pdfs limiting the frequency of use so that effects do not accumulate at the 

treatment site.

Three other herbicides proposed for use in the action alternatives are within the top 100 reported 

statewide in 2007: imazapyr, sulfometuron methyl, and triclopyr. None of these are first-choice herbicides 

in any alternative.

We are proposing a very low level of herbicide use compared to river basin or statewide use. The Forest 

Service contribution to cumulative herbicide use would remain low in all alternatives. No water quality 

issues related to pesticides have been identified in the waters in the project area (none of the streams in 

the area are 303d listed for chemical contamination).

Any herbicide reaching the stream would be quickly diluted and as the herbicide moved downstream it 

would become less and less likely to cause impacts. For instance, one of the relatively most mobile, 

persistent and toxic herbicides proposed for use in two alternatives, picloram, would become diluted by 

85 to 98 percent by the time it moves 100 meters (328 feet) away from the application site (Evens and 

Duseja 1973). Glyphosate would be diluted sufficiently to stop affecting plants about 100 feet from the 

application site (Thistle 2007).

NWQAP Pesticide Study

Since 1991, the National Water Quality Assessment Program (NWQAP) has implemented 

interdisciplinary assessments in 51 of the Nation’s most important river basins and aquifers, referred to as 

Study Units, and the High Plains Regional Ground Water Study. The USGS published a report: 

“Pesticides in the Nation’s Streams and Ground Water, 1992–2001” (Gillom and others 2006) that 

presented evaluations of pesticides in streams and ground water based on findings for the first decadal 

cycle of NAWQA. The study found that undeveloped streams had one or more detectable pesticides or 

degrades 65 percent of the time. The study stated that presence of pesticide compounds in predominantly 

undeveloped watersheds may result from past or present uses within the watershed for purposes such as 

forest management or maintenance of rights-of-way, uses associated with small areas of urban or 

agricultural land, or atmospheric transport from other areas. None of the herbicides proposed for use in 

this project were detected in the national samples (however it is acknowledged that glyphosate is widely 

used but was omitted from the study). 

The report discusses the many delivery mechanisms of pesticides to surface and ground water: 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

78

Pesticides are transported to streams and ground water primarily by runoff and recharge. 

Nonpoint sources of pesticides originating from areas where they were applied—rather than point 

sources such as wastewater discharges—are the most widespread causes of pesticide occurrence 

in streams and ground water (Modified from Majewski and Capel 1995.) The atmosphere is often 

overlooked as a source of pesticides, which return to earth with precipitation and dry deposition 

and can reach streams and ground water. Streams are particularly vulnerable to pesticide 

contamination because runoff from agricultural and urban areas flows directly into streams along 

with both dissolved and particle-associated pesticides. Ground water is most susceptible to 

contamination in areas where soils and the underlying unsaturated zone are most permeable and 

drainage practices do not divert recharge to surface waters.

The study also stated: 

Pesticide occurrence in streams and ground water does not necessarily cause adverse effects on 

aquatic ecosystems or humans. The potential for effects can be assessed by comparing measured 

pesticide concentrations with water-quality benchmarks, which are based on the concentrations at 

which effects may occur. No streams draining undeveloped land, and only one stream in a 

watershed with mixed land uses, had an annual mean concentration greater than a human-health 

benchmark.

This study supports the conclusion that this project, combined with other herbicide use on lands of other 

ownership, would not result in herbicide delivery to streams over a threshold of concern for people or the 

environment. The State of California also conducted monitoring on surface water where 40,631 pounds of 

active ingredient of 13 herbicides and 19 insecticides were applied within the privately-owned watersheds 

upstream of sampled locations. No detectable concentrations of any herbicides were identified (reliable 

detection limits ranged from 0.04 to 2.0 ppb). The analysis included glyphosate and triclopyr. The results 

could have been affected by several months passing between dry weather application and the first rain, 

potentially allowing chemical degradation or adsorption to soil; or dilution of stream flow between 

application and monitoring sites may have contributed to the lack of positive detections (Jones et al.

2000). 

Clackamas River Pesticide Study

Closer to home, a study about the background levels of pesticides in surface waters was done on the 

Clackamas River, part of the Willamette River Basin in western Oregon. The Pesticide occurrence and 

distribution in the lower Clackamas River basin, Oregon, 2000–2005 (Carpenter et al. 2008) was done as 

part of the NWQAP.

The Clackamas study took place from 2000–2005. Within 119 water samples from the Clackamas and its 

tributaries, 63 pesticide compounds: 33 herbicides, 15 insecticides, 6 fungicides, and 9 pesticides 

degradates were detected. Fifty-seven pesticides or degradates were detected in the tributaries (mostly 

during storms), whereas fewer compounds (26) were detected in samples of source water from the lower 

Mainstem Clackamas River, with fewest (15) occurring in drinking water.

The study stated that the two most commonly detected pesticides were the triazine herbicides simazine 

and atrazine, which occurred in about one-half of samples. It also said that the active ingredients in the 

“common household herbicides” RoundUpTM (glyphosate) and CrossbowTM (triclopyr and 2,4-D) also 

were frequently detected together. These three herbicides often made up most of the total pesticide 

concentration in tributaries throughout the study area. 

The study stated that pesticides were most prevalent in the Clackamas River during storms, and were 

present in all storm-runoff samples — averaging 10 individual pesticides per sample from these streams. 

Two tributaries contained 17–18 different pesticides each during a storm in May 2005. These medium-
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

79

sized streams drain a mix of agricultural land (row crops and nurseries), pastureland, and rural residential 

areas. Two small streams that drain the highly urban and industrial northwestern part of the lower basin 

had the greatest pesticide loads. Streams draining predominantly forested basins contained fewer pesticide 

detections (2–5 pesticides). The study stated that pesticide use on the Mount Hood National Forest, which 

comprises most of the Federal land in the upper Clackamas River Basin, was a relatively insignificant 

contribution.

Invasive Plant Spread and Cumulative Effects

Invasive plant target species on the Malheur National Forest are predominantly annual and perennial forb 

species. Scotch broom, an invasive woody shrub, has limited occurrence in this dry habitat, preferring 

higher moisture and cool conditions on the western Cascade forests. Most of the forbs that are invasive on 

the Malheur National Forest have a tap root that mines a greater depth of soil to acquire water and 

nutrients (Kulmatiski et al. 2008). Annual plants such as the annual grasses do not penetrate deep into 

soil, but grow quickly during ample moisture and when nutrient levels are high (Eviner and Firestone 

2007). Thus, these plants have high propensity to grow on disturbed areas where water-holding capacity 

and organic matter levels are low for most of the year except during the short nutrient-burst periods when 

moisture and cold temperatures are not limiting.

The majority of the invasive plants on the Malheur National Forest have strong affinity to open light 

conditions and low shade tolerance. Thus, a strong correlation exists for invasive plants in recently 

deforested areas, road corridor openings and open rangelands. The low shade tolerance of most the weed 

species found on the Malheur National Forest is evident in studies from the Rocky Mountains and eastern 

Washington. Studies of edge environments found substantial drops in weeds moving away from major 

roadways in shaded environments (Hansen and Clevenger 2005, Pauchard and Alaback 2006, Buonopane 

et al. 2013). The central Washington study found that invasive plants, many common to the Malheur NF, 

on average did not penetrate further than 32 feet from the roadside where a forest canopy existed 

(Buonopane et al. 2013). Similarly, a Canadian study in eastern front Rocky Mountains observed 

substantial decrease in invasive plants 32 feet from a roadway in a forested environment as compared to 

about 490 feet in a rangeland environment. Field observations in the Malheur National Forest had a 

similar trend.

Disturbances that can be subject to weed invasion vary in frequency and intensity (James et al. 2010). A 

forest fire that burns at high and moderate severity can completely eliminate the overstory and understory 

plant canopy and bare soil. The combusted organic material leaves a high nutrient load. Though the 

disturbance has high intensity, the spike in nutrient load and amount of exposed bare soil decreases 

rapidly within 5 years as the native vegetation recolonizes the site and the risk of weed invasion declines. 

In contrast, livestock grazing occurs every season. The scale of the disturbance can be much less intense 

than a damaging wildfire since grazing exposes a fraction of soil area compared to wildfire; however, the 

intensity of the grazing increases if cattle are concentrated in specific areas. 

Ground disturbance associated with natural processes such as wildland fire, and human activities, such as 

road use, may favor the spread of invasive plants and discourage the reestablishment of native species. 

Seastedt et al. 2008, notes that human-caused disturbance can change soil conditions to which native 

species have adapted, which further results in conditions that favor invasive plants. Repeated road 

clearing and graveling, an open gravel pit, or a cleared compacted recreation area create environments 

that favor colonists species or vegetation that can optimize a large volume of soil with a taproot or species 

which germinate quickly, grow and set seed during the limited growing conditions of the site. Roadside 

environments have coarser texture growing substrate with higher rock content and thus represent growing 

environments that favor invasive plants (Gelbard and Belnap 2003).Generally; disturbed environments 

have greater available resources for invasive plants because of exposed soil, open light, and higher 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

80

nutrient and water availability. Shade under forest canopies substantially limits weed growth. Most of the 

primary target species on the Forest do not invade shaded environments.

The relationship between OHV trail use, travel access management, and the introduction, establishment 

and spread of invasive plants was discussed in the R6 2005 FEIS. Off-highway vehicle use can influence 

the spread of invasive plants by disturbing soil and carrying seed several orders of magnitude greater than 

‘conventional’ dispersal methods (R6 2005 FEIS p. 3-15). Vehicle traffic is considered the major vector 

for weed seeds since long stretches of roadways have invasive plants; vehicles cover large distances and 

can pick-up and deposit seeds into new areas (Trombulak and Frissell 2000, Zouhar 2008, Flory and Clay 

2009, Birdsall et al. 2011).

Invasive plant density drops in shaded environments (Hansen and Clevenger 2005, Pauchard and Alaback 

2006, Buonopane et al. 2013). Buonopane et al. (2013) found high rates of noxious weed seeds in the 

topsoil and litter layer well within the Malheur National Forest adjacent to infested roadsides. This 

indicates that invasive plants would be readily introduced to nearby disturbed areas even if no invasive 

plants are visible under the existing forest canopy. Roads and rights-of-way have the highest incidence of 

invasive plants due to perpetual disturbance together with a constant seed source from passing traffic 

(Zouhar 2008, Birsall et al. 2011). The open light conditions inherent to roads creates ideal habitat since 

most invasive plants on the Forest do not tolerate shade. The road disturbance footprint has gravelly road 

fill emplaced next to dugout ditches, and bared cutslopes, open sites for invasive plants to establish. 

Roadways and railways fragment the landscape, creating edge environments where invasive plants can 

thrive (Hansen and Clevenger 2005).

Roads and traffic are primary vectors for invasive plant spread. Invasive plants are found where vehicle 

traffic congregates; recreation areas, parking lots and where forest management activities concentrate at 

log landings. Road maintenance activities can also spread invasive plants from mowing and grading 

activities. Transplanted road materials from infested rock pits may carry weed seeds and plant parts into 

more remote locations of the Forest. Measures such as using weed-free products and timing road 

maintenance to avoid spreading invasive plants can help prevent invasive plant spread.

Roads vary for risk of invasive plants depending on the level of construction. A four-wheel-drive twotrack vehicle has much less potential for sustaining invasive plants compared to a high-level constructed

highway. The construction footprint extends from the roadside to the edge where the natural vegetation 

dominates. Typically, the edge of the roadcut demarcates the change when roads cross forests. Gelbard 

and Belnap (2003) documented an average 50-foot novel vegetation width along paved roadways 

compared to a 6-foot width along four-wheel-drive two tracks. The large unique vegetation span along the 

paved road coincided with the placement of fill and excavation. When comparing level of exotic plants, 

the researchers found a four time increase in cheatgrass along the paved roads versus the two-track road. 

A paved road also sheds water more effectively than low bermed primitive roads, creating high water and 

nutrient availability for exotic plant growth. Other authors report changes away from weedy roadside 

vegetation at an average 98 feet in Illinois (Flory and Clay 2009) and 32 feet in east slope Washington 

(Buonopane et al. 2013) for forests along major roadways.

Streams have annual disturbance from fluctuating streamflow. Snowmelt flush bares stream edges leaving 

gravel bars and silt that is primary succession habitat. Invasive plants can easily occupy these sites, but 

the mesic conditions and well-adapted riparian vegetation readily compete to re-occupy these sites. The 

riparian vegetation forms a type of biotic resistance that damps the spread of invasive plants. The seed 

dispersal of invasive plants is periodic, and dispersed by streamwater, birds, and animals along the 

riparian corridor.

Grazing lands experience annual disturbance from livestock along with intermittent vehicle use that can 

bare soils in livestock congregation areas near troughs, salt licks, fences and water ways. Plant parts may 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

81

stick to animals and be transported into rangelands. The grazing activities on the Forest result in overall 

moderate level of disturbance and occur within a timeframe of less than 6 months per year. The moderate 

level corresponds to the small and distributed amount of disturbance across the allotment.

Vegetation clearing from fuels and logging activities disturbs soils from log yarding. Temporary 

transportation routes result in severe disturbance but lack annual traffic. The initial soil mixing from 

logging activities can lead to short-term increases in nutrient release (Booth et al. 2004). The available 

nutrients on these disturbed skid trails and lack of competing plants create ripe conditions for noxious 

invasive plants to spread. The sites remain open to infestation while native understory and overstory 

vegetation re-occupy the site in the initial period after logging for 1 to 3 years. However, the propagule 

pressure from vehicle traffic is limited to the logging activity.

Burned areas have conditions that favor invasive plant spread by eliminating competing plants and 

bolstering the nutrient availability (Zouhar 2008, James et al 2010). The initial nutrient flush is a result of 

the thermal decomposition of burned vegetation combined with the subsequent further decomposition and 

release of nutrients by soil organisms (Hart et al. 2005). These conditions create extremely high invasion 

potential a few years following fire, but risk decreases over time as native vegetation recolonizes and 

nutrient levels drop (Zouhar 2008). Places of high heat from heavy fuels burning may favor invasion by 

Canada thistle and bull thistle. During field surveys of the Malheur National Forest invasive plant sites, 

Canada thistle was found to colonize old burned pile scars; the thistle has high tolerance for the alkaline 

and poor soil conditions associated with these severely burned areas (Korb et al. 2004, Meyer 2009). 

In burned areas, the risk for weed infestation decreases with time much like after timber harvest. The 

initial disturbance has much traffic from fire suppression followed by rehabilitation and possible salvage 

activities; although wildfire typically results in a much higher intensity disturbance than timber harvest 

from complete combustion of forest and shrublands during very dry hot conditions.

Prescribed fire results in low intensity burning that retains vegetation generally across 85 percent of the 

forest floor and leaves less than 15 percent soil cover. These are default values used in the Forest Service 

Water Erosion Prediction Project’s Disturbed WEPP application. Increased nutrient pulses result from 1 to 

2 years (Hart et al. 2005) but fewer disturbances create an overall low risk for invasion.

The various sections of chapter 3 address cumulative effects arising from treatment of invasive plant over 

the next 5 to 15 years. We will likely have a need for continued applications of herbicides and other 

integrated treatments throughout the life of the project. Chapter 3 discusses how the use of herbicides 

through the life of the project could further affect National Forest System lands on the Forest that are 

being impacted by ground disturbance. 

Table 24 displays potential disturbance frequency and intensity, and invasive plant propagule pressure 

associated with ongoing activities that are vectors for invasive plant spread. Disturbance frequency and 

intensity and propagule pressure strongly factors influence the rate that invasive plants are likely to spread 

along vectors. The most applicable R6 2005 ROD Standard dealing with preventing the spread of invasive 

plants via each vector is also shown. Prevention is an important aspect of our invasive plant management 

program. National policies and regional and local plans are in place to reduce the potential for invasive 

plants to become introduced, established or to spread as a result of our activities. See chapter 3.1.4, 

Treatment Effectiveness, for more information about how the location of infestations and surrounding 

vectors influence our treatment and restoration methods.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

82

Table 24. Potential disturbance frequency for invasive plants spread

Vector

Disturbance 

Frequency/ 

Potential

Maximum 

Intensity

Potential 

Propagule 

Pressure

Most Applicable R6 Management Direction/

Prevention Considerations

Recreation sites 

management, dispersed 

and developed sites; 

campgrounds, hunter 

camps, trailheads.

Perpetual/Low High

R6 Goal 1, Objectives 1.2; 2.4, 2.5; Standards

1, 4;

outreach and education, travel management, 

recreation management

Livestock grazing; 

Dry open grassland 

steppe, shrub lands, dry 

forestlands

Seasonal/Moderate

to High

Moderate to 

High

R6 Goals 1, 2; Objectives 1.2, 2.1, 2.2; 

Objective 5.3; Standards 4,6;

AMPs and annual operating plans,

Vegetation 

management (thinning 

and brushing, logging, 

burning)

Periodic/High

(especially yarding 

corridors and 

landings, pile 

burning)

High

R6 Goals 1,2; Objectives 1.1, 2.1, 2.2, 

Standards 1, 2, 3, 13

Strategy to prevent Canada thistle

Wildland fire and 

incident response

Periodic/Low to 

High Moderate

R6 Goals 1, 2; Objectives 1.1, 1.3, 1.5 2.3; 

Standards 1, 2*, 3, 13

*although emergency situations like wildland 

fire are explicitly exempt from this equipment 

cleaning standard, Forests report that it 

happens routinely.

Roads 

(road maintenance, 

construction, 

reconstruction and use)

Perpetual/High High

R6 Goals 1,2; Objectives 1.1, 2.4, 2.5;

Standards 1, 2, 7, 8, 13

Forests report excellent coordination with 

engineering staff , quarries are inspected and 

road materials are weed free

Closing roads Periodic/Low Moderate R6 Goal 2; Objective 2.4; Standards 1, 2, 3, 13

Restoring roads and 

landings

One time/

Low to High Moderate R6 Goals 1, 2; Objective 1.1; 2.1, 2.4; 

Standards 1, 2, 3, 13

Adjacent agriculture Perpetual/Low Low R6 Goal 5; objectives 5.1-5.3

Stream restoration (i.e.,

fish passage and 

habitat projects, riparian 

vegetation restoration), 

Stream flow

Seasonal/High Low

R6 Goals 1, 2; Objectives 1.1, 1.3, 1.5, 2.1, 

2.2; standards 1, 2,

Keep equipment working near streams clean.

Reasonably Foreseeable Projects on the Malheur National Forest

The Forest Service is proposing a variety of activities throughout the planning area, below is a listing of 

projects that foreseeably could overlap in time and space with invasive plant treatments. Additional 

ongoing projects may overlap with invasive plant treatment (for instance road, trail and administrative site 

maintenance; and vegetation and habitat management and restoration).

The cumulative effects analysis addresses at the potential for the lingering impacts of invasive plant 

treatments to overlap in time and space with the effects of a particular project and cause additive, 

synergistic or other impacts. The cumulative effects analysis also considers the ongoing activities 

described in the previous table. 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

83

Table 25. Foreseeable future projects on the Forest with project details, vectors for invasive plant spread, 

watershed(s) affected and implementation schedule

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Bald Butte LO 

Decommission

Remove Lookout with 

explosives

Recreation Site 

management Middle Silver Creek 2013

Bear Creek Riparian 

Juniper Thinning Thin 47 acres of juniper Vegetation 

Management

Upper South Fork 

John Day River 2014

Blue Mountain Snow 

Park

Clearing trees and 

leveling 7 acres and 

paving parking area; 

construction of 

warming hut, 

restrooms, and 

grooming shed; 

construction of pad for 

fuel tank

Recreation Site 

management

Summit Creek 

(170702030102) 2013

Buck and Rock 

Springs Campground 

Hazard Tree Removal 

Project

Remove hazard trees Recreation Site 

management

Upper Silver Creek 

and Wolf Creek 2013

Camp Creek LWD

Felling and placing 

entire trees ranging 

from 4- 20 inches in 

diameter within the 

following streams and 

their associated 

Riparian Habitat 

Conservation Areas 

(RHCAs)

Stream 

Restoration

Upper Camp Creek 

(170702030205); Lick 

Creek (170702030205)

2013-14

Campground Hazard 

Tree Project 

Remove hazard trees 

in D-Lake, Idlewild, 

Joaquin Miller, 

Yellowjacket, Emigrant 

Creek, Falls Camp

Vegetation 

Management

Upper Silver, Upper 

Silvies, North Basin, 

Emigrant Creek

2013

Dairy EA

Commercial harvest, 

road closures and 

decommissioning

Vegetation 

Management Upper Silver Creek

2013-2014 road 

closures may go 

on for years

Damon

RX fire, commercial 

and non-commercial

harvest, road closures 

and decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Van Aspen-Silvies 

River (171200020105); 

Lower Scotty Creek 

(171200020104); 

Shirtail Creek 

(171200020301)

FY 11 to FY 13

Dragon's Head 

Plantation PCT thin plantations

Vegetation 

Management -

Ground 

disturbance, 

open canopy

Wolf Creek and Upper 

Silvies River 2013 and beyond
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

84

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Dragon's Hump 

Plantation PCT

PCT and treat slash on 

5000 acres of 

plantations

Vegetation 

Management

Middle Silvies and 

Emigrant Creek 2013 and beyond

Egley Aspen 

Restoration Project

thin and remove

conifers up to 20.9 

inches in 20 acres of 

aspen

Vegetation 

Management Emigrant Creek 2013

Egley/Pine Springs 

Overlook Interpretive 

Display Update and 

Toilet Replacement 

project

replace toilet Recreation Site 

management Middle Silver Creek

unknown, no 

funding, low 

priority

Elk 16

RX fire, commercial 

and non-commercial

harvest, road closures 

and decommissioning, 

aspen restoration, 

aquatic restoration

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings, 

Stream

Restoration

Elk Creek and Crane 

Creek Subwatershed FY 2015

Galena Project

RX fire, commercial 

and non-commercial

harvest, road closures 

and decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Vinegar Creek-MFJDR 

(170702030201); Little 

Boulder Creek-MFJDR 

(170702030202)

FY 14 to FY 17

Green Ant Project 

(Formerly the Ant and 

Emigrant Projects)

Commercial harvest, 

road closures and 

decommissioning

Vegetation 

Management Emigrant Creek 2013 and beyond

Idlewild Snowpark 

Relocation Project Relocate snowpark Recreation Site 

management North Basin 2013

Jane Hazardous Fuel 

Reduction Project

RX fire, commercial 

and non- commercial 

harvest, road closures 

and decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Wolf Creek 2013 and beyond

JB Spring 

Development and 

Trough

Develop spring, thin 5 

acres of juniper

Livestock 

Grazing,

Vegetation 

Management

Griffin Creek/Upper 

Malheur River 2013

Keeney Meadows 

Aspen

Non-commercial 

thinning and fencing 10 

aspen stands

Vegetation 

Management

Bridge Creek 

(170702030105); 

Headwaters Long 

Creek 

(170702030401); East 

Fork Beech Creek 

(170702010802); 

Upper Camp Creek 

(170702030205); 

Headwaters Long 

Creek 

(170702030401); 

July - Aug 2014

Logan Valley Grazing

Authorization

Grazing authorization 

on the Summit Prairie, 

Logan Valley, McCoy 

Creek, and Lake Creek 

Grazing Allotment

Livestock 

Grazing

Lake Creek, 

Bosenberg Creek, 

Upper Big Creek, 

Summit Creek 

Subwatershed

FY 2014
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

85

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Malheur River Range 

Aquatics Projects

Extension of the 

Malheur River Drift 

Fence. Cross Springs 

water source 

reconstruction and 

extension to a second 

trough. Development of 

Dollar Basin Spring

Livestock 

Grazing

Lake Creek and 

Bosenberg Creek 

Subwatershed

FY 2013

Marshall/Devine 

Hazardous Fuel 

Reduction Project

RX fire, commercial 

and non-commercial

harvest, road closures 

and decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Upper Silvies River 

and North Basin

2013-2014 road 

closures may go 

on for years

Murderer's Creek 

Juniper Management 

Project

Cutting of juniper and 

mixed conifer, fuel 

treatment, aspen 

restoration, and 

watershed 

improvement activities.

Vegetation 

Management; 

Stream 

Restoration

Deardorff Creek 

(170702010502); 

Corner Creek-South 

Fork John Day River 

(170702010402); 

Lower Murderers 

Creek 

(170702010305); 

Lower Deer Creek 

(170702010206)

FY 2014

Plantation 

Maintenance 

Fox/Camp Creek

Non-commercial 

thinning of plantations

Vegetation 

Management

Dixie Meadows 

(170702010602); Bear 

Creek (17070201603); 

Grub Creek 

(170702010607); 

Upper Beech Creek 

(170702010801); East 

Fork Beech Creek 

(170702010802); 

Lower Beech Creek 

(170702010803); Birch 

Creek 

(170702010905); Dry 

Creek-John Day River 

(170702010906); 

Belshaw Creek 

(170702011003); 

Cummings Creek 

(170702011005); 

Wiley Creek 

(170702020902); 

McHaley Creek 

(170702020903); 

Lower Fox Creek 

(170702020904); 

Upper Cottonwood 

Creek 

(170702020905); 

Upper Camp Creek 

(170702030205); Lick 

Creek 

(170702030206); 

Lower Camp Creek 

(170702030207)

FY 13 to FY 23
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

86

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Plantation 

Maintenance Long 

Creek

Non-commercial 

thinning of plantations

Vegetation 

Management

Indian Creek-MFJDR 

(170702030303); Slide 

Creek 

(170702030304); 

Granite Creek-MFJDR 

(170702030305); 

Headwaters Long 

Creek 

(170702030401); 

Upper Long Creek 

(170702030402); 

Basin Creek 

(170702030404); 

Basin Creek 

(170702030406); 

Upper Deer Creek 

(170702021001); 

Upper Fox Creek 

(170702020901); 

McHaley Creek 

(170702020903)

FY 12 to FY 22

Sawtooth and 

Emigrant Creek 

Culvert Replacement 

replace culverts Stream 

restoration Emigrant Creek

Sawtooth 

complete, 

Emigrant creek 

not, no funding, 

low priority

Sawtooth and Nicoll 

Checkdam 

Modification

modify existing 

structures

Stream 

restoration

Emigrant Creek and 

Upper Silver Creek

unknown, no 

funding, low 

priority

Schurtz Creek StoryFry Riparian 

Restoration Project

Fence and thin conifers 

less than 21 inches

Vegetation 

Management Wolf Creek 2013-2014

Season of Burn 

Research Project Rx burn research units Vegetation 

Management

Pine Creek and Upper 

Silvies River 2013 and beyond

SF John Day Culverts 

Replacements Replace 3 culverts Stream 

Restoration

Upper South Fork 

John Day River 2013 and beyond

Soda Bear

RX fire, commercial 

and non-commercial

harvest, road closures 

and decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Middle Bear Creek 

(171200020202); 

Lower Bear Creek 

(171200020204)

FY 13 to FY 15

South Fork John Day 

Riparian Juniper 

Thinning

thin 90 acres of juniper Vegetation 

Management

Upper South Fork 

John Day River

unknown, no 

funding, low 

priority

Starr Aspen

Commercial and Noncommercial thinning, 

Rx fire, fencing, wood 

in streams, road 

closures

Vegetation

Management, 

Closing Roads, 

Restoring Roads 

and Landings, 

Stream 

Restoration

Starr Creek-Silvies 

River (171200020102) FY 15 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

87

Project name Project Details Potential Vector Watershed(s) Implementation

Schedule

Starr HFRA

RX fire, commercial 

and non-commercial

harvest, road closures

Vegetation 

Management, 

Closing Roads,

Restoring Roads 

and Landings

Starr Creek-Silvies 

River (171200020102) FY 12 to FY 15

Summit

RX fire, commercial 

and non-commercial

harvest, road closures 

and decommissioning, 

aspen restoration, 

aquatic restoration

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings, 

Stream 

Restoration

Summit Creek and 

Tureman Creek 

Subwatersheds

FY 2016

Thompson Butte SUP 

Passive Reflector 

Removal

remove reflector Recreation Site 

management Pine Creek 2013

UMF Culvert 

Replacement

Replacement of 15 

culverts located on 

twelve tributaries in two 

watersheds of the 

Middle Fork John Day 

River subbasin. 

Stream 

Restoration

Summit Creek 

(170702030102); 

Bridge Creek 

(170702030105); 

Vinegar Creek-MFJDR

(170702030205); Little 

Boulder Creek-MFJDR 

(170702030202); 

Granite BoulderMFJDR 

(170702030203); 

Balance Creek 

(170702030208)

July - Aug 2014

Upper Pine 

Hazardous fuel 

Reduction Project

RX fire, commercial 

and non-commercial

harvest, road closures 

and decommissioning

Vegetation 

Management, 

Closing Roads, 

Restoring Roads 

and Landings

Pine Creek

2014-2015 road 

closures may go 

on for years

Voigt Ditch Headgate 

Replacement

Replacing current head 

gate with a new one 

including a measuring 

device and extending 

pipe down existing 

easement.

Adjacent 

Agriculture

Mill Creek 

(170702030106) July - Aug 2013

Whistle Rx Burn Rx Burn 3450 acres

Ground 

disturbance, 

open canopy

Upper Silver Creek unknown, low 

priority

Under all action alternatives, some level of invasive plant control would occur on 2,124 acres, and of this, 

1,067 acres occur within watersheds where some future management activity is anticipated. Watersheds 

that contain mapped invasive plants and future management activities are displayed in table 26. However, 

through the life of the project, newly detected infestations in any watershed could be treated according to 

the alternative selected.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

88

Table 26. Watersheds containing planned future activities and invasive plant treatments

Watershed Future

Activity1

Invasive Plant

Acreage2

Birch Creek P 1

Bosenberg Creek G 4

Bridge Creek T, R,G 26

Crane Creek T,B, 12

Deardorff Creek T 11

Dry Cr. John Day River P <1

Elk Creek T,B 24

Emigrant Creek T,R 44

Granite Boulder Creek R,P 120

Long Creek P 1

Indian Creek P 1

Lake Creek G 3

Lick Creek G 8

Little Boulder Creek T,B,R 139

Long Creek P 18

Lower Bear Creek T,B 1

Lower Deer Creek T, 1

Lower Scotty Creek T,B 3

Middle Bear Creek T,B 2

Middle Silvies River R 6

Mill Creek R 145

North Basin T,B,F,R 15

Pine Creek B,R, 79

Slide Creek P 6

Starr Creek T,F,B 16

Summit Creek T,B,G 15

Upper Big Creek G 5

Upper Camp Creek G 14

Upper Deer Creek P 1

Upper Fox Creek P 22

Upper Long Creek P 18

Upper Malheur River P 45

Upper South Fork John Day River T 46

Upper Silver Creek T,B,R 20

Upper Silvies River T,B,F,R,P 56

Van Aspen-Silvies River T,B 15

Vinegar Creek T,B,R 81

Wiley Creek P,B,R 2

Wolf Creek T 38

Total Acreage Invasive Plants 1,067

1 – Activity Codes (T)-Timber harvest, (B)-Burning, (F)-Fuel Reduction, (R)-Recreation/facility, (P)-Plantation thinning, (G)-Grazing

improvements. 2 – Invasive plants that don’t occur in watersheds with foreseeable future projects are not displayed.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

89

3.2 Human Health

3.2.1 Introduction

This section summarizes information from the R6 2005 FEIS and accompanying Appendix Q: Human 

Health Risk Assessment, which detailed the potential for health effects from non-herbicide treatments as 

well as the use of 10 of the herbicides proposed for this project, and is incorporated by reference in this 

EIS. This section also discusses the proposal to add a new herbicide, aminopyralid, which has been shown 

to be more effective with less risk of adverse effects. The Aminopyralid Risk Assessment (SERA, 2007) 

conducted a scientific human health risk assessment and is the primary source of toxicological 

information about that herbicide. Pacific Northwest Region 6 Pesticide Use Coordination staff reviewed 

the information about aminopyralid and found that it poses low risk to human health and compares 

favorably to the herbicides approved in the R6 2005 ROD (see table 18, chapter 3.1.2 in this DEIS).

The R6 2005 ROD adopted standards to minimize herbicide exposures of concern to workers and the 

public based on the human health risk assessments. This analysis is tiered to the human health toxicity 

information in the R6 2005 FEIS. Herbicide active ingredients, metabolites, inert ingredients, and 

adjuvants, and people with particular herbicide sensitivity were addressed. 

Hazards normally encountered while working in the woods (strains, sprains, falls) are possible during 

herbicide and non-herbicide invasive plant treatment operations. Such hazards are mitigated through 

worker compliance with occupational health and safety standards and are not a significant issue for this 

project-level analysis. Non-herbicide treatments are routinely implemented on the Malheur National 

Forest and no extraordinary circumstances have been found requiring the need for additional human 

health analysis for manual and mechanical type treatments. Although the action alternatives may rely on 

varying levels of non-herbicide treatments, the difference between the exposures to occupational hazards 

are negligible. For more information on potential effects of non-herbicide treatments, see the R6 2005 

FEIS chapter 4.5.

Many people express concern about the effects of herbicides on human health, thus herbicide toxicity and 

their impact on people are significant public issues. Herbicide use has been studied comprehensively 

through the R6 2005 FEIS; the results of risk assessments indicate that herbicide exposures from projects 

that follow R6 2005 ROD standards are unlikely to harm anyone’s health. This conclusion is based on 

facts about chemistry of the herbicides considered for use and the mechanisms by which exposures of 

concern might occur. The following section summarizes these analyses to determine whether herbicide 

treatments proposed for the Forest would pose any unique risks not already addressed.

The use of herbicide in the action alternatives would be according to label requirements, with further 

direction in Malheur National Forest LRMP as amended by the R6 2005 ROD for standards and other 

management requirements associated with the project. Scientific herbicide risk assessments are updated 

on an ongoing basis, for instance the glyphosate risk assessment was updated in 2010 (SERA 2010).

Regulatory Framework and Compliance 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) established the United States system of 

pesticide regulation to protect applicators, consumers and the environment. It is administered by the 

Environmental Protection Agency and the appropriate environmental agencies of the respective states. 

The Federal Insecticide, Fungicide, and Rodenticide Act requires registration for all herbicides, after 

extensive testing, to evaluate whether a pesticide has the potential to cause adverse effects on humans, 

wildlife, fish, and plants, including endangered species and non-target organisms, as well as possible 

contamination of surface water or ground water from leaching, runoff, and spray drift. 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

90

When registered, a label is created to instruct the applicator on the proper usage of the material and 

required personal protective equipment. The EPA also must approve the language that appears on each 

pesticide label and the product can only be used legally according to the directions on the labeling 

accompanying it at the time of sale.

The Forest Service is authorized by FIFRA and the Cooperative Forestry Assistance Act to use pesticides 

for multiple-use resource management and maintenance of the quality of the environment as long as the 

actions comply with the National Environmental Policy Act and the Council on Environmental Quality 

regulations. Forest Service Manual (FSM 2150) and Forest Service Handbook (FSH 2109) provide 

direction on safe use of pesticides, including direction on storage and transport, and development of 

safety plans and emergency spill plans.

In addition to label requirements and direction contained in FSM/FSH, the Forest LRMP as amended by 

the R6 2005 ROD, programmatically approves the use of certain herbicides and adopted standards to 

minimize herbicide exposures of concern to workers and the public. See table 1 in chapter 1.7 for a list of 

these standards and chapter 3.1.2 for risk assessment terminology.

All alternatives comply with standards, policies, and laws aimed at protecting worker safety and public 

health. This project would not result in disproportionate impacts to low income or minority group.

3.2.2 Affected Environment 

The Malheur National Forest lies in a relatively remote part of Oregon, however people live near, spend 

time in, work in, or depend on forest products from the Malheur National Forest (Forest). Some dispersed 

and developed recreation areas (trailheads, campgrounds, picnic areas, recreation sites) and traditional 

gathering and special forest product collection areas currently occur in or near the vicinity of invasive 

plant sites (see chapters 3.3, 3.9 and 3.10 for more information). People engaged in forest activities could 

potentially be inadvertently exposed to herbicides from treatment of invasive plants in or near these areas.

Hunting is by far the greatest use on the Forest (chapter 3.9).

A variety of mushrooms, berries, roots, and herbs, some of which have cultural importance to traditional 

gatherers, occur on the Forest. Cultural plants are used for food and baskets and traditional gathering is 

essential to the maintenance of tribal traditions and culture. Gathering is also economically important.

Gatherers return to the accustomed gathering areas of their ancestors to tend and harvest plants to be used 

for traditional purposes. The Forest also issues permits for special forest products, such as firewood 

gathering. Firewood gatherers have a greater potential for contact with contaminated vegetation than the 

general public because cutting sites are in accessible, disturbed areas that might contain invasive plants.

Special forest product collectors could have a greater potential for contact with contaminated vegetation 

than the general public.

Invasive plant infested sites are scattered throughout the Malheur National Forest and occupy less than 1

percent of National Forest System lands. Invasive plant treatments on the Forest are implemented through 

Forest Service contracts or in partnership with county operations. Applicators are generally from the 

communities in and around the Forest, and are licensed by the State of Oregon and well-trained in safe 

herbicide application and transportation practices. Licensed applicators are required to take regular 

training in order to maintain their license (ODA 2013).

The Malheur National Forest has several formal agreements for use of drinking water. The Hydrology

section lists municipal watersheds, springs, and well intakes with formal agreements where known 

invasive plant populations exist.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

91

3.2.3 Environmental Consequences

Worker Herbicide Exposure Analysis 

The risk assessments include analysis for both workers and the general public. This section focuses on the 

risks of proposed herbicide application to applicators themselves. Herbicide applicators are more likely 

than the general public to be exposed to herbicides, and may handle undiluted herbicide concentrate 

during mixing and loading. In routine broadcast and spot applications, workers may contact and 

internalize herbicides mainly through exposed skin, but also through the eyes, mouth, nose or lungs.

Worker exposure is influenced by the application rate selected for the herbicide, the number of hours 

worked per day, the acres treated per hour, and variability in human dermal absorption rates.

All herbicides can cause irritation and damage to the skin and eyes if mishandled. Eye or skin irritation 

would likely be the only overt effect because of mishandling these herbicides. These effects can be 

minimized or avoided by prudent industrial hygiene practices during handling. Worker exposure can be 

effectively managed through ordinary prudent practices, limiting the number of hours per day that 

workers are exposed to herbicide, and limiting the application rates and application methods for situations 

that may affect worker health. Herbicide labels indicate the personal protective equipment required for 

applicators.

Appendix Q-Human Health Risk Assessment, of the R6 2005 FEIS, and the 2007 aminopyralid risk 

assessment, summarizes risks for backpack and broadcast spraying at typical and maximum label rates, 

under normal application and maximum exposures. Four potential exposure levels were evaluated, 

ranging from predicted average exposure to unlikely maximum exposures. Risks from 

accidental/incidental exposures are also displayed. Backpack spray exposures assume that workers treat a 

little more than 4 acres per day and broadcast spray exposures assume that workers treat 112 acres per 

day. For both scenarios, it is assumed that the workers do not receive any protection from exposure 

provided by clothing

Accidental worker exposures are most likely to involve splashing a solution of herbicides into the eyes or 

on the skin. Two general types of exposure are modeled: one involving direct contact with a solution of 

the herbicide and another associated with accidental spills of the herbicide concentrate onto the surface of 

the skin. Exposure scenarios involving direct contact with herbicide solutions are characterized by 

immersing unprotected hands for 1 minute or wearing contaminated gloves for 1 hour. Workers are not 

likely to immerse their hands in herbicide; however, the contamination of gloves or other clothing is 

possible.

Exposure scenarios involving chemical spills onto the skin are characterized by a spill onto the lower legs 

as well as a spill onto the hands. In these scenarios, it is assumed that a solution of the chemical is spilled 

onto a given surface area of skin and that a certain amount of the chemical adheres to the skin.

The herbicides proposed for use under all alternatives have little potential to harm workers. In most cases, 

even when maximum rates and exposures were considered, hazard quotient (HQ) values were below the 

threshold of concern (HQ values ranged from 0.01 to 1). However, HQ values are greater than 1 for the 

herbicides chlorsulfuron, sulfometuron methyl, triclopyr and the surfactant called NPE for the following 

scenarios:

1. Broadcast application of chlorsulfuron at maximum rate/exposure

2. Backpack and broadcast application of sulfometuron methyl at maximum rate/exposure

3. Triclopyr 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

92

4. Backpack and broadcast application of NPE surfactant at maximum rate/exposure

Besides the unlikely maximum exposure scenarios described in the risk assessments, operational 

exposures would remain below the threshold of concern for all herbicides proposed for use except for 

triclopyr. The risk assessment found that a low risk of impaired kidney function is associated with 

operational triclopyr exposures. There are differences between the toxicity of the aquatic formulation 

(Garlon 3A®) and the terrestrial formulation (Garlon 4®). The aquatic formulation is less toxic.

Under a backpack (spot) application scenario, using the Garlon 4® formulation of triclopyr, workers 

could be exposed to herbicides at a level above the threshold of concern (HQ is greater than 1). Protective 

procedures to avoid the maximum potential exposure would be particularly important for workers who 

may apply triclopyr repeatedly at typical rates over a period of several weeks or longer. The HQ values 

are as high as 16 for the maximum backpack-applicator exposure scenario, however this type of exposure 

would be implausible because applicators are required to wear long pants, long sleeves, and gloves and 

comply with other personal safety practices and project design features. Accidental exposure to the 

Garlon 4® formulation of triclopyr can also have impacts that are more serious to the eyes. Triclopyr is 

not among the first-choice herbicide in any alternative.

The surfactant NPE is also associated with some human health risks at typical rates. For NPE, the HQ=5 

for maximum plausible backpack applicator exposure scenario. The HQ = 10 for broadcast applications 

including NPE under a maximum exposure scenario. However, pdf F2 limits the amount of NPE that 

would be applied.

In addition, two herbicides, picloram and clopyralid, contain an industrial by-product of the 

manufacturing process that is linked to cancer: hexachlorobenzene (HCB). Picloram contains a higher 

concentration of HCB than does clopyralid. One alternative (D) would use picloram as the first-choice

herbicide for about 63 acres. One operational exposure scenario resulted in HCB exposure above the 

cancer risk threshold: boom broadcast application of picloram at the maximum application rate, treating 

112 acres in one day, and not wearing any protective clothing. Required personal protective equipment 

and pdfs (F group) would make it unlikely for any workers to actually receive the maximum exposure and 

thus, use of this herbicide would not result in measurable cancer risks to workers.

Public Herbicide Exposure Analysis

Under normal conditions, the general public would not be exposed to substantial levels of any herbicides 

used in the implementation of this project. Appendix Q of the R6 2005 FEIS and the aminopyralid risk 

assessment considered both plausible and highly unlikely accidental acute exposures, as well as long term 

chronic exposures to herbicide ingredients, and displays results assuming a human directly contacts 

herbicide, contacts sprayed vegetation, or consumes sprayed vegetation, contaminated water or fish. Few 

plausible scenarios exist that exceed even the most conservative threshold of concern for public health 

and safety. Below the threshold of concern (HQ less than or equal to 1), the risk is extremely low for any 

adverse effects due to the particular exposure scenario.

Direct Contact

There is virtually no chance of the public being directly sprayed given the broadcast, spot, and hand/select 

methods proposed in the action alternatives. A person could brush up against sprayed vegetation soon 

after herbicide is applied. Such contact is unlikely because spraying occurs during the work-week (not on 

weekends), and public exposure would be discouraged during and after herbicide application, through 

notification or signing.

For all herbicides, direct contact with sprayed vegetation would not exceed a level of concern. The risk 

assessments evaluated an accidental scenario where a small naked child is completely covered from a
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

93

direct herbicide spray. Even under this extreme and highly unlikely scenario, none of the proposed 

herbicides exceeded a HQ of 1, indicating a very low risk from direct contact.

Eating Contaminated Berries, Mushrooms or other Subsistence/Traditional Gathering Plant 

Resources

The public could be exposed to herbicide if they eat contaminated berries, mushrooms, or other plants.

Directly sprayed plant materials would likely show signs of either dye (see pdf F6), or herbicide damage, 

reducing the likelihood they would be consumed. However, non-target berries or mushrooms could also 

be contaminated by drift or uptake from the soil, which would result in lower herbicide residues than 

direct spraying. The R6 2005 FEIS and the aminopyralid risk assessment considered both short- term 

acute exposure (eating 1 pound) and chronic 90 day consumption scenarios for eating contaminated 

berries. These scenarios also approximate the effects of eating other contaminated products, such as 

mushrooms (Durkin and Durkin 2005). None of the proposed herbicides would result in a hazard quotient

greater than 1 for either acute or chronic exposures from eating contaminated berries, indicating potential 

consumption of plant materials with herbicide residues poses a low risk.

Hazard quotients greater than 1 were calculated for consumption of NPE surfactant at the highest acute 

exposures. Project design features would limit use of NPE to at or below the typical application rate, 

reducing this risk. Other pdfs to prevent public exposure include closure of recreation sites during 

application, use of dye in spray mixes, public notification, posting of treatment sites, supplying 

information during the special forest products permitting process, and coordination with the Native 

American Tribes.

People who harvest or use special forest products or cultural plants may have multiple exposures as a 

result of handling, chewing, and eating contaminated plant material. Such doses would be additive, but 

are still unlikely to exceed a threshold of concern (see the cumulative effects section that follows).

Drinking Contaminated Water

Acute and long-term exposures from direct contact or consumption of water following herbicide 

application were evaluated in the R6 2005 FEIS and the aminopyralid risk assessment. Risks from 

hypothetical drinking water sources were evaluated for: 1) a stream contaminated with herbicide residues 

by runoff or leaching from an adjacent herbicide application; and 2) drinking water from a pond 

contaminated by runoff or leaching. The risk assessments also evaluated an accidental exposure scenario 

where a small child drinks one liter of contaminated water from a quarter-acre pond where 200 gallons of 

herbicide was spilled.

The only scenario that resulted in HQs greater than 1 was the extreme example of the 200 gallon spill. A 

spill of this magnitude is not plausible and would be avoided by applying the pdfs that limit the amount of 

material allowed to be transported to treatment sites, and required safety measures. The potential risk of 

human health effects from any herbicide spill into drinking water would be avoided or mitigated by 

appropriate spill response identified in the spill response plan, periodic equipment inspections, and 

carrying an emergency response kit in vehicles transporting herbicides.

Drinking water sources would be further protected by pdf H9. Herbicide use would not occur within 100 

feet of wells or 200 feet of spring developments. See chapter 3.5 for information on drinking water 

sources.

Consuming Contaminated Fish 

Both acute and long-term exposure scenarios involving the consumption of contaminated fish were 

evaluated using the herbicide concentrations in the contaminated water scenarios described above. Acute 

exposure was based on the assumption that an angler consumes fish taken from contaminated water 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

94

shortly after an accidental spill into a pond. Chronic exposures were assumed to occur over a lifetime of 

eating contaminated fish. Native American subsistence groups were considered to have higher exposure 

rates than recreational anglers.

Some chemicals may be concentrated from contaminated water into the tissues of fish. This process is 

called bioconcentration. Bioconcentration at first increases with the length of exposure, but eventually 

reaches a constant maximum level. It is measured as the ratio of the concentration in the fish compared to 

the concentration in the water, referred to as the bioconcentration factor (BCF). A BCF less than or equal 

to 1 indicates that fish excrete a chemical faster than, or as fast as, they can absorb it and therefore no 

bioconcentration would occur.

Of the 11 proposed herbicides, three slightly exceed a BCF of 1 (chlorsulfuron has a BCF of 1.5; 

sethoxydim, a BCF of 7; and sulfometuron methyl, a BCF of 7). Hexachlorobenzene has a high BCF of 

2,000, ranging from 2,000 – 20,000. The 2011 risk assessment for picloram (SERA 2011) quantitatively 

assessed chronic risk from HCB using a BCF of 20,000 for consumption of contaminated fish by 

subsistence populations. The HQ for carcinogenicity was 0.4; below the level of concern; however, 

because it occurs at such low levels in picloram (8 parts per million) and clopyralid (less than 2.5 parts 

per million) the risk from bioconcentration is low. Likewise, the HQ for clopyralid is below the level of 

concern (clopyralid has much less HCB than does picloram). 

Bioconcentration was taken into account when determining exposures and resulting dose from eating 

contaminated fish for all herbicides; these results are shown in Appendix Q of the R6 2005 FEIS and the 

Aminopyralid Risk Assessment(SERA 2007).

The risk assessments found little risk from eating contaminated fish, under both the acute and chronic 

scenarios. Hazard quotients were less than or equal to 1 for all chemicals and situations evaluated, 

including a lifetime of subsistence fishing and cancer risk. Chapter 3.5 and 3.6 has more information 

about potential effects water quality and fish.

Multiple Chemical Sensitivity

The following information was adapted from USDA 2012, Gypsy Moth Management in the United Sates, 

a Cooperative Approach. 

Some people feel that they suffer from Multiple Chemical Sensitivity (MCS), which is sometimes 

referred to as Idiopathic Environmental Intolerances (IEI). In general, individuals with MCS report that 

they experience a variety of adverse effects as a result of very low levels of exposure to chemicals 

(including herbicides) that are generally tolerated by individuals who do not have MCS. 

Forest Service risk assessments incorporate an uncertainty factor of 10 to account for sensitive 

individuals, which may or may not eliminate risk that an individual may suffer symptoms. However, the 

uncertainty factor for sensitive individuals addresses variability in tolerances within a normal population. 

Individuals reporting MCS assert, either explicitly or implicitly, that they are atypically sensitive. There is 

no current consensus on the diagnosis and cause of MCS. 

Until the etiology and pathogenesis of MCS has been clarified an organic cause of the MCS, associated 

symptoms and symptom complexes cannot be entirely ruled out. The Forest Service has no way to resolve 

concerns for MCS at the project level.

Endocrine Disruption

The Environmental Protection Agency has recently worked to establish appropriate tests and benchmarks 

for endocrine disruption effects. In 2009, they released a list of pesticides (based on the high potential for 

human exposure) that will be tested for potential to cause endocrine disruption. Glyphosate was the only 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

95

herbicide considered for use on the Malheur National Forest that was included in the initial EPA testing. 

Current status of these studies indicate that some tier-1 studies for glyphosate have been finished, some 

will not be finished until 2014, and some tier-2 studies have been ordered. Results are not yet available. 

Potential effects to endocrine systems from chemicals are most often studied by evaluating toxic effects to 

estrogen, androgen, and thyroid hormone systems and changes in the structure of major endocrine glands 

(adrenal, hypothalamus, pancreas, parathyroid, pituitary, thyroid, ovary, and testis). In addition, the results 

of multigenerational studies can be indicative of potential endocrine disruption. Studies are lacking for 

most herbicides on the potential to bind to estrogen or androgen receptors. To the extent that data is 

available, the Forest Service risk assessments address endocrine effects for the proposed herbicides and 

are summarized here.

There is no evidence of direct effects to the endocrine system, nor reproductive or developmental effects 

from aminopyralid (SERA 2007), chlorsulfuron (SERA 2004a), imazapic (SERA 2004c), imazapyr 

(SERA 2011b), metsulfuron methyl (SERA 2004d), or picloram (SERA 2011c).

One study found that chlorsulfuron produced a slight decrease in fertility index in rats in a 3-generation 

study when rats were fed 125 mg/kg/day, but other studies have not found adverse effects on reproductive 

systems (SERA 2004a).

Clopyralid, sethoxydim, and triclopyr have not been found to cause reproductive effects at doses that do 

not also produce direct maternal toxicity, suggesting a direct toxic effect rather than an effect to the 

endocrine functions (SERA 2001, 2004b, 2011c). 

Additionally, for Imazapyr, EPA states in their review of toxicity data that there was no evidence of 

estrogen, androgen and/or thyroid agonistic or antagonistic activity (US EPA/OPP 2005).

Some studies of sulfometuron methyl reported changes in rat testes, reproductive performance and in 

thyroid function (SERA 2004e). In specific reproductive studies with dietary exposures, there were no 

adverse effects to reproduction found (SERA 2004e).

Endocrine disruption and glyphosate was discussed in the updated Glyphosate Risk Assessment (SERA 

2011a). SERA 2011 stated that “some recent studies raise concern that glyphosate and some glyphosate 

formulations may be able to impact endocrine function through the inhibition of hormone synthesis 

(Richard et al. 2005; Benachour et al.2007a, b), binding to hormone receptors (Gasnier et al. 2009), or the 

alteration of gene expression (Hokanson et al. 2007)” (all references as cited in SERA 2011). Evaluation 

of the studies indicates that endocrine disruption effects were indicated for surfactants in the formulations 

rather than glyphosate itself. “Most of the in vitro studies... assayed both glyphosate as well as 

glyphosate formulations, and most of the studies clearly indicate that the biological activity of glyphosate 

is less than that of glyphosate formulations” (SERA 2011). The studies that raise the most concern were 

from formulations not manufactured in the U.S. Based on the studies using formulations from outside the 

United States, “there is concern that glyphosate formulations may have an impact on these endpoints and 

that some of these effects could be seen under typical application conditions in the United States. In the 

absence of comparable studies on U.S. formulations, however, it is not clear whether the studies on 

glyphosate formulations used outside the United States are applicable to risks posed by U.S. formulations 

of glyphosate” (SERA 2011).

Additionally, there is a lack of specific information on the composition of different surfactants used in 

different formulations of glyphosate, as this information is identified as confidential business information. 

This lack of information limits the hazard identification for some toxic effects (SERA 2011). Given data 

limitations, the current practice of risk assessment is to use very protective exposure and dose scenarios, 

which are used in the 2011 glyphosate risk assessment and this analysis. Until more data on surfactants 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

96

becomes available, it is not clear that assessment relies on “the most toxic surfactant in the most sensitive 

species” for the quantitative analysis (SERA 2011).

On June 14, 2013, EPA released a revised second list of chemicals for screening tests. Picloram and HCB 

are the only chemicals on that list relevant to the proposed herbicide use on the Forest. EPA (2013) notes 

“this list should not be construed as a list of known or likely endocrine disruptors. Nothing in the 

approach for generating the initial list provides a basis to infer that by simply being on this list these 

chemicals are suspected to interfere with the endocrine systems of humans or other species, and it would 

be inappropriate to do so.”

While the potential for the proposed herbicides to cause endocrine disruption effects is a current data gap, 

the potential for these effects are to actually occur are greatly reduced by measures such as required use of 

proper protective equipment, public notification, use of licensed applicators, limiting application rates and 

other relevant pdfs.

One type of surfactant used in several herbicide formulations is NPE. This complex of surfactants was 

analyzed in a risk assessment (Bakke 2003) and the R6 2005 EIS and its Appendix Q. NPE surfactants are 

formed through the combination of ethylene oxide with nonylphenol (NP). Both NP/NPE exhibit 

estrogen-like properties, although they are much weaker (1,000 to 100,000 times weaker) than natural 

estrogen. NP/NPE are used in industrial processing and are present in detergents and personal care 

products (moisturizers, deodorants, perfumes, shampoos, and soaps). Animal studies suggest that acute 

exposures at high levels may cause subclinical effects to the liver or kidneys. The risk analysis for NPE 

found that typical backpack application of herbicide containing NPE surfactant at typical exposures and a 

rate of 1.67 lbs./acre would add 0.1 to the cumulative HQ for these types of chemicals. For the public, 

values ranged between 0.00001 (eating contaminated fish) to 0.2 (consuming a pound of berries at typical 

exposures). These additions may be negligible depending on the background exposures, lifestyles, 

absorption rates, and other chemical exposures of workers and the public.

While data is limited regarding the potential for the proposed herbicides to cause endocrine disruption 

effects, is a current data gap, the potential for these effects are to actually occur are evaluated and 

accounted for by using protective thresholds (or toxicity values). Results of all herbicide risk assessments 

indicate that there is no evidence to suggest that these types of effects will occur from the proposed 

herbicides. Additionally, this project requires certain, greatly reduced by pdfs that reduce exposure, such 

as measures such as required use of proper protective equipment, public notification, use of licensed 

applicators, limiting application rates and other relevant pdfs.

Environmental Justice and Disproportionate Effects

The R6 2005 FEIS noted that some minority groups may be disproportionately exposed to herbicides, 

either because they are disproportionately represented in the pool of likely forest workers, or in the pool 

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

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

herbicide use. On the Malheur National Forest, Asian matsutake mushroom pickers and others who 

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

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

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

sections. Even given plausible inadvertent acute or chronic exposures, minority forest workers, special 

forest product harvesters, and subsistence gatherers are not likely to be exposed to a dose that exceeds a 

threshold of concern. Project design features requiring public and tribal notification, use of dye in spray 

mixes, on-the-ground signing, and other rate restrictions on herbicide and NPE applications would further 

reduce the potential for exposure.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

97

Direct and Indirect Effects of Alternatives

Alternative A – No Action

No invasive plant treatments would be completed under alternative A, so there would be no effects on 

human health from this project.

Alternative B – Proposed Action

Workers and the public may be exposed to the herbicides used to treat invasive plants under this 

alternative. However, no exposures exceeding a threshold of concern are predicted and no effects to 

human health are indicated. Aminopyralid is among the low-risk available herbicides relative to human 

health, so the addition of this herbicide in this alternative does not change the effect conclusions. The risk 

characterization takes into account the quantitative analyses and other information in the risk assessments 

and the implementation of project design features (table 9). Table 27 lists specific pdfs in alternative B 

that address human health concerns.

Table 27. Project design features in alternative b that address human health concerns

Concern Project Design Features to Address Concern

Workers

Limits on the application rates of chlorsulfuron, picloram, sulfometuron 

methyl, and NPE surfactants. 

Aminopyralid is used in lower rates than other herbicides, which reduces 

potential exposure to workers 

Safety Plan, Emergency Spill Response Plan, Emergency Spill Kit, 

Personal Protective Equipment required.

Traffic control and signing as needed.

Public

Limits on the application rates of NPE surfactants. 

Aminopyralid is used in lower rates than other herbicides, which reduces 

potential exposure to the general public 

Public notification 

Treatment areas posted 

Use of blue dye

Recreation sites closed during application 

Safety Plan, Emergency Spill Response Plan and Emergency Spill Kit 

required.

Cultural Use Plants Public measures above plus: Tribal review and coordination to avoid 

herbicide use in cultural plant collecting areas.

Drinking Water

Herbicide-use buffers 

Herbicide use would not occur within 100 feet of wells or 200 feet of 

spring developments.

Safety Plan, Emergency Spill Response Plan, and Emergency Spill Kit 

required.

Alternative C

Workers and the public may be exposed to the herbicides used to treat invasive plants in this alternative.

However, no exposures exceeding a threshold of concern are predicted. This conclusion is based on facts 

about the chemistry of the herbicides considered for use and the mechanisms by which exposures of 

concern might occur. Since there would be less herbicide use overall, there would be less risk of exposure 

associated with alternative C, however the difference in impact on human health would not be measurable 

or meaningful.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

98

Alternative D

Workers and the public may be exposed to the herbicides used to treat invasive plants in this alternative.

The following table compares the use of herbicides under alternatives B and D and shows that less 

broadcasting overall would occur due to the loss of aminopyralid as an option in infested areas that lie 

near streams or other water bodies. However, this would do nothing to mitigate human health risks from 

the proposed action. In addition, about 63 acres would be treated with picloram as a first-choice herbicide. 

Concerns about picloram were discussed in the previous section; the 63 acres of picloram that would be 

the first year/first choice herbicide would not result in meaningful or measurable harm to workers or the

public. About 725 acres of glyphosate would be the first-choice herbicide under alternative D. Some 

people have expressed concerns about overuse of glyphosate in general in Oregon; however the extent of 

use on this project would have no measurable impact on human health. 

Cumulative Effects 

Alternative A would have no cumulative effects on human health. The proposed use of herbicides in all 

action alternatives could result in cumulative doses of the same or different herbicides to workers or the 

general public. Cumulative doses are possible within the context of this project, or when combined with 

herbicide use on adjacent private lands or home use by a worker or member of the general public.

However, the risk is very small that a person would receive additive exposures during the time period in 

which the herbicide remains un-metabolized in their body. These herbicides do not bio-accumulate in 

humans and are rapidly eliminated from the body. Chronic (daily over a period of time) worker exposure 

was considered in SERA Risk Assessments; chronic exposures do not amount to levels of concern 

because the herbicide ingredients are water-soluble and are not retained in the body (they are rapidly 

eliminated).

The SERA Risk Assessments evaluated chronic exposure scenarios that would involve the public, 

including repeated drinking of contaminated water, repeated consumption of contaminated berries, and 

repeated consumption of contaminated fish. The potential for cumulative human health effects from any 

herbicide use proposed in this EIS, combined with other potential herbicide applications in the analysis 

area, is encompassed in the health risks estimated for chronic exposure scenarios. A person could be 

exposed to herbicides by more than one scenario; for instance, a person handling, and then consuming 

sprayed berries. The cumulative impact of such cases may be quantitatively characterized by adding the 

HQs for each exposure scenario. The herbicides together would not bioaccumulate. 

Using glyphosate as an example, the typical levels of exposure for a woman being directly sprayed on the 

lower legs, staying in contact with contaminated vegetation, eating contaminated fruit, and consuming 

contaminated fish leads to a combined (acute) HQ of 0.012. Similarly, for all of the chronic glyphosate 

exposure scenarios, the addition of all possible pathways lead to HQs that are two orders of magnitude 

less than 1, indicating an acceptable level of cumulative risk even with multiple exposure scenarios.

Even if a herbicide with a greater hazard quotient than glyphosate were used, berry harvesting (dermal 

exposure) and the subsequent eating (oral exposure) would allow the body to metabolize some of the 

initial dose before receiving the second dose, thus reducing the cumulative dose. These factors make the 

risk implausible that a combined dose would exceed the threshold of concern. Slight exceedences could 

cause clinically detectable physiologic changes, but are unlikely to produce any human health symptoms 

detectable by a person.

The R6 2005 FEIS considered the potential for synergistic effects of exposure to two or more chemicals:

“Combinations of chemicals in low doses (less than one tenth of RfD) have rarely demonstrated 

synergistic effects. Review of the scientific literature on toxicological effects and toxicological 

interactions of agricultural chemicals indicate that exposure to a mixture of pesticides is more likely to 

lead to additive rather than synergistic effects (ATSDR, 2004; U.S.EPA/ORD, 2000). Based on the limited 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

99

data available on chemical combinations involving the twelve herbicides considered in this EIS, it is 

possible, but unlikely, that synergistic effects could occur as a result of exposure to the herbicides 

considered in this analysis. Synergistic or additive effects, if any, are expected to be insignificant” (R6 

2005 FEIS p. 4-3). Additional information about herbicide use on other land ownerships in Oregon and 

potential for cumulative effects is in chapter 3.1.5. The ongoing and foreseeable projects and activities 

within the project area would not combine with this project and cause cumulative effects of concern to 

human health.

3.3 Botany

3.3.1 Introduction

This section summarizes the findings of a biological evaluation and botany specialist report prepared to 

document potential effects from implementing the proposed alternatives to fungal, lichen, and plant 

species that are federally listed as threatened, endangered, or proposed for federal listing under the 

Endangered Species Act of 1973, as amended, and also to fungal, lichen, and plant species identified as 

sensitive on the regional forester’s special status species list (USDA Forest Service 2011). These species 

are collectively referred to as sensitive plants. This section also addresses effects on plants that are 

culturally significant to local Native American tribes, special forest products (non-timber forest products), 

and plant pollinators. These are often referred to as species of concern. Effects on common non-target 

plants are also discussed.

Endangered Species Act (Federally Listed Species)

No documented populations or potential habitat exists on the Malheur National Forest for any fungal, 

lichen, or plant species federally listed or proposed for listing under the Endangered Species Act. Hence, 

consultation with the U.S. Fish and Wildlife Service is not necessary.

Forest Service Designated Sensitive Species

This analysis addresses plant species designated as sensitive on the Pacific Northwest Region 6 Regional 

Forester's Special Status Species List (USDA Forest Service 2011). The list includes vascular plants, 

nonvascular plants (mosses and liverworts), lichens, and fungi. They are referred to here as “sensitive 

plants.” There are currently 88 species of sensitive plants documented, or suspected to occur, on the 

Malheur National Forest. All federally proposed, listed endangered or listed threatened plant species (as 

defined by the Endangered Species act of 1973) are included on this list. Effects analysis determinations 

follow definitions as outlined in Forest Service Manual 2672.42.

Although there is a small chance of negative impacts to sensitive plant species from activities proposed in 

any of the action alternatives (MIIH), the potential of negative impacts is relatively small. The areas that 

would be treated are a small percentage of the known populations and potential habitat for sensitive plants 

species. Therefore, although the project may impact individuals and habitats for sensitive plants, 

implementation of any alternative would not result in a trend toward federal listing of any sensitive plant. 

The selection of any action alternative would not lead to a reduction in the long-term viability of any 

sensitive plant species on the Malheur National Forest.

Regulatory Framework and Compliance

All alternatives would allow for the continued viability of native vegetation, sensitive plants, special 

forest products and pollinators on the Malheur National Forest. All alternatives comply with the Malheur 

National Forest Land and Resource Management Plan.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

100

3.3.2 Affected Environment

Native Vegetation

The Malheur National Forest located in east central Oregon contains a wide diversity of plant species and 

communities due to varying elevation and precipitation zones that occur within eastern Oregon. 

Elevations on the Forest vary from 3,900 feet (at the Forest boundary south of Mt. Vernon, Oregon) to 

9,038 feet on Strawberry Mountain. The result is a diverse and productive landscape of grasslands, sage, 

and juniper; as well as forests of pine, fir, and other tree species, and mountain lakes and meadows. 

Given this combination of physiography and climate, habitats are highly variable and retain a legacy of 

botanical diversity. 

Since the time of the first movement of people into the area and the associated establishment and spread 

of invasive weeds along vectors (highways, railroads, canoes, rafts, and other transportation methods),

invasive plants have altered habitats and vegetation types across the landscape. For example, many areas 

within the forest have become permanently altered by annual grasses, which have become naturalized. In 

certain instances this permanent alteration of habitat has affected native vegetation (Olson 1999). Eastside 

forests are more susceptible to invasive plants than other forests in the region (R6 2005 FEIS), because 

their grasslands, riparian areas, and relatively dry, open forests (with frequent gaps in the plant cover), 

favor invasive plant establishment (R5 FEIS 2005). The moist forests and high montane areas have 

relatively closed plant cover or have extreme climate or soils, which are tolerated by fewer invasive plant 

species. Invasive plants tend to colonize disturbed ground along and around developments such as roads, 

highways, utility (powerline) corridors, recreational residences, trails, campgrounds and quarries. These 

are all places where native vegetation has been removed and disturbance has created areas for invasive 

plants to establish. The susceptibility of plant communities to invasion can also be influenced by 

community structure, and the biological traits of the invader species.

Plant communities can be classified by a variety of factors such as vegetation structure, site moisture, 

overstory, and understory. The 2005 FEIS used broad potential vegetation groups (PVGs) to rate the 

susceptibility of vegetation to invasive plant establishment. Table 28 lists potential vegetation groups 

(PVG) found on the Malheur National Forest, their susceptibility to damage from invasive plants, the 

local plant community types that correspond to these broad PVG types, and mapped acres of invasive 

plants within the plant community types. The groups are aggregations of plant associations and represent 

a combination of temperature and moisture regimes for this Forest. Overall, most plant community types 

found on the Malheur National Forest are moderately to highly susceptible to invasion.

Table 28. Potential Vegetation Groups on the Malheur National Forest’s 1.7 million acres and their 

susceptibility to invasive plants

Potential Vegetation Group Percent of Forest Susceptibility to 

Invasion1 Infested acres (all species)2

Cold forest 2 Moderate 5

Cold herbland 0.1 Moderate 0.1

Cold shrubland 0.2 Moderate 0.3

Cool-cold riparian forest 0.000007 Moderate-high 0

Cool-cold riparian herbland 0.0002 Moderate-high 0.06

Dry Douglas-fir forest 16 Moderate-high 290

Dry grand-fir forest 24 Moderate-high 503

Dry ponderosa pine forest 21 Moderate-high 457

Hot-dry pine forest 10 Moderate-high 136

Dry herbland 2 High 29
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

101

Potential Vegetation Group Percent of Forest Susceptibility to 

Invasion1 Infested acres (all species)2

Dry shrubland 6 High 43

Juniper woodland 3 Moderate-high 28

Moist forest 13 Moderate-high 456

Moist herbland 0.55 Moderate-high 18

Moist shrubland 0.8 Moderate 29

Warm-hot riparian herbland 1 High 74

Warm-hot riparian forest 0.00003 Moderate-high 0.3

Warm-hot riparian shrubland 0.0009 High 26

Whitebark pine forest 0.4 Moderate-high 0.4

Total 100.0

1 Susceptibility ratings (derived from R6 2005 FEIS): High = high susceptibility to invasion. Invasive plant species invade the cover 

type successfully and becomes dominant or co-dominant even in the absence of intense or frequent disturbance; Moderate = 

moderate susceptibility to invasion. Invasive plant species 

is a “colonizer” that invades the cover type successfully following high intensity or frequent disturbance that impacts the soil surface 

or removes the normal canopy; Low = low susceptibility to invasion. Invasive weed species does not establish because the cover 

type does not provide suitable habitat.

2 Some mapping error due to overlap in species occurrences in duplicate potential vegetation groups in GIS database

Sensitive Plants

The following sources of information were used to determine which sensitive plant species, and their 

respective habitats, may occur within the project area.

♦ The Regional Forester’s Sensitive Species List (USDA Forest Service 2011)18

♦ The Forest Service’s Natural Resource Manager Database (NRM) – Threatened, endangered, and 

sensitive species geographic information system (GIS) database, and other pertinent GIS mapping 

layers (potential natural vegetation, streams and wetlands, aerial imagery).

♦ Project GIS layer showing proposed treatment areas.

Table 29. Sensitive plant populations within 100 feet of proposed invasive treatment areas

5th Field Watershed Sensitive Plant Species Invasive Species Distance Between 

Species

Bridge Creek -

1707020301

Blandow’s feather moss

(Helodium blandowii)

Hound’s tongue

(Cynoglossum officinale) 30 feet – 1 site

Fields Creek

John Day River -

1707020110

Colonial luina

(Luina serpentina)

Dalmatian toadflax

(Linaria dalmatica) 57 feet – 1 site

Spotted knapweed

(Centaurea stoebe ssp. 

micranthos)

51 feet – 1 site

Headwaters Silvies 

River - 1712000201

Crenulate moonwort

(Botrychium crenulatum)

Canada thistle

(Cirsium arvense) 54 feet – 1 site

Upper Silvies River -

1712000203 Idaho sedge

(Carex idahoa)

Canada thistle

(Cirsium arvense) 0 feet – 1 site

Hound’s tongue 0 feet – 1 site

 18 Forest Service Manual 2670.5 defines sensitive species as those plant and animal species identified by a Regional 

Forester for which population viability is a concern, as evidenced by significant current or predicted downward 

trends in population numbers, density, or habitat capability that would reduce a species existing distribution.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

102

5th Field Watershed Sensitive Plant Species Invasive Species Distance Between 

Species

(Cynoglossum officinale)

Deschutes milk vetch

(Astragalus tegetarioides)

Dalmatian toadflax

(Linaria dalmatica) 0 feet – 3 sites

Middle Silvies River

- 1712000204

Deschutes milk vetch

(Astragalus tegetarioides)

Spotted knapweed

(Centaurea stoebe ssp. 

micranthos)

0 feet – 1 site

White-top

(Cardaria draba) 79 feet – 1 site

Emigrant Creek -

1712000205

Peck’s long-bearded sego 

lily (Calochortus 

longebarbatus var. peckii)

Yellow toadflax or 

Butter-and-eggs

(Linaria vulgaris)

0 feet-3 sites

North Basin -

1712000101

Deschutes milk vetch

(Astragalus tegetarioides)

Dalmation toadflax

(Linaria dalmatica) 0 feet – 1 site

Table 30 that follows lists all Region 6 sensitive plant species that are documented or suspected to occur 

on the Malheur National Forest.

Table 30. Sensitive plant species documented (D), suspected (S), or having a historical record (H) on the 

Malheur National Forest

Malheur National Forest Sensitive Plant Species

Taxa 

Type Scientific Name Common Name

Occurrence 

on the 

Forest1

Fungus Pseudorhizina californica umbrella false morel S

Lichen Texosporium sancti-jacobi woven spore lichen S

Liverwort Anastrophyllum minutum tiny notchwort S

Liverwort Anthelia julacea alpine silverwort S

Liverwort Barbilophozia lycopodioides giant fourpoint, maple liverwort, greater 

pawwort S

Liverwort Harpanthus flotovianus great mountain flapwort S

Liverwort Jungermannia polaris Arctic flapwort S

Liverwort Lophozia gillmanii Gillman's pawwort S

Liverwort Peltolepis quadrata shieldscale liverwort S

Liverwort Preissia quadrata blister ribbon, narrow mushroomheaded liverwort D

Liverwort Ptilidium pulcherrimum lovely fuzzwort, naugahyde liverwort S

Moss Encalypta brevipes candle snuffer moss, stubby 

extinguisher moss S

Moss Entosthodon fascicularis banded cord-moss, Hasselquist's 

hyssop

S

Moss Helodium blandowii Blandow's feather moss, wet plume 

moss

D

Moss Meesia uliginosa Meesia moss D

Moss Pseudocalliergon trifarium blunt water moss, worm moss S

Moss Schistidium cinclidodonteum schistidium moss S
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

103

Malheur National Forest Sensitive Plant Species

Taxa 

Type Scientific Name Common Name

Occurrence 

on the 

Forest1

Moss Schistostega pennata schistostega moss S

Moss Splachnum ampullaceum purple-vased stink moss, small capsule 

dung moss S

Moss Tetraphis geniculata tetraphis moss S

Moss Tomentypnum nitens tomentypnum moss D

Moss Tortula mucronifolia mucron-leaf tortula moss S

Vascular Achnatherum hendersonii Henderson's ricegrass S

Vascular Achnetherum wallowaense Wallowa ricegrass S

Vascular Artemisia arbuscula ssp. longicaulis Lahontan sagebrush S

Vascular Astragalus tegetarioides Deschutes milkvetch, bastard milkvetch D

Vascular Botrychium ascendens upward-lobed moonwort D

Vascular Botrychium crenulatum crenulate moonwort D

Vascular Botrychium hesperium western moonwort S

Vascular Botrychium lineare slender moonwort S

Vascular Botrychium lunaria common moonwort D

Vascular Botrychium montanum mountain moonwort D

Vascular Botrychium paradoxum twin-spiked moonwort S

Vascular Botrychium pedunculosum stalked moonwort S

Vascular Bupleurum americanum American thorough-wax S

Vascular Calochortus longebarbatus var. 

longebarbatus long-bearded sego-lily S

Vascular Calochortus longebarbatus var. peckii Peck's long-bearded sego-lily D

Vascular Camissonia pygmaea dwarf evening-primrose S

Vascular Carex atrosquama blackened or brass-fruit sedge S

Vascular Carex cordillerana cordilleran sedge D

Vascular Carex diandra lesser panicled sedge S

Vascular Carex idahoa Idaho sedge D

Vascular Carex lasiocarpa var. americana slender wooly sedge S

Vascular Carex media Scandinavian sedge S

Vascular Carex micropoda timberline sedge S

Vascular Carex nardina spikenard sedge S

Vascular Carex pelocarpa dusky-seed or new sedge S

Vascular Carex retrorsa retrorse sedge S

Vascular Carex saxatilis russet sedge S

Vascular Carex scirpoidea ssp. stenochlaena Alaska single-spiked sedge D

Vascular Carex subnigricans nearly black or dark alpine sedge S

Vascular Carex vernacula native sedge S

Vascular Chaenactis xantiana desert chaenactis S

Vascular Cheilanthes feei Fee's lip fern S

Vascular Cistanthe rosea rosy pussypaws H

Vascular Cryptogramma stelleri Steller's rock-brake S
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

104

Malheur National Forest Sensitive Plant Species

Taxa 

Type Scientific Name Common Name

Occurrence 

on the 

Forest1

Vascular Cymopterus nivalis snowline cymopterus D

Vascular Cypripedium fasciculatum clustered lady's-slipper S

Vascular Elatine brachysperma short-seeded waterwort S

Vascular Eleocharis bolanderi Bolander's spike-rush D

Vascular Eriogonum cusikii Cusick's buckwheat S

Vascular Eriogonum salicornioides playa or saltwort buckwheat S

Vascular Heliotropium curassavicum salt heliotrope S

Vascular Kobresia myosuroides Bellard's kobresia S

Vascular Listera borealis northern twayblade D

Vascular Lomatium erythrocarpum red-fruited desert-parsley S

Vascular Luina serpentina colonial luina D

Vascular Lupinus cusickii var. cusickii Cusick's lupine S

Vascular Lycopodium complanatum ground-cedar S

Vascular Mimulus evanescens disappearing monkey-flower S

Vascular Muhlenbergia minutissima annual or little-seed muhly grass S

Vascular Ophioglossum pusillum adder's-tongue S

Vascular Pellaea bridgesii Bridge's cliff-brake S

Vascular Phacelia minutissima least or dwarf phacelia D

Vascular Phlox hendersonii Henderson's phlox S

Vascular Phlox multiflora many-flowered phlox S

Vascular Pinus albicaulis whitebark pine D

Vascular Pleuropogon oregonus Oregon semaphore grass S

Vascular Potamogeton diversifolius diverse-leaved pondweed S

Vascular Rotala ramosior lowland toothcup S

Vascular Salix farriae Farr's willow S

Vascular Salix wolfii Wolf's willow S

Vascular Saxifraga adscendens ssp. oregonensis wedge-leaved saxifrage S

Vascular Stanleya confertiflora biennial stanleya S

Vascular Thelypodium eucosmum arrow-leaf thelypody D

Vascular Trifolium douglasii Douglas' clover S

Vascular Trollius laxus ssp. albiflorus American globeflower S

Vascular Utricularia minor lesser bladderwort S

Botanical Surveys

Sensitive plant botany surveys have not been completed in most of the areas proposed for invasive species 

treatments. These areas were inventoried for the invasive species, but not for sensitive species. Some 

selected locations targeted for treatment did receive sensitive plant surveys in 2013. No overlap between 

sensitive plant populations and invasive plant populations were found during these surveys (NRM 

database 2013).

Project design features stipulate that site-specific surveys for sensitive plants will be conducted prior to 

project implementation. In areas with high potential for sensitive plant species habitat, a Forest Service 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

105

botanist or otherwise qualified person will examine all areas of potential ground disturbance or herbicide 

application at the appropriate time of the year to identify targeted sensitive plant species before 

implementation.

Culturally Significant Plants

Traditional cultural plants such as bitterroot (Lewisia rediviva), biscuitroot (Lomatium spp.), camas 

(Camassia quamash), chokecherry (Prunus emarginata), and huckleberry (Vaccinium membranaceum)

are found in the project area. These and other culturally important plants are collected and used by Native 

American tribal members and the general public as food, medicine, or in ceremonial activities. These 

species occur in various habitats across the Malheur National Forest. Specific locations where these 

species occur are not mapped or tracked by the Forest. No permits are required to collect these species for 

personal use.

Special Forest Products

Special forest products include all non-timber products that require a permit for commercial or personal 

use collecting. This includes firewood, posts and poles, Christmas trees, pine cones, burls, mushrooms, 

and commercial collecting of medicinal or food plants. Also included are permits for collection of seeds, 

cuttings, or whole plants for propagation or landscaping. Decorative rocks and landscaping rocks are also

collected under permit. Permits are not required for small quantities of mushrooms (less than one gallon 

per day), huckleberries, and other roots and fruits. The most common special forest product collected in 

the Malheur National Forest is firewood, followed by posts and poles. Mushroom permits are generally 

sold in quantity after wild fires, when morel mushrooms are in abundance. These activities may occur in 

the same general vicinity where invasive species treatments may be implemented. Specific locations 

where these species occur are not mapped or tracked by the Malheur National Forest.

Pollinators

A reduction or shift in pollinator species could lead to changes in plant species composition or diversity 

(USDA Forest Service 2005a, 4-27). Native pollinators have co-evolved with the plants they visit, such 

that their physiology is matched to most efficiently exploit the nectar and pollen resources of the flowers 

upon which they specialize. It is highly likely that reduced species diversity from invasive plants has 

indirect negative effects on pollinators.

Many invasive plants are early successional species, meaning they colonize areas that have been recently 

disturbed. Since invasive plants have the ability to deplete available resources to lower levels than native 

vegetation can tolerate, they can quickly dominate disturbed sites and displace native vegetation. When 

invasive plants dominate native plant communities, native plant species diversity is decreased. The North 

American Pollinator Protection Campaign (2006) determined that invasive plants, left untreated, shift 

species composition and affect pollinated plants by disrupting the structure and function of ecosystems.

Colony Collapse Disorder

Pesticides are one of several factors thought to possibly contribute to catastrophic losses of honey bees,

known as “colony collapse disorder” or CCD, reported since 2006. Thus, a discussion of the possible 

connection of herbicide use proposed for the action alternatives and CCD is warranted.

The European honey bee (Apis mellifera) is not native to the American continents, but was introduced by 

European settlers in the 1600s. It is widely distributed and commercially produced in the U.S. with 

escaped feral colonies formerly present across most of the country (parasitic mites have destroyed most of 

the feral honey bees across the United States (CCD Steering Committee 2007)). The honey bee is used to 

pollinate agricultural crops and produce honey. The honey bee adds about $15 billion in value to 

agricultural crops each year (Morse and Calderone 2000). 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

106

In 2006-2007, commercial honey bees in North America, and other parts of the world, experienced 

alarming declines characterized by the disappearance of adult bees from the hives with no or few dead 

bees near the hive; healthy, capped brood; food reserves that have not been robbed; minimal evidence of 

wax moth or hive beetle damage; and a laying queen with immature bees and newly emerged attendants 

(CCD Steering Committee 2007, Winfree et al. 2007). This phenomenon has been termed “colony 

collapse disorder.” By 2007, almost 30 percent of beekeepers in the U.S. reported losses of up to 90 

percent of their colonies (Cox-Foster et al. 2007; Winfree et al. 2007). CCD has not been reported in wild 

native bees (Winfree et al. 2007).

Suspected causes of CCD include the following factors, alone or in combination: 1) environmental and 

nutritional stress; 2) new and /or re-emerging pathogens; 3) pests that attack bees; and 4) pesticides (CCD

Steering Committee 2007). Several major setbacks to honey bee populations over the last two decades 

have combined to increase stress on the remaining hives, as they are moved and worked for their 

pollination services over longer seasons and larger geographic areas. Climate change, drought, and 

unseasonably cold weather combine to create increased stress on bee populations. Commercial bees are 

often fed high fructose corn syrup, which may contribute to some nutritional deficiencies. Nutritional 

deficiencies are thought to make the bees more susceptible to attack from pathogen and anecdotal 

evidence indicates that hives that are fed nutritional supplements over the winter are more resistant to 

CCD (Anonymous 2009).

Pathogens are primary suspect because CCD is transmissible to other hives through the reuse of 

equipment from CCD-affected colonies, and such transmission can be broken by irradiation of the 

equipment before use (Pettis et al. 2007). A recent paper using current gene technology has indicated that 

Israeli acute paralysis virus is strongly correlated with CCD and is a current leading candidate for its 

cause, alone or in combination with other factors (Cox-Foster et al. 2007, Kaplan 2008). Another recent 

paper implicates an infection from the parasite Nosema ceranae, but losses from CCD in hives treated for 

this parasite may differ between European and American hives (Higes et al. 2009, Goodman 2009).

Pests including the varroa mite, small hive beetle, wax moth, and others stress bees and may harbor 

infectious agents. In particular, the varroa mite has been responsible for catastrophic losses of 50 to 100 

percent in many beekeeping operations and has eliminated most feral bee colonies. In addition, the varroa 

mite is known to carry pathogens transmitted to bees and is thought to suppress the immunity of honey 

bees (Shen et al. 2005). 

Pesticide exposure may affect bees through direct toxicity or by adding additional stress. Beekeepers treat 

hives with miticides and fungicides and bees may be exposed to pesticides while foraging on agricultural 

crops. Currently, the classes of pesticides thought to be the most likely contributors to, and being 

researched for correlation with, CCD include insecticides, miticides, and fungicides (CCD Steering 

Committee 2007). Recent research has found higher-than-expected levels of miticides and traces of a 

wide variety of agricultural chemicals in bee hives, but no consistent pattern in levels or types of 

chemicals identified (Kaplan 2008). 

3.3.3 Environmental Consequences

Methodology

There is no potential habitat on the Malheur National Forest for any federally listed or proposed plant 

species. All alternatives for this project comply with Forest Plan standards and guidelines and Forest 

Service direction for management of sensitive plants and special forest products. Therefore, there is no 

effect from any of the alternatives to federally listed threatened, endangered, or plants proposed for 

federal listing. Hence, consultation with the U.S. Fish and Wildlife Service is not necessary for federally 

listed or proposed plants.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

107

The four possible effect calls for sensitive plants are outlined in Forest Service Manual 2670. These 

definitions were used to guide the determination of effects:

§ NI - Species that occur in habitats which are not expected to be directly or indirectly affected in any 

way, are given a “No Impact” determination.

§ BI - Species and their potential habitats that could be favorably affected by a particular alternative 

are given a determination of “Beneficial Impact”.

§ MIIH - Species and potential habitat that could possibly be negatively affected are given a 

determination of “May impact individuals or habitat, but will not likely contribute to a trend 

towards federal listing or cause a loss of viability to the population or species”. This call is used in 

cases where there is unsurveyed potential habitat, or where potential impacts are uncertain, or 

considered to be relatively minor.

This acknowledges that the action could have negative impacts, but due to (1) the complexity of the 

proposed action, (2) the differential impacts across the landscape and (3) the lack of best available 

science, the degree and consequence of the negative impacts are not known with certainty.

Additionally, this recognizes that even the most substantial impacts of the proposed action will not 

contribute to a trend toward listing the species under the Endangered Species Act. The effects are 

expected to be minor enough that they will not cause a loss of viability of the species in the 

planning area.

§ WIFV - Species and habitat that will most likely be negatively affected by the project, a 

determination of “Will impact individuals or habitat with a consequence that the action may 

contribute to a trend towards federal listing, or cause a loss of viability to the population or 

species”. This call is used in cases where negative impacts will clearly occur, and they are of a 

magnitude that they may cross a threshold leading to Federal Listing under the Endangered Species 

Act.

Since all of the action alternatives include similar activities and project design features, the analysis will 

focus primarily on a general discussion of potential effects. Then the individual alternatives will be 

compared in relation to the amount of area, and various herbicides proposed for treatment under each 

alternative.

Incomplete and Unavailable Information

Invasive plant sites and known populations of sensitive plant species on the Malheur National Forest have 

typically been mapped with an accuracy of 100 feet, or better. Small mapping errors may mean that sites 

on the ground are actually further apart or closer together than displayed in GIS. Additionally, invasive 

species and sensitive plant populations may expand or contract over time. Confirmation of the exact 

location of known sensitive plant sites will occur during planning, treatment, and monitoring of sites.

The only sensitive fungus currently suspected on the Malheur National Forest is the umbrella false-morel 

(Pseudorhizina californica). Fungi only fruit under very specific moisture and temperature conditions.

Therefore, it is very difficult to locate species of fungi because of their ephemeral nature. It is very 

possible that there are undocumented populations of the umbrella false-morel on the Forest.

Some sensitive plant species don’t produce above-ground plants every year. These plants include some 

grape-ferns (Botrychium spp.), and many annual species which are dependent upon sufficient early spring 

rains, Some of the annual sensitive species include least phacelia (Phacelia minutissima), disappearing 

monkeyflower (Mimulus evanescens), dwarf evening-primrose (Camissonia pygmaea) annual muhly 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

108

grass (Muhlenbergia minutissima), lowland tooth-cup (Rotala ramosior), and desert chaenactis 

(Chaenactis xantiana).

Some species, such as the least phacelia, annual muhly grass, and grapeferns, are so tiny and difficult to 

find in dense vegetation that even expert botanists may overlook them during surveys. Many of the nonvascular plants are very difficult to identify; it is possible that botanists may also overlook some of these 

species. For these reasons, it is not possible to state with 100 percent certainty that all sensitive plant 

species will be detected during sensitive plant surveys.

Information about the effects of the proposed herbicides on lichens, bryophytes, and fungi is generally 

lacking. Data on the susceptibility of different nontarget plant species and families to particular herbicides 

is conducted with agricultural crop species and not those that may better represent nontarget plants in the 

natural environment.

Spatial and Temporal Context for Effects Analysis

The spatial context for this analysis is the entire area managed by the Malheur National Forest. This scale 

is large enough to identify trends to botanical species of conservation concern that could result from 

implementing this project. The temporal context for effects analysis includes short-term and long-term 

effects. Short-term effects for this analysis are considered to be 1 to 2 years after treatment. Long-term 

effects for this analysis are considered to be longer than 2 years. 

Effects to Sensitive Plants Common to All Action Alternatives

All of the action alternatives allow the use of manual, cultural, and mechanical control of invasive 

species. In addition, all action alternatives allow various amounts of herbicide treatment. Project design 

features for sensitive plants are the same for all action alternatives. The potential direct and indirect 

effects discussed below therefore apply to all alternatives.

Unless otherwise cited, information in this section incorporates by reference analysis discussed in Section 

4.3 and Appendix J of the R6 2005 FEIS (USDA Forest Service 2005a).

All invasive plant treatments are designed to kill or prevent growth and reproduction of target plants.

During treatment implementation, direct effects to adjacent non-target plant species may also occur. In 

most cases, impacts to non-target plants would be minor, and would occur in the immediate vicinity of the 

treated site. To help minimize effects to sensitive plant species, surveys will be conducted in potential 

habitat for sensitive plants before treatments. Monitoring and adaptive management are also important 

components of all alternatives that will allow for improving project implementation as more information 

is collected. In addition, project design features would help to reduce the risk of impacts to sensitive plant 

populations and habitats.

A beneficial indirect effect of proposed treatments is that non-target plants would increase growth and 

abundance as competition from invasive plants is reduced. This would result in restoration of native plant 

communities as invasive species are controlled or eliminated. Overall, the short-term negative effects of 

treatments are expected to be less than the long-term indirect benefits of removing invasive plants.

Manual and Mechanical Control Effects

All alternatives include manual and mechanical control. Manual control includes hand pulling, grubbing 

with tools such as a shovel or hoe, and removing and bagging seed heads. Mechanical control includes the 

use of equipment such as mowers or string trimmers.

Control of invasive plants using manual or mechanical methods may potentially directly affect non-target 

plants. Direct negative effects may include mortality of individuals, reduced vigor due to trampling or 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

109

removal of above ground parts, and reduced seed production. These effects would be minor with manual 

control and mechanical control using string trimmers. There would be less ability to target individual 

plants with mowing, resulting in greater risk of potential negative effects to non-target plants in the 

treated area.

The project design feature Group I are designed to ensure that botanical surveys occur when warranted

before project implementation , which will greatly reduce the possibility of these activities negatively 

impacting sensitive plants. Additional protection will be provided by the pdf that provides for buffers of 

known sensitive plant sites (table 9).

Indirect effects of manual and mechanical methods include soil disturbance and reduced plant cover and 

shading. Depending on the magnitude of the disturbance, indirect effects may also reduce soil

productivity, change the capacity of the soil to hold moisture, and lead to disruption of mycorrhizal and 

bacterial soil activities and increases in soil surface temperatures. These changes may promote 

germination of invasive plant seeds in the seed bank, or provide sites for additional invasive species to 

become established. Because manual controls would be used primarily on small or low-density 

infestations of non-rhizomatous species, and mechanical control would be used on selected sites in 

combination with other methods, these negative effects are likely to be minor. Over time, with repeated

treatments, reduction of invasive species through manual and mechanical control would likely provide 

space for increased germination and growth of native plant species.

Cultural Control Effects

Cultural control techniques proposed in the action alternatives include mulching, seeding, planting, and 

solarization (covering areas with black plastic). Direct and indirect effects from these activities are similar 

to manual and mechanical control effects and are not likely to substantially impact sensitive plants (see 

R6 2005 FEIS Appendix J). 

Effects of Biological Control Agents

Biological control agents would be authorized under all action alternatives. Most of the agents available 

for control of invasive species have previously been released in or near the project area, so many are 

already present on the Forest. Under alternative A-no action, biological control agents will not be 

deliberately released. 

The analyses of the environmental effects of biological control agents have been completed under 

documents developed by Agricultural Plant Health and Insect Service (APHIS) for approval of their use. 

The completed environmental impact statements are available at: 

http://www.aphis.usda.gov/ppq/enviro_docs/index.html.

Even though control agents are reviewed and approved by APHIS prior to release in this country, there is 

a slight risk that an approved agent may unintentionally affect native plants or animals. There also 

remains the possibility that regardless of what the Forest Service does, unapproved agents or agents 

known to affect non-target plants could spread from neighboring lands onto National Forest System lands.

Herbicide Control Effects

Under alternative A-no action, herbicide use will no longer be authorized on the portions of the Ochoco 

National Forest administered by the Malheur National Forest, but may occur along State road rights-ofway and easements as a part of ongoing actions.

All action alternatives include some herbicide control. The action alternatives allow various chemicals 

and levels of chemical use across the Malheur National Forest. The potential for negative effects from 

herbicide use increases directly in relation to how many acres are treated, and the toxicity of various 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

110

chemicals. Effects on non-target plants would vary based on the herbicide properties, application rate, 

timing of application, application method, site conditions, and the susceptibility of the non-target plants. 

Use of non-selective herbicides with residual soil activity and relatively high risk for offsite effects could 

result in the most damage to non-target plant species. Use of selective herbicides could shift the 

composition of the plant community, as less tolerant species are replaced by more tolerant species. At 

many herbicide-treated sites, selective herbicides would result in greater impacts to native broad-leaved 

forbs than trees, shrubs, or grasses. 

Forest roads facilitate the spread of invasive plants; they have a substantial effect on the establishment 

and subsequent invasion by providing prime habitat for colonization and serving as corridors for spread.

Additionally, other management activities that create soil disturbance are also closely associated with 

roads. For example, landings, staging areas, and livestock handling facilities, are almost always adjacent 

to roads.

In contrast, most sensitive plant sites are not adjacent to roads. Sensitive plants generally require specific 

microsites that are generally not in disturbed habitats. Most of the sensitive plant habitat within the 

treatment areas is currently not infested with invasive plants. The fact that there are only eight known 

populations of sensitive plants within 100 feet of proposed treatment areas illustrates this point. It is 

possible that there are additional undiscovered populations of sensitive plants in areas that may be treated 

during the life of this project. The median distance of mapped invasive plant sites to a road is 4 feet and 

more than 65 percent of known invasive plant sites are within 25 feet of a road center.

Project design features that restrict herbicide application rates, and require pre-treatment assessments to 

confirm sensitive species populations, as well as surveys of high potential sensitive plant habitats, and 

required monitoring would reduce the chances of inadvertent spraying of sensitive plant populations. 

Additional protection will be provided by project design features that monitor and can change herbicideuse buffers of known sensitive plant sites. 

Offsite Movement of Herbicides

Although potential for offsite movement varies among herbicides and their application rate, the amounts 

transported offsite are likely to be quite small. Some plant species are so highly sensitive to certain 

herbicides that they may be affected by exposure concentrations 100 to 5,000 times less than the typical 

application rate. The toxicity of herbicides to terrestrial plants is determined by studies of seed 

emergence, seed germination, and post-emergence applications, using crop and forage plants. 

The probability of non-target plants being affected by soil blown from treated sites is low for all 

herbicides, despite the risks described in the previous paragraph. Potential for wind erosion in the project 

area is highest on traveled road surfaces and in large burned areas immediately after a fire. Invasive plants 

generally do not occur on active road surfaces. While invasive plants do invade burned areas, infestations 

generally arise over a 10-year period, and are not treated the same season as the fire. None of the known 

treatment sites is considered to have high risk of wind erosion.

Drift could potentially affect non-target plants adjacent to treatment sites; the risk would be greatest 

during use of picloram and the sulfonylurea herbicides. Offsite drift is a physical process dependent on 

application rate, droplet size, and weather conditions. To reduce drift, herbicide labels have advisories for 

wind velocity and nozzle pressure/droplet size. The presence of intercepting vegetation at application sites 

can also limit drift. Drift is most associated with broadcast, rather than spot applications. Marrs et al. 

(1989) examined the distances that drift from broadcast applications affected non-target vascular plants 

and found observations consistent with drift deposition models. The maximum safe distance at which no 

lethal effects were found was 20 feet, but for most herbicides, the distance was 7 feet or less. Generally, 

damage symptoms were found at greater distances than lethal effects, but in most cases, there was rapid 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

111

recovery by the end of the growing season. No effects were seen to non-target vascular plants further than 

66 feet from the broadcast treatment zone. Damage to non-target plants outside of treated areas from drift 

has not been observed at sites on the Forest spot treated with glyphosate or picloram in the past.

Project design feature I -4 (table 9) restricts use of herbicides to no closer than 100 feet from known 

sensitive plant populations, so would greatly reduce the chance of negative impacts from herbicide drift.

Runoff could potentially impact germinating seedlings of non-target plants down slope of treatment sites.

GLEAMS modeling indicate damage from runoff is most likely to occur under conditions where 

picloram, imazapyr, or sulfonylurea herbicides are applied to sites with clay soils right before a 

thunderstorm. The risk on other soil types is low.

Unintended Direct Spray

Unintended direct spray would result in an exposure level equivalent to the application rate, and is much 

more likely than wind erosion, drift, or runoff to cause impacts to non-target plants. The potential for 

damage to non-target plants would be greater during broadcast spraying than during spot spraying or 

wicking, which are much more selective application methods and generally apply less herbicide per acre.

Broadcast applications would be used on dense patches of invasive plants that have few interspersed 

native species; therefore, it is unlikely that substantial impacts to desirable plants would occur. Spot

spraying or wicking could damage plants growing immediately adjacent to or among target invasive 

plants. Monitoring of past spot applications on other forests has found these techniques to be highly 

accurate, with most of the visible damage to non-target plants occurring within less than 10 feet of treated 

plants (Desser Declaration in Case No. CV-10-1397-SI, 2012)

Residual Soil Activity

Many herbicides have residual soil activity. Root uptake by nearby non-target plants could result in their 

damage or mortality. Some herbicides (especially picloram, aminopyralid, imazapyr, and imazapic) can 

persist and remain active in soil for two or more seasons. This can prevent germination and establishment 

of susceptible plants. As noted above, past spot applications of picloram on other forests have not resulted 

in observable damage to non-target plants outside of the immediate treated area, either from unintended 

direct spray or from residual soil activity. The main desire is to recover desired plant communities, and 

picloram could persist to exclude desired forb type vegetation. However, pdfs (see soils section below) 

eliminate the potential for herbicide persistence in the soil to have long term effects on native plant 

communities. 

Herbicide Effects to Fungi/Soil Organisms

Herbicides have the potential to affect soil and soil organisms, including fungi. Herbicide effects on soil 

organisms are not well studied. For the proposed herbicides, risk assessments found typical application 

rates of picloram could inhibit soil microbial activity, although the indirect effect this would have on nontarget plants is not known. Existing studies of herbicide effects on formation of mycorrhizal associations 

in forest and nursery settings indicate little effect (Busse et al. 2004). More information on effects on soil 

organisms is in chapter 3.4.

There is only one sensitive fungal species suspected to occur on the Malheur National Forest. The 

umbrella false morel (Pseudorhizina californica, formerly known as Gyromitra californica) is a fungus

that is associated with forest litter, rotting wood and mineral soil. It is found in riparian areas, coniferous 

forests, and sometimes in old logging skid trails (Aurora 1986). Habitat for this species is most likely in 

areas that are not highly susceptible to invasive plant infestations (except in log skidding trails). Although 

the location of the mycelia of these species is not known in many cases, it is unlikely they occur in areas 

that would be treated by application of herbicides.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

112

Herbicide Effects to Bryophytes and Lichens

Little information is available about how herbicides may affect lichens and bryophytes. Concerns have 

been raised about drift from some herbicides decreasing the sustainability, relative long-term abundance, 

and diversity of lichens and bryophytes (Newmaster et al. 1999; R6 2005 FEIS). Lichens and bryophytes 

lack roots and instead obtain moisture and nutrients directly from the atmosphere; therefore, they are 

particularly sensitive and vulnerable to aerosols and contaminants in the atmosphere such as herbicide 

mist. Sensitive bryophyte and lichen species known to occur on the Malheur National Forest are generally 

found in wetlands, on rock surfaces, and in late-successional forest ecosystems.

Potential Effects to Special Forest Products

The main special forest product that is gathered on the Malheur National Forest is firewood. Posts and 

poles are another important non-timber product. All proposed treatments for invasive plant species should 

have no effect to opportunities to gather these products. Any potential negative effect would be human 

exposure to herbicides. The risks of human exposure to herbicides are discussed in other sections of this 

document.

There is a chance that plants gathered for food and medicinal purposes may be impacted by invasive 

species treatments. Mechanical, cultural, and herbicide treatments should only minimally impact these 

plants. This is due to the relatively small areas of treatment, especially when compared to the amount of 

habitat for these species. The project design feature that dictates the use of blue dye (pdf F6) and public

education about the dye should greatly reduce the risk of human exposure to herbicides when collecting 

special forest products.

The risk of negative impacts to special forest products is low; therefore, the risk from each alternative is 

determined to be minimal. No comparison of the alternatives is needed in terms of effects to special forest 

products. None of the alternatives would result in measurable impacts to special forest products.

Potential Effects to Pollinators

Pollinators can be impacted directly or indirectly by herbicides, possibly resulting in decreased 

reproduction of some non-target plants. Little information is available on the effects of herbicides on 

native pollinators, which include a wide variety of invertebrates (beetles, wasps, bees, butterflies, moths), 

and some vertebrate species. Known quantified effects are from direct spray on the nonnative honeybee. 

Of the herbicides proposed for use, only glyphosate was shown to have negative impacts to honeybees at 

the highest application rates. None of the herbicides proposed for use are expected to have toxic effects 

when used at typical application rates (R6 2005 FEIS). The scale of treatment is so low that any adverse 

effects would be immeasurable. 

Colony Collapse Disorder

Herbicides have a low likelihood of being implicated in CCD. Other pesticides, like miticides, may 

contribute to conditions that favor CCD. None of the herbicides included in the proposed action or 

alternatives exceeded toxicity values for honey bees at typical application rates. At highest application 

rates, only glyphosate caused any mortality, and this necessitated a direct spray at the highest rate. 

Herbicides are not typically used directly on the agricultural crops that honey bees pollinate because they 

would have a high likelihood of adversely affecting the agricultural crop (unlike on grass crops where 

selective herbicides are used on the crop directly). However, herbicides are used near these crops to 

control invasive plants. 

Herbicides used in the action alternatives have a very low probability to cause any affect to honey bees or 

contribute to CCD because: 1) treatments on the Forest are often in remote locations far from commercial 

bee hives; 2) treatments in the vicinity of bee hives would only entail treatment of patches of invasive 

plants and not a widespread application likely to expose honey bees; 3) these herbicides have a low 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

113

toxicity to honey bees; 4) affects to bees from these herbicides only occurred for one herbicide at the 

highest application rate, which is not applied in a spray application (in practice, highest application rates 

of glyphosate are used in wicking, wiping, or injection applications which are unlikely to expose bees).

Currently, the pathogen Israeli acute paralysis virus and the parasite Nosema ceranae are the leading 

candidates for cause of CCD. In addition, recent studies (Cameron et al. 2011) show that the declining 

species have been reported to have lower genetic diversity and higher infection rates from the pathogen 

Nosema bombi than co-occurring species that are not declining. Causes for the higher susceptibility of 

declining species are unknown, but current research has not suggested that herbicides are a factor.

Implementation of any of the action alternatives would not have adverse effects on honey bees or 

contribute to the potential cause(s) of CCD.

Effects on Culturally Significant Plants

Non-herbicide treatment methods are not likely to affect culturally significant plants. Manual methods 

such as weed pulling allow a great deal of plant specificity and reduce the likelihood of impacts to nontarget species. Proposed herbicide treatments have the potential to effect broadleaf varieties and grasses 

that could potentially include culturally significant plants. Project design features would help prevent

impacts to non-target vegetation, including fungi, vascular, and non-vascular plants. Project design 

features require consultation with affected Tribes as treatments are scheduled, so that tribal members may 

provide input or be notified prior to gathering culturally significant plants. Individual cultural plants 

identified by Tribes would be buffered as described for botanical species of conservation concern. The 

project design feature that dictates the use of blue dye (pdf F6) and public education about the dye would 

greatly reduce the risk of human exposure to herbicides when collecting culturally significant plants.

Effects of Alternatives

Alternative A

None of the proposed activities would occur under alternative A-no action, thus there would be no direct

or indirect effects to botanical resources from invasive plant treatments. Therefore, implementation of the 

no-action alternative would have no impact (NI) to sensitive plants, and would not lead to any direct 

negative impacts to culturally significant plants, special forest products, or pollinators.

Since invasive plants often out-compete native plants, the risk to sensitive plants from invasive plants 

increases with the number of acres of invasive plant infestation. Up to 30,000 acres could be infested over 

a 15 year period if no treatment occurs and invasive plants spread at a rate of 10 percent per year (see R6 

2005 FEIS and ROD and section 3.1.4 for more information on invasive plant spread). Alternative A will 

not achieve the goal of reducing acreage or suppressing, containing, controlling or eradicating invasive 

plants. This alternative would not meet the desired future condition “to retain healthy native plant 

communities that are diverse and resilient, and restore ecosystems that are being damaged, and to provide 

high quality habitat for native organisms throughout the forest, and assure that invasive plants do not 

jeopardize the ability of the forest to provide goods and services communities expect.” Invasive species 

would continue to spread and could eventually adversely impact sensitive species. 

Alternative B

Biological control agents must be rigorously tested for host specificity and approved by APHIS prior to 

release in the United States. The agents proposed for release meet the host-specificity requirements of the 

R6 2005 ROD Treatment Restoration Standard 14. There is a slight risk that an approved agent could 

attack a closely related non-target plant species. There are currently no known threats from biological 

control agents specific to Malheur NF sensitive species. Therefore, no direct effects from the use of 

biological control agents to sensitive plant species would occur.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

114

Cultural techniques that include seeding and planting native plants may change the species composition at 

treatment sites. Heavy seeding of native or short-lived nonnative grasses could delay germination and 

growth of other native plants. However, in areas where competitive seeding may be used, the invasive 

plant infestations are generally so dense that the native plant community has already been drastically 

altered. Reducing the invasive plants and establishing desirable vegetation would improve the probability 

that a native community could reestablish over time. Impurities in seed lots could potentially introduce 

nonnative or invasive species, but the requirement to use certified weed-free seed would reduce this risk. 

Project design features that include surveys and buffers for sensitive plants (table 9 pdf Group I) would

help to reduce the risk that cultural control methods may negatively impact sensitive plants. Therefore, 

cultural techniques would not have any direct negative impacts to sensitive plant species or habitat.

The use of herbicides could potentially kill common native and sensitive plants. Alternative B proposes 

treating up to 2,124 acres per year with herbicides. Common plants near infested areas could be killed; 

broadcast treatments are the most likely to result in some loss of common native vegetation within 100 

feet of target plants. Spot and hand treatments could also kill common plants that are adjacent to treatment 

sites.

Project design features ensure pre-treatment surveys would be completed for sensitive plant habitat. If any 

sensitive plants are located during these surveys, pdfs and buffers would be applied to protect the 

populations of sensitive plants. No treatments are proposed in aquatic habitats, therefore there would be 

no direct impact to aquatic sensitive plant species.

Alternative B-proposed action would lead to a reduction in the extent and density of invasive plant 

species in the project area. This would reduce competition and displacement of sensitive plant species 

over the life of the project. Therefore, the indirect long-term effect of implementation of alternative B 

would lead to a beneficial impact to sensitive plant species in the project area (BI). The degree of this 

beneficial impact is directly correlated with how many acres of invasive species are reduced or 

eliminated.

The sensitive plants survey requirement also provides a large measure of protection for sensitive plant 

species. However, there is always a small possibility that some populations of sensitive plants may be 

overlooked during sensitive plant surveys. For this reason, it is not possible to state with 100 percent

certainty that all sensitive plant species will be detected during sensitive plant surveys. There is a slight 

chance that undetected sensitive plant populations may be negatively impacted by proposed treatments. 

Therefore, the direct effect of alternative B -proposed action on sensitive plant populations and habitat 

potentially found in treatment areas is, the proposed action may impact individuals or habitat, but will not 

likely contribute to a trend towards federal listing, or cause a loss of viability to the population or species 

(MIIH).

Early Detection and Rapid Response (EDRR)

The effects of the EDRR process are the same as the direct and indirect effects because the project design 

features, annual and life of the project caps, and implementation planning process serve to ensure that 

future treatments are similar to those analyzed. The requirement that areas proposed for treatment be 

surveyed for sensitive plants would provide a large measure of protection for sensitive plant species.

Cumulative Effects

In the past, present, and reasonably foreseeable future, there have been and will continue to be projects 

and activities within the planning area that may cause impacts to sensitive plants and their habitats on the 

Malheur National Forest. Projects and activities that reduce native plant cover and create ground 

disturbance increase the risk of invasive plant infestation. Chapter 3.1.5 discusses ongoing activities that 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

115

also may be vectors of spread for invasive plants and foreseeable future projects on the Malheur National 

Forest.

Road construction and recreation developments have permanently removed native plant habitat in parts of 

the planning area, and disturbed roadsides continue to be a major conduit for invasive plant spread. Public 

use of National Forest System lands will likely continue to increase with population growth. This will 

contribute to the spread of invasive plants along roads and in recreation areas.

Historically, people using pack stock brought hay and feed from other areas for their animals. This feed 

often contained invasive plant species seed. This contributed to the introduction of new invasive species 

to the area. As part of the R6 2005 ROD, this potential vector of invasive species was reduced by 

regulations that require the use of certified weed-free feed for all recreational and permitted stock on the 

Malheur National Forest (Directive R6-2009-001). The cumulative effect of these regulations is there 

would be fewer introductions of new invasive weed species and new populations of invasive plants in the 

project area. This would help to reduce the long-term risk to sensitive and other plant species of concern.

Past timber harvest created highly disturbed habitat that has remained open and susceptible to infestation 

for 25-30 years. Current and planned timber harvest on National Forest System lands in the project area 

are mostly thinning treatments with the objective of maintaining mature forest and improving forest 

health. Harvests are often combined with understory fuels treatments. These types of activities are 

designed to restore habitats to historical stand conditions. Current treatments, when compared to past 

clear cutting, are less likely to create unnaturally large openings, which leads to more bare ground, which 

provides good germination sites for invasive species. These vegetation management activities have the 

potential to increase suitable habitat for invasive plant species.

Domestic livestock grazing is a well-documented vector for invasive species seed transport. Livestock 

grazing has occurred in most of the project area for decades and has resulted in changes in plant

communities, especially in nonforested and riparian areas. Grazing has a direct effect on plants through 

biomass removal and trampling. Grazing can have an indirect effect on plant species by causing soil 

compaction, soil disturbance, and alteration of nutrient cycling. The degree of impact to plant species 

from grazing is related to the timing, duration, and intensity of the grazing action, as well as the 

individual characteristics and habitat requirements of the plant species. Grazing may reduce the 

competitive ability of perennial native grasses in rangeland and meadow habitats and creates localized 

areas of bare ground susceptible to infestation.

The historical abundance and distribution of sensitive species on the Forest is not known. Past activities 

have likely affected their current abundance and distribution. Beginning in approximately 1990, botanical 

surveys and biological evaluations were conducted for most Forest Service projects planned and 

implemented in the project area. These efforts analyzed effects to species included on the Region 6 

sensitive plant list at the time of the analysis. As a result, activities conducted, ongoing, and planned since 

1990 have been designed to reduce impacts to sensitive species.

Chapter 3.1.5 introduces the basis for the cumulative effects analysis and displays a table lists the past and

present vectors of invasive plant spread and reasonably foreseeable future projects within the project area.

Alternative C

Direct and Indirect Effects 

The primary difference between alternatives B and C is the amount and types of herbicides used.

Alternative C would not allow the use of picloram and would not allow broad spraying. It also would

prohibit the use of herbicides within 100 feet of water bodies. The maximum number of acres of herbicide 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

116

treatment annually is 735 (as compared with the 2,124 acres proposed in alternative B). The same project 

design features will apply for sensitive plant protection with additional protection provided near streams.

The effects for alternative C would be very similar as alternative B; however, there will be less use of 

herbicide and consequently less risk of negative impacts from herbicides relative to alternative B. There 

would be no herbicide treatments within 100 feet of water bodies, so there would be no risk from 

herbicides to sensitive plants that occur within 100 feet of water bodies. Although the risk to sensitive 

plants is relatively lower under alternative C, the same potential sources of risk still apply. The possibility 

of accidentally treating undiscovered populations of rare plants does exist. Therefore, implementation of 

alternative C may impact individuals or habitat, but will not likely contribute to a trend towards federal 

listing, or cause a loss of viability to the population or species (MIIH).

Alternative C would lead to a reduction in the extent and density of invasive plant species in the project 

area. This would reduce competition and displacement of sensitive plant species over the life of the 

project. Therefore, the indirect long-term effect of implementation of alternative C would lead to a 

beneficial impact to sensitive plant species in the project area (BI). The degree of this beneficial impact is 

directly correlated with how many acres of invasive species that are reduced or eliminated. For this 

reason, alternative C will not lead to as great of a beneficial impact as alternative B (see chapter 3.1.4 for 

more information about treatment effectiveness).

Early Detection and Rapid Response

The effects of the EDRR process are the same as the direct and indirect effects because the project design 

features, annual and life of the project caps, and implementation planning process serve to ensure that 

future treatments are similar to those analyzed. The requirement that areas proposed for treatment be 

surveyed for sensitive plants would provide a large measure of protection for sensitive plant species. 

However, the loss of treatment effectiveness due to fewer acres treated compared to alternative B would 

be magnified over the life of the project (see chapter 3.1.4).

Cumulative Effects

Cumulative effects for alternative C would be similar as for alternative B. See discussion above.

Alternative D

The difference between alternatives B and D is the first year/first choice herbicides proposed, which 

indirectly influences the herbicide application method. Alternative D would not allow the use of 

aminopyralid, which would increase the use of other herbicides, thereby increasing the acreage that would 

need to be spot or hand treated and changing the herbicide-use buffers required. See chapter 3.1.4 for 

more discussion of the effectiveness of alternative D vs. alternative B. The maximum number of acres of 

herbicide treatment annually is 1,654, which is the same as for alternative B. The same project design 

features will apply for sensitive plant protections.

The risks to sensitive plants from alternative D are similar to alternative B. The same potential sources of 

risk to sensitive plants apply. The greatest potential risk of negative impacts to sensitive plant species is 

due to the possibility of accidentally treating undiscovered populations of rare plants. The fact that less 

broadcasting would likely occur would increase operator control and reduce potential for overspray, drift 

or accidentally impacting sensitive plants. This would also result in less potential risk to common nontarget plants.

Therefore, the direct effect of alternative D on sensitive plant populations and habitat potentially found in 

treatment areas is that implementation of alternative D may impact individuals or habitat, but will not 

likely contribute to a trend towards federal listing, or cause a loss of viability to the population or species 

(MIIH).
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

117

Alternative D would lead to a reduction in the extent and density of invasive plant species in the project 

area, however it would take more time compared to alternative B (see chapter 3.1.4). This would reduce 

competition and displacement of sensitive plant species over the life of the project. However, indirect 

long-term effects of implementation of alternative D would lead to a beneficial impact to sensitive plant 

species in the project area (BI). The degree of this beneficial impact is directly correlated with how many 

acres of invasive species that are reduced or eliminated. Alternative D is less favorable than alternative B 

in terms of protecting native plant communities because it is more costly and would take longer to 

implement.

Early Detection and Rapid Response (EDRR)

The effects of the EDRR process are the same as the direct and indirect effects because the project design 

features, annual and life of the project caps, and implementation planning process serve to ensure that 

future treatments are similar to those analyzed. The requirement that areas proposed for treatment be 

surveyed for sensitive plants would provide a large measure of protection for sensitive plant species. 

However, the loss of treatment effectiveness compared to alternative B would be magnified over the life 

of the project (see chapter 3.1.4).

Cumulative Effects

Cumulative effects for alternative D would be similar as for alternative B. See discussion above.

Summary of Effects to Botanical Resources

Table 31. Summary of effects to sensitive plants and special forest products

Issue and 

Indicator Alternative A Alternative B Alternative C Alternative D

Type and extent of 

herbicide use within 

100 feet of sensitive 

plants and special 

forest products

none

Project design features

prohibits broadcast 

herbicide use within100 

feet of sensitive plant 

populations. Spot

applications will be used 

within 100 feet of 

sensitive plant 

populations. Project 

design feature for use of 

blue dye will alert special 

forest product gatherers 

of herbicide spray areas. 

Same as Alt B Same as Alt B

Effectiveness of 

buffers and project 

design features to 

prevent impacts to 

non-target 

vegetation

NA

Buffers and pdfs would

substantially reduce the 

chance of herbicide use 

within 100 feet of 

sensitive plant 

populations.

Same as Alt B Same as Alt B

Compliance with 

existing 

management 

direction and 

disclosure of 

findings

Will not achieve 

goal of adequately 

treating invasive 

plants

Meets full compliance Meets full compliance Meets full compliance

Determination of 

short-term effects to 

Sensitive Plants

NA

Uncertainties due to 

difficulty of location and 

identification of all 

populations of sensitive 

plants leads to a call of 

Uncertainties due to 

difficulty of location 

and identification of all 

populations of 

sensitive plants leads 

Uncertainties due to 

difficulty of location 

and identification of all 

populations of 

sensitive plants leads 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

118

Issue and 

Indicator Alternative A Alternative B Alternative C Alternative D

may impact individuals 

or habitat (MIIH). Risk is 

directly correlated with 

number of acres treated.

to a call of may 

impact individuals or 

habitat (MIIH). Risk is 

directly correlated with 

acres treated. Slightly 

lower risk than 

alternative B due to 

treating fewer acres

with herbicide, and not 

using picloram (which 

is more persistent in 

the soil).

to a call of may 

impact individuals or 

habitat (MIIH). Risk is 

directly correlated with 

acres treated. Slightly 

higher risk than 

alternative B due to 

lower effectiveness of 

chemicals other than 

aminopyralid.

Determination of 

long-term effects to 

sensitive plants

Spread of invasive 

plants would lead 

to a long term 

negative impact to 

sensitive plants.

Reduction in amount and 

extent of invasive plants 

would lead to a long term 

beneficial impact to 

sensitive plants (BI).

Reduction in amount 

and extent of invasive 

plants would lead to a 

long term beneficial 

impact to sensitive 

plants (BI).

Reduction in amount 

and extent of invasive 

plants would lead to a 

long term beneficial 

impact to sensitive 

plants (BI).

3.4 Soils

3.4.1 Introduction

This section describes the potential direct, indirect and cumulative impacts on soil from proposed invasive 

plant treatments. Herbicides may accumulate in soils and harm soil biology, nutrient cycling, and the 

organisms necessary for decomposition and soil productivity. There is also a concern that herbicide 

treatment on riparian areas would adversely affect water quality and aquatic organisms. 

Soils regulate the fate of herbicide through soil properties. The soil litter and medium itself controls the 

persistence and chance for herbicide to either percolate or runoff to non-target areas. This analysis 

addresses the fate of herbicide within soils considering the unique environment conditions of the Malheur 

National Forest and site-specific characteristics. Factors other than taxonomic soil type usually determine 

the fate of herbicides within the soil, such as of groundcover, compaction, gradient, and biological 

capacity. Biological capacity is the ability of soil organisms to decompose litter and relates directly to 

fertility. Higher amounts of organic matter, water, light and favorable temperature affects the ability of 

soil organisms to process vegetation and herbicide residue.

Regulatory Framework and Compliance

Proposed treatments in all action alternatives would not lead to detrimental soil disturbance, nor 

substantially add to levels of detrimental disturbance from prior activities. Thus, the Malheur National 

Forest LRMP standard to retain effective cover would be met. Further, most of the invasive plant 

treatments occur on administrative use lands where productivity is not the primary purpose. All 

alternatives would meet Malheur National Forest LRMP objectives (USDA Forest Service 1990, p. 4-21) 

and regional guidance (USDA Forest Service 1998) for soils.

3.4.2 Affected Environment

Geology 

The geology of the Malheur National Forest is amongst the oldest and most complex in Oregon. 

Remnants of a shallow seafloor and sediments thereon were accreted onto the one-time edge of the North 

American tectonic plate (Brooks 1979). Under pressure and heat these layers were metamorphosed into 

argillites, quartzite, amphibolites that predominate in the center of the Malheur National Forest, Aldrich 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

119

Mountain, and Bear Valley Basin. This process was concomitant with volcanism, and intrusion of oceanic 

crust, which are the frequent large bodies of serpentine common to the areas mentioned. A thick sequence 

of sediment, eroded from the one-time coast range, approximately where the Blue Mountains are today, 

deposited into the John Day geosyncline. These sediments are the mudstone, shale, graywacke and 

volcanic rocks that overlay the seafloor sedimentary rocks, but now in turn, are often eroded away to 

expose the older rock. 

Starting about 35 million years ago massive volcanism and attendant uplift resulted in widespread and 

thick sequence of basalt and andesite lava flows from vents and fissures, interlayered with pyroclastic 

tuffs, as well as conglomerates and breccia created during erosive periods between bouts of volcanism. 

Much of the Malheur National Forest is covered by the Clarno, John Day, Strawberry and Columbia 

Group basalts and andesites (Brown and Thayer, 1966; Greene et al, 1972). These rocks frequently 

compose the upper ridges and mountain tops, except in the northeast quadrant where uplift and erosion 

has led to extensive exposure of old seafloor sediments or granitic batholith. 

The larger valleys, the John Day, Bear Valley Basin, for example are filled with recent (Holocene) 

alluvium, but there are also extensive coarse sediment fans of the Pliocene and Pleistocene epoch on 

lower slopes and bottoms of the larger valleys.

Climate

The climatic conditions that favor invasive plants on the Malheur National Forest were derived by 

associating current invasive plant sites with annual mean minimum temperature and precipitation from 

PRISM 30 meter grid data (Daly et al 2008). Mean minimum temperature is a good relative measure of 

growing season. Most of the invasive plants occur in areas of the forest with a mean minimum 

temperature above 28 degrees Fahrenheit. Thus the abundance of invasive plant infestations declines 

substantially above 6000 feet where mean minimum temperatures are less than 28 degrees Fahrenheit and 

a short growing season becomes a limiting factor (figure 6). In terms of growing season, invasive plants 

on the Malheur National Forest tend to establish in areas with 54 to 85 frost free days. 

Climatic conditions favorable to invasive plants are mostly in the northern and western portions of the 

Malheur National Forest, and around the 5,000-6,000 foot elevation zone, where greater available

moisture and moderate growing temperatures prevail. In contrast, much lower distribution of invasive 

plant sites occur in the southwestern quarter where the climate is colder and dry.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

120

Figure 6. Target invasive plant sites by elevation

Location of Invasive Plants and Soil Conditions

The list of site types in chapter 3 (table 19) shows most the invasive plant sites occupy roadside settings, 

with natural soil conditions making up a small portion of the current invasive plant sites. Roadside areas 

provide more available light and less competition for moisture and nutrients, and are frequently disturbed, 

which favor the typical early seral stage invasive plants. Roadsides have compacted gravels formed for 

roadbase that may or may not have a developing litter layer where roadside vegetation grows. The soil 

properties for disturbed roadside environments will be moderate to poor drainage and considered to have 

low fertility. However, open light conditions and pooled water from roadside drainage increases water 

availability for grasses and forbs compared to adjacent natural soils.

Natural soils have disturbed conditions from vegetation management, recreation, grazing or wildfire that 

compacts, bares the surface, but leaves the soil profile in place. The range of natural soils and more 

importantly the range of soil properties that could influence herbicide movement were derived by 

overlapping the Soil Survey Geographic Database (SSURGO) Database mapping with invasive plant 

sites. The mapping however, is complete only for the northern portion of the Malheur National Forest and 

contains 41 percent of the invasive plant sites. The lack of soil mapping is not necessarily an impediment 

to analysis since the environmental fate of the herbicides is more related to the level of disturbance than 

the soil series, and the diversity of soils series within the mapped area is representative of the relevant soil 

properties across the Malheur National Forest.

The SSURGO mapping has an accuracy of 40 acres for the map units and thus represents a fine scale 

compared to prior soil surveys. This mapping covers the diverse terrain and landforms common to the rest 

of the Malheur National Forest. The exception would be that a higher presence of volcanic ash is found in 

the northern portion of the forest. Table 32 lists soil properties associated with the dominant soil types and 

affiliated geology derived from the northern portion of the forest. 

Table 33 lists the soil properties that contrast soil capacity to hold water and provide nutrients. Soil 

properties for organic matter, soil depth, hydrologic conductivity, cation exchange capacity and pH were 

derived from the NRCS Soil Data Viewer. Strong gradients in fertility are found between grassland and 

forest soils in the project area. Grassland and forb rich soils have high organic matter content along with 

finer textures that hold water longer into the dry season. The parent rock mineralogy affects the soil 

texture – degree of clay - rock content, cation exchange content, pH and available minerals. With 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

121

exception to the valley bottoms, most of the Malheur National Forest soils have high percent gravel to 

cobble rock fragments. The pH ranges from 6 to 7, having no indication of acidic or alkaline conditions 

that limit productivity.

The cation exchange capacity (CEC) serves as an indicator for fertility and adsorption of applied 

herbicides. The cation exchange capacity is an index of available sites for solutes/ions to attach to soil 

particles. A higher CEC represents increased ability to hold and release various chemical elements – a 

relative higher capacity for holding nutrients. The soils in the project area have CEC of 5 to 35 meq/ gram 

of soil for mineral soil horizons (table 33). Humus, highly decomposed organic matter within the soil, has 

the strongest impact on overall CEC since humus itself has CEC in the range of 100 to 200 meq. The clay 

influenced soils have the highest CEC at 35 meq since clay minerals have high surface to volume ratios 

that bolster CEC. Though not listed in table 33 grasslands with deep accumulations of organic matter will 

have CEC in the range of 30 to 50 CEC.

The dominant soil series in the northern half of the project area developed on andesite and basalt rocks 

and range from shallow to very deep soils. These series correlate with 23 percent of the invasive plant 

sites and comprise the Fivebeaver, Wonder, Bigcow and Rebarrow soil series. Soils derived in these 

volcanic ash materials generally have silt loam textures, gravelly to stoney conditions and clay contents 

less than 20 percent. These soils transmit water effectively at 70 to 97 μm/s except for the shallow 

Fivebeaver series. Higher water availability is found in the Wonder, Bigcow and Rebarrow soils which 

have higher ash deposition and deeper soil matrix. Available water in these ash influenced basalt and 

andesite soils has potential 9 to 14 cm; the range for all the mapped soils is 4 to 15 cm. Values below 4 cm 

indicate low available water. 

Tuvame and Mellow soils, the dominant soils with valleys, account for 7 percent of the invasive plant 

sites. The poor to very poorly drained soils have seasonal water close to the surface, and support various 

sedge vegetation. These soils have very deep matrix and less rock than the volcanic soil on adjacent 

hillslopes. Available water in these soils depends on the closeness to the drainage; the loam to silt loam 

textures support moderate water movement through the soil profile due to lack clay to hold water. The 

available water is listed 11 cm; however the valley bottom position suggests water could be more 

abundant.

Soils that have inherently high erodibility include those on steep slopes, developed in volcanic tuff. Btree, 

Lamulita and Humarel soil series occur on tuff and welded pyroclasic flows, correlated to 6 percent of the 

invasive plant sites. The duff decomposes easily forming clayey soils. Where deep and well-developed,

the soil matrix has a high CEC at 35 meq, not including the forest floor. Because of the finer texture, the 

water movement through the soil matrix is reduced compared to the andesite and basalt soils at 47 to 69 

μm/s. These soils have values of available water similar to the harder rock volcanic soils at 7 to 14 cm, 

controlled mostly by soil depth.

The metavolcanic soils, which developed on very hard resistant rock, correlate with 4 percent of the 

invasive plant sites. These include the serpentine derived soils which have inherently poor growing 

conditions. The dominant soils series include the Lemoncreek and Hondu soil series which have ashy 

topsoil, and support mixed conifer forests. These rocky soils have less than 14 percent clay, silt loam to 

sandy loam textures and have low organic matter within the soil matrix. These soils have a low ability to

hold water with only 7 cm estimated water.

Granitic derived soils only account for less than 1 percent of the invasive plant sites. Though normally 

well drained, the ash influence increases water holding capacity on these soils. The Gorhamgulch soil 

series is the predominant soil type. Soils support mixed conifer forest. The cation exchange capacity is 

moderate at 15 meq. Available water is high at 15 cm.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

122

Table 32. Most common soil types from SSURGO mapping-sort is from dry to mesic vegetation types

Soil Series Area 

(%) Geology Characteristic Vegetation Where found

Bocker 3.4 Andesite and Basalt Shallow, mollisol Sage steppe Lava plateau

Anatone 2.2 Andesite and Basalt Shallow, mollisol Sage steppe Lava plateau

Fivebeaver 5.0 Andesite and Basalt Shallow, mollisol Ponderosa pine 

and Douglas-fir

Plateaus and 

backslopes

Wonder 6.9 Andesite and Basalt Ashy, rocky 

inceptisol

Mixed conifer 

forest

Montane ridges and 

shoulder slopes

Bigcow 6.2 Andesite and Basalt Ashy, rocky 

inceptisol

Lodgepole pine 

and grand fir Hillslopes

Bennett-creek 4.1 Andesite and Basalt Thick ash, alfic 

forest soil

Ponderosa pine 

and Douglas-fir

Lower hillslopes and 

footslopes

Deardorf 2.2 Andesite and Basalt Thick ash,rocky, 

moist forest soil

Mixed conifer 

forest

Montane ridges and 

shoulder slopes

Rebarrow 5.6 Andesite and Basalt Thick ash,rocky, 

moist forest soil Moist grand fir Mountain valleys

Linecreek 2.2 Basalt Ashy, rocky alfisol Ponderosa pine 

and Douglas-fir Plateaus, canyons, hills

Olot 2.0 Basalt Thick ash, rocky 

forest soil

Mixed conifer 

forest Mountains and plateaus

Tovame 4.0 Valley bottom

Somewhat poorly 

drained, terrace 

soils

Cinquefoil and 

sedges Dry meadows

Melloe 3.2 Valley bottom

Poorly drained, 

aquic soils within 

valley alluvium

Alder and sedge Wet meadows

Btree 2.9 Acidic Tuffs Thick ash, alfic 

forest soil on tuff

Mixed conifer 

forest Mountains and canyons

Lamulita 1.5 tuff breccia

Clay and rock, 

ashey, open forest 

soil on tuff

Grand fir, Douglasfir, and ponderosa 

pine

Plateuas and hillslopes

Humarel 2.0 welded pyroclastic 

flows/ clay rich mafic

Clay and rock, 

ashey, open forest 

soil on tuff

Ponderosa pine 

and Douglas-fir Hillslopes

Lemon-creek 2.3 Metavolcanics 

(serpentine)

Ashy, rocky forest 

soil on 

metavolcanics

Mixed conifer 

forest Hillslopes

Hondu 1.4 argillite and 

metavolcanics

Deep and rocky, 

ashy dry forest soil 

on argillite and 

metavolcanics

Grand fir, Douglasfir, and ponderosa 

pine

Hillslopes

Gorham-gulch 0.5 granite rock Ashy, forest soil on 

granite

Mixed conifer 

forest Hillslopes

*The percent area found within invasive plant mapping.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

123

Table 33. Soil properties of prevalent soil series

Soil Series Depth (in) Dominant Texture Clay 

(%)

OM 

(%)

CEC

* 

Ksat*

*

Available Water 

***

Bocker Shallow cobbly siltloam 22.2 1.5 15 9 3.71

Anatone Shallow cobbly siltloam 23.2 1.82 21 9 2.61

Fivebeaver Shallow cobbly siltloam 18.4 6.34 21.4 23.56 4.51

Wonder Very Deep gravelly siltloam 6.2 16.45 15 97 9.56

Bigcow Very Deep gravelly siltloam 6.2 16.45 15 97 9.56

Bennettcreek Mod Deep siltloam 6.5 10.67 5 52.68 8.52

Deardorf Very Deep stoney siltloam 8.8 10.42 15 69.4 14.42

Rebarrow Very Deep siltloam 8.8 10.42 15 69.4 14.42

Linecreek Mod Deep extremely cobbly loam 6.5 10.67 5 52.68 10.06

Olot Mod Deep stoney siltloam 10.6 11.2 17 69.4 12.73

Tovame Very Deep siltloam 9 5.25 15 28 10.95

Melloe Very Deep loam 9 5.25 15 28 10.95

Btree Deep siltloam 8.8 11.42 15 69.4 14.86

Lamulita Deep clay loam 26.8 13.38 32.8 47.4 9.91

Humarel Mod Deep very gravelly clay loam 30.8 12.42 35.2 47.4 7.13

Lemoncreek Mod Deep siltloam 13.6 4.64 12.7 23.56 7.13

Hondu Very Deep sandy loam 6.6 4.78 14.7 25.08 7.14

Gorhamgulch Very Deep siltloam over cobbly 

sandy loam 6.2 11.42 15 52.68 15.08

*Cation exchange capacity in meq/100g for top 10 inches of soil

**Saturated hydrologic conductivity in top 20 inches soil (μm/s)

***Available water holding capacity within top 20 inches soil (cm)

3.4.3 Environmental Consequences

Methodology

The R6 2005 FEIS analyzed herbicide effects to soil organisms and this analysis is incorporated by 

reference.

Factors other than taxonomic soil type usually determine the fate of herbicides within the soil, such as of 

groundcover, compaction, gradient, and biological capacity. Biological capacity is the ability of soil 

organisms to decompose litter and relates directly to fertility. Higher amounts of organic matter, water, 

light and favorable temperature affects the ability of soil organisms to process vegetation and herbicide 

residue.

The main consideration for soils is the ability to filter and degrade herbicide residue depending on surface 

conditions. Site-specific soil and climactic conditions were modeled to examine the depth of percolation 

of herbicides for typical soil conditions.

Soils were characterized using the Terrestrial Ecosystem Unit Inventory (TEUI) that is currently 

completed for a third of the Malheur National Forest. Older soils information (Carlson 1974) was used to 

analyze areas not mapped with the TEUI.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

124

Spatial and Temporal Context for Effects Analysis

Project duration is 5 to 15 years. Repeated treatments, manual, mechanical or chemical may be necessary 

in sequential years or the same year on the same ground (generally to treat missed plants during initial 

treatment). All action alternatives may result in repeated treatments through the life of the project. Active 

restoration may occur to reduce the time necessary after treatment to mitigate the effects of soil 

disturbance or persistence of various chemical herbicides.

Effects of Alternative A – No Action

Alternative A would not authorize any invasive plant treatments so would not have direct effects on the 

soil resource. Based on current spread rates (4-12% as per R6 2005 FEIS and ROD), invasive weed 

populations would continue to grow along the main travel corridors leading to higher risk for spread onto 

the Malheur National Forest. The effect on soils is a shift away from natural plant and soil communities as 

invasive plants occupy new sites. Where invasive plants invade newly disturbed sites such as wildland 

fire areas, the invasive plants can affect the recovery trajectory for desired plant and soil communities

Effects Common to All Action Alternatives

Direct and Indirect Effects Summary

All action alternatives expand the tools for controlling invasive plants. Non-herbicide treatments would

have negligible effects to soils. Soils would also not be adversely affected from the herbicide treatments 

due to the typical rates of application and the prevalence of sites on non-natural surfaces such as road 

sides, trailways, and at parking areas. Soil productivity would not be directly affected. Indirect effects 

may include a shift in the composition of plant and soil biota related to use of herbicides. However the

project design features applied to all action alternatives make this unlikely because restrictions on the rate, 

type, and frequency of specific herbicides (see pdf groups F and H, chapter 2, table 9) would reduce 

herbicide build up in the soil and impacts on soil organisms or productivity.

Direct and Indirect Effects from Non-herbicide Treatments

The non-herbicide treatments would have very minor effects on soils. Some soil disturbance could occur 

from pulling invasive plants. Typical treatments result in less than 1 square foot loosened soil as pulling is 

typically used on sparse scattered infestations rather than large, densely infested areas. These disturbances 

do not adversely affect overall site productive capacity since they are small and distributed, and do not 

lead to substantial soil loss. The retained cover of target plant species curtails erosion of loosened soil. 

Bare soils would remain below 10 percent areal extent for a treatment site and restoration (mulching, 

seeding, planting) would occur as needed (see chapter 2).

Direct and Indirect Effects from Herbicide Treatments

Herbicides would be sprayed directly on target species using ground based methods (hand, spot and 

broadcast) in all action alternatives; as per the pdfs, all methods, including broadcast would be 

implemented in a manner that reduces potential for non-target species and bare soil to be affected. Some 

soil will be directly sprayed by broadcast applications.

Herbicide application temporarily disturbs soils by altering vegetation cover and reducing the annual 

plant production. The effect is temporary, less than ten years, as desired vegetation returns. The 

disturbance does not result in detrimental soil disturbance that is an indication for permanent reductions to 

soil productivity. 

The primary consideration for soils is the ability to filter and degrade herbicide residue depending on 

surface conditions. The major pathway for herbicide degradation is metabolism by soil microbes. Halflives for herbicides range widely depending on the growing conditions for soil microbes. Herbicide 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

125

decays from toxic levels by microbial decomposition, sunlight degradation, and hydrolysis after 

absorption in the soil profile (Bollag and Liu 1990). Most of the recommended herbicides primarily 

degrade by microbes metabolizing the residue (SERA 2004b, d, e, 2007, 2011a-d). Chlorsulfuron and 

metsulfuron methyl also degrade strongly by hydrolysis (SERA 2004a, 2004c). 

Indirect effects of herbicide transport to non-target plants and to groundwater resources are influenced by 

soil properties. Herbicide labels list soil texture as one means to control offsite spread. Herbicide labels 

have broad applications with agricultural settings having bare soil as a prominent use. For the typical 

application on Malheur National Forest, plant cover, groundcover, slope steepness and condition of the 

soil surface factor into the offsite movement in the Malheur National Forest setting. Also, the degree of 

saturation and compaction contributes to runoff. Leaching corresponds to the position in the valley 

bottom, porosity of soil material, and rainfall that could transport herbicide residue downward along a 

wetting front. To the extent that organic matter and productive soils exist, leaching would largely be 

controlled for in the topsoil as soil microbes metabolize herbicide residue. 

The GLEAMS model (see chapter 3.5 for details) was used to examine the fate of herbicides in the 

rooting zone of the soil and to evaluate the potential for herbicides to run off or leach through soils and 

reach water bodies. The modeling included a scenario for herbicide application on the most common soil 

type along a roadside. Figure 7 displays the results by soil depth versus magnitude of herbicide 

concentration. Dot size represents the level of herbicide concentration (larger dots mean more herbicide 

found in that soil layer). The Wonder soil series was used, having gravelly silt loam topsoil over gravelly 

loam subsoil and developed in andesite and basalt parent material to greater than 80 inch depth. Climate

data was taken from the nearby Austin station and modeled for summer. 

The results of the GLEAMS modeling shows all the herbicides do not penetrate lower than 36 inches 

using the highest application rates. The faint dot of aminopyralid represents small herbicide 

concentrations. The sharp decrease in depth illustrates the adsorption of herbicides to soil despite their 

high solubility. The topsoil organics and mineral matrix bind the bulk of the herbicide in the top inches as 

reflected in the modeling results.

Figure 7. Modeled soil concentrations (ppm) on Wonder Series soils in the Clear Creek watershed
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

126

Despite the low risk for offsite transport by water, a risk for offsite transport by dust was identified for the 

sulfonylurea herbicides where applied to bare soil conditions along roadsides, native surface roads and 

cleared vegetation areas. Chlorsulfuron, sulfometuron methyl, and metsulfuron methyl binds particularly 

tightly to clay particles. Risk to non-target plants from herbicide-laden dust was addressed in the risk 

assessments for these herbicides. To mitigate this risk, these herbicides can only be applied on ashy soil, 

or light sandy soil during moist conditions (pdf F5). Further, application during calm wind conditions 

lowers risk for offsite transport (pdf F3).

Direct and Indirect Effects to Soil Organisms

Impacts to soil organisms would be low and transitory due to the type of herbicide, low application rate, 

and Malheur National Forest climate. The R6 2005 ROD (amended Malheur National Forest LRMP) 

limited the use of herbicides to those that are unlikely to affect soil productivity and soil organisms. This 

analysis incorporates by reference the R6 2005 FEIS analysis and findings regarding impacts on soil 

organisms and productivity.

Impacts to soils and soil microbial community would largely be indirect, related to removal of targeted 

vegetation and shift to desired plant species. Changes in vegetation type can shift below ground 

composition of soil organisms (Wardle et al. 2004, Wolf and Klironomos 2005). Indirect boosts in 

decomposition rates may result as soil microbes metabolize dead plant tissue. Slight increases in 

microbial activity may occur as the bacteria break down the herbicide. This effect was observed by 

Ratcliff et al. (2006) where a growth increase in bacteria followed a glyphosate spill; the researchers 

reasoned that the increase is temporary as the bacteria metabolize the herbicide.

Eight of the 10 herbicides approved in the R6 2005 ROD were not found to pose deleterious effects to 

soils. Picloram and sulfometuron methyl had potential affects to soil microbes in laboratory tests but not 

in field studies. These risks were reduced by limiting frequency and rate of application. The project 

proposes use of sulfometuron methyl at rates half that analyzed in the SERA risk assessment. Picloram 

use in alternatives B and D has specific design criteria to avoid use on inherently poor soils and limit 

repeat application (pdf H3 and H4). Picloram would not be used in alternative C.

Aminopyralid may be used in Alternatives B and C. The 2007 SERA Risk Assessment does not indicate 

any risk to soil microbes.

Using the SERA risk assessments, short term impacts to soil organisms from picloram, imazapyr, 

metsulfuron methyl, and sulfometuron methyl could occur for high rate applications on poor soils. In 

laboratory assays, short-term decreases for some types of soil microbes are reported with high 

concentrations above the amounts expected in soils. The effect of the herbicides decreases with time as 

other microbes, less sensitive to herbicide, decompose the active ingredient. The project microbial 

decomposition of each herbicide can be compared in table 37. Persistent herbicides such as picloram have 

longer half-lives. Impacts to microbes would be least where soils have a high degree of productive 

capacity with adequate organic matter, aeration and moisture. 

For picloram, the SERA risk assessment cited a slight decrease in the N fixing bacteria Azotobactor for a 

two week period at picloram concentrations of 10 ppm (see Tu 1994). In general, laboratory assays found 

little detectible changes in microbial activity below 50 ppm soil concentrations (SERA 2011c). Within the 

SERA risk assessment, GLEAMS model results show that for the clay, loam and sandy soils the soil 

concentration after application would be below 10 ppm. Results for GLEAMS-Driver modeling on the 

Malheur National Forest sites for a typical silt loam soil would have 0.3 ppm of picloram following 

treatment (figure 7). The GLEAMS-Driver is a module that uses climate data specific to an area. Given 

picloram’s persistence (half-live 80 days to 3 years), this project limits application to once a year (pdf 

H4). Similarly, picloram is excluded from use on poor soils where natural plant communities are desired 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

127

(pdf H3). The emphasis on natural plant community addresses uses on administrative sites and roadsides 

which have unique conditions that favor desired non-native species as protective groundcover.

For metsulfuron methyl, findings from one study showed slight growth reduction of common soil 

bacterium above 5 ppm soil concentrations (SERA 2004c). These effects increased with dosage. Modeled 

metsulfuron soil concentrations are 0.06 ppm. As with picloram, metsulfuron methyl is known to be 

persistent with half-live of 120 days (see Hydrology section). In agricultural studies, metsulfuron methyl 

use was linked to damaged rotation or substitution crops from persistence (Yu et al. 2005). The Yu et al. 

(2005) study demonstrated the detoxifying efficacy of a certain fungus that used metsulfuron methyl as a 

carbon source. Given the persistence and reliance of microbial degradation, the proposed action is for half 

the use rate commonly used in USFS applications (see SERA analysis 2004c). The project limits potential 

buildup of this persistent herbicide by limiting to once per season and avoiding use on poor soils where 

decomposition rates are low and native vegetation is desired (pdf H3, H4).

Tests for sulfometuron methyl depressing microbial activity showed mixed results from laboratory studies 

(SERA 2004d). Studies found both no effect and lower microbial biomass using herbicide concentrations 

near the rates evaluated in the SERA risk assessment. Overall, the risk assessment information was 

uncertain on the effects to any particular microbial group. Since herbicide half-life indicates the 

decomposition and thus microbial activity, this provides some indication on the toxicity. Field studies 

suggest the half-life is at 10 to 100 days (SERA 2004d) with higher decomposition in humid climates 

(Anderson and Dulka 1985). The half-life range shows ready decomposition by at least some microbial 

groups.

The proposed application rates for sulfometuron methyl are half of the highest rate used by the SERA risk 

assessment and modeled soil concentrations less than half that used in the environment fate experiment by 

Anderson and Dulka (1985). Note, this study showed that soil concentrations of 0.14 ppm followed first 

order decay equations, suggesting that no depression of microbial activity was found. The proposed level 

of sulfometuron methyl would have soil concentrations at 0.11 ppm, slightly lower than that used in the 

study.

The direct effect of herbicides on fungal and bacterial soil microorganisms vary with the herbicide used, 

and even then depend on the residue reaching the soil and the degradation rate, or half-life of the 

chemical. The effect to micro-organisms is usually not gauged by direct measurements, but inferred by 

changes in productivity factors such as respiration (CO2 production), of which microbial activity is one 

cause (SERA, 2011b). However the measurement of toxicity of herbicides to soil micro-organisms may 

be relevant only in the soil medium itself. Busse et al. (2001) showed that glyphosate, which can be toxic 

to microbes grown directly on the herbicide in the laboratory, had an un-measurable effect on microbes 

when applied directly to soil in the laboratory or in the field. In a follow-up study on glyphosate effects to 

soil microbial community structure, Ratcliff et al. (2006) showed a sizable increase in the bacteria to 

fungal ratio for the spill scenario (100% solution) and not for the diluted field rate. The increase may be 

only temporary as bacteria metabolize the herbicide, a labile carbon source, with an anticipated return to 

normal composition as the active carbon supply returns to natural levels.

Imazapyr and triclopyr have been shown to temporarily depress microbial activity for select organisms.

Imazapyr soil concentrations over 20 ppm were reported to slow cellulose decomposition by microbes in 

the lab (SERA 2011d). For the Malheur National Forest project, predicted soil concentrations are 0.50 

ppm, below the 20 ppm level that effects were found. Triclopyr has reportedly significantly slowed 

growth of bacterial and fungal strains in laboratory assays where over concentrations exceeded 1000 ppm 

(SERA 2011a). Some fungal strains had detectible changes to growth down to as little as 0.1 ppm. When 

testing natural soil samples, no detectible changes to microbial function or community structure was 

found for a rate of 1.2 lb. a.i./acre (Houston et al. 1998). The typical rate for triclopyr on the Malheur 

National Forest would be 1 lb./acre. Model runs using a high rate at 2 lb./acre show average soil 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

128

concentrations of 0.6 ppm. At this concentration, triclopyr has very low potential for slowing fungal 

growth. 

The capacity for soil microbes to decompose herbicide residue would be greater on natural soils 

compared to developed environments such as roads, and facility pads. The herbicides have wide-ranging 

half-lives depending on the biological capacity in the soil. The SERA risk assessment for aminopyralid 

lists half- lives of 14-343 days (SERA 2007). Since the microbial decay of herbicide is the primary fate, 

high productivity soils decrease the half- life and thus residency.

Decomposition processes need adequate water supply, air and carbon, which is highest on natural 

surfaces. Water has been shown the most critical factor for productivity, as microbial activity drops 

substantially under soil moisture content of ten percent (Davidson et al. 1998). Litter and forest floor 

layers provide a large proportion of CEC capacity that adsorbs herbicide residue. The litter and forest 

floor also reduces water losses to evaporation. 

Eighty three percent of the currently mapped infested acres occur along roadsides and administrative sites 

that are non-natural sites. Since these constructed surfaces lack diverse plants and soil microbes, herbicide 

decay by soil microbes would be reduced. However, herbicides would also decay by photolysis for all 

selected herbicides. Similar effects would apply to compacted and bared soils such as skidtrails, log 

landings, off-road parking, and cattle troughs. 

Inherently poor soils include shallow, droughty and serpentine soils. These soils have less capacity for 

decomposition and thus result in longer herbicide residence times. Thin basalt soils are prevalent across 

the Malheur National Forest, but have high concentrations of organic matter in the topsoil that alleviates 

concern. Serpentine soils have isolated locations across the forest. The highest density is within in the 

northern portion of forest which coincides with the fine scale SSURGO mapping. Of the invasive plant 

sites, twenty sites occur on road templates on or adjacent to serpentine soils comprising 62 acres. Mapped 

as either Lemoncreek or Cotay soil series, these soils have ash influence that would ameliorate the poor 

growing conditions associated with serpentine. The Lemoncreek soil has shallow topsoil and thus a higher 

risk than the Cotay soil series. The infestations have primarily Canada thistle and sulphur cinquefoil. The 

sites situate in the Mosquito Creek-upper Bear watershed that drains to the Middle Fork John Day River. 

Most occur within the old Summit Wildfire burn area. Other sites include Little Boulder Creek-Deerhorn 

and Vinegar Creek subwatersheds of the Middle Fork John Day River. 

Where shallow and disturbed soils exist and the desired condition is to restore natural vegetation rather 

than maintaining vegetation cover and excluding invasive plants, the use of picloram and sulfometuron 

methyl could reduce potential revegetation. These herbicides persist and poor soil conditions could 

lengthen already long residency times. The climatic limits, pdfs and herbicide-use buffers minimize the 

potential for leaching and runoff thereby reducing risk to the extent possible. Picloram application is 

limited to once per year and excluded on poor soils or shallow soils where productivity may be reduced to 

the extent that decomposition of the herbicide residue would be stalled (pdfs H3, H4). This effectively 

reduces the potential for picloram to build up in the soil and have impacts on soil organisms or 

productivity. 

Effects from Early Detection Rapid Response 

The current invasive plants sites represent the range of environmental conditions expected on the Malheur 

National Forest thereby accounting for potential consequences. These conditions were used to analyze 

and produce project design features that establish a sufficient layer of protection for soil organisms and to 

limit offsite transport to non-target plants and groundwater. 

None of the proposed treatment methods would create large bare areas or result in heavy disturbance to 

the soil surface. Thus, disturbances would not be large enough to contribute measurable levels of erosion 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

129

or sediment delivery to streams. As a result, there is little potential for this project to adversely affect soils 

or contribute to meaningful cumulative effects when combined with past and ongoing Malheur National 

Forest activities.

Repeated treatment of herbicides was raised as a concern. The low toxicity and low application rates 

reduce this risk overall; note that the typical rate would be used in most cases. The eleven herbicides used 

under this alternative have relatively short half-lives, at less than 3 months where productive soils (table 

37). Buildup from repeated uses of picloram and metsulfuron methyl was identified as a concern based on 

findings from the SERA assessments (SERA 2004d, 2011c). Using these herbicides would have short 

term transient effects that could slow growth of select soil microbes. These herbicides have half-lives of 

90 days and 10-100 days (table 37) depending on soil conditions. The project limits use of metsulfuron 

methyl to once a year to minimize soil buildup (pdf H4). Since soil conditions determine the buildup 

potential – a lack of soil microbes equates to lack of decomposition – the use of metsulfuron methyl and 

picloram would be avoided on sites with poor soil conditions (pdf H3) where restoration to native 

vegetation is desired. Gravel pits and parking lots would be examples of infertile areas where herbicide 

buildup would not be a concern.

Cumulative Effects Common to All Action Alternatives

Treatment scenarios would not measurably affect soils or soil productivity when compared with 

background conditions and ground disturbance created by ongoing activities. Thus, there is no potential 

for these effects to cause additive, synergistic, or other negative long-term cumulative effects. Manual, 

mechanical and cultural treatments would likely result in very small disturbances, less than 1 square foot, 

which would not be large enough to have adverse cumulative effects when combined with past and 

ongoing Malheur National Forest activities.

Most forest or riparian sites proposed for treatment will have treatment and monitoring of invasive 

populations extended through the project term (15 years). Foreseeable management activities on these 

sites are dispersed recreation travel, prescribed burns, wildfire suppression activities, and vegetation 

management including timber harvest. Although these activities could result in direct detrimental 

disturbance to the sites, the effects to soils from herbicide applications proposed under this project are 

unlikely to incrementally change soil characteristics enough to alter the productivity of any treated sites. 

Activities proposed under this project are not likely to be additive to the impacts of any other activities 

that could be cumulative to existing conditions on these sites. 

The ongoing forest management and recreation activities in addition to natural disturbance from wildfire 

create the potential for increased use of herbicide and/ or manual treatments. The proposed herbicide 

spraying assumes a reduction in treatment over time. However, ongoing forest activities may increase the 

open sites available for invasive plants to spread. The risk is controlled by existing prevention measures. 

Timber sale contracts have provisions to wash rigs as do fire suppression activities. Similarly, road 

management has specific contractual agreements that control against invasive plant spread. 

The effects of the herbicide treatments do not harm soil organisms but do change the vegetation 

composition which results in a minor level of disturbance. Ongoing management activities outlined in 

chapter 3.1.5 create a very large disturbance footprint compared to the effects of any action alternative. A 

list of forestwide projects are scheduled (2013-2015) that will be concurrent with the action alternatives 

(table 25). These projects include: prescribed burning, plantation thinning, replacing road culverts, road 

decommissioning, snow park relocation, aspen release, juniper thinning, toilet replacement, commercial 

timber harvest, parking lot paving, gate replacement, and demolition of a structure by explosion, fencing 

and other sundry and related activities. Most of the activities will involve a level of ground disturbance 

and many will probably risk increasing sediment delivery to streams.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

130

Figure 8 shows the median disturbance acreage for the Malheur National Forest for the past 10 years. 

High severity disturbance results in detrimental soil conditions that reduce native vegetation cover and 

impairs soil function. Detrimental disturbance results when management activities physically alter soils 

and remove organic matter to the extent that soil recovery remains very slow (USDA Forest Service 

1998). Low severity disturbance results in short term reductions to vegetation cover that last less than ten 

years. Invasive plant treatment would not be considered a high severity disturbance. Invasive plant 

treatment might temporarily slow recovery of native vegetation within some treatment sites, but would 

eventually help restore desired vegetation. 

Figure 8. Disturbance from ongoing forest activities

Road-related disturbance accounts for the most extensive disturbance across the forest. Most of the 

existing invasive plants are mapped along road templates (83 percent). The road templates are not 

intended as a part of the productive land base and thus minor changes to plant cover from herbicide 

treatment would not have adverse effects.

Outside of the roads, herbicide application impacts vegetation cover on approximately 85 acres where 

maintaining a productive land base is the primary purpose. For this area, forest activities or disturbances 

result from livestock grazing, timber and fuel management, prescribed fire, and wildfire. Herbicide 

application within areas disturbed by recent activities could temporarily slow the recovery trajectory of 

native vegetation. The impact would temporarily decrease soil productivity by decreasing overall plant 

production. Soil productivity would recover as desired vegetation re-establishes.

The short-term reduction in vegetation growth that creates minor soil disturbance is a tradeoff. Given the 

large disturbance footprint and continued invasive plant presence along the roads, future additive effects 

from herbicide application and forest activities are reduced if treatment occurs along prominent vectors. 

The proposed methods reduce populations of invasive plants at rock pits and stockpiled road materials. 

Using invasive plant-free road materials (i.e., rock and gravel) cuts down the potential spread onto 

adjoining road prisms and within planned harvest units. Administrative sites, campgrounds, roads—

essentially all areas that have unnatural surfaces and perpetual propagule pressure from traffic flow—

have the highest risk for cumulative increase in invasive plant spread. These activities correspond to 79 

percent of the current invasive plant sites. Since other activities —whether range, timber, or recreation 

management —largely depend on road access, the extent of the infrastructure represents the net effect of 

all the Malheur National Forest activities. 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

131

The action alternatives reduce the chance for spreading invasive plants from other forest management 

activities by controlling the level of infestation. The proposed methods reduce populations of invasive 

plants at rock pits and stockpiled road materials. Insuring weed-free road material cuts down the potential 

spread onto adjoining road prisms and within planned harvest units. Administrative sites, campgrounds,

and roads have unnatural surfaces and perpetual propagule pressure from traffic flow, and therefore have 

the highest risk for cumulative increase in invasive plant spread. These activities correspond to 79 percent 

of the current noxious invasive plant sites.

Vegetation management, including timber harvest, may result in a heavy disturbance, although there 

would be rapid recovery of native vegetation. Currently, the Malheur National Forest harvests roughly 

7,583 acres of timber annually using the median value from the last 10 years. However, together with 

wildfire, only 6 percent of the invasive plant sites correlate with timber harvest and wildfire events. 

Livestock grazing requires road access and creates heavy disturbance along fence lines, and around stock 

ponds and troughs. This disturbance has a small footprint; cattle trails typically have 2- to 4-foot width 

and stock troughs may have 0.25acres of compacted, barren ground. These features are evenly distributed 

across thousands of acres, as opposed to confined disturbance that results from timber harvest or wildfire. 

The distributed nature and seasonal disturbance creates a moderate risk for cumulative effects from

livestock grazing. Two percent of the invasive plant sites can be attributed to grazing, while disturbance 

along fence lines forestwide accounts for 0.3 percent of all known infested areas.

Differences between Alternatives

The differences between alternatives would not substantially change their impact on soils because manual 

and herbicide treatments of invasive plants are unlikely to affect soil properties or productivity. Properties 

of soils in the Malheur National Forest limit off-site movement of herbicides through the soil profile. 

Alternative B utilizes the most aminopyralid and allows the most broadcasting of the alternatives. 

Alternative C reduces the amount of herbicide used, and excludes use on sites that fall within 100 feet of 

streams, lakes, ponds and wetlands. This alternative also excludes use of picloram. Thus, the risk for 

herbicide buildup is reduced in this alternative because so little herbicide is comparatively used and 

because picloram is eliminated.

Alternative D would use 440 more acres of chlorsulfuron, 725 more acres of glyphosate and 63 more 

acres of picloram as first-choice herbicides (table 14). However, the pdfs, herbicide-use buffers and 

project caps ensure there would be no measurable adverse effects to soil from these differences.

3.5 Water Quality

3.5.1 Introduction

This section analyzes the effects to water quality from herbicide and non-herbicide treatment on 2,124

acres where invasive plants have been identified. The Affected Environment section briefly describes the 

existing conditions of water bodies on the Malheur National Forest, as well as the landscape: geology, 

climate, soil and stream-flow responses, which are important parameters in the model used to determine 

the fate of the chemical herbicides or assessing the relative risk to water quality of particular sites.

Results of modeling for water and soil concentration are reported in parts per million (ppm).

Sedimentation from manual methods will be analyzed by determining probable affected acres within the 

scope of major watershed area. 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

132

Regulatory Framework and Compliance

All land management activities on National Forest System lands are to be conducted in accordance with 

Forest Plan standards and guidelines for water quality and other resource protection. Use of Best 

Management Practices (BMPs) in National Forests is required by the National Forest Management Act 

(NFMA) and prescribed in the LRMPs. Consequently, all land management activities, must be 

implemented using BMPs for control of non-point source water pollution (USDA Forest Service 2011).

The anti-degradation EPA policy 40 C.F. R. Section 131.12 states that existing water quality, even when it 

exceeds required levels for stated beneficial uses will be maintained. Potential effects of the proposed 

action, either through surface runoff of sediment and chemicals or chemicals entering water bodies 

through groundwater sources do not constitute a significant degradation of quality or impair existing 

beneficial uses.

This project would comply with all Oregon water quality standards and requirements set by the Oregon 

Department of Environmental Quality as well as requirements of Oregon Department of Forestry, Forest 

Practices Rules EC1194, including herbicide use buffers as appropriate and Oregon Administrative Rules 

629-620-000 through 629-6200-0800 rules for mixing chemicals near streams. No 303(d) streams would 

be adversely affected by the project. 

3.5.2 Affected Environment

Climate

The climate of the Malheur National Forest is cold winters and warm summers, total precipitation is 

modest. Annual averages from operating weather stations in and around the Malheur National Forest 

range from 21 to 11 inches, at elevations between 3,000 and 4,600 feet (WRCC 2013). Precipitation is 

distributed across the year, most between the months of October and May as snow, with relatively dry 

summer months. However, the occurrence of the largest events varies considerably; sometimes occasional 

summer convective storms bring high intensity rainfall. Figure 9 that follows shows the Austin weather 

station (elevation 4,200’) for select years. The Austin station is near the headwaters of the Middle Fork 

John Day River, within the Forest boundary. A thirty-day moving average was added in order to smooth 

the graph and clearly show seasonal pattern.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

133

Figure 9. Precipitation pattern at Austin weather station

Stream Flow

There are few gauged streams in the Malheur National Forest, and fewer yet with overlapping records. 

Two gauges are used here for comparison. The Middle Fork John Day at Ritter (USGS station # 

14044000) (USGS 2013) has a drainage area of 515 square miles. The gauge is at an elevation of 2,545 

feet. It drains the northeastern portion of the Malheur National Forest. Strawberry Creek (USGS station 

#14037500) drains 7 square miles of the north flank of Strawberry Mountain. The gauge is at 4,900 feet 

elevation.

Figure 10 shows mean daily flow for period of record overlap. The patterns of flow are nearly identical, 

though Strawberry Creek lags by a month or more in peak flow. Both are snowmelt dominated in terms of 

peak flow and total yield, between the months of March and May for the Middle Fork, and typically June 

and even early July for Strawberry Creek.

The geology of Strawberry Creek watershed is entirely within the Strawberry Formation, basalt and 

andesite lava rock. The Middle Fork has a majority of its drainage in volcanic rock of the Strawberry, 

Columbia River Group or Clarno, but also significant amounts of area in granitics and serpentines and 

meta-volcanics of the Canyon Mountain Complex. The precipitation record from the John Day weather 

station is given as well to show the influence of events. Heavy rainfall in the summer or early fall can 

cause minor peaks in the hydrograph, but the occurrence of annual peak flow and most of flow yield is 

due to snowmelt runoff in late spring—early summer and is typically regardless of precipitation amount.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

134

Figure 10. Stream flow at selected gages and precipitation at John Day

Water Quality

The anti-degradation EPA policy 40 C.F. R. Section 131.12 states that existing water quality, even when it 

exceeds required levels for stated beneficial uses will be maintained. The Malheur National Forest Land 

and Resource Management Plan stated direction for water quality is to meet state of Oregon standards 

(IV-2) and comply with state requirements in accordance with the Clean Water Act (IV-39); website: 

http://www.fs.usda.gov/detail/malheur/landmanagement/?cid=fsbdev3_033814

Use of water quality and other resource protection BMPs (USDA Forest Service 2012) in National Forests 

is required by the National Forest Management Act (NFMA). Pertinent practices to this project assure 

proper mixing, application and clean-up as well as evaluation and monitoring of application that guard

against use on unintended targets. Project design features, particularly parts F, G and H (see chapter 2, 

table 9) incorporate BMPs on the handling of chemicals (Section 5, (8—13).

There are 6,220 mapped miles of stream channel on the Malheur National Forest. About 2,788 miles or 45 

percent of the total is mapped as perennial, meaning flow is typically sustained beyond the influence of 

wet season or snowmelt through most of the year.

Section 303(d) of the Clean Water Act (1972) requires that the state list water bodies on biennial basis that 

do not meet minimum requirements for stated beneficial uses. The State of Oregon Department of 

Environmental Quality is the responsible agency for assessing and listing impaired streams. As of this 

writing the 2012 report was not complete. The 2010 list is referenced 

(http://www.deq.state.or.us/wq/assessment/assessment.htm). Category 5A streams are those listed and 

needing an EPA approved Total Maximum Daily Load (TMDL) of pollutant allowed to meet water 

quality standards. Category 4A streams are those that have approved TMDL, and have subsequently been 

de-listed from the 303(d). 

Category 4A streams within the Malheur National Forest boundary are the John Day River System, 

including the Middle Fork and South Fork and their tributaries with approved TMDL for temperature. 

Issues are water temperature for life stages of red band and cut throat trout. Category 5A streams are 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

135

within the Silvies River system and include Hay, Myrtle and Skull Creeks for water temperature; and 

within Silver Creek system: Nicoll, Claw, Sawmill, Salt Canyon and Mainstem Silver for water 

temperature. 

Other streams listed yet have insufficient information to determine if streams violate standards 

insufficient information are the Middle Fork John Day and the following tributaries: Long Creek, 

Deadwood, and Vinegar for bio-criteria, Long and Summit Creeks for sediment. The Silvies River and 

following tributaries: Camp, Bear Canyon, Van Aspen Antelope for bio-criteria, and main stem Silvies for 

dissolved oxygen. Finally the upper John Day River is listed for bio-criteria, dissolved oxygen and 

sediment.

Table 34. Beneficial uses of major streams on the Malheur National Forest

Category 5A Category 4A Insufficient Information

Temperature Temperature Dissolved 

Oxygen Bio-criteria Sediment

Silvies R. and 

Silver Crk.

M. and S. Fk. John 

Day R. and 

tributaries

Up. John Day 

R.; Silvies R.

M. Fk. John Day R. and 

tributaries (Long, Deadwood and 

Vinegar crks); Up. John Day R.; 

Silvies R. and tributaries

Up. John Day R., 

Long and Summit 

Cks. on M. Fk. John 

Day R.

Table 35. Drinking water sources

Site Name Source NFS acres in 

watershed Comments

Municipal : Streams with Surface Water Intake

Canyon City Byram Gulch 610 Flows directly from Strawberry Mountain Wilderness

Prairie City Dixie Creek 9,300 0.44 acres of infestation, none within 100 feet of stream

Springs with Formal Agreement

Canyon Creek 

Meadow

EF Canyon 

Creek 4,200 0.2 acres of infestation, none within 200 feet of stream

Dixie Campground Trib. Of Bridge 

Creek 470 0.23 acres of infestation, but none upstream of 

campground

Idewild 

Campground Devine Canyon 350 About 0.1 acre of infestation within campground, and 1.0 

acre along roads on watershed slopes

Magone Lake 

Campground Lake Creek 150

0.36 acre of infestation along shore of the lake 

downstream of campground and none within 100 feet of 

stream.

Parish Cabin 

Campground Bear Creek 14,000

1.5 acre of infestation along roads within watershed. 0.1 

acre within 100 feet of stream about 5 miles above 

campground

Strawberry 

Campground

Strawberry 

Creek 2,300 No infestation in watershed.

Trout Farm 

Campground

Trib. of John 

Day R. 300 No infestation within watershed

Wells with Formal Agreement

Big Creek 

Campground Big Creek 16,400 7.2 acres of infestation along roads within watershed, about 2 acres within 100 feet of stream

John Day John Day River 100,000

Mount Vernon John Day River 200,000 Unknown

Seneca Silvies River 123,700
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

136

Site Name Source NFS acres in 

watershed Comments

Yellowjacket 

Campground

Yellowjacket 

Creek 3,700

About 7.7 acres of infestation within watershed, and 

about 4.7 acres within campground area. About 2.5 

acres within 100 feet of stream or reservoir.

Austin House 

Restaurant Bridge Creek 11,000 About 1`2.5 acres of infestation, most along Hi-way 26

Invasive Plants Near Roads and Streams

Most mapped invasive plants occur along, or near forest roads. Since roads are preferentially routed up 

valley bottoms to access ridges, they are built alongside higher order (3rd and 4th) streams which constitute 

the majority of the Forest’s perennial streams. Equipment, humans and livestock travel along the roads is 

the main avenue for seed distribution, and the disturbed ground immediately adjacent to the road running 

surfaces are common locations for invasive plants. 

About 1,312 acres of invasive plant sites are within about 100 feet (33 meters) of roads within the project 

area (see site type #2, chapter 3.1.3) when the portion of infested sites that meet the criteria (not the entire 

site) are considered. This amounts to about 61 percent of total infested acreage.

There is a strong association between forest roads and perennial stream channels. About 2,138 miles of 

the Malheur National Forest System roads are within about 300 feet (100 meters) of mapped stream 

courses (34 percent of the total stream mileage).

When only portions of infested sites (not the entire infested acreage in the site) are considered, about 471 

acres of mapped weeds are within 100 feet (33 meters) of streams (see site type #7, chapter 3.1.3).

Table 36. Acres of occurrence of invasive plants near roads and streams

Distance of Occurrence Acres of mapped invasive 

plants

Percentage of total mapped 

invasive plants

Within 100 feet of Forest roads 1,321 61

Within 300 feet of Forest roads 1,725 81

Within 100 feet of streams 471 22

Herbicide Use

Herbicides that are highly water soluble or strongly adsorbed to soil particles have the potential to move 

off site following application. Once into solution herbicides may transport through the soil as 

groundwater flow, potentially reaching natural surface water bodies. However, as groundwater is 

dispersed through a soil there is also increasing chance that chemicals will adsorb to the soil. Precipitation 

events immediately following herbicide application can push herbicide deeper into the soil column 

(percolation). The depth of herbicide transport is influenced by soil properties, herbicide properties, and 

amount of precipitation. Given these parameters, the depth of herbicide movement in the soil was 

estimated using the GLEAMS-Driver model for representative sites.

Runoff risk is particularly high for saturated soils during snowmelt, because of low infiltration capacity.

Spraying in spring when soil moisture is high and groundwater flow active may pose greater risk to 

transport of chemicals than in early fall when soil moisture content is very low, even under the same 

conditions of precipitation. Increased runoff and percolation can pose increase risk of contaminating 

surface water. To limit risk of offsite movement of herbicides, pdfs H5 and H6 limit herbicide spraying in 

conditions of high water table or saturated soils and H11gives parameters on allowable weather 

conditions for spraying.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

137

The duration or half-life of the herbicide in the soil also influences risk of off-site movement and potential 

risk to water quality. Percolation that stops in the top few inches of the soil, in the zone of microbial 

activity, would degrade faster and pose less risk to water quality. Herbicides that percolate deeper tend to 

degrade more slowly and pose more risk to water quality.

Roadside treatments pose the greatest risk to water contamination from herbicide spraying because 

roadsides are more compacted and promote more runoff and roadside ditches may have direct connection 

to a stream channel. In these circumstances ditches may effectively circumvent streamside buffers. 

3.5.3 Environmental Consequences 

Methodology 

Analysis for herbicide effects used published assessments (SERA, 2001, 2004a-d, 2005, 2007, and 2011ad), which provided parameters of degradation in various mediums, adsorption in soil, solubility in water. 

These parameters were used in the GLEAMS model (in the risk assessments) and GLEAMS-Driver 

utility (for site-specific analyses) to assess potential risk of off-site movement of herbicides, potential 

effects to water quality, and effectiveness of stream buffers. Assumptions are that herbicide application 

rates would be no more than the maximum rate (see table 18 in chapter 3.1.2). We conducted runs on 4 

sites on the Malheur National Forest, using local soil, precipitation, slope, vegetative cover, streamflow. 

The start date of the model runs was June 15 of any given year. Applications were modeled once a year on 

that date. 

Spatial and Temporal Context for Effects Analysis 

Project duration is 5-15 years. Repeated treatments, manual, mechanical or chemical may be necessary in 

sequential years or the same year on the same ground. There is the potential, under the proposed action 

that a given site will be impacted for up to 15 years and whatever recovery time necessary after that to 

mitigate the effects of soil disturbance or persistence of various chemical herbicides. The proposed action 

also provides for additional treatment of newly invaded sites during the life of the project.

Early Detection Rapid Response (EDRR)

Early Detection Rapid Response (EDRR) is an essential component of the proposed action because the 

precise location of target plants is subject to change, and new infestations may grow substantially in area 

during the time taken to prepare new NEPA documents. The highest risk is for spread along infested 

roadways that provide open sites for weeds and high propagule pressure from passing traffic. The current 

use of pdfs and buffers would limit offsite effect from runoff, erosion transport and leaching as discussed 

above for new detections.

Effects of Alternatives

Alternative A – No Action

There are no direct, indirect or cumulative effects of choosing the no-action alternative. See chapter 3.1.5

for more information about the potential for spread of invasive plants over time within the Malheur 

National Forest. The impacts from invasive plant spread are not expected to impact hydrology or water 

quality given the types of infestations found within the project area. However, over time, invasive plants 

could outcompete desirable vegetation that helps maintain functional riparian areas and stream conditions. 

Alternative B – Proposed Action

The proposed action would allow spraying of herbicides on up to 2,124 acres per year over the life of the 

project. Some non-herbicide treatments would occur in combination with herbicide treatments but the first 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

138

year/first choice treatment would be aminopyralid, chlorsulfuron and metsulfuron, with non-herbicide 

follow up as needed.

Non-Herbicide Treatments

Manual methods are hand-pulling or using hand tools. Ground disturbance would occur from drawing up 

a plant by its roots, or digging sufficiently to leverage roots out. Other treatments, cutting, clipping, 

mowing and mulching do not incur any disturbance of the ground. There is short-term risk of erosion if a 

contiguous patch of ground is disturbed sufficiently to initiate surface erosion, such as a road cut bank or 

fill slope. No impacts to water quality are associated with biological or cultural treatments. 

Herbicide Treatment

The following table 37 gives physical and chemical characteristics of the 11 herbicides proposed for use. 

These characteristics are important in the following discussion of alternatives and analysis based on the 

GLEAMS model.

Table 37. Herbicides physical/chemical properties

Herbicide

Toxicity to 

Aquatic 

Organisms

Adsorption

Water 

Solubility 

(ppm)

Degradation 

Half-Life (days)

Soil 

Microbes

Water and 

Sunlight

Groundwater

Aminopyralid low low 205,000 14-343 0.6 127-447

Clopyralid low low 1,000 12-70 8-40 261

Chlorsulfuron low low 27,900 120-180 ? 37-168

Glyphosate moderate strong 12,000 3-130 4-11 50-70

Imazapic No info moderate >2670 25-142 1-2 30

Imazapyr low low 11-13,500 210-2154

500 stable in 

anaerobic 

conditions

N/A

Metsulfuron

methyl low low ≈3,000-10,000 pH neutral 30-126 7-8 35 +

Picloram low low 200-400,000

18-300 in 

aerobic 

conditions; 

stable in 

anaerobic

2.6

14 aerobic; 

stable in 

anaerobic 

conditions

Sethoxydim low low 4700 @pH7

1-60 the 

high end of 

range is

anaerobic 

conditions

5-43 155+@ pH7

Sulfometuron 

methyl low low 300 @ pH7 10-100 20-60 44-113

Triclopyr TEA

Inhibits 

fungal and 

bacterial 

growth

low 8,100 14-46 2-6 hours 6 hours

Triclopyr (BEE) high strong 2-23 0.2-40 

0.5-8.7

Depending on 

pH

≈6

*--Values in parts per million (ppm)
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

139

Herbicides would be sprayed or wicked on leaves and stems of target plants or cut stumps. Herbicide that 

falls onto the soil could travel offsite by surface runoff or groundwater flow.

Once in soil, herbicide not directly absorbed into plant roots is typically metabolized by microbes (Bollag 

and Liu 1990) with the exception of Triclopyr, which is degraded by hydrolysis. Hydrolysis is the process 

by which the water molecule breaks down a compound into at least two separate constituents. Half-life of 

herbicides in soil is affected by its rate of adsorption to soil particles or organic matter incorporated into 

the soil. The stronger the adsorption the more likely chemicals will be retained in top soil layers for 

microbial degradation. Organic matter in particular has an affinity for adsorption.

Degradation proceeds rapidly in presence of sunlight, or by soil microbes when soil moisture is ample.

Soil moisture of less than 10 percent becomes a limiting factor in microbial activity (Davidson 1998).

Outside these environments—on the soil surface or within the top few inches of the soil where microbial 

activity is high—the half-life of herbicides is measured in months. All but one of the herbicides is 

relatively highly soluble and therefore will readily transport deep into a soil column with percolating 

water. The notable exception is triclopyr BEE which disassociates through hydrolysis very quickly to 

triclopyr TEA, which has moderately high solubility.

Surface Runoff

Resistance to surface flow on most natural surfaces is amply provided by vegetation and litter cover. Most 

Forest soils have very low runoff potential if undisturbed. Rainfall intensity only rarely exceeds 

infiltration capacity of intact soils with cover.

It is unlikely that whole surfaces of treated areas would be made barren by herbicide treatment. In some 

cases, treated dead invasive plants would provide a dead organic cover on the soil. By the same token 

manual grubbing and hand pulling of invasive plants would leave the uprooted vegetation on the ground. 

pdf H3 (table 9) avoids spray treatment on extensive bare areas or obviously poor surface conditions. In 

the event of surface runoff from a treated area winnowing of sediment laden sheet flow can be as much as 

90 percent effective by a vegetative buffer of 100 feet in width, even on steep slopes (Castelle et al. 1994, 

Castelle and Johnson 2000, Fischer and Fischinich 2004)

Treatment on roads does pose a greater risk to eventual surface water contamination because surface 

runoff from bare and or compacted surfaces within the road prism shed precipitation water more readily 

and frequently than natural slopes. In a study at Lake Tahoe, Grismer and Hogan (2005) showed runoff 

from bare road cut slopes have 10 to 50 times the runoff of similar intact native soils. Further and possibly 

more significant, road prism runoff from running surfaces and cut banks is often facilitated with 

engineered ditches and relief pipes. To the extent that drainage may lead onto natural slopes, road surface 

runoff may be buffered. However, road segments that cross streams or penetrate into stream buffers 

provide routes for contaminants to reach streams, whether from rutted running surface, roadside ditches or 

runoff projected onto natural slopes an inadequate distance from the channel for proper buffering. 

Surface sheet flow can carry fine grain soil particles of the order of silts and clays (less than 0.0625 mm 

in diameter). Despite high solubility in water of the herbicides, the typical herbicide molecule has a very 

large mass and some attraction to negatively charge soil particles means that transport in water is only 

likely to occur when attached to soil particles that may be moved by shallow sheet flow.

Results from modeling are shown in table 38 and include a treatment along roads. These results agree 

well with monitoring results from applications on roads in Oregon’s Willamette Valley by the Oregon 

Department of Transportation (Berg 2004).
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

140

Soil Water (Interstitial) Transport

Ten of the 11 proposed herbicides are highly soluble in water with solubility greater than 300 mg/l 

(Bautista and Bulkin 2008). Once into solution, herbicides may transport through the soil as groundwater 

flow, potentially reaching natural surface water bodies. However, another possibility remains; as 

groundwater is dispersed through a soil there is also increasing chance that chemicals will adsorb to the 

soil. The depth of a wetting front for precipitation events following herbicide application marks the 

probable depth of penetration of chemicals and an accumulation zone from additional applications of 

herbicides.

Direct foliar application lowers offsite effects for leaching. If rainfall were to occur during application or 

within the first day after, the risk for leaching exists for all the herbicides. Project design feature H11 

(table 9) lowers leaching risk by avoiding treatment within 24 hours of forecasted rainfall. 

Runoff risk is particularly high for saturated soils during snowmelt, because of low infiltration capacity.

Herbicide application of highly soluble chemicals is avoided during snowmelt when soils are likely to be 

saturated (table 9, pdf H5, H6).

Spraying in spring when soil moisture is high and groundwater flow active may pose greater risk to 

transport of chemicals than in early fall when soil moisture content is very low, even under the same 

conditions of precipitation. Chemicals move into the soil with infiltrating precipitation, but depth of initial 

movement is important. A contaminated wetting front that stops in the top few inches of the soil, in the 

zone of microbial activity, would degrade faster. Herbicides infiltrating into soil with high water content 

and active gravity flow may quickly percolate beyond the range of most soil biota that would reduce the 

chemical. Herbicide half-life (the time it takes half the chemical to degrade), increases sharply when in 

groundwater. Project design feature H10 (table 9) safeguards against spraying under conditions of active 

infiltration or obvious saturated conditions, when herbicides most easily are transported deep into the soil 

column. 

The Groundwater Loading Effect of Agricultural Management Systems (GLEAMS) model (Website: 

http://www.tifton.uga.edu/sewrl/Gleams/gleams_y2k_update.htm), is used to examine the fate of 

herbicides in the rooting zone of the soil. It may be modified for site specific parameters of climate, soils, 

topography, vegetation cover and size and flow rate of natural water bodies and application rate of 

herbicides. We chose these sites because they represent the most sensitive of the known sites for water 

quality. Three of the four sites were adjacent to streams with flow rates varying by an order of magnitude. 

Two of the steams are mapped as bull trout spawning and rearing reaches. 

Table 38. GLEAMS model runs results. All values in ppm.

Dominant soil 

series/map location

Soil series/ 

Texture

General 

Surface 

Condition

Herbicide 

Suite

Conc. In 

Soil 

(12”) 

Conc. In 

Soil (36”)

Peak 

Conc. In 

Water**

Site#1

Invasive: sulphur 

cinquefoil

First choice: 

metsulfuron methyl

Location: T12S 

R31E S18, 

Road: maintenance 

Level 2 Road # 4110

HUC6: Beech

Stream name: Ennis 

Creek

Humarel soil series

Very gravelly clay 

loam, very cobbly 

clay, moderately 

deep, 31 inches

Native surface 

road in conifer 

forest with fair 

grass cover, 

high runoff 

potential, poor 

surface 

condition

Treatment area: 

2800 feet long, 

50 feet wide 

centered on 

road, 0-100 feet 

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapic

imazapyr

0.036

0.0965

0.1169

1.3141

0.0687

0.4026

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.00

0.0001

0.0000

0.0001

0.0002

0.0011
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

141

Dominant soil 

series/map location

Soil series/ 

Texture

General 

Surface 

Condition

Herbicide 

Suite

Conc. In 

Soil 

(12”) 

Conc. In 

Soil (36”)

Peak 

Conc. In 

Water**

Model Run design 

flow 

2cfs 

from stream. Hill 

slope gradient 

20%

metsulfuron

picloram

sethoxydim

sulfometuron

triclopyr*

0.0582

0.3477

0.0975

0.0816

0.5517

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0001

0.0003

0.0001

0.0005

Site# 2

Invasive: Canada 

thistle

First Choice: 

Aminopyralid

Location: T10S 

R34E S35

Road: Maintenance 

Level 2 Road #7106

HUC6: Camp Creek

Stream name: 

unnamed

Model Run design

flow 

2cfs

Five Beaver soil 

series

gravelly silt 

loam/extremely 

cobbly silt loam, 

shallow depth, 14 

inches

Native surface 

road in conifer 

forest with fair 

grass cover, 

high runoff 

potential, poor 

surface 

condition

Treatment area 

1800 feet long 

50 feet wide 

centered on 

road, 350 to 700 

feet from 

stream. Hill 

slope gradient 

27%

aminopyralid

chlorsulfron

clopyralid

glyphosate

imazapic

imazapyr

metsulfuron

picloram

sethoxydim

sulfometuron

triclopyr*

0.0372

0.0832

0.1402

1.3524

0.0709

0.04965

0.0599

0.0356

0.1007

0.1122

0.5659

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0004

0.0000

0.0018

0.0000

0.0001

0.0008

0.0000

0.0003

0.0002

0.0002

0.0003

Site#3

Invasive: St. 

Johnswort

First choice: 

aminopyralid

Location: T10S 

R34E S32, 

HUC6: Camp Creek

Stream name: 

Granite Boulder 

Creek, bull trout 

spawning/rearing

Model Run design 

flow 10cfs

Melloe soil series 

Loam/very cobbly 

sandy clay loam,

very deep, 79

inches

Conifer forest, 

excellent grass, 

moderate runoff 

potential

Treatment area: 

350 feet X 500 

feet along 

Granite Boulder 

Creek and 

below Road 

4611 Hill slope 

3%

aminopyralid

chlorsulfron

clopyralid

glyphosate

imazapic

imazapyr

metsulfuron

picloram

sethoxydim

0.03445

0.0355

0.1304

1.3117

0.0691

0.4854

0.0579

0.3440

0.0978

0.0124

0.0119

0.0475

0.4373

0.0230

0.1619

0.0195

0.1174

0.0326

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

142

Dominant soil 

series/map location

Soil series/ 

Texture

General 

Surface 

Condition

Herbicide 

Suite

Conc. In 

Soil 

(12”) 

Conc. In 

Soil (36”)

Peak 

Conc. In 

Water**

sulfometuron

triclopyr*

0.1091

0.5520

0.0364

0.1843

0.0000

0.0000

Site#4

Invasive: 

houndstongue

First choice: 

chlorsulfron

Location: T11S 

R35E S34, 

Road: maintenance 

Level 2 Road # 2255

HUC6: Clear Creek

Stream name: Clear 

Creek/bull trout 

spawning—rearing 

Model Run design 

flow 

2cfs

Wonder soil series, 

Gravelly silt 

loam/gravelly 

loam, very deep, 

79 inches

Native surface 

road in conifer 

forest with fair 

grass cover, 

high runoff 

potential, poor 

surface 

condition

Treatment area 

1,180 feet long 

and 50 feet wide 

centered on 

road, 180 to 250 

feet from stream

aminopyralid

chlorsulfuron

clopyralid

glyphosate

imazapic

imazapyr

metsulfuron

picloram

sethoxydim

sulfometuron

triclopyr*

0.0372

0.0834

0.1406

1.3525

0.0.071

0.4977

0.0600

0.3601

0.1010

0.1126

0.5676

0.0128

0.0279

0.0490

0.4508

0.0.0237

0.1659

0.0201

0.1208

0.0337

0.0375

0.1893

0.0000

0.0000

0.0000

0.0000

0.0000

0.0002

0.0000

0.0001

0.0001

0.0001

0.0002

*--GLEAMS does not model for ester form triclopyr BEE, only for Triclopyr TEA.

Results of GLEAMS runs are shown in table 38 on selected sites. The location of the selected sites is 

displayed in figure 11. We modeled the results of using any of the 11 herbicides at these sites, however, 

only the first-choice herbicide and other effective herbicides described in table 8 would likely be used, 

unless a new target species were to occupy these sites and need treatment under our EDRR proposal.

None of the predicted peak concentrations in water exceeds drinking water standards as defined by the 

state of Oregon (State of Oregon 2004). Ninety-one different contaminants currently have concentration 

standards including glyphosate (0.7mg/l limit), picloram (0.5 mg/l) and pentachlorophenol the active 

ingredient in clopyralid (0.001 mg/l). In all cases predicted water concentrations are 3 to 4 orders of 

magnitude lower than for the chemicals with stated thresholds

None of the concentrations are of a magnitude that would likely trigger listing as a 303d stream. 

Beneficial uses of streams flowing from the Malheur National Forest are to which impairments are 

evaluated and thereby inclusion on the state 303(d) list are aquatic life, or cool water aquatic life (State of 

Oregon 2010 integrated 303(d0 and 305(b) 

report:http://www.deq.state.or.us/wq/assessment/2010Report.htm). Peak water concentrations predicted 

are far below the levels of concern for fish (see Fisheries report; EIS chapter 3.6) by several orders of 

magnitude. Herbicide spraying largely avoids riparian areas, and in the case of riparian application is not 

of the extent to affect riparian vegetation that shade water and maintain water temperatures. First, 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

143

application within riparian zones would be direct to stems of invasive plants, and second, large woody 

species of the type that provide significant shade would be unaffected. 

Figure 11. Location in Middle Fork John Day River of GLEAMS model sites

Purple shaded streams are bull trout spawning and rearing; green shading is invasive plants sites

In soil and water the conversion of triclopyr BEE and TEA to triclopyr acid is rapid. Both BEE and TEA 

hydrolyze quickly in natural water. Microbial degradation also degrades triclopyr in water. Once TEA and 

TBEE convert to triclopyr, there is little toxicological hazard to aquatic organisms and triclopyr does not 

bio-accumulate to a great extent (Ganapathy 1997).

Effectiveness of Buffers

Bakke (2001) in a review of monitoring results after herbicide spraying on Eldorado and Stanislaus 

National Forests found that buffers of greater than 20 feet were completely effective in eliminating 

Glyphosate and Triclopyr in detectable levels (about 0.5 parts per billion) in adjacent streams. Slight but 

detectable levels (0.5-2.4) were found when buffer widths were 10-15 feet for Glyphosate on the 

Stanislaus National Forest.

Berg (2004) in a comprehensive review of Best Management Practices associated with herbicide spraying 

in region 5 and elsewhere in the United States found similar results. Detectable levels of herbicides such 

as Glyphosate, Triclopyr and Clopyralid were found in various locations (Washington, Oregon, New York 

and Florida) mainly as a result of drift from boom broadcast spray or aerial application. An Oregon 

Department of Transportation study sampled runoff from road shoulders after treatment of Glyphosate, 

with no buffers on a stream. Under simulated rainfall of high intensity they found 100’s of ppb could be 

transported off site. In a similar test, under natural rainfall 0.1-1 ppb was detected leaving the road prism.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

144

The results of these studies show that the GLEAMS results for this project are reasonable, and that the 

greatest risk is from roads with direct hydrologic connection to stream channels

Cumulative Effects 

Depths of maximum concentration presented in GLEAMS results are between 8 and 12 inches (table 38). 

Although the application of herbicide is likely in successive years on most sites, the time between 

applications and the half-life of the various herbicides will minimize residue accumulations. Applying 

herbicides at typical and not maximum recommended rates will limit the amount of excess residue present 

on site each year, while the presence of soil microbes and soil temperatures conducive to degrading the 

herbicides will limit the amount of accumulation.

A list of forestwide projects are scheduled (2013-2015) that will be concurrent with the proposed action

(table 25). There is no other use of herbicide, although most of the activities will involve a level of ground 

disturbance and many will probably risk increasing sediment delivery to streams. However, since the 

amount of sediment that would reach streams in alternative B is so low, there would be no potential for 

cumulative effects to sediment delivery.

Invasive plants are throughout the Malheur National Forest but concentrated in the Middle Fork John Day

drainage. Half-life period, solubility or adsorption of each herbicide determines how readily each will 

transport off site. The greatest risk to water contamination is the possibility of transport of residue 

herbicide on roads that have direct connection to a stream channel. In these circumstances engineered 

drainage features may circumvent buffers. Herbicide half-life period and pdf that limit re-treatments of 

more persistent herbicides largely precludes cumulative effects from multiple treatments at a single site.

The result of the GLEAMS model runs on various scenarios of sites within the project area is consistent

results of several monitoring studies reviewed by Bakke (2001) and Berg (2004). Amounts of herbicides 

in streams are predicted to be below levels of concern for aquatic health. Effect of manual treatment on 

water quality is slight to unmeasureable (R6 FEIS 2005 Appendix J) and adverse impacts would be 

minimal in this alternative. 

Alternative C

Alternative C would have no herbicide use within 100 feet of a stream channel. While table 39 shows that 

under no modeled scenario do the peak water concentration approach the levels of concern for aquatic 

organisms, providing for increased buffer would further reduce effects. GLEAMS model was run for the 

most soluble and/or most toxic of the suite of chemicals that are proposed, for 100 foot buffer sites on 

Granite Boulder Creek and Ennis Creek. These results are given below in table 39.

Table 39. GLEAMS model results for alternative C 

Dominant soil 

series/map 

location

Soil series/ 

Texture General Surface Condition Herbicide 

Suite

Conc. In 

Soil 

(12”) 

Conc. 

In Soil 

(36”)

Peak 

Conc. In 

Water**

Site#1

HUC6: Beech

Stream name: 

Ennis Creek

Humarel soil 

series

Treated area condition: 

native surface road in 

conifer forest with fair grass 

cover, high runoff potential, 

poor surface condition

Stream buffer 100 feet wide, 

good grass cover, good soil 

condition

aminopyralid

clopyralid

imazapyr

picloram

triclopyr*

0.0000

0.0000

0.00.29

0.0000

0.0013

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0001

0.0000
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

145

Dominant soil 

series/map 

location

Soil series/ 

Texture General Surface Condition Herbicide 

Suite

Conc. In 

Soil 

(12”) 

Conc. 

In Soil 

(36”)

Peak 

Conc. In 

Water**

Site# 2

HUC6: Camp 

Creek

Stream name: 

unnamed

Fivebeaver 

soil series

Treated area condition: 

native surface road in 

conifer forest with fair grass 

cover, high runoff potential, 

poor surface condition; 

Stream buffer 100 feet wide, 

good grass cover, good soil 

condition

aminopyralid

clopyralid

imazapyr

picloram

triclopyr*

0.0000

0.0001

0.0027

0.0002

0.001

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

All values in ppm

Table 39 above shows that the peak water concentration are measurably lower within the buffer than out 

(compare to table 38) but that in any case peak water concentrations remain far below any levels of 

concern for aquatic organisms (table 39).

The Water Erosion Prediction Program (WEPP) (Elliot 2004) was used to assess, quantitatively the 

impact of increased manual grubbing of invasive plants on sediment delivery. WEPP has a disturbed 

forest slope, and a forest road application, so that manual grubbing and a typical forest road may be 

compared for amount of sediment produced on a unit area basis of an acre. The Austin weather station 

was used, as with the GLEAMS model. The following parameters were used for inputs into WEPP for the 

Malheur National Forest road application: 0.5 percent grade, 14 feet wide, in-sloped but not ditched with 

medium traffic for equivalent area of treated ground produced over 2 tons of sediment a year on an acre 

basis compared to less than 2 pounds for a natural hill slope treated by manual grubbing, which assumed 

about 40 percent remnant cover, but otherwise in good condition, i.e. non-compacted or rutted.

To take this to a broader scope Camp Creek HUC 5 which contains two of the GLEAMS modeled site has 

677 acres of mapped invasive plants or 31 percent of the total, and also 127 acres of mapped invasive 

acres within 100 feet of a stream channel, 27 percent of the total. Within the Camp Creek watershed is 

150 miles of roads, of which 22.5 miles is within 100 feet of a stream, or approximately 38 acres of 

running surface which equals 78 tons of sediment per year versus 0.06 tons from manual treatment. The 

road surfaces are contributing sediment every year though rates will vary widely according to slope and 

drainage. The above calculations are assuming that every acre of invasive plants in the stream proximity 

will be 100 percent treated.

There would be slight decreases in water concentration of chemicals due to use of wider stream buffers, 

but as with alternative B these levels are barely at detectable levels and far below levels of concern for 

aquatic organisms. There is the potential for increase in sediment delivered to streams because of manual 

treatment within the buffers however this level of activity is well below current delivery rates and likely 

not at measurable levels in streams which contain known aquatic resources.

Cumulative Effects 

As with alternative B there are no other activities that use herbicides on the Malheur National Forest, and 

water concentrations of chemicals under alternative C would be below measured levels of concern. The 

increased potential for sediment delivery to channels is still far below current levels associated with roads 

and ground disturbing activities on a yearly basis and below detectable levels.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

146

Alternative D

Direct and Indirect Effects

Effects of alternative D would be similar to alternative B, except an LRMP amendment would not be 

completed and aminopyralid would not be approved for use on the Malheur National Forest. 

Aminopyralid would not be used to treat known sites or new detections. Compared to alternative B, more 

picloram, clopyralid, and glyphosate would likely be used in lieu of aminopyralid. Herbicide treatment 

could be up to 2,124 acres per year under this alternative.

Glyphosate has high water solubility, but also has very strong adsorption qualities, and in the GLEAMS

model runs never penetrated beyond 8 inches into the soil. It also has a moderately higher toxicity to 

aquatic organisms than the other chemicals being considered here; however never in the model runs,

because of adsorption rate, registered detectable limits of concentration in water. Model runs assume high 

maximum application rates of 7 pounds per acre. It is not expected that wider use of glyphosate due to 

selection of this alternative would lead to water concentrations higher than the model results.

Picloram also has very high water solubility and low adsorption rate to soil, so the chemical has a high 

ability to transport with groundwater, and is very stable under anaerobic conditions. Otherwise it has 

average or even low persistence in research studies. Still, its toxicity to fish and invertebrates is relatively 

high, and because of it transportability and persistence in sediments (where anaerobic conditions might 

prevail), in general use, it poses one of the greatest environmental risks of the entire suite of chemicals 

being proposed. 

Clopyralid has moderately low solubility and soil absorption rate. Toxicity to aquatic organisms is also 

low with LC50 concentrations many orders of magnitude above modeled runs. Clopyralid has however 

high resistance to degradation, particularly in absence of sunlight, nonetheless it is not expected that 

increased use of clopyralid will pose greater risk than model results imply.

Cumulative Effects 

As with alternative B there are no other activities that use herbicides on the Malheur National Forest, and 

water concentrations of chemicals under alternative D, would be below measured levels of concern. The 

potential for sediment delivery to channels would also be very similar to alternative B, which is far below 

current levels associated with roads and ground disturbing activities, and below detectable levels.

3.6 Fisheries

3.6.1 Introduction

Fish species of special conservation concern (e.g., federally listed, USFS sensitive, USFS management 

indicator species) within the aquatic environment analyzed in this report include the native bull trout, 

middle Columbia River steelhead, middle Columbia River Chinook salmon (including essential fish 

habitat), redband (rainbow) trout, and westslope cutthroat trout (table 40). In addition, one USFS sensitive 

aquatic macroinvertebrates and one amphibian species are addressed. All aquatic species of special 

conservation concern (and their habitat) will be analyzed for both effects to individuals and effects to 

habitat.

During public scoping, concerns were raised about the use of herbicides near streams or other surface 

water that may result in herbicide concentrations in water that are harmful to fish (particularly ESA listed 

fish and native fish) and other aquatic organisms. Manual and mechanical treatments can also impact 

water quality, fish, and other aquatic species by disturbing riparian structure or increasing sedimentation. 

This report estimates effects to aquatic species and their habitat from herbicide and non-herbicide 

treatment methods. 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

147

Detailed analyses of federally listed fish species are provided in the project fisheries biological 

assessment (for preferred alternative only). Similarly, USFS sensitive aquatic species are analyzed in the 

project biological evaluation (for all EIS action alternatives).

PACFISH and INFISH are programmatic strategies to help maintain and restore aquatic habitats on the 

Malheur National Forest and other Forests east of the Cascade Mountains. Riparian Management 

Objectives (RMOs) are identified in these strategies and Forest projects are designed to contribute to 

meeting these objectives, or at least not block attainment of RMOs. Our progress toward maintaining and 

restoring good fish habitat is measured at the 3rd to 6th order streams scale, based on measurable 

indicators of good fish habitat.

The indicators are pool frequency, water temperature, amount of large woody debris, lower bank angle of 

the creek, and width to depth ratio. These indicators are addressed through the matrix of pathways and 

indicators discussed for fish species.

Treatments authorized under this invasive plant treatment project could be implemented as part of aquatic 

habitat restoration activities on the Forest. The long term intent is to restore native plant communities to 

the extent possible. However, treatments near the aquatic environment have the potential for short-term 

adverse impacts. In general, these adverse impacts are very small in comparison to the beneficial impact 

of the restoration.

Regulatory Framework

The Executive Order 12962 of 1995 (aquatic systems and recreational fisheries) requires federal agencies 

to conserve, restore, and enhance aquatic systems to provide for increased recreational fishing 

opportunities nationwide. The Order requires federal agencies to evaluate the effects of federally funded 

actions on aquatic systems and document those effects relative to the purpose of this order.

The two principle laws relevant to fisheries management are the National Forest Management Act of 1976 

(NFMA) and the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531 et seq.). Direction 

relative to fisheries is as follows:

• NFMA requires the Forest Service to manage fish and wildlife habitat to maintain viable 

populations of all native and desirable non-native wildlife species and conserve all listed 

threatened or endangered species populations (36CFR219.19).

• ESA requires the Forest Service to manage for the recovery of threatened and endangered species 

and the ecosystems upon which they depend. Forests are required to consult with the U.S. Fish 

and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS) if a proposed 

activity may affect the population or habitat of a listed species.

The Malheur National Forest Land and Resource Management Plan (LRMP) as amended (USDA Forest 

Service 1990), provides direction to protect and manage resources. The specialist report cites a detailed 

list of the portions of the Forest LRMP relevant to fisheries and fisheries habitat requirements. In addition 

Forest standards and guidelines along with relevant laws are cited. Of special interest are Forest LRMP

amendment 29 and PACFISH/INFISH (1995). Recommendations regarding fisheries habitat would 

adhere to this regulatory framework.

Fish-bearing streams, are assigned 600-foot wide (total width) riparian habitat conservation areas 

(RHCAs), as defined within PACFISH/INFISH. RHCA widths along other streams in the Project Area

vary depending on whether streamflow is perennial or intermittent. Treatment within RHCAs is generally 

more restrictive than that within terrestrial habitat types.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

148

Key Watersheds: The intent of designating Key Watersheds is to provide a pattern of protection across 

the landscape where habitat for fish species of special conservation concern would receive increased 

attention and treatment. Priority within these watersheds would be to protect, or restore habitat for listed 

stocks, stocks of special interest or concern, or salmonid assemblages of critical value for productivity or 

biodiversity. Criteria considered to designate Key Watersheds are:

1. Watersheds with stocks listed pursuant to the ESA, or stocks identified in the 1991 American 

Fisheries Society report as “at risk” or subsequent scientific stock status reviews; or 

2. Watersheds that contain excellent habitat for mixed salmonid assemblages; or

3. Degraded watersheds with a high restoration potential

Threatened and endangered species are listed under the ESA; whereas, sensitive species are identified by 

the Forest Service Regional Forester. An endangered species is an animal or plant species that is in danger 

of extinction throughout all or a significant portion of its range. A threatened species is an animal or plant 

species that is likely to become endangered within the foreseeable future throughout all or a significant 

portion of its range. A sensitive species is an animal or plant species for which species viability is a 

concern either a) because of current or predicted downward trend in population numbers or density, or b) 

because of current or predicted downward trends in habitat capability that would reduce a species’ 

existing distribution. Forest Plan Standard 62 (p. IV-32) gives direction to meet all legal and biological 

requirements for the conservation of threatened and endangered plants and animals. 

Standard 62 states, “Assess all proposed projects that involve habitat changes or disturbance and have the 

potential to alter the habitat of threatened, endangered or sensitive plant and animal species.”

When threatened or endangered species or habitats are present, follow the required biological assessment 

process, according to the requirements of the ESA (Public Law 93-205). Forest Plan Standard 64 further 

states, “Meet all consultation requirements with the USFWS and state agencies.” Effects to aquatic 

threatened, endangered, and sensitive species are analyzed in the Aquatic Biological 

Assessment/Evaluation located in the Project Record.

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (Public Law 104-267), requires the inclusion of Chinook salmon 

Essential Fish Habitat (EFH) descriptions in Federal fishery management plans. In addition, the MSA 

requires Federal agencies to consult with NMFS on activities that may adversely affect EFH.

Management Indicator Species (MIS) are species of vertebrates and invertebrates whose population 

changes are believed to best indicate the effects of land management activities. Through the MIS concept, 

the total number of species found within the Forest is analyzed using a subset of species that collectively 

represent habitats, species, and associated management concerns. The MIS are used to assess the 

maintenance of populations (the ability of a population to sustain itself naturally) and biological diversity 

(which includes genetic diversity, species diversity, and habitat diversity), and to assess effects on species 

in public demand. Forest Plan Standard 61 (p. IV-32) lists species and gives direction to provide for 

habitat requirements of MIS species. Aquatic MIS on the Forest include: rainbow/redband trout, bull trout 

and steelhead trout.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

149

3.6.2 Affected Environment

Aquatic Species of Conservation Concern

Table 40 describes aquatic species of conservation concern on the Malheur National Forest. It includes the 

status of each species, whether it is documented or suspected to occur on the Forest, and other specific 

information about the populations that could be affected by forest activities. 

Table 40. Aquatic species of conservation concern

Species Status Occurrence Note

Middle Columbia River 

steelhead 

(Oncorhynchus mykiss)

Federally threatened, 

designated critical 

habitat

Documented occurrence

Middle Columbia River 

distinct population 

segment (DPS)

Bull trout (Salvelinus 

confluentus)

Federally threatened, 

designated critical 

habitat

Documented occurrence

John Day and Malheur 

species management 

units (SMUs)

Middle Columbia River 

Chinook salmon 

(Oncorhynchus 

tshawytscha)

Essential fish habitat 

and USFS sensitive Documented occurrence Essential fish habitat 

(EFH)

Redband trout 

(Oncorhynchus mykiss 

gairdneri)

USFS sensitive* Documented occurrence Widespread

Westslope cutthroat 

trout (Oncorhynchus 

clarkia lewisi )

USFS sensitive* Documented occurrence Present in John Day 

River and tributaries

Western ridged mussel 

(Gonidea angulata) USFS sensitive* Documented occurrence Only known in Middle 

Fork John Day River

*From 2011 Region 6 list.

Steelhead

Steelhead (Middle Columbia DPS, MCR steelhead) was listed by NMFS as threatened under the Federal 

Endangered Species Act (ESA) on March 25, 1999 (64 FR 15417). Middle Colombia River steelhead are 

also a Malheur National Forest management indicator species (MIS). Critical habitat for MCR steelhead 

was designated on September 2, 2005 (70 FR 52630). 

Life History (NatureServe 2013): Migrates between freshwater breeding and marine nonbreeding habitats. 

steelhead typically spend 2 years in fresh water, migrate to marine waters where they spend 2-3 years, 

then return to natal stream to spawn. Most middle Columbia River steelhead smolt at 2 years and spend 1-

2 years in salt water prior to re-entering fresh water, where they remain up to a year before spawning. 

First-time spawners generally are 4-5 years old. Individuals are capable of spawning more than once 

before they die, though spawning more than twice is rare. Steelhead eggs incubate 1.5-4 months before 

hatching (varies with temperature). Juveniles spend 1-4 (generally 2) years in fresh water before 

migrating to the ocean as smolt.

Steelhead are capable of surviving in a wide range of temperature conditions. They do best where 

dissolved oxygen concentration is at least 7 ppm. In streams, deep low velocity pools are important 

wintering habitats. Freshwater habitat types utilized include: big and medium rivers, creeks, low to high 

gradient, pools, and riffles. Usually requires a gravel stream riffle for successful spawning. Eggs are laid 

in gravel in a depression made by the female. Salinity of 8 ppt is the upper limit for normal development 

of eggs and alevins.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

150

John Day River Status (ODFW 2009): The John Day River Major Population Group (MPG) covers 

Oregon’s John Day River drainage. The MPG contains five extant populations (Lower Mainstem John 

Day, North Fork John Day, Middle Fork John Day, South Fork John Day and Upper Mainstem John Day). 

Steelhead in these populations are exclusively summer steelhead. The MPG is one of the few remaining 

summer steelhead groups in the Interior Columbia basin that has had no intentional influence from 

introduced hatchery steelhead and that has recently been classified as strong or healthy. Spawning is 

widely distributed across tributary and mainstem habitats.

The Lower Mainstem John Day River population includes tributaries to the John Day River downstream 

of the South Fork John Day River. This widespread population is the most differentiated ecologically 

from other populations, occupying the lower, drier, Columbia Plateau ecoregion. The North Fork John 

Day River population occupies the highest elevation, wettest area in the John Day basin. Population 

boundaries include the main stem and tributaries of the North Fork John Day River. The population was 

defined based on habitat characteristics, basin topography, and demographic patterns. The Middle Fork 

John Day River population resides in the Middle Fork John Day and all its tributaries. Spawning areas in 

the Middle Fork John Day River are separated substantially from all other spawning areas; except for 

those in the North Fork John Day, that exhibit different habitat characteristics.

Table 41. Special Status Fish in John Day River Watersheds

Watershed Population Current Risk Status

North Fork John Day Highly viable

Upper Mainstem John Day Moderate risk

Lower Mainstem John Day Moderate risk

Middle Fork John Day Moderate risk

South Fork John Day Moderate risk

The following are major limiting factors for the John Day River MPG:

Main limiting factors and threats:

Degraded tributary habitat

Mainstem passage

Hatchery related effects

Predation/competition/disease in mainstem and estuary

Within the analysis area, there are approximately 409 miles of designated critical habitat, dispersed 

throughout 15 watersheds (table 40). A detailed biological assessment (BA) will be prepared for the 

preferred alternative and ESA Section 7 Consultation with the National Marine Fisheries Service (NMFS) 

is underway.

Bull Trout

Bull trout were listed by the USFWS as threatened under the Federal ESA on June 10, 1998 (63 FR 

31647). Critical habitat for bull trout was not designated in the analysis area by the USFWS (70 FR 

56212). Bull trout are also a Malheur National Forest MIS.

The analysis area includes portions of both the John Day and Malheur bull trout species management 

units (SMUs).
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

151

Life History (USDI 2002): Bull trout have more specific habitat requirements than most other salmonid. 

Habitat components that influence bull trout distribution and abundance include water temperature, cover, 

channel form and stability, substrate for spawning and rearing, and migratory corridors. Bull trout are 

found in colder streams and require colder water than most other salmonid for incubation, juvenile 

rearing, and spawning. Spawning and rearing areas are often associated with cold-water springs, 

groundwater infiltration, and/or the coldest streams in a watershed. Throughout their lives, bull trout 

require complex forms of cover, including large woody debris, undercut banks, boulders, and pools. 

Alterations in channel form and reductions in channel stability result in habitat degradation and reduced 

survival of bull trout eggs and juveniles. Channel alterations may reduce the abundance and quality of 

side channels, stream margins, and pools, which are areas bull trout frequently inhabit. For spawning and 

early rearing bull trout require loose, clean gravel relatively free of fine sediments. Because bull trout 

have a relatively long incubation and development period within spawning gravel (greater than 200 days), 

transport of bedload in unstable channels may kill young bull trout. Bull trout use migratory corridors to 

move from spawning and rearing habitats to foraging and overwintering habitats and back. Different 

habitats provide bull trout with diverse resources, and migratory corridors allow local populations to 

connect, which may increase the potential for gene flow and support or refounding of populations. 

Declines in bull trout distribution and abundance are the results of combined effects of the following: 

habitat degradation and fragmentation, the blockage of migratory corridors, poor water quality, angler 

harvest and poaching, entrainment (process by which aquatic organisms are pulled through a diversion 

structure or other device) into diversion channels and dams, and introduced nonnative species. Specific 

land and water management activities that continue to depress bull trout populations and degrade habitat 

include dams and other diversion structures, forest management practices, livestock grazing, agriculture, 

road construction and maintenance, mining, and urban and rural development. Some threats to bull trout 

are the continuing effects of past land management activities.

Bull trout are present within both the Malheur River and John Day River drainages. Occupied waters 

within the John Day River drainage include: headwaters of the North Fork John Day River, Middle Fork 

John Day River, and upper mainstem John Day River and tributaries, with seasonal use of the mainstem 

river downstream to the vicinity of the town of John Day. The John Day River Recovery Unit Team has 

identified 12 extant local populations in the recovery unit. Within the Malheur River drainage occupied 

areas include: North Fork Malheur River and the Upper Malheur River sub-basins, and the Mainstem 

Malheur River from headwaters downstream to Namorf Dam.

Within the analysis area there are approximately 202 miles of designated critical habitat, dispersed 

throughout 6 watersheds within the John Day River and Malheur River drainages.

Redband Trout

Redband trout are currently on the Region 6 USFS sensitive species list, and are also considered a MIS 

species on the Malheur National Forest.

Life History: This is a resident form of rainbow trout, and exhibits habitat preferences similar to those for 

steelhead (described above). Redband trout may migrate within river systems, but do not migrate to the 

ocean. Redband trout populations are widely distributed in all/most major stream drainages (and 

tributaries) within the Malheur National Forest, including the John Day River, Malheur River, and Silvies 

River (table 42).

Westslope Cutthroat Trout

Westslope cutthroat trout are currently on the Region 6 USFS sensitive species list, and are also 

considered a MIS species on the Malheur National Forest.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

152

Life History (NatureServe 2013): Habitat includes small mountain streams, main rivers, and large 

natural lakes; requires cool, clean, well-oxygenated water; in rivers, adults prefer large pools and slow 

velocity areas (stream reaches with numerous pools and some form of cover generally have the highest 

fish densities); often occurs near shore in lakes. Juveniles of migratory populations may spend 1-4 years 

in their natal streams, and then move (usually in spring or early summer, and/or in fall in some systems) 

to a main river or lake where they remain until they spawn. Many fry disperse downstream after 

emergence. Juveniles tend to overwinter in interstitial spaces in the substrate. Larger individuals 

congregate in pools in winter. 

Spawns in small tributary streams on clean gravel substrate; mean water depth is 17-20 cm and mean 

water velocity is 0.3-0.4 m/sec; tends to spawn in natal stream. Adfluvial populations live in large lakes in 

the upper Columbia drainage and spawn in lake tributaries. Fluvial populations live and grow in rivers 

and spawn in tributaries. Resident populations complete the entire life history in tributaries. All three lifehistory forms may occur in a single basin. Migrants may spawn in the lower reaches of the same streams 

used by resident fishes. Maturing adfluvial fishes move into the vicinity of tributaries in fall and winter 

and remain there until they begin to migrate upstream in spring. Of migratory spawners, some remain in 

tributaries during summer months but most return to the main river or lake soon after spawning

Westslope cutthroat trout distribution is not precisely known, but is known to occur within the North Fork 

John Day River and upper mainstem John Day River (widely distributed)

Chinook salmon

Spring Chinook salmon are a Region 6 sensitive species. Essential Fish Habitat (EFH) for spring Chinook 

salmon has been designated by NMFS in the analysis area. 

Life History (USDA 2008a): Salmon are sensitive to changes in water quality and habitat. Juvenile 

Chinook salmon are generally associated with pool habitats. An increase in sediment lowers spawning 

success and reduces the quantity and quality of pool and interstitial habitat. Other important habitat 

features include healthy riparian vegetation, undercut banks and large woody debris.

Adult spring Chinook salmon return to the main stem John Day River and Middle Fork John Day River 

during the spring. Spawning occurs within both drainages, with the majority in the Middle Fork John Day. 

Adults hold in deep pools during the summer while sexually maturing. Spawning occurs during fall, 

generally from August through September. Embryos incubate over the winter and emergence occurs the 

following spring. Juveniles generally rear for one year in freshwater. Juveniles use habitats with slower 

water velocities (pools, glides, and side channels). Juveniles overwinter in deep pools with abundant 

cover. Smoltification and emigration to the ocean occurs in the spring of their second year. The ocean 

rearing phase lasts from 1 to 3 years.

For this analysis, Essential Fish Habitat (EFH) for Chinook salmon is approximated by the distribution of 

steelhead, which includes most perennial streams within the John Day River drainage. Consultation with 

the National Marine Fisheries Service (NMFS) will be conducted.

Western ridged mussel (Jepsen et al. 2010)

The western ridged mussel (Gonidea angulata) is widely distributed from southern British Columbia to 

southern California, and can be found east to Idaho and Nevada. G. angulata inhabits cold creeks and 

streams from low to mid-elevations. Hardhead, Pit sculpin and Tule perch are documented fish hosts for

G. angulata in northern California, although little is known about the fish species that serve as hosts for 

this mussel throughout other parts of its range. G. angulata is sedentary as an adult and probably lives for 

20-30 years, and thus can be an important indicator of habitat quality. G. angulata is a filter feeder that 

consumes plankton and other suspended solids, nutrients and contaminants from the water column. The 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

153

large beds of G. angulata can improve water quality by reducing turbidity and controlling nutrient levels. 

Some Native American tribes historically harvested this animal and used it for food, tools and adornment. 

Populations of G. angulata have likely been extirpated in central and southern California, and it has 

probably declined in abundance in numerous watersheds, including the Columbia and Snake River 

watersheds in Washington and Oregon. The western ridged mussel belongs to a monotypic genus and thus 

would be considered a high priority for conservation. Lack of information on the western ridged mussel’s 

current and historical abundance and distribution, and a lack of understanding of which host fish species it 

uses will impede conservation efforts.

Western ridged mussels have been documented in the Middle Fork John Day River drainage.

Please note that conclusions from the analysis for fishes will be used to qualitatively estimate effects for 

invertebrates since the aquatic species utilize the same habitat, and detailed distribution and habitat 

requirements are not well known for the invertebrates.

The following table displays fish species of aquatic concern within 5th field watersheds on the Malheur 

National Forest. The table shows the acreage infested within each 5th field watershed, and how much of 

the near-stream area (generally within 100 feet of streams and other water bodies) is currently infested in 

each watershed on National Forest System land; total infested acres is approximately 462 acres, with 117 

of these acres located within 25 feet of streams. The order of the watersheds is in descending order of the 

percent (on Forest System lands only) of total near-stream area with mapped infestations. This table 

underscores the fact that most of the 5th field watersheds have scattered infestations that occupy a very 

small percentage of the near-stream area. Of the 39 5th-field watersheds on the Malheur National Forest, 

33 have less than one-half of 1 percent of the near-stream area occupied by invasive plants. 

Table 42. Invasive Plants and Fish Species in 5th field watersheds

Watershed Name HUC 5 code Infested acres

Percent of total nearstream area Fish species*

Upper Middle Fork 

John Day River

1707020301 94.21 1.50 BT, CH, ST, RT

Pine Creek 1705011603 31.01 1.45 RT

Big Creek 1707020303 49.8 1.04 BT, CH, ST, RT

Middle South Fork 

John Day River 1707020103 27.62 .96 CH, ST, RT, WT

Camp Creek 1707020302 94.96 .69 BT, CH, ST, RT

North Basin 1712000101 15.97 .51 RT

Beech Creek 1707020109 21.43 .48 CH, ST, RT, WT

Upper Malheur 

River-Griffin Creek 1705011605 1.64 .43 RT

Upper South Fork 

John Day River 1707020101 18.20 .43 RT

Upper Silvies 

River 1712000201 19.63 .39 RT

Wolf Creek 1705011602 13.97 .33 RT

Little Malheur 

River 1705011612 4.88 .22 RT

Trout Creek 1712000203 19.86 .39 RT

Otis Creek 1705011606 2.15 .22 RT

Silvies Canyon 1712000205 4.97 .16 RT

Emigrant Creek 1712000206 9.79 .11 RT
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

154

Watershed Name HUC 5 code Infested acres

Percent of total nearstream area Fish species*

Bear Creek 1712000202 1.47 .05 RT

Canyon Creek 1707020107 3.66 .05 CH, ST, RT, WT

Fields Creek 1707020111 1.52 .04 CH, ST, RT, WT

Cottonwood Creek 1707020209 3.84 .13 CH, ST, RT, WT

Upper Silver 

Creek 1712000403 .48 .02 RT

Upper North Fork 

Malheur River 1705011611 6.55 .10 BT, RT

Long Creek 1707020304 .64 .02 CH, ST, RT, WT

Upper John Day 

River 1707020106 4.69 .13 BT, CH, ST, RT, WT

Laycock Creek 1707020110 .87 .03 CH, ST, RT, WT

Lower North Fork 

John Day River 1707020210 .17 .00 CH, ST, RT, WT

Murderers Creek 1707020104 1.30 .02 CH, ST, RT, WT

Upper Malheur 

River 1705011601 6.50 .09 BT, RT

Strawberry Creek 1707020108 .44 .01 BT, CH, ST, RT, WT

Buck Creek 1707030303 0.00 0.00% RT

Claw Creek 1712000402 0.00 0.00% RT

Desolation Creek 1707020204 0.00 0.00% RT

Granite Creek 1707020202 0.00 0.00% RT

Grindstone Creek 1707030306 0.00 0.00% RT

Headwaters Silver 

Creek 1712000401 .17 0.00% RT

Lower South Fork 

John Day River 1707020105 0.00 0.00% CH, ST, RT, WT

South Fork Beaver 

Creek 1707030307 0.00 0.00% RT

Twelvemile Creek 1707030305 0.00 0.00% RT

Willow Creek 1712000207 0.00 0.00% RT

Total: 462

* Estimate of potential presence: BT = bull trout, CH = Chinook salmon, RT – redband trout, ST = 

steelhead trout, WT = westslope cutthroat trout

3.6.3 Environmental Consequences

Analysis Methodology

The fisheries analysis is tiered to programmatic documents such as PACFISH and INFISH, and the R6 

2005 FEIS. At the project scale, the different treatment methods were mapped and overlaid with fish 

distribution to see if potentially harmful treatments might occur in proximity to habitat for aquatic species 

of conservation concern. The analysis on treatments is focused within infested areas that lie within 100 

feet of aquatic habitat. 19

 19 If any part of the infested area is within 100 feet of a stream or other water body, the entire area is considered a 

“riparian unit” even if only a portion of the infested sites is near the water body.
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

155

Analysis includes consideration of effects at the infested site scale and also at various watershed scales to 

determine relative risk to fish from the project. The SERA Risk Assessments and GLEAMS model (see

Soil and Water section above for details) were used to determine whether herbicide use could result in 

measurable delivery of herbicide to the stream. For all treatment types (herbicide and non-herbicide), we 

determined the potential for ground disturbing activity that could result in sediment delivery to a stream.

The spatial analysis boundary for aquatics effects are is the administrative boundary of the Malheur 

National Forest. Detectable effects, such as increased turbidity resulting from sediment created by the 

project, are not expected to extend beyond the Malheur National Forest boundary. The temporal boundary 

for analysis extends 15 years into the future (the life of the project). “Short-term” effects refer to the time 

period within 2 years of site-specific (e.g., within a watershed) implementation, with “long-term” 

extending from 2-15 years. The spatial and temporal boundaries are identical for all effects: direct, 

indirect, and cumulative.

Incomplete and Unavailable Information 

The distribution of aquatic organisms throughout the entire analysis area (forest administrative boundary)

is not precisely known. The locations of actual treatment could change over time as new sites of invasive 

plants are discovered or known sites change in size. To ensure that the analysis covers conditions subject 

to change over time (see Early Detection and Rapid Response discussion in chapter 2), we developed 

treatment sideboards and caps, and added many layers of caution to ensure that the analysis describes a 

worst case scenario in terms of adverse effects to aquatic species of concern. Thus, although the precise 

locations, timing and specific treatment methods in any watershed may vary, the impacts have been 

considered in this analysis.

Alternative A

Since no project activities would occur, there are no direct, indirect, or cumulative effects associated with 

choosing the no-action alternative. Not taking action means that the need for eradication, control, 

containment and suppression of invasive plants would not occur and adverse effects on native plant 

communities described previously would continue. Aquatic habitats are harmed when invasive species 

outcompete native vegetation. Native vegetation supports the biotic (e.g., invertebrate community) and 

abiotic (soil stabilization) attributes necessary for high quality aquatic habitat. Continued expansion of 

invasive plants, as is likely occur with no action, (see chapter 3.1.4), would continue to change nearstream biotic and abiotic attributes, and could degrade aquatic and riparian habitats.

Alternative B

Introduction 

The following analysis discusses the potential direct and indirect effects on near-stream and aquatic 

habitat indicators at the site and small watershed scale. Unless otherwise specified, the analysis of habitat 

indicators is relevant to all fish species (federally listed, USFS Sensitive, and MIS) as they share 

overlapping habitat and have very similar habitat requirements.

In summary, serious adverse effects on aquatic organisms, in the short or long term, are unlikely.

Concentrations of herbicides potentially delivered to any water body on the Forest would remain well 

below levels capable of measurably affecting aquatic organisms (chapter 3.4 GLEAMS model results).

Potential effects due to sediment input are discussed below; while sediment contribution from invasive 

plant treatments would be relatively minor, treatments in riparian areas could result in minor local 

changes to fish habitat.
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

156

Direct and Indirect Effects 

Risk assessment worksheets produced by SERA and based on the comprehensive reports (SERA, 2001, 

2004a-d, 2005, 2007, and 2011a-d) have listed concentration levels deemed at acute or chronic toxicity 

for aquatic organisms potentially at risk from water contamination. Table 43 lists these thresholds. 

Generally, the lowest toxicity index available for the species most sensitive to effects was used. Measured 

chronic data (NOEC) was used when they were lower than 1/20th of an acute LC50 because they account 

for at least some sublethal effects, and doses that are protective in chronic exposures are more certain to 

be protective in acute exposures.

Table 43. Levels of concern for fish from project herbicides based on the R6 2005 FEIS and 2007 SERA Risk 

Assessment for aminopyralid

Herbicide Duration Endpoint* Dose** Species Effect Noted at 

LOAEL***

Aminopyralid Acute NOEC 50mg/l Rainbow 

Trout None available

Chronic NOEC 1.35 mg/l Rainbow 

Trout None available

Chronic NOEC1 3.2 mg/L Brown trout rainbow trout length 

affected at 66mg/L

Clopyralid Acute NOEC 5 mg/L (1/20th

of LC50)

Rainbow 

trout LC50 at 103 mg/L

Chronic none available

Glyphosate (no 

surfactant) Acute NOEC 0.5 mg/L 

(1/20th/LC50)

Rainbow 

trout LC50 at 10 mg/L

Chronic NOEC 2.57 mg/L2 Rainbow 

trout

Life-cycle study in 

minnows; LOAEL not 

given

Glyphosate with 

POEA surfactant Acute NOEC

0.065 mg/L 

(1/20th of 

LC50)

Rainbow 

trout

LC50 at 1.3 mg/L for 

fingerlings (surfactant 

formulation)

Chronic NOEC 0.36 mg/L salmonid

estimated from full lifecycle study of minnows 

(surfactant formulation)

Imazapic Acute NOEC 100 mg/L all fish at 100 mg/L, no 

statistically sig. mortality

Chronic NOEC 100 mg/L fathead 

minnow

No treatment related 

effects to hatch or 

growth

Imazapyr Acute NOEC 5 mg/L (1/20th

LC50)

trout, 

catfish, 

bluegill

LC50 at 110-180 mg/L 

for North American 

species

Chronic NOEC 43.1 mg/L Rainbow

“nearly significant” 

effects on early life 

stages at 92.4 mg/L

Metsulfuron methyl Acute NOEC 10 mg/L Rainbow lethargy, erratic 

swimming at 100 mg/L

Chronic NOEC 4.5 mg/L Rainbow standard length effects 

at 8 mg/L

Picloram Acute NOEC 0.04 mg/L 

(1/20th LC50)

Cutthroat 

trout LC50 at 0.80 mg/L

Chronic NOEC 0.55 mg/L Rainbow 

trout

body weight and length 

of fry reduced at 0.88 
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

157

Herbicide Duration Endpoint* Dose** Species Effect Noted at 

LOAEL***

mg/L

Sethoxydim Acute NOEC 0.06 mg/L 

(1/20th LC50)

Rainbow 

trout

LC50 of Poast at 1.2 

mg/L

Chronic NOEC none available

Sulfometuron methyl Acute NOEC 7.3 mg/L Fathead 

minnow

No signs of toxicity at 

highest doses tested

Chronic NOEC 1.17 mg/L Fathead 

minnow

No effects on hatch, 

survival or growth at 

highest doses tested

Triclopyr acid Acute NOEC 0.26 mg/L 

(1/20th LC50)

Chum 

salmon LC50 at 5.3 mg/L3

Chronic NOEC 104 mg/L Fathead 

minnow

Reduced survival of 

embryo/larval stages at 

140 mg/L

Triclopyr BEE Acute 0.012 mg/L Bluegill 

sunfish LC50 at 0.25 mg/L

Chronic4 NOEC 104 mg/L Fathead 

minnow

Reduced survival of 

embryo/larval stages at 

140 mg/L

*--NOEC = No Observed Effect Concentration

**--LC50, Lethal Concentration, 50% kill

***--LOAEL—Lowest Observed Adverse Effect Level

The GLEAMS model was run on four sites within the project area that had the greatest potential for 

herbicide delivery to water near fish habitat. Results indicate that herbicide concentrations in the water are

at least 3 orders of magnitude less than levels of concern for fish, amphibians and aquatic invertebrates 

(table 38, chapter 3.5.3). Very little herbicide would reach water, even in an unbuffered scenario, because 

most of the herbicide is taken up in the plants and soil. The greatest amount of herbicide reaching streams 

in the GLEAMS model results was 0.0011ppm (same as mg/l). This was for the herbicide imazapyr. The 

acute threshold of concern for this herbicide is 5 mg/l; several orders of magnitude larger than the 

expected peak concentration in water, even in the unbuffered, high risk sites). 

Indirect effects from herbicide and non-herbicide treatment methods are possible if bare soil exists 

following treatment, due to the potential for erosion and sediment delivery to streams, primarily in the 

time period between application and native plant regrowth, when soil may be slightly destabilized. 

Vegetation reduction in near-stream areas could slightly alter the food base for fish by changing habitat 

for terrestrial invertebrates; this potential effect would be short term and affect a small minority of total 

terrestrial habitat. The common control measures (table 8) describe the types of treatments proposed for 

the invasive plant target species currently mapped on the Malheur National Forest. 

Project design features and annual and life of the project “caps” would be implemented to minimize or 

eliminate adverse effects at any scale, even assuming the maximum possible treatment that could occur. 

Effects capable of reaching an adverse level for federally listed fish would be related to short-term (a few 

years post-treatment) increases in sediment and turbidity; both herbicide and non-herbicide treatment 

methods could destabilize near-stream soils, though non-herbicide methods (e.g., pulling) generally pose 

a greater risk due to increased soil disturbance. Watershed-based results were extrapolated to the western 

ridged mussel through the assumption that this sympatic species shares most habitat requirements with 

native fish, and results are logically transferable. Assuming that near-stream native vegetation is 

beneficial to aquatic habitat, the long-term result of this project for all aquatic species would be positive 
Chapter 3 – Malheur National Forest Invasive Plant Treatment Draft Environmental Impact Statement

158

as invasive plants are replaced by native species. This change would presumably occur within a few years 

post-treatment in most cases.

Effects on Habitat Indicators

The proposed action would have minimal effects on habitat for aquatic organisms, including species of 

conservation concern. As discussed above, PACFISH-INFISH established riparian management 

objectives to maintain or restore habitat quality for aquatic organisms. Habitat indicators are monitored to 

ensure the trend is in a positive direction, especially over the long term. The PACFISH –INFISH habitat 

indicators are pool frequency, water temperature, amount of large woody debris, lower bank angle of the 

creek, and width to depth ratio. Treatment of invasive plants on the Malheur National Forest is not likely 

to measurably affect any of these indicators. Further discussion about fish habitat indicators is in the 

sections below. Several overlapping types of analysis are done for aquatic organisms, mainly focused on 

species of conservation concern. The following is an analysis of the effects on Steelhead Primary 

Constituent Elements (PCE) for designated critical habitat (NMFS 2005) as determined via analysis of 

“Matrix of Pathways and Indicators” (MPI) analysis. This analysis also covers the Essential Habitat 

Features of Chinook salmon designated critical habitat.

The following analysis results are largely dependent upon project design features and project caps that 

were developed to minimize or prevent a wide range of effect types. A selection of those particularly 

important to chemical contamination and sediment habitat indicators includes the following:

Variable width herbicide-use buffers for all herbicides based on aquatic risk (table 10 and table 11).

No more than 10 percent of the total acres of any 6th field watershed, and no more than 10 acres 

within 100 feet of any water body in a 6th field watershed would be treated with herbicide in a single 

year. 

In riparian and aquatic settings, vehicles (including all-terrain vehicles) used to access invasive plant 

sites or for broadcast spraying will not travel off roadways, trails and parking areas..

For the complete list of project design features see table 9.

PCE Crosswalk – Bull Trout

A crosswalk between the Bull Trout Matrix of Pathways and Indicators (MPI) and Primary Constituent 

Elements (PCEs) of Proposed Critical Habitat. The Matrix of Pathway Indicators (MPI) for bull trout is 

used to evaluate and document baseline conditions and to aid in determining whether a project is likely to 

adversely affect or result in the incidental take of bull trout.

The MPI analysis incorporates 4 population indicators and 19 physical habitat indicators. Analysis of the 

habitat indicators can provide a thorough evaluation of the existing baseline condition and potential 

project impacts to the PCEs of proposed critical habitat for bull trout. Table 44 shows the relationship 

between the PCEs for bull trout critical habitat and the MPI habitat indicators.

The limited ground disturbance and absence of in-stream treatment would limit potential effects to the 

following habitat indicators: temperature, sediment, chemical contaminants/nutrients, large woody debris, 

pool frequency and quality, and riparian conservation areas. The majority of these effects would be of 

very low magnitude, and undetectable in most areas. Treated riparian area vegetation would likely 

experience rapid regrowth, and the majority of near-stream vegetation would not be treated. Stream 

reaches where treatment is concentrated could experience measurable levels of sediment/turbidity 

increase post-project during storm events, but these effects would be spatially restricted, short-term, and 

low-magnitude. PCEs potentially affected (most undetectable) include: 1, 2, 3, 4, 5, 6, 7, and 8. Note: A 

detailed analysis of habitat indicators and PCEs will be completed within the fisheries biological 

assessment for the selected alternative
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

159

Table 44. Bull trout PCEs and MPI habitat indicators

Diagnostic Pathway 

Indicator

PCE 1 PCE 2 PCE 3 PCE 4 PCE 5 PCE 6 PCE 7 PCE 8 PCE 9

Springs, seeps, 

groundwater

Migratory 

Habitats

Abundant 

food base

Complex 

habitats

Water 

Temperature

Substrate 

Features

Natural 

Hydrograph

Water 

quality 

and 

quantity

Predators 

competition

Water Quality

Temperature x x x x

Sediment x x x x

Chemical contaminants 

nutrients x x x x

Habitat Access

Physical Barriers x x x x

Habitat Elements

Substrate Embeddedness x x x

Large Woody Debris x x

Pool Frequency and 

Quality x x x

Large Pools x x

Off-Channel Habitat x x

Refugia x x x

Channel Conditions and Dynamics

Wetted Width/Maximum 

Depth Ratio x x x

Streambank Condition x x x x

Floodplain Connectivity x x x x x x

Flow/Hydrology

Changes in Peak/Base 

Flows x x x x x

Drainage Network 

Increase x x x

Watershed Conditions

Road Density and 

Location x x x

Disturbance History x x x x

Riparian Conservation 

Areas x x x x x

Disturbance Regime x x x
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

160

Pathway: Water Quality

Indicator: Temperature, PCE Crosswalk: Spawning, Rearing, Migration habitat PCEs

Stream temperature is controlled by many variables at each site. These include topographic shading, 

stream orientation, channel morphology, discharge, air temperature, and interactions with ground water, 

which would not be measurably influenced by invasive plant treatments in the vast majority of treatment 

locations. In a few areas, treatment of invasive plants would change understory and ground vegetation, 

and would be limited in quantity by project design features and project “caps,” the majority of shadeproviding vegetation is expected to be retained. This small percentage near-stream areas needing 

treatment would not be capable of changing solar radiation to a degree that would measurably affect 

stream temperature. Therefore, direct or indirect effects on the temperature indicator would not affect 

spawning, rearing, or migration PCEs.

Pathway: Water Quality

Indicator: Chemical Contaminants/Nutrients, PCE Crosswalk: Spawning habitat PCEs

The most likely routes for herbicide delivery to water are potential runoff from a large rain storm soon 

after application, especially from treated roadside ditches. Other concerns such as drift, overspray, and 

spills are addressed through project design features were designed to control drift and overspray.

GLEAMS model results (table 38, chapter 3.5.3) indicate that no chemical water concentrations would 

approach levels of concern for any aquatic species, therefore effects from chemical contamination are 

expected to be negligible in all project watersheds.

The potential risk from accidental spills in RHCAs exists; however, pdf G describes the mechanism to 

minimize the occurrence and restrict highly concentrated chemicals proximity to water.

In summary, alternative B is not likely to adversely affect water quality or result in water contamination 

that could adversely affect fish.

Pathway: Channel Condition & Dynamics

Indicator: Floodplain Connectivity, PCE Crosswalk: Rearing habitat PCE

Some invasive plant treatments can have long-term positive effects on floodplains and streambanks when 

infestations of invasive plants on valley bottom areas are removed. Valley-bottom infestations often 

encroach on floodplains where road-related, grazing, or recreational activities have led to the 

establishment of invasive plant populations. Removal of such infestations is expected to benefit aquatic 

and terrestrial communities in the long-term by increasing floodplain area available for nutrient, sediment 

and large wood storage, and flood flow refugia. Potential localized, short-term, and low-magnitude 

sediment/turbidity increases would not be sufficient to alter channel condition and dynamics. Therefore, 

alternative B is unlikely to affect floodplain connectivity or fish rearing habitat.

Pathway: Habitat Access

Indicator: Physical Barriers, PCE Crosswalk: Migration habitat PCE

Invasive plant treatments would not create physical barriers or otherwise degrade access to aquatic habitat 

since there is no causal mechanism from proposed activities. Habitat access, physical barriers and 

migration habitat would not be affected by alternative B. 

Pathway: Habitat Elements
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

161

Indicator: Substrate/Sediment, PCE Crosswalk: Spawning, Rearing habitat PCEs

Herbicide treatment methods that would be utilized within the riparian areas include spot- spray and hand 

applications. These treatment types are unlikely to produce measurable sediment in the majority of 

locations because very little ground disturbance would take place, though very minor inputs could 

conceivably occur during the period of time between plant death and regrowth. Manual labor such as 

hand pulling may result in localized soil disturbance, but increases of sediment to streams would likely be 

undetectable in most areas. In the few areas where more intense treatment could occur, disturbance areas 

would be limited in quantity by herbicide-use buffers, project design features and project “caps”. 

Sediment increases would be limited to short-term (e.g., a few hours/days) inputs during, and 

immediately following, intense precipitation events. A small increase in turbidity is the most likely effect 

and minor increases in surface fines could occur in some pool habitat. The substrate/sediment indicator 

would not be measurably affected over the long-term because treatment of invasive plants would not 

result in a chronic sediment source; less disturbance would occur during retreatment because populations 

would decrease each treatment entry (see 3.1.4 for more information on treatment effectiveness).

Sediment could affect spawning and rearing PCEs over the short-term within a small minority of 

available habitat; however no measurable change is expected long-term.

Indicator: Large Woody Debris, and Pool Area, Quality and Frequency, PCE Crosswalk: Spawning 

habitat PCE

Treatment of invasive plants would not impact pool area, quality, and frequency as a causal mechanism 

does not exist.

Near-stream treatment of invasive plants would not impact current wood debris in streams. As the vast 

majority of native vegetation would be retained in all treatment sites, it is highly unlikely that future 

woody debris recruitment would be affected. Therefore, spawning habitat would not be affected by 

changes to the large woody debris, and pool area, quality and frequency indicators

Pathway: Flow/Hydrology

Indicator: Change in Peak/Base Flows, PCE Crosswalk: Spawning, Rearing, Migration habitat 

PCEs

A small percentage of each watershed (even small subwatershed) would be treated during a single year; in 

most cases it would be less than one percent. Project “caps” establish an absolute maximum of 10 percent

of any 6th field watershed per year, but this is highly unlikely to occur given that the current level of 

infestation is far lower. The treatments will not affect stream flow or fish migration habitat.

Effects at the 5th field Watershed Scale

Several 5th field watersheds have scattered infestations within 100 feet of aquatic habitat (table 45). The 

focus of the effects analysis for aquatic organisms is on the eight 6th-field watersheds where more than 

one-half of 1 percent of the area within 100 feet of streams or other water bodies is infested. 20 These 

include: Big Creek, Camp Creek, Middle South Fork John Day River, North Basin, Pine Creek, and 

Upper Middle Fork John Day River (figure 12).

 20 Treatment of scattered infestations that occupy less than one-half of one percent of the riparian area in a 6th-field 

watershed are unlikely to have any detectable effects to fish or other aquatic organisms (professional judgment, 

Mease 2013). This is a very conservative level, far below the treatment limits associated with the pdfs and annual 

and life of the project caps. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

162

Table 45. Invasive Plants and Fish Species in 5th field watersheds

Watershed Name

(alphabetical order) HUC 5 code Infested acres

Percent of total nearstream area Fish species*

Big Creek (Middle 

Fork John Day River) 1707020303 49.80 1.04% BT, CH, ST, RT

Camp Creek (Middle 

Fork John Day River) 1707020302 94.96 .69% BT, CH, ST, RT

Middle South Fork 

John Day River 1707020103 27.62 .96% CH, ST, RT, WT

North Basin (Malheur 

River) 1712000101 15.97 .51% RT

Pine Creek 1705011603 31.01 1.45% RT

Upper Middle Fork 

John Day River 1707020301 94.21 1.50% BT, CH, ST, RT
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

163

Figure 12. Focus watersheds for fisheries analysis
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

164

Big Creek Watershed

Approximately 49.80 acres (1.04%) of near-stream treatment is proposed on National Forest System land 

within this watershed.

This watershed contains critical habitat for both steelhead and bull trout, and essential fish habitat for 

Chinook salmon. Habitat exists for redband trout, westslope cutthroat trout (not currently present), and 

western ridged mussel. This watershed is an example of “higher” relative risk, since it contains a 

relatively higher percentage of treatment and contains multiple aquatic species of special conservation 

concern.

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations 

within the following steelhead and/or bull trout critical habitat streams: Middle Fork John Day River, Elk

Creek, Deep Creek, Mosquito Creek, Deadwood Creek, and Swamp Gulch. The areas of highest relative 

risk for measurable sediment effects are along Deep Creek and Mosquito Creek, where, respectively, 

approximately 1 mile (16 acres) and 1⁄2-mile (5-8 acres) of treatment are proposed. The remainders of the 

units are small and spatially separated. Potential sediment/turbidity effects to fish include, but are not 

limited to: altering behavior (e.g., feeding efficiency), gill trauma, oxygen depletion, reduction in habitat 

quality for multiple life stages, and reduction of food organisms. These segments represent less than 10

percent of stream length within the sub-watershed; therefore any effects would be low magnitude and 

short term.

Camp Creek Watershed

Approximately 94.96 acres (.69%) of near-stream treatment is proposed on National Forest System land 

within this watershed.

This watershed contains critical habitat for both steelhead and bull trout, and essential fish habitat for 

Chinook salmon. Habitat exists for redband trout, westslope cutthroat trout, Columbia spotted frog, and 

aquatic invertebrates. This watershed is an example of “higher” relative risk, since it contains a relatively 

higher percentage of treatment and contains multiple aquatic species of special conservation concern.

Infestations are widely distributed throughout this watershed, both along critical habitat and in tributary 

reaches. Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot 

locations within the following steelhead and/or bull trout critical habitat streams: Camp Creek, 

Cottonwood Creek, Lick Creek, Myrtle Creek, Big Boulder Creek, Badger Creek, Dry Creek, Beaver 

Creek, Ragged Creek, Butte Creek, Little Boulder Creek, Windlass Creek, Tincup Creek, Granite Boulder 

Creek, Vincent Creek, Vinegar Creek, Davis Creek, Placer Gulch, Middle Fork John Day River, Blue 

Gulch, Lemon Creek. The areas of highest relative risk for measurable sediment effects are along Caribou 

Creek and Little Boulder Creek, where approximately 1⁄2-mile of treatment would occur along each 

stream. The remainders of units are small (less than 1⁄4-mile along stream) and spatially separated.

Potential sediment/turbidity effects to fish include, but are not limited to: altering behavior (e.g., feeding 

efficiency), gill trauma, oxygen depletion, reduction in habitat quality for multiple life stages, and 

reduction of food organisms. In total, segments proposed for treatment represent less than 10 percent of 

stream length within any sub-watershed; therefore any effects would be low magnitude and short term.

Middle South Fork John Day River

Approximately 27.62 acres (.96%) of near-stream treatment is proposed on National Forest System land 

within this watershed.

This watershed contains critical habitat for steelhead and essential fish habitat for Chinook salmon. 

Habitat exists for redband trout and westslope cutthroat trout.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

165

Most of the treatment proposed in this watershed is along Deer Creek and North Fork Deer Creek, both of 

which are designated critical habitat. Potential sediment/turbidity effects to fishes include, but are not 

limited to: altering behavior (e.g., feeding efficiency), gill trauma, oxygen depletion, reduction in habitat 

quality for multiple life stages, and reduction of food organisms. More than a mile of treatment could 

occur along these two streams. Project “caps” would limit total annual treatment to 10% of the 6th field 

watershed (Corral Creek) where a relatively high concentration of sites exists. In addition, no more than 

10 acres of treatment would occur per year within 100 feet of streams in this sub-watershed. Because 

more treatment could be concentrated in a localized area, sediment/turbidity could be of greater 

magnitude than other areas (low moderate), however duration would be short term. 

North Basin

Approximately 15.97 acres (.51%) of near-stream treatment is proposed on National Forest System land 

within this watershed.

There is no critical habitat for federally listed species within this watershed. Redband trout may be 

present.

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations 

within the following streams: Polson Creek, Devine Canyon, Armstrong Canyon, Cow Creek, Rattlesnake 

Creek, East Fork Rattlesnake Creek, West Fork Rattlesnake Creek, and Middle Fork Rattlesnake Creek. A 

few sites within the Rattlesnake Creek drainage are approximately 1⁄2-mile in length; these sites pose the 

greatest risk of potentially measurable sediment/turbidity effects. Because less than 10 percent of this subwatershed would be treated, any effects that could occur would be of low magnitude and short term. 

Pine Creek

Approximately 31.01 acres (1.45%) of near-stream treatment is proposed on National Forest System land 

within this watershed.

There is no critical habitat for federally listed species within this watershed. Redband trout may be 

present.

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations

within the following streams: Pine Creek and unnamed tributaries, West Fork Pine Creek, and Alkali 

Creek and unnamed tributary. One site along an unnamed tributary in the headwaters of Pine Creek, and a 

site along West Fork Pine Creek, each exceed 1⁄2-mile in length. These areas pose the greatest risk of 

producing measurable sediment/turbidity effects. Potential sediment/turbidity effects to fishes include, but 

are not limited to: altering behavior (e.g., feeding efficiency), gill trauma, oxygen depletion, reduction in 

habitat quality for multiple life stages, and reduction of food organisms. Because less than 10 percent of 

this sub-watershed would be treated, any effects that could occur would be of low magnitude and short 

term.

Upper Middle Fork John Day River

Approximately 94.21 acres (1.50%) of near-stream treatment is proposed on National Forest System land 

within this watershed.

This watershed contains critical habitat for steelhead and bull trout, and essential fish habitat for Chinook 

salmon. Habitat exists for redband trout, westslope cutthroat trout (not currently present), and western 

ridged mussel. This watershed is an example of “higher” relative risk, since it contains a relatively higher 

percentage of treatment and contains multiple aquatic species of special conservation concern.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

166

Based on proximity, detectable sediment effects (e.g., turbidity) could potentially occur in spot locations 

within the following steelhead and/or bull trout critical habitat streams: Middle Fork John Day River, 

Bridge Creek, Clear Creek, Dry Fork Clear Creek, Mill Creek, Crawford Creek, Summit Creek, Idaho 

Creek, and Squaw Creek. The area of highest relative risk for measurable sediment effects is along 

Crawford Creek, where more than a mile of treatment along the stream is proposed. Project “caps” would 

limit total annual treatment to 10 percent of the 6th field watershed (Mill Creek) where this relatively high 

concentration of sites exists. In addition, no more than 10 acres of treatment would occur per year within 

100 feet of streams in this sub-watershed. Because there would be more treatment concentrated in a 

localized area, sediment/turbidity could be of greater magnitude than other areas (low-moderate), 

however duration would be short term.

Species of Conservation Concern Determinations 

Based on quantity of proposed treatment near streams, short-term detectable effects were determined to 

be possible in six watersheds (5th field HUC): Big Creek, Camp Creek, Middle South Fork John Day 

River, North Basin, Pine Creek, and Upper Middle Fork John Day River. Measurable effects in other 

watersheds from treatment of currently mapped infestations are not expected. , More site-specific 

information about fisheries impacts at the sub-watershed scale (6th field HUC) will be developed through 

the ongoing ESA Section 7 consultation process.

Federally Listed Fishes and their Designated Critical Habitat

For federally listed species (steelhead, bull trout) and essential fish habitat (Chinook salmon), the 

potential for short-term adverse effects was determined to exist in four watersheds within the project area: 

Big Creek, Camp Creek, Middle South Fork John Day River, and Upper Middle Fork John Day River. 

Although effects (sediment/turbidity) from these activities are expected to be minor, they could exceed 

the “discountable” threshold, and are therefore “likely to adversely affect fish and their designated critical 

habitat” (see preceding watershed scale analysis for rationale). Potential effects to habitat indicators other 

than sediment are not expected to approach adverse levels. Consultation will be completed with U.S. Fish 

and Wildlife Service and the National Marine Fisheries Service on the preferred alternative prior to a final 

agency decision.

Forest Service Sensitive Species

Forest Service Sensitive species (trout and mussel) exhibit largely overlapping ranges and similar 

vulnerability to effects with the federally listed fishes; therefore, the following determination applies: 

“May impact individuals, but is not likely to cause a trend toward federal listing or loss of viability within 

the planning area.”

Forest Service Management Indicator Species

Forest Service Management Indicator Species (MIS) (resident trout group – e.g., redband) overlap the 

distribution of federally listed fishes, and exhibit similar vulnerability to effects. In summary, there would 

be no reduction in quantity (miles) of stream habitat due to project actions. Habitat quality may be slightly 

reduced in the short-term due to post-implementation sediment input resulting from dead near-stream 

vegetation. This potential effect would occur within a fraction of 1 percent of available habitat; therefore, 

the following determination applies: “May impact individuals, but is not likely to cause a trend toward 

federal listing or loss of viability within the planning area.” In the long term, near-stream conditions 

would be improved as native vegetation re-establishes.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

167

Table 46. Draft Determinations for Fish Species of Conservation Concern

Species Status Determination

Middle Columbia River steelhead 

DPS and designated critical 

habitat

Federally threatened May affect, likely to adversely 

affect.

Columbia River and Malheur 

River bull trout SMUs and 

designated critical habitat

Federally threatened May affect, likely to adversely 

affect.

Middle Columbia River Chinook 

salmon

Essential fish habitat and USFS 

sensitive

Adverse modification of essential 

fish habitat. May impact 

individuals, but is not likely to 

cause a trend toward federal 

listing or loss of viability within the 

planning area.

Redband trout

USFS sensitive

May impact individuals, but is not 

likely to cause a trend toward 

federal listing or loss of viability 

within the planning area.

Westslope cutthroat trout

Western ridged mussel 

Resident trout group (same 

effects as above for same/other 

trout species)

USFS Management Indicator 

Species (MIS)

May impact individuals, but is not 

likely to cause a trend toward 

federal listing or loss of viability 

within the planning area.

Land and Resource Management Plan Amendment

The effects of adding aminopyralid to the list of available herbicides would not adversely affect fish. The 

Environmental Protection Agency classified aminopyralid as a “reduced risk” herbicide and stated that the 

use of aminopyralid as a replacement for other herbicides will decrease risk to some nontarget species 

[including fish] (U.S. EPA 2005 in SERA 2007 Risk Assessment).

Early Detection and Rapid Response

The early detection and rapid response component of the project would have similar impacts to treatment 

of known sites due to the implementation planning process that would ensure new detections are treated 

according to pdfs, treatment caps and herbicide-use buffers. The greatest potential impact would be 

localized sediment/turbidity of low-moderate magnitude as discussed above for areas that currently have 

the highest concentration of invasive plants in a subwatershed.

Direct and Indirect Effects of Alternative C

The conclusions from the analysis for alternative B generally apply to alternative C, with the following 

qualitative differences and clarifications.

The risk of chemical contamination of aquatic habitat from herbicide application associated with 

alternative B would be eliminated due to the absence of near-stream herbicide application. See 

GLEAMS model results for alternative C in chapter 3.5.3 indicating the absence of any herbicide 

reaching streams due to the prohibition on any herbicide use within 100 feet of streams.

A measurable increase in sediment production could result from alternative C as compared to 

alternative B due to an increase in non-herbicide methods, many of which would produce more soil 

disturbance and associated mobilization into stream channels (see chapter 3.4). Treatments would be 

less effective and would require more treatment entries to reach desired conditions (see chapter 3.1.4) 

which could compound the potential effect on sediment and turbidity. 

To the extent that the greater costs and time to reach desired conditions associated with alternative C 

(see chapter 3.1.4), there could be less short- and long-term benefit to the aquatic environment.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

168

Direct and Indirect Effects of Alternative D

The conclusions from the analysis for alternative B generally apply to alternative D, with the following 

qualitative differences and clarifications.

The risk of harm to aquatic habitat from herbicide application would increase because of increased use of 

picloram and glyphosate, two of the herbicides posing greatest risk to aquatic organisms. However, 

despite the increased use of these herbicides, GLEAMS model results show a low risk of these herbicides 

reaching streams. Project design features, herbicide-use buffers and project “caps” provide substantial 

protection, making detectable difference in effects to aquatic organisms and their habitat unlikely, except 

in the case of an unexpected over-application (e.g., spill near water). To the extent that the greater costs 

and time to reach desired conditions associated with alternative D (see chapter 3.1.4), there could be less 

short- and long-term benefit to the aquatic environment. All other potential effects would be similar to 

alternative B, including sediment from all treatment methods. 

Cumulative Effects of All Action Alternatives

The baseline for cumulative effects analysis is the current condition as described in the affected 

environment section above. The differences between alternatives in terms of impacts to fisheries are so 

small that cumulative effects would be the same across alternatives. 

Current and reasonably foreseeable actions on National Forest System lands are listed in chapter 3.1.5. 

Actions that could add to effects within specific watersheds where measureable project-related effects 

(e.g., sediment production) are deemed possible will be addressed qualitatively within the analysis below. 

For the remaining watersheds, where project effects are deemed absent or “discountable”, there would be 

no meaningful additions to the combined effects from other actions.

Herbicides are commonly applied for a variety of agricultural, landscaping and invasive plant 

management purposes. Herbicide use occurs on tribal lands, state and county lands, private forestry lands, 

rangelands, utility corridors, road rights-of-way, and private property. Studies (see chapter 3.1.5) have 

shown that pesticides are commonly found in surface waters in Oregon and throughout the United States. 

However, the studies indicate that herbicide use similar to the type proposed in this project would not 

result in harmful concentrations of herbicide in water. These potential additions will be analyzed 

qualitatively based on percentage of non-national forest lands present within specific watersheds where 

effects are potentially measurable.

Based on the preceding analysis and professional judgment, potential project effects would represent a 

very small percentage of the total (cumulative) from all actions combined. Natural background seasonal 

fluctuation along with sediment/turbidity effects from other actions (e.g., roads, timber harvest, grazing)

exceeds any potential production from invasive plant treatment by orders of magnitude. Herbicide 

concentrations from the project are expected to be undetectable or very low in all waterways, and would 

therefore add little or nothing to cumulative effects.

Sediment production from project actions could add to sources derived from other actions on National 

Forest System lands, tribal lands, state and county lands, private forestry lands, rangelands, utility 

corridors, road rights-of-way, and private property. These potential additions will be analyzed 

qualitatively based on percentage of lands of other ownerships present within specific watersheds where 

effects are potentially measurable.

Within the six watersheds where project-related sediment/turbidity effects could potentially exceed the 

“discountable” threshold, effects are low magnitude and short term. Streams listed (303(d)) for sediment 

within the Middle Fork John Day and Upper John Day watersheds (see Water Quality section) are not 

expected to incur any detectable long-term sediment additions from project activities; spatially isolated 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

169

short-term sediment effects would be limited to low-magnitude turbidity increases and pool surface-fines.

Analysis at the sub-watershed level (6th field HUC) will be completed as part of the Section 7 ESA

consultation process. 

Table 47. Cumulative effects, qualitative estimates within focus watersheds for fisheries

Watershed

Name 

Currently 

Infested 

acres

Other current/future 

Federal actions capable 

of contributing sediment

Percent of 

watershed 

private land 

(approximate)

Projectrelated 

sediment 

based on 

current 

infestations

Long-Term 

Total

Big Creek

(Middle Fork 

John Day 

River)

50 Road maintenance, 

grazing 60%

Low quantity, 

short duration 

(<2 years)

Pre-project 

levels

Camp Creek

(Middle Fork 

John Day 

River)

100

Road maintenance,

prescription fire, timber 

harvest, road 

closures/decommissioning, 

culvert replacements, large 

woody debris in-stream 

placement, grazing

<5%

Low quantity, 

short duration 

(<2 years)

Pre-project 

levels

Middle South 

Fork John Day 

River

28

Road maintenance, juniper 

and mixed conifer cutting, 

fuel treatment, aspen 

restoration, watershed

improvement activities, 

grazing

75%

Low quantity, 

short duration 

(<2 years)

Pre-project 

levels

North Basin 16

Road maintenance, snow 

park relocation, 

prescription fire, timber 

harvest, road 

closures/decommissioning, 

hazard trees, grazing

75%

Very low 

quantity, short 

duration (<2

years)

Pre-project 

levels

Pine Creek

(Malheur River) 31 Road maintenance, prescription fire, grazing 60%

Low quantity, 

short duration 

(<2 years)

Pre-project 

levels

Upper Middle 

Fork John Day 

River

94

Road maintenance, snow 

park, prescription fire, 

timber harvest, road 

closures/decommissioning, 

aspen restoration, aquatic 

restoration, culvert 

replacements, grazing 

<5%

Low quantity, 

short duration 

(<2 years)

Pre-project 

levels

Several other stressors on fish exist, including hydropower development, habitat degradation from human 

activities, direct harvest of fish, and competition from hatchery fish (USDA Forest Service 2008b). These 

are part of the existing condition for aquatic organisms and this project will not influence these 

conditions. 

The analysis assumes maximum levels of treatment over the life of the project. Even given these unlikely 

treatment levels, project-related additions to existing cumulative effects are likely to be minor or nonexistent. At any given site, direct or indirect adverse effects to aquatic organisms under all alternatives

would be low magnitude, localized, and short term. The potential to affect the aquatic environment is 

limited to a low amount of herbicide or sediment, and minor impacts on native riparian vegetation (see 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

170

previous sections of this EIS). These effects are not of a type or extent that would combine with ongoing 

human activities or foreseeable projects on the Forest and produce long-term, cumulative impacts, even 

considering the vectors of invasive plant spread described in chapter 3.1.5.

3.7 Wildlife

3.7.1 Introduction

National Forest System land on the Malheur National Forest (Forest) provides diverse habitats for 

wildlife including grasslands, sagebrush and juniper; fir and pine forests and mountain lakes and 

meadows. These varied habitats provide for a diversity of wildlife including 365 vertebrate species 

including 22 fish, 9 amphibians, 14 reptiles, 235 birds and 85 mammals (Forest LRMP p. III-42). Invasive 

plants have become established and continue to spread, causing a loss of wildlife habitat and posing a risk 

of injury to wildlife on the Malheur National Forest. This section addresses the impacts and benefits of 

the proposed Malheur National Forest Site-Specific Invasive Plants Treatment Project on wildlife and 

wildlife habitat.

Regulatory Framework

The following is a summary of regulatory direction specifically applicable to the management of wildlife 

resources on the project area.

• National Environmental Policy Act (NEPA) of 1969 (as amended) – NEPA requires that effects of 

management actions on wildlife be disclosed and requires that management provide for a 

diversity of plant and animal communities (16 USC 1604((g)(3)(B))

• Endangered Species Act (ESA) of 1973 (as amended) - ESA requires the Forest Service to 

manage for the recovery of threatened and endangered species and the ecosystems, upon which 

they depend. Forests are also required to consult with the United States Fish and Wildlife Service 

if a proposed activity may affect the population or habitat of a listed species.

• National Forest Management Act (NMFA) of 1976 (as amended) - NFMA requires the Forest 

Service to manage fish and wildlife habitat to maintain viable populations of all native and 

desirable non-native vertebrate wildlife species and conserve all listed threatened or endangered 

species populations (36 CFR219.19).

• Executive Order 13186 (Migratory Bird Treaty Act) - The MBTA established an international 

framework for the protection and conservation of migratory birds. This Act makes it illegal, 

unless permitted by regulations, to “pursue, hunt, take, capture, purchase, deliver for shipment, 

ship, cause to be carried by any means whatever, receive for shipment, transportation or carriage, 

or export, at any time, or in any manner, any migratory bird.” Within the NEPA process, effects of 

proposed actions on migratory birds will be evaluated and actions will consider approaches to 

identify and minimize take (USDA Forest Service 2008).

• Forest Service Manual Direction regarding wildlife (FSM 2600) - Forest Service Manual 

direction provides guidance related to Threatened, Endangered and Sensitive (TES) species. It 

requires that the Forest Service identify and prescribe measures to prevent adverse modifications 

or destruction of critical habitat and other habitats essential for the conservation of endangered, 

threatened and proposed species (FSM 2670.31 (6)). It also requires the Regional Forester to 

identify sensitive species for each National Forest where species viability may be a concern 

(Under FSM 2670.32) and mitigate adverse impacts of management activities (FSM 2634).
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

171

The Forest LRMP provides comprehensive guidance for wildlife management. The wildlife report details 

specific objectives, standards and guidelines related to wildlife. This project has very limited impacts to 

wildlife species and most of the Forest LRMP wildlife management direction is not applicable to this 

project.

3.7.2 Affected Environment

Invasive Plants Influence Wildlife Habitat

Invasive plants are thought to generally degrade wildlife habitat, especially for species that require intact 

native plant ecosystems. Some wildlife species use invasive plants for food or cover. For example, 

American goldfinch (Carduelis tristis), and red-winged blackbird (Agelaius phoeniceus) use purple 

loosestrife (Kiviat 1996; and Thompson 1987), and native bighorn sheep will eat cheatgrass (Csuti et al. 

2001). It has been reported that elk, deer, and rodents eat rosettes and seed heads of spotted knapweed.

Doves, hummingbirds, honeybees, and the endangered southwestern willow flycatcher (Empidonax trailii

extimus) are known to use saltcedar (Barrows 1996).

The few uses that an invasive plant may provide do not outweigh the adverse impacts to an entire 

ecosystem (Zavaleta 2000). Invasive plants have adversely impacted habitat for native wildlife in Oregon

(ODFW 2006). Species of wildlife that depend upon native vegetation for food, shelter, or breeding can 

be adversely affected by invasive plants. Species restricted to very specific habitats, for example ponddwelling amphibians, are more susceptible to adverse effects.

Displacement of native plant communities by non-native plants results in alterations to the structure and 

function of ecosystems and constitutes a principle mechanism for loss of biodiversity at regional and 

global scales (Lacey and Olson 1991). Mills et al. (1989) and Germaine et al. (1998) found that native 

bird species diversity and density were positively correlated with the volume of native vegetation, but 

were negatively correlated or uncorrelated with the volume of exotic vegetation. 

Invasive plants can adversely affect wildlife species by eliminating required habitat components, 

including surface water (Dudley 2000; Horton 1977), reducing available forage quantity or quality 

(Bedunah and Carpenter 1989; Rice et al. 1997; Trammell and Butler 1995); reducing preferred cover 

(Rawinski and Malecki 1984; Thompson et al., 1987); drastically altering habitat composition due to 

altered fire cycles (D’Antonio and Vitousek 1992; Mack 1981; Randall 1996; Whisenant 1990); and 

physical injury, such as that caused by long spines or “foxtails” (Archer 2001). In the case of common 

burdock (Arctium minus), the prickly burs can trap bats and hummingbirds and cause direct mortality to 

individuals (Raloff 1998). Invasive plants that grow large and densely (e.g., giant reed, Himalayan 

blackberry) can act as physical barriers to water sources and essential habitat.

Invasive plants can act as a population sink by attracting a species and then exposing it to increased 

mortality or failed reproduction (Chew 1981). Schmidt and Whelan (1999) reported that native birds 

increased their use of exotic Lonicera and Rhamnus shrubs over native trees, even though nests built in 

the exotic shrubs experienced significantly higher mortality rates.

Some invasive plants (such as knapweed) contain chemical compounds that make the plant unpalatable to 

grazing animals. Chemical compounds in these invasive plants disrupt microbial activity in the rumen, or 

cause discomfort after being ingested, resulting in a reduced or avoided consumption of the invasive plant 

(Olson 1999).

Habitats that become dominated by invasive plants are often not used, or are used much less, by native 

and rare wildlife species, and species such as yellow starthistle and knapweed reduce wildlife habitat 

(USDA Forest Service 2007, Utah State University 2013), and degrade upland game bird habitat. Some 

hunters and wildlife managers are concerned that invasive plants are degrading the quality of remaining 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

172

habitat for deer and elk, adversely affecting distribution of the animals and hunting opportunities.

Trammell and Butler (1995) found that deer, elk, and bison avoided sites infested with leafy spurge 

(Euphorbia esula). Tamarisk stands have fewer and less diverse populations of wildlife (Jakle and Gatz 

1985; Olson 1999). Invasion by purple loosestrife makes habitat unsuitable for numerous birds, reptiles, 

and mammals (Kiviat 1996; Lor 2000; Rawinski 1984 and Malecki 1984; and Thompson et al. 1987; 

Weihe and Neely, 1997; Weiher et al. 1996). Reed canarygrass, implicated in the loss of Oregon spotted 

frog habitat, may have contributed to contractions in the range of Oregon spotted frogs in western Oregon 

(Hayes 1997; McAllister and Leonard 1997). Bald eagle mortality in other parts of the U.S. has been 

linked to a toxin produced by cyanobacteria that grow on the invasive aquatic plant, Hydrilla verticillata

(Wilde 2005).

In summary, invasive plants are known or suspected of causing the following effects:

♦ Embedded seeds in animal body parts (e.g. foxtails), or entrapment (e.g. common burdock) 

leading to injury or death.

♦ Scratches leading to infection.

♦ Alteration of habitat structure leading to habitat loss or increased chance of predation (Schmidt 

and Whelan 1999). 

♦ Change to effective population size through nutritional deficiencies or direct physical mortality.

♦ Poisoning due to direct or indirect ingestion of toxic compounds found on or in invasive plants.

♦ Altered food web and nutrient cycling (Allison and Vitousek 2004; Ehrenfeld 2003; Rimer and 

Evans 2006).

♦ Source-sink population demography, with more demographic sinks than sources.

♦ Lack of proper forage quantity or nutritional value at critical life periods.

Terrestrial Wildlife Species of Conservation Concern

Federally Listed Species

The following section discusses species that have been, are currently, are proposed for or are candidates 

for listing under the federal Endangered Species Act (ESA). Threatened and endangered species evaluated 

include the Canada lynx (threatened) and North American wolverine (proposed for listing). Three species, 

the bald eagle, peregrine falcon, and gray wolf have been delisted (USFWS 2007a, USFWS 20011a) and 

are currently managed as Region 6 sensitive species. The project area is within the range of and provides 

habitat for the Columbia spotted frog and greater sage grouse. Because they have not been formally listed, 

these two species are also Forest Service sensitive species.

Table 48. ESA species (listed, proposed, candidate, delisted)

Common

Name

Scientific

Name

Conservation 

Status Species Presence

Canada Lynx Lynx Canadensis Threatened Not Present

North American 

Wolverine Gulo gulo luscus Proposed for Listing Suspected

Gray Wolf1 Canis lupus Delisted-Sensitive Suspected

Bald Eagle1 Haliaeetus 

leucocephalus Delisted-Sensitive Documented

American Peregrine 

Falcon1 Falco peregrinus anatum Delisted-Sensitive Documented
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

173

Common

Name

Scientific

Name

Conservation 

Status Species Presence

Greater Sage Grouse1 Centrocercus 

urophasianus Candidate-Sensitive Documented

Columbia spotted frog1 Rana luteiventris Candidate-Sensitive Documented

1

Evaluated as a Region 6 sensitive species (USDA Forest Service 2011)

The following is a brief description of the species’ life history, threats and generally recognized species 

protection measures. The species status and available habitat on the project area and the amount of habitat 

currently affected by known invasive plant sites are also discussed. Additional information on federally 

listed species can also be found in the biological assessment prepared for the R6 2005 FEIS, which is 

incorporated by reference into this analysis. 

Canada lynx

Status, Life History and Habitat Description - The population, distribution, life history, habitat status and 

recovery objectives for Canada lynx are detailed in Ruggiero et al. (1999), Ruediger et al. (2000), USDI 

Fish and Wildlife Service (2006) and USDI Fish and Wildlife Service (2007c). The following is a 

summary of lynx habitat preferences and biology.

Lynx are highly specialized predators of snowshoe hare (Lepus americanus) and habitat can generally be 

described as moist boreal forests that have cold, snowy winters and a snowshoe hare prey base (USDI 

Fish and Wildlife Service 2006). Lynx habitat generally consists of lodgepole pine, subalpine fir, and 

Engelmann spruce, whereas dry forest types (e.g. ponderosa pine and climax lodgepole pine) generally do 

not provide suitable habitat (Ruediger et al. 2000).

Snow conditions also determine the distribution of lynx (Ruggiero et al. 1999) as lynx are adapted for 

hunting snowshoe hares and surviving in areas that have cold winters and deep, fluffy snow for extended 

periods. Because of the patchiness and temporal nature of high quality snowshoe hare habitat, lynx 

populations require large boreal forest landscapes to ensure that sufficient high-quality snowshoe hare 

habitat is available at any point in time so that lynx may move freely among patches of suitable habitat 

and among subpopulations of lynx (USDI Fish and Wildlife Service 2009a). 

Lynx are highly mobile and long-distance movements (greater than 60 miles) are characteristic (Aubry et 

al. 2000 in Ruggiero et al. 1999). Lynx disperse primarily when snowshoe hare populations decline. Subadults also disperse when prey is abundant and lynx make exploratory movements outside their home 

range (USDI Fish and Wildlife Service 2009a). 

Lynx den sites are located where coarse woody debris, such as downed logs and windfalls and den habitat 

may be located in older regenerating stands or in mature forest where downed woody debris is available

(USDI Fish and Wildlife Service 2007c). Lynx productivity is highly dependent on the quantity and 

quality of winter snowshoe hare habitat which is a limiting factor for lynx persistence. 

Threats - Risk factors for lynx include direct human threat (shooting, trapping, vehicle collisions), as well 

as changes in forage and denning habitat. Lynx have evolved a competitive advantage in deep snow 

environments due to their large paws that allow them to hunt prey where other predators cannot because 

of snow conditions. There is a concern that compacted snow routes allow these other predator’s access 

into isolated areas that are normally used exclusively by lynx (Wisdom et al. 2000). This increased access 

can also increase lynx vulnerability to harvest, collision, or harassment. These concerns have not been 

conclusively verified however. Fire suppression and logging have altered the mosaic of habitats needed 

for prey species and denning sites (ibid.). Invasive plants have not been identified as a threat to lynx.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

174

Project Area Status - The Blue Mountains represent the southern extent of lynx distribution, which would 

explain the rarity of this species on the periphery of its range both historically and now (USDI FWS 

2005), lynx habitat in northeast Oregon is categorized as “peripheral area”. Only four relatively recent 

specimens are known, one from Wallowa County in 1964, Benton County in 1974, Harney County in 

1993 (McKelvey et al. 2000), and near Burns in 1994. Self-maintaining populations of lynx in Oregon 

have not existed historically (Verts and Carraway 1998). Based on limited verified records, lack of 

evidence of reproduction and occurrences in atypical habitat that correspond with cyclic highs, lynx have 

never maintained resident populations, although they are considered an infrequent and casual visitor by 

the state of Oregon (Ruediger et al. 2000, pp. 4-7).

Winter track surveys for lynx and wolverine were conducted by the Forest from 1991-1994 and no 

confirmed lynx tracks were found. Hair snares were used to survey for lynx, according to the National 

Lynx Survey, during the summers of 1999-2001. There were no lynx detections confirmed from this 

survey effort. It is unknown whether lynx are currently present on the Forest, but there are no verified 

records and there is no evidence of occupation or reproduction that would indicate colonization or 

sustained use by lynx. 

Occupied lynx habitat includes lands that either 1) have had at least two verified lynx observations or 

records since 1999, or 2) where there is evidence of lynx reproduction on the national forest (USDI FWS 

2006a). The project area is considered unoccupied lynx habitat because neither of these conditions exists.

Lynx habitat within the project area was mapped using the vegetation and environmental conditions for 

the Northern Rocky Mountains geographic area, and more specifically, the Blue Mountain Section, 

including northeast Oregon and west-central Idaho. Primary vegetation was based on the direction 

provided in the Canada Lynx Conservation Assessment and Strategy (LCAS) (Ruediger et al. 2000), and 

follow-up guidance from the Forest Service Regional Office and the Lynx Biology Team. Sixth code 

Hydrologic Unit Codes (HUC), were used as the basis for delineating lynx habitat across the Malheur 

National Forest. Although the Lynx Conservation Agreement (May 2006), states that the LCAS does not 

apply to forests that are considered as having unoccupied habitat, the lynx analysis units (LAU) acreage 

was used to identify potential lynx habitat on the Malheur National Forest. Suitable lynx habitat occurs in 

the Strawberry, Glacier and Indian Lynx Analysis Units. 

Table 49 identifies the total amount and type of suitable lynx habitat within project area LAUs, as defined 

in the LCAS, as well as known invasive plant infestations within suitable habitat. 

Currently, 16 acres of suitable lynx habitat are affected by invasive plants. The small amount of habitat 

affected by invasive plants is due largely to the low density of roads within potential habitat, which serve 

as primary vectors for the spread of invasive plants and lynx prefer remote, forested areas.

Table 49. Acres of Lynx habitat in the project area

Habitat Denning

(ac)

Foraging

(ac)

Total

(ac)

Suitable Lynx Habitat 26,849 14,158 41,007

Habitat Affected by Invasive Plants 8 8 16

Wolverine

Status Life History and Habitat Description - The wolverine is now a proposed threatened species, per 

findings of the USDI Fish and Wildlife Service, 50 CFR Part 17, 78 FR 7864, Endangered and Threatened 

Wildlife and Plants: Threatened Status for the Distinct Population Segment of the North American 

Wolverine Occurring in the Contiguous United States, dated February 4, 2013, found at 

http://federalregister.gov/a/2013-0148. It has a global rank of G4, and is a State threatened species.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

175

Wolverine is a solitary and highly mobile species that tends to inhabit remote areas and occurs at 

relatively low densities (Banci 1994). Wolverines range widely from subalpine talus slopes to big game 

winter ranges, occupying higher ranges in the summer and riparian habitats in the spring. Ruggiero et al 

(1999) found that wolverines used higher elevations in the snow-free season to avoid high temperatures 

and human activity. Wolverine habitat is best defined in terms of adequate year-round food supplies in 

large sparsely inhabited areas, rather than in terms of particular types of topography or plant associations. 

No particular habitat components or habitat management techniques can presently be singled out for 

wolverine and success of wolverine may relate to the availability of large areas of remote, rugged uplands 

that are difficult to access by humans (Hatler 1989). Wolverines occur in low densities in all places they 

have been studied (Ruggiero et al. 1994). This is generally attributed to naturally low reproductive rates 

and delayed sexual maturity of the species. 

Wolverines are opportunistic feeders and consume a variety of foods depending on availability. They 

primarily scavenge carrion, but also prey on small mammals and birds, and eat fruits, berries and insects 

(USDI Fish and Wildlife Service 2010). In both Montana and Idaho, big game carrion appears to be the 

major food source with snowshoe hare, squirrels, and small mammals making up the rest of their diet 

(Hornocker and Hash 1981). Large mammal carrion is an important dietary component, particularly in 

winter when other prey is scarce (Banci 1994, Pasitschniak and Lariviere 1995) and they rely heavily on 

the presence of other predators. Wolverines will also search for caches made by itself, other wolverines, 

or other carnivores during the winter.

Female wolverines use two kinds of dens for reproduction. Females use natal (birthing) dens to give birth 

and raise kits early postpartum, prior to weaning. They are excavated in snow and persistent, stable snow 

greater than 5 ft. in depth appears to be a requirement for natal denning, (USDI Fish and Wildlife Service 

2013a). In Montana, natal dens occur above 7,874 feet and are located on north aspects in avalanche 

debris typically in alpine habitats near timberline (USDI Fish and Wildlife Service 2013a). Prior to 

weaning, females may move kits to one or multiple alternate den sites, referred to as maternal dens. The 

movement of kits from natal to maternal dens may be a response by the female to den disturbance, better 

food availability in the new location, predation risk, or deteriorating den conditions in the natal den 

(Magoun and Copeland 1998). 

Post-weaning dens are called rendezvous sites. These dens may be used through early July. Females leave 

their kits at rendezvous sites while foraging, and return periodically to provide food for the kits. These 

sites are characterized by natural (unexcavated) cavities formed by large boulders, downed logs 

(avalanche debris), and snow (Inman et al. 2007). They may also occur in talus or coniferous riparian 

zones.

Wolverine home ranges are generally extremely large and the availability and distribution of food is likely 

the primary factor in determining wolverine movements and home range. Home ranges of adult 

wolverines range from less than 38.5 square miles to 348 square miles (USDI Fish and Wildlife Service 

2010). Home ranges of adult males and females overlap extensively with the range of one male covering 

the ranges of two to six females, which is considered one reproductive unit.

Witmer et al. (1998) suggested long-term conservation of wolverine can be achieved through maintenance 

of large, remote areas of habitat and engaging in management activities that do not decrease ungulate prey 

density.

Threats - Wolverines have few natural predators although both interspecific and intraspecific mortalities 

have been documented. Wolverines are susceptible to mortality through hunting and trapping and human 

caused disturbances near den sites (Banci 1994, Hornocker and Hash 1981, Copeland 1996). Wolverine

naturally occur at low densities (Hornocker and Hash 1981, Copeland 1996) and within the area known to 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

176

currently have wolverine populations, relatively few wolverines can coexist due to their naturally low 

population densities.

In their proposed rule to list the wolverine as threatened (USDI Fish and Wildlife Service 2013a), it was 

determined that the impacts of climate change constitute a threat to the contiguous U.S. DPS of the 

wolverine. Wolverine populations in the remaining U.S. range appear to be at numbers so low that their 

continued existence could be at risk. These risks come from three main factors: (1) small total population 

size, 2) effective population below that needed to maintain genetic diversity and demographic stability, 

and 3) fragmented nature of wolverine habitat in the contiguous United States that results in smaller, 

isolated island patches separated by unsuitable habitats. Other threats are secondary and only rise to the 

level of threats to the DPS as they may work in concert with climate changes to affect the third risk factor; 

habitat. In their finding on the wolverine DPS, the USFWS discussed a variety of impacts to wolverine 

habitat including: (1) climate change, (2) human use and disturbance, (3) dispersed recreational activities, 

(4) infrastructure development, (5) transportation corridors, and (6) land management. The primary 

impact of climate change on wolverines is expected to be changes to the availability and distribution of 

wolverine habitat.

Project Area Status - Prior to 1973, wolverines were classified as furbearers in Oregon. Numerous 

animals have been collected or sighted around the northwest. A query of the Oregon Natural Heritage 

database reveals that there are about 150 observations of wolverines in Oregon, with most occurring in 

the mountainous northeast (Baker, Grant, Umatilla, Union and Wallowa Counties) region (ODFW 2013).

Although recent sightings, tracks and a road kill document their presence (Csuti et al 2001), they are 

considered rare throughout all of Oregon, Washington, Idaho, and California.

Periodically throughout the 1990s, wolverine surveys were conducted across the Forest. Records for 

eastern Oregon include a partial skeleton and tufts of fur found near Canyon Mountain, Grant County 

(1992), tracks and a possible denning site discovered in the Strawberry Mountain Wilderness (1997), 

tracks that were noted in the Monument Rock Wilderness (1997), and hair and track collection on Snow 

Mountain Ranger District, Ochoco National Forest (1992). There have been additional unconfirmed 

sightings reported periodically on the Forest although there are no recent verified locations or physical 

evidence of their occurrence. Sightings are mostly from wilderness, or more remote, high-elevation areas.

In the Blue Mountains, source habitat for wolverine occurs primarily in wilderness and large roadless 

areas; although no den sites have been identified. Areas of low human impacts, low human disturbance, 

and high deer and elk concentrations are preferred. The best source habitat is located in the Strawberry 

Mountain Wilderness, Monument Rock Wilderness, Vinegar Hill-Indian Rock Scenic Area, the Jump Off 

Joe, Dixie Butte and Dry Cabin Wildlife Emphasis Areas, and the Shaketable, McClellan Mountain, 

Aldrich Mountain Roadless and Baldy Mountain Roadless Areas.

Collectively, the Malheur National Forest includes approximately 82, 555 acres of wilderness and 

approximately 180, 822 acres of roadless areas and these lands are most likely to be used for denning or 

dispersal. Using the forest GIS habitat layer, potentially suitable den habitat exists on approximately 

1,200 acres forest-wide, with 430 acres occurring in more remote wilderness or roadless areas. Of this, 

almost 80 percent occurs in the Strawberry wilderness. Because deep, persistent snow is characteristic of 

dispersal habitat (Schwartz et al 2009), wolverine dispersal habitat is more likely to occur on upper 

elevation ridges and mountains, whereas potential foraging habitat occurs across much of the Forest.

Invasive plants have not been identified as a primary threat to wolverine. Of the 1,200 acres of den 

habitat, known infestations of invasive plants occur on less than one acre. The low level of invasive 

weeds is likely a result of the low management/use levels associated with wilderness/roadless areas, 

although extensive surveys have not been conducted in remote areas of the Forest.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

177

Forest Service (R6) Sensitive Species

Several terrestrial mammals, birds, amphibians and invertebrate species found or suspected to be on the 

Malheur National Forest are Forest Service Sensitive Species (Table 50, Regional Forester’s Sensitive 

Species List 2011 (USDA Forest Service 2011a)). Management of Forest Service Sensitive Species is a 

proactive approach for meeting the Agencies obligations under the Endangered Species Act and the 

National Forest Management Act (NFMA), and National Policy direction as stated in the 2670 section of 

the Forest Service Manual and the U.S. Department of Agriculture Regulation 9500-4. The primary 

objectives of the Sensitive Species program are to ensure species viability throughout their geographic 

ranges and to preclude trends toward endangerment that would result in a need for federal listing. Species 

identified by the Fish and Wildlife Service as “candidates” for listing under the ESA, as well as species 

that have been de-listed from ESA are managed as R6 Sensitive Species (USDA Forest Service 2011a).

Other species of regional and local conservation concern are also managed as Sensitive Species. This 

section contains a general description of the species’ life history, project area habitat and threats. The two 

woodpeckers shown below are also Management Indicator Species (discussed in the next section below). 

Table 50. Forest Service sensitive species in the project area

Common

Name

Scientific

Name

Species

Status2

Project Area

Documentation1

Mammals

Gray Wolf Canis lupus DL east of Hwy 395, S S

Pygmy rabbit Brachylagus idahoensis S S

Townsend’s Big-eared Bat Corynorhinus townsendii S D

Pallid Bat Antrozous pallidus S S

Fringed Myotis Myotis thysanodes S S

Birds

Bald eagle Haliaeetus leucocephalus DL, S D

American peregrine falcon Falco peregrinus anatum DL, S D

Grasshopper Sparrow Ammodramus savannarum S S

Wallowa Rosy Finch Leucosticte tephrocotis wallowa S S

Greater Sage Grouse Centrocercus urophasianus C, S D

Bufflehead Bucephala albeola S D

Upland Sandpiper Bartramia longicauda S D

Bobolink Dolichonyx oryzivorus S D

Lewis’ woodpecker Melanerpes lewis S, D

White-headed woodpecker Picoides albolarvatus S, D

Amphibians

Columbia spotted frog Rana luteiventris C, S D

Invertebrates

Shortface lanx Fisherola nuttalli S S

Johnson Hairstreak Callophrys johnsoni S S

Silver-bordered Fritillary Boloria selene S D

Harney Basin Duskysnail Colligyrus depressus S D

Columbia Clubtail Gomphus lynnae S S

1 – D – species had been recently documented, S-species thought to occur or that may have suitable habitat

2 - C- candidate for ESA listing, DL-delisted from ESA, S-Region 6 Sensitive Species
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

178

Gray Wolf

Habitat and Threats - The gray wolf is a habitat generalist inhabiting a variety of plant communities, 

typically containing a mix of forested and open areas with a variety of topographic features (Verts and 

Carraway 1998, Witmer et al. 1998). Habitat can include forests of all types, rangelands, brushland, 

steppes, agricultural lands, wetlands, deserts, tundra, and barren ground areas, although the gray wolf 

appears to be more prey dependent than cover dependent. Prey species include white-tailed and mule 

deer, moose, elk, woodland caribou, bighorn sheep, mountain goat, beaver, and snowshoe hare, with small 

mammals, birds, and large invertebrates sometimes being taken, although ungulates comprise 90 percent 

or more of their diet (USDI FWS 1987). They are also opportunistic feeders and will prey on carrion 

when it is available (Witmer et al. 1998).

Wisdom et al. (2000) suggested four major challenges to wolf conservation within the Interior Columbia 

Basin: excessive mortality from humans, mortality related to roads, displacement from habitat by human 

activities and population isolation. Consequently the ability of wolves to persist will be determined 

largely by the degree of human tolerance for the species (Oregon DFW 2005). 

Project Area Information - In Oregon, wolves have increased steadily since re-introduction and wolf 

numbers are currently well above recovery objectives. In northeastern Oregon suitable habitat includes 

Eagle Cap, Wenaha-Tucannon, North Fork John Day, Strawberry Mountain wilderness areas, Hells 

Canyon NRA, designated roadless areas on public lands and areas characterized by low density of open 

roads. Such areas would be characterized as highly suitable because human densities and activity levels 

are low, whereas ungulate numbers are considered adequate to support wolves (Oregon DFW 2005).

The Idaho wolf population has been increasing steadily, and dispersal into the Blue Mountains is expected 

to continue (Oregon DFW 2005). In July 2008, a wolf pack that includes both adults and pups was 

confirmed in a forested area of northern Union county and was the first evidence of multiple wolves and 

wolf reproduction in Oregon. By the end of 2012, Oregon’s minimum wolf count included 53 wolves 

including seven packs and at least five breeding pairs. Another breeding pair was added in February 2013 

(Oregon DFW 2013b). 

While occasional wolf sightings are reported, the gray wolf has not been confirmed within the project 

area. Wolf sighting information to date seems to indicate transient or lone individuals that are not part of a 

resident pack. However the project area provides suitable remote forest habitat and supports large 

populations of big game (Oregon DFW 2005). As a result and considering that a pack has been 

documented approximately 75 miles northeast in Union county, it is likely that over time wolf use could 

occur within the project area. 

Although foraging or dispersal habitat is relatively widespread, remote habitat suitable for denning or 

rendezvous sites is restricted to relatively un-roaded areas. Consequently suitable wolf habitat largely 

occurs within wilderness and roadless areas, which make up almost 263,377 acres on the Forest.

Currently only 16 acres of the wilderness/roadless lands on the Forest have documented infestations of 

invasive plants. However as described under wolverine, due to the lack of surveys in these remote areas, 

infestations may be larger than is currently documented. Although not a threat to wolves, invasive plants 

may adversely affect the quality of habitat for big game populations.

Pygmy Rabbit

Habitat and Threats - Oregon populations of pygmy rabbits are listed as a species of concern under the 

Endangered Species Act (USDI Fish and Wildlife Service 2013b). They typically occur in areas of tall, 

dense sagebrush (Artemisia spp.) cover and are highly dependent on sagebrush to provide food, cover and 

protection from predators throughout the year (USDI Fish and Wildlife Service 2005c, USDI Fish and 

Wildlife Service 2013b). The winter diet of pygmy rabbits is comprised on up to 99 percent sagebrush.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

179

While big sagebrush is the main food of this species, native grasses and forbs are also eaten in mid-late 

summer. Also there is evidence that pygmy rabbits prefer native grasses as forage over other foods during 

this period (USDI Fish and Wildlife Service 2005c).

These rabbits may be active at any time of the day or night, although most activity occurs during midmorning (USDI Fish and Wildlife Service 2005c). Pygmy rabbits dig their own burrows and need deep 

loose textured soils for burrow construction, although they occasionally make use of burrows abandoned 

by other species. As a result they may occur in areas of shallower or more compact soils that support 

sufficient shrub cover (USDI Fish and Wildlife Service 2013b). 

Pygmy rabbits are slow and subject to predation in open areas. Predation is the primary cause of mortality 

among adults and juveniles and can be as high as 50 percent in the first five weeks of life (USDI FWS b). 

Accordingly, pygmy rabbits tend to stay close to their burrows and have small home ranges, although 

home range size and movement distance is variable (U.S. Fish and Wildlife Service 2005c). Loss of 

sagebrush is the main reason for decline of pygmy rabbit populations (USDA Forest Service 2013b).

Agriculture, livestock grazing and associated developments, type conversions of big sagebrush to 

livestock forage, prescribed and wild fires, invasive plants, and roads also degrade their habitat. The 

invasive cheatgrass (Bromus tectorum) is of particular concern because it invades the understory of big 

sagebrush shrubs making a critical habitat site unsuitable for the rabbit (Weiss and Verts 1984).

Cheatgrass and other invasive plants replace important forage species, introduce a perpetuating fire cycle 

into big sagebrush habitat (Whisenant 1990), may reduce predator detection, impede movement, and limit 

dispersal of the pygmy rabbit. McAdoo et al. (2004) stated that weed control is an example of the highest 

priority habitat treatments for sagebrush-associated wildlife and invasive plants are considered a threat to 

the rabbit’s habitat (USDI FWS 2013b). Finally, due to its dependence on cover and limited dispersal 

ability, fragmentation of sagebrush habitat is considered a threat to this species (USDI FWS 2005c). 

Project Area Information - The project area is near the northern boundary of this species range (USDI 

FWS 2005c) and historically, pygmy rabbits have been collected from Deschutes, Klamath, Crook, Lake, 

Grant, Harney, Baker and Malheur Counties in Oregon. However the range of the pygmy rabbit in Oregon 

may have decreased and boundaries of the current distribution are not known (USGS 2007). Not all 

potentially suitable sites appear to be occupied and populations are susceptible to rapid declines and local 

extirpation (Weiss and Verts 1984). Historical and suitable pygmy rabbit habitat was surveyed on State, 

Bureau of Land Management (BLM) and private land in Malheur, Harney, Lake and Deschutes Counties 

in 2004/2005 (USGS 2007). Sighting within Harney County indicate that this species occurs mainly in the 

sagebrush basin south of Burns Oregon. Also an active burrow was documented southeast of Burns, 

Oregon, approximately 17 miles south of the Forest boundary (USGS 2007). 

While there have been no surveys conducted on the Malheur National Forest, and pygmy rabbits have not 

been documented within the project area, suitable habitat exists. Using GIS and Oregon GAP data for big 

sagebrush communities, suitable pygmy rabbit habitat was identified and occurs on approximately 24,715 

acres within the project area. However it is recognized that this is likely an overestimate of the acres of 

suitable habitat, since many sites would not have preferred cover and soil conditions. Currently less than 

10 acres of invasive plants have been documented in suitable habitat.

Townsend’s Big-eared Bat

Habitat and Threats - Townsend’s big-eared bats inhabit a wide variety of habitats from old-growth 

forests to desert. It roosts in caves, mines, rock crevices, buildings, and bridges and hollows of trees, but 

is primarily cave-dependent. The Townsend’s big-eared bat is a moth specialist with over 90 percent of its 

diet composed of moths. It captures prey in flight or by gleaning from foliage (Csuti et al. 2001). They 

forage in edge habitats along streams and woodlands, and within a variety of wooded types. They can 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

180

travel long distances while foraging, including movements of over 90 miles during a single evening 

(WBWG 2005).

The primary threat to the Townsend’s big eared bat is disturbance and/or destruction of roost sites (e.g. 

recreational caving, mine exploration, mine reclamation) and studies in Oregon and Washington have 

reported sizeable reduction numbers due to human visitation and mining (WBWG 2005). Invasive plants 

are not considered a threat to Townsend’s big-eared bats or their habitat.

Project Area Information - Townsend’s big eared bats have been documented from all five project area 

counties (NatureServe 2013). Also they have been recently documented on the Emigrant Creek district, 

and from caves in Dayville and the John Day fossil beds, approximately ten miles east of the project area

(Reames 2013).

Due to the variety of habitat utilized, foraging habitat occurs across the forest, whereas roost and 

hibernacula occurs in buildings, bridges or other structures scattered across the project area. Suitable 

Townsend’s big-eared foraging habitat includes forested and shrub habitat scattered across the project 

area, and of this approximately 1,975 acres have documented infestations of invasive plants. Invasive 

plants do not pose direct threats to this species.

Pallid Bat

Habitat and Threats - The Pallid bat is a year-round resident and most commonly inhabits arid deserts 

and grasslands often near rock outcrops and water, and is less abundant in conifer and mixed forests. This 

bat usually roosts in rock crevices or buildings, and less frequently roosts in caves, tree hollows and 

mines. Oregon night roosts were in buildings, under rock overhangs, and under bridges. It prefers narrow 

crevices in caves as hibernation and shows strong fidelity to roosts both within and between years 

(NatureServe 2013). Pallid bats are opportunistic generalists that glean a variety of arthropod prey from 

surfaces, as well as capture insects on the wing (WBWG 2005). Food items include flightless arthropods, 

crickets, moths, beetles and may eat small vertebrates (NatureServe 2013, WBWG 2005). They forage 

over open shrub-steppe grasslands, oak, savannahs, open ponderosa pine forest, talus slopes, gravel roads 

and orchards (WBWG 2005). 

Pallid bats tend to roost gregariously and are sensitive to disturbance. Loss of modification of foraging 

habitat due to prescribed fire, urban development, agriculture or pesticide use pose potential threats 

(WBWG 2005). Approximately 1,043 acres of preferred riparian, woodland, shrub and grassland habitats 

are known to contain invasive plants. Invasive plants do not pose a direct threat to this species.

Project Area Information - The pallid bat has been documented from Haney, Grant and Malheur 

Counties (NatureServe 2013), including Goose Rocks and the Pallisades (John Day Fossil Beds), 

approximately 10 miles east of the project area. Suitable cliffline habitat occurs along the Malheur River 

canyon, Devine Canyon down to Burns, Oregon, along Middle Fork and Coyote Bluff, and this species 

has been documented at three mine sites in the Vinegar Hill area in 2009 and 2010 (Reames 2013). 

Potential roost and hibernacula occur in cliffline habitat along primary river corridors and in buildings or 

structures scattered across the forest. Pallid bat foraging habitat includes open canopy ponderosa pine 

stands, woodlands, grassland and shrub habitats, which occur on approximately 361,000 acres across the 

Forest. Invasive plants have been documented on 428 acres of this. Invasive plants are not a direct threat 

to this species.

Fringed Myotis

Habitat and Threats - The fringed myotis is a year-round resident in Oregon (NatureServe 2013). While 

distribution is patchy, it is most common in drier woodlands (oak, pinyon juniper and ponderosa pine), 

but is found in a variety of habitats including desert scrub, mesic coniferous forest, grassland and sage-
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

181

grass steppe (WBWG 2005). This species roosts in buildings, underground mines, rocks, cliff faces, and 

bridges, although roosting in large decadent trees and snags is common. Maternity roosts are colonial, 

whereas males are thought to roost singly or in small groups. Hibernation occurs in caves, mines and 

buildings (WBWG 2005). 

The fringed bat feeds on a variety of invertebrate taxa and the relative importance of prey items may vary 

according to prey availability, geography and season. The two most important items commonly reported 

in its diet are beetles (Coleoptera) and moths (Lepidoptera); however flightless taxa such as crickets and 

spiders have been reported. This species is adapted to foraging within the forest interior, as well as along 

forest edges. Modification or loss of roosting habitat is the primary threat, including human impacts to 

caves and hibernacula as well as reduction in forest and suitable snags. Chemicals that affect bats or their 

prey are also a threat (WBWG 2005). 

Project Area Information - The fringed myotis has been documented from Haney and Grant Counties 

(NatureServe 2013), including at the Dunstan Preserve (Middle Fork John Day). Due to the variety of 

habitat utilized, foraging habitat occurs across the forest, whereas roost habitat occurs within mature 

forested habitat, as well as in caves and buildings and along clifflines. While invasive plants are not 

considered a direct threat to this species, approximately 2,124 acres of suitable foraging/roost habitat 

currently contain invasive plants.

Bald Eagle

Habitat and Threats - Bald eagles are protected under the migratory bird treaty act (USDI FWS 2008) 

and the Bald and Golden Eagle Protection Act (USDI FWS 1999b). Management direction is outlined in 

the Bald and Golden Eagle Protection Act. 

Bald eagles are most common along coasts, major rivers, lakes and reservoirs (U.S. Fish and Wildlife

Service 1986), and require accessible prey and trees for suitable nesting and roosting habitat (Stalmaster 

1987). Food availability, such as aggregations of waterfowl or salmon runs, is a primary factor attracting 

bald eagles to wintering areas and influences the distribution of nests and territories (Stalmaster 1987).

Bald eagles feed primarily on fish during the breeding season, and eat waterfowl, seabirds and carrion 

during the winter (U.S. Fish and Wildlife Service 1995).

Bald eagles usually nest in trees near water, but are known to nest on cliffs and (rarely) on the ground.

Nest sites are usually in large trees along shorelines in relatively remote areas that are free of disturbance.

Adults tend to use the same breeding areas year after year, and often the same nest, though a breeding 

area may include one or more alternative nests (U.S. Fish and Wildlife Service 1999a). Wintering eagles 

can be found concentrated at salmon spawning areas and waterfowl wintering areas and a communal 

winter roost generally hosts several eagles each evening at the same site. Winter roosts also tend to offer 

more protection from the weather than diurnal roosts (USDI 1986). Isolation is an important feature of 

winter and night roosts, which are usually located in remote areas with less human disturbance.

A current threat to bald eagles is mortality caused by a new disease, avian vacuolar myelinopathy (AVM) 

(U.S. Fish and Wildlife Service 1999a). A recent hypothesis implicates a type of cyanobacteria that grows 

on the invasive aquatic plant, Hydrilla verticillata (Wilde 2004). The cyanobacteria are thought to 

produce a neurotoxin that is fatal to herbivorous birds and their avian predators. Mortalities caused by 

AVM can have localized impact on bald eagles but there is currently no evidence that the overall recovery 

of the population is affected (U.S. Fish and Wildlife Service 1999a). The invasive aquatic plant, Hydrilla 

verticillata is not known to occur within the project area. 

Bald eagles are still protected by The Bald and Golden Eagle Protection Act, The Lacey Act, and the 

Migratory Bird Treaty Act, whereas management direction is provided in the National Bald Eagle 

Management Guidelines (USFWS 2007b). The guidelines contain recommendations for avoiding 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

182

disturbance to nesting, roosting, and foraging eagles. Agencies are also directed by the Recovery Plan to 

address the issues of forested habitat management, prey species management, forest insect risk 

management, and contingency planning for wildfire risks to eagle habitat.

Project Area Information - The Malheur National Forest has four known bald eagle nest sites, including 

two nests on the Emigrant Ranger District (Silvies River and Delintment Nests) and two nests on the Blue 

Mountain District (Galena and Bear Valley). Also two nests occur immediately south of the proclamation 

boundary on Bureau of Land Management (BLM) administered lands (personal communication between 

Clark Reams and Howard Richburg 2013). The Silvies River and Delintment Lake territories fall within 

the Harney Basin/Warner Mountains recovery zone (RZ21), which has a habitat management goal of 16 

nesting territories and a population goal of 10 breeding pairs of bald eagles. The Blue Mountain nests fall

within the Blue Mountains recovery zone (RZ9), which has a habitat management goal of 14 nesting 

territories, and a population goal of 8 breeding pairs of bald eagles.

There are four designated bald eagle winter roosts on the Forest (Management Area 5) which total 2,507 

acres. Eagles typically arrive in early November and depart about the end of April. The birds often utilize 

private lands in the valleys during the day and fly to different roost areas on the Forest in the evening. The 

Rattlesnake and Coffeepot roosts are located on the Emigrant Creek District along the southern edge of 

the Forest. Roosts on the Blue Mountain Ranger District are on the perimeter of Bear Valley. Winter bird 

count surveys are conducted annually; the Emigrant Creek roost sites get consistent high use, peaking at 

about 50 to 70 birds. The Blue Mountain roost sites are used annually but only support a few eagles. The 

LRMP establishes management area direction for communal winter roost areas, which includes 

maintaining the integrity of the roost sites, maintaining large diameter trees, and minimizing or avoiding 

disturbance during roosting periods. Seasonal closures are typically applied to management activities 

from December 1st through April 1st to help minimize disturbance.

Invasive plants do not pose a threat to the bald eagle. Infestations have been mapped within 3 acres of 

designated winter roost, and 9 acres of infestations are mapped within one-half mile of the Bear Valley 

nest. 

American Peregrine Falcon

Habitat and Threats - Peregrine falcons that inhabit cliffs located generally within approximately 0.5 

miles of riparian habitat (source of prey). Peregrines are aerial predators who feed mostly on birds. Much 

of the prey consists of species the size of pigeons and doves; however avian prey ranges in size.

Disturbance by human activity during the nesting season can cause nest sites and new territories to be 

abandoned, egg breakage, or diversion of adult attention. Peregrine falcons in the Pacific Northwest are 

most affected by bio-accumulation of contaminants, and direct disturbance (Pagel 2006). Invasive plants 

do not adversely affect peregrine falcons.

Project Area Information - While there are no known nest sites, peregrine falcons have been observed on

the Malheur National Forest. Use occurs seasonally as individuals migrate through the area in the spring 

and fall.

In 1992, surveys to identify probable nest sites were conducted on the Malheur National Forest. Cliff 

systems were rated high, medium or low potential as hack sites or cross-foster locations. Sixteen cliff 

systems were surveyed. Locations included: Aldrich Mountain, Baldy Mountain, Canyon Mountain, 

Coyote Bluffs, Fields Peak, Nipple Butte/lake Butte, Malheur River Canyon/Black Canyon, McClellen 

Creek, Moon Mountain, Riley Creek, Ragged Rocks, Silvies Canyon, and multiple cliff systems in and 

around Strawberry Lakes. Most of the cliff systems are located along the series of mountain ranges that 

parallel the John Day Valley on the south side of the valley, primarily the Aldrich and Strawberry 

Mountains on the Blue Mountain and Prairie City Ranger Districts. Coyote Bluffs and Ragged Rocks are 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

183

located in the Middle Fork John Day River drainage on the Blue Mountain Ranger District. Silvies 

Canyon is located south on the Emigrant Creek District. The Malheur River Canyon cliffs are located on 

the Prairie City Ranger District. Strawberry Lakes was rated high potential for nesting habitat; Ragged 

Rocks and Black Canyon were rated medium to high potential. The remaining cliff systems were rated 

medium to low potential. Sites have been periodically surveyed but no nesting peregrines have been 

identified at any of the sites.

While there are no nest sites known to occur on the Forest, suitable foraging habitat occurs across the 

project area.

Grasshopper Sparrow

Habitat and Threats - Although this species has a widespread distribution, it often breeds locally and is 

considered rare or uncommon in much of its range (Slater 2004). In Oregon it is considered one of the 

more enigmatic and erratic birds and a small population may appear in an area, persist for a few years, 

and then disappear, only to return in the future. Suitable habitat in the state is concentrated north of the 

project area in Morrow, Umatilla and Gillam Counties, although suitable grassland habitat occurs in both 

Harney and Malheur Counties (OSU 2013).

The grasshopper sparrow is found in a variety of open grassland types, but is area sensitive and large 

tracks of grassland are more likely to support populations (Slater 2004, PIF 2000, Dechant 2002a). They 

prefer grasslands of intermediate height and are often associated with clumped vegetation interspersed 

with patches of bare ground. Other habitat requirements include moderately deep litter and sparse 

coverage of woody vegetation and shrubs (NatureServe 2013, Slater 2004, Oregon DFW 2013, Janes 

1983, Dechant 2002a). In Morrow county the grasshopper sparrow is occurs at low densities and Holmes 

and Miller (2010) found that grasshopper sparrows were most numerous in perennial grasslands and least 

abundant in depleted sagebrush and sagebrush/annual grass communities.

The grasshopper sparrow forages almost exclusively on bare ground and eats insects, other small 

invertebrates, grain and seeds (NatureServe 2013). During the breeding season grasshoppers (Orthoptera) 

have been documented comprising the majority (greater than 60 percent) of their diet, with seeds taken 

secondarily (Slater 2004). The greatest threats to grassland species such as the grasshopper sparrow 

include continued habitat loss due to encroachment of woody vegetation (Oregon DFW 2013, Slater 

2004), habitat fragmentation and habitat degradation from grazing and fire (Slater 2004). Conservation 

issues specific to the grasshopper sparrow in the Columbia basin (Altman and Holmes 2000) include; 1) 

conversion of bunchgrass habitat to agriculture, 2) alteration of bunchgrass habitat from intensive grazing 

and exotic grass/forb invasions, 3) vulnerability due to agricultural use, 4) shrub encroachment from 

overgrazing and fire suppression, and 5) early season mowing.

Project Area Information - While the grassland sparrow has not been documented on the Forest, larger 

grassland habitat greater than 20 acres in size exists on 46,523 acres and of this, 71 acres are infested with 

invasive plants. However this would be considered an overestimate of suitable habitat because not all 

acres would have the structural characteristics preferred (i.e. clumped vegetation of intermediate height 

with patches of bare ground). Also in many areas they have been documented preferring grasslands 

greater than 75 acres in size (NatureServe 2013).

Wallowa Rosy Finch

Habitat and Threats - This species is restricted to the Wallowa Mountains in Northeast Oregon and 

winters to West-Central Nevada (Clements 2012). Like Leucosticte tephrocotis, the Wallowa rosy-finch 

breeds on the highest alpine peaks, as well as in barren cirques below timbered peaks on the Wallowa 

Mountains. Young remain with adults until fall and they move to lower altitudes and latitudes during the 

winter (OSU 2013). Nests are usually in rock crevices or holes in cliffs. Foraging occurs on the ground 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

184

for seeds and in the spring they glean wind-transported insects from snow. Later in the season they may 

glean insects from vegetation or may chase flying insects in the air (NatureServe 2013). While most high 

elevation habitats are protected, this species can be most benefitted by monitoring and protection of 

known sites.

Project Area Information - Habitat locations for this species have not been mapped on the Malheur 

National Forest. However, habitats are not likely to be infested with invasive plants because they lie in 

remote, high elevation areas that are distant from primary invasive plant vectors. Thus, potentially 

suitable habitat is not likely to be infested with invasive plants, and invasive plants are not a direct threat 

to the Wallowa rosy finch.

Greater Sage Grouse

Status and Habitat Description - A Greater Sage Grouse and Sagebrush Habitat Conservation Team, 

consisting of state and federal agencies, private landowners, conservation groups and academics, was 

established in 2001 to craft a comprehensive set of planning guidelines for sage grouse and sagebrush 

habitats in Oregon. The primary goal of the guidelines is to maintain existing sagebrush-steppe habitats in 

order to sustain sage grouse populations and protect options for future management.

Sage grouse breed on sites called leks (strutting grounds) in March-April. The same lek sites tend to be 

used year after year and they are established in open areas surrounded by sagebrush, which is used for 

escape and protection from predators (Connelly et al. 1991). Optimum sage grouse nesting habitat 

consists of a healthy sagebrush ecosystem including sagebrush plants and an herbaceous understory 

composed of grasses and forbs.

Sage grouse nesting and early brood-rearing occurs in April-June, which is considered a critical time for 

sage grouse. Early brood-rearing generally occurs relatively close to nest sites; however, movements of 

individual broods may be highly variable (Connelly 1982). Hens with broods tend to select habitats 

having a wide diversity of plant species that tend to provide an equivalent diversity of insects that are 

important chick foods. In June and July, as sagebrush habitats dry and herbaceous plants mature, hens 

usually move their broods to moister sites in or adjacent to sagebrush cover where more succulent 

vegetation is available (Connelly and Markham 1983, Connelly et al. 1988). Examples of such habitats 

include low sagebrush (Artemisia nova; A. arbuscula) plant communities, wet meadows and riparian 

areas (Connelly et al. 1988, Connelly and Markham 1983).

Major threats to the species are habitat conversion and degradation. Declines in sage grouse populations 

have been linked to agricultural conversion, rangeland conversion, livestock management, wildfire, 

prescribed fire, fire rehabilitation, structure and infrastructure development, juniper expansion, and 

invasions of exotic species (Blus et al. 1989; Braun 1987, Braun 1998, Connelly et al. 2000, Quigley and, 

Swensen et al. 1987, Wisdom et al. 2000, USDI Fish and Wildlife Service 2003c).

Cheatgrass (Bromus tectorum) invasion has particularly degraded sage grouse habitat by and altering fire 

cycles in the sagebrush-steppe ecosystem (Crawford et al. 2004). The presence of cheatgrass fills in voids 

between shrubs and will carry frequent fires in the same areas. The frequent fires prohibit reestablishment of the big sagebrush and create cheatgrass monocultures that are unsuitable for sage grouse. 

Additional threats include herbicide and insecticide use (Crawford et al. 2004). Insecticide application to 

alfalfa fields in Idaho resulted in mortality to sage grouse that fed on contaminated insects (Blus et al. 

1989, Connelly and Blus 1991). Herbicides were commonly used in sage grouse habitat until the1980s to 

reduce cover of sagebrush and increase livestock forage and these habitat alterations created areas 

unsuitable for sage grouse.

Project Area Information - The largest sagebrush habitats are located on the Emigrant Creek and Prairie 

City Ranger Districts, particularly along the southern boundary of the Forest where sagebrush shrublands 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

185

extend off the Forest and on to BLM lands. Habitat on National Forest System land is often considered 

marginal when compared to larger expanses of habitat located on Bureau of Land Management (BLM) 

and private lands to the south of the Forest and in larger valleys such as Bear Valley and Silvies Valley. 

On the northern half of the Forest, sage brush habitats are small and highly fragmented. There have been 

incidental sightings of sage grouse on the Forest, but sightings are uncommon. There are no documented 

leks or key brood-rearing habitat identified. Sage grouse use appears to be occasional and random within 

suitable habitat.

In 1993, Oregon Department of Fish and Wildlife (ODFW) biologists estimated that Bear Valley had 

about 60 birds and a stable population. In 2003, ODFW revised the 1993 estimates and believe grouse 

populations in Bear Valley may have declined, primarily due to predation (coyotes), but also because of 

livestock grazing and agricultural conversion. Approximately 139,500 acres of suitable habitat have been 

mapped on the Malheur National Forest and 79 acres of invasive plants have been mapped within this 

habitat.

Bufflehead

Habitat and Threats - The bufflehead is a tree-nesting, diving duck whose population has declined 

throughout some of its range (Marshall et al. 2003). For nesting, it uses mountain lakes surrounded by 

woodlands with snags (mostly aspen, but it will use ponderosa pine and Douglas-fir). Buffleheads are 

common in parts of Oregon and Washington during winter, but are rare during the breeding season.

Buffleheads eat animal matter, with common diet items including aquatic insects and larvae, physid 

snails, fish and sometimes herring eggs or salmon carrion. They also eat seeds of aquatic plants, such as 

smartweed, alkali bulrush, and sago pondweed (Marshall et al. 2003). Although no threats to buffleheads 

were identified, the lack of suitable breeding habitat (tree cavities adjacent to lakes) would be limiting in

many areas. 

Project Area Information - Although breeding has not been documented in eastern Oregon, the Forest 

provides stopover habitat during migration and buffleheads have been documented adjacent to the Forest 

in Bear Valley. Suitable habitat includes Forest lakes and wetlands, which occur on approximately 350 

acres Forest-wide and these areas could be used as “stopover” habitat during migration. Currently less 

than an acre of suitable Bufflehead habitat is known to be infested with invasive plants. Invasive plants 

have been identified as a threat to waterfowl (Blossey 1999).

Upland Sandpiper

Habitat and Threats - Upland sandpipers are a rare breeder in large montane meadows within forests of

eastern Oregon and are almost never observed away from their breeding grounds (Oregon DFW 2013). 

They generally nest in extensive, open tracts of short grassland habitat, including native prairie, dry 

meadows, pastures, domestic hayfields, and short-grass savanna, plowed fields along highway rights-ofways and on airfields. Preferred habitat includes large areas of short grass for feeding and courtship with 

interspersed or adjacent taller grasses for nesting and brood cover (Dechant 2002b).

In the Blue Mountains, upland sandpiper habitat is large flat or gently rolling expanses of grassland in 

mountain valleys and open uplands with small creek drainages and wet to dry meadows. Use areas have a 

wide diversity of plants, and forb abundance is particularly important. Occurrence of upland sandpipers is 

positively correlated with patch size and they often utilize meadows which are generally at least 125 acres 

in size. They selectively nest where the vegetation is between 6 and 13 inches tall and avoid fields 

containing relatively uniform stands of grass, tall undisturbed stands of grass, or those seeded to smooth 

brome. Upland sandpipers have strong site fidelity, returning to the same area about the same time each 

year. Other key habitat features near nest sites are loafing and feeding areas that have shorter, sparser 

vegetation than nesting areas and the proximity of a small shrub or tree. Sandpipers are very secretive and 

easily disturbed by humans (Altman 2000).
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

186

Upland sandpipers feed primarily on insects, but also eat ants, berries, and seeds of grasses and forbs 

(Csuti et al. 2001). They prefer upland sites that have higher soil moisture than adjacent areas and 

foraging sites often had surface water during spring. A moderate threat to upland sandpiper habitat exists 

from declines associated with plowing of natural grasslands, degradation and fragmentation of habitat due 

to increased urbanization, farming practices and forest succession (NatureServe 2013).

Project Area Information - From the 1980s through 1991, numbers in Oregon were the largest population 

of nesting sandpipers west of the Rockies. Seven locations make up the Oregon population, and two of 

those areas are Bear Valley and Logan Valley on the Malheur National Forest. In Bear Valley and Logan 

Valley, numbers of nesting upland sandpipers have been declining since mid-1980s.

Bear Valley and Logan Valley locations accounted for over half of the sandpipers in the state in 1984, 

when 23 pair (7 nests) and 3 singles were found in Bear Valley, and 12 pair (2 nests) and 6 singles were 

found in Logan Valley. Nests have been found along ditches or near moist areas, often adjacent to 

sagebrush. Both Bear Valley and Logan Valley have areas of short grasses mixed with forbs and scattered 

sagebrush patches. The removal of sagebrush and the seeding of non-native grasses have altered the 

habitat in Bear Valley east of Highway 395, where upland sandpipers nested in the 1980s. Although bird 

numbers have declined, management has not changed in the rest of Bear Valley, which contains the 

majority of the occupied habitat. Logan Valley management has apparently changed and lodgepole pine 

has encroached in the valley. Water regimes and drainage patterns have also changed which have affected 

the character of the habitat

Potential upland sandpiper habitat includes all grassland and shrubland habitat that is 125 acres in size or 

more and on slopes of less than 25 percent (Dechant 2002b). Approximately 78,669 acres exist Forestwide, although due to the height and structural preferences, preferred habitat would be less. Of the larger 

grassland/shrub habitats that provide potentially suitable habitat 72 acres are currently infested with 

invasive weeds.

Bobolink

Habitat and Threats - The bobolink is a bird of open prairies, grasslands, wet meadows, pastures, and 

grain crops. In Oregon, there are only a few disjunction populations that breed in irrigated hay meadows 

fringed with willows or in wet, grassy meadows with local growths of forbs and sedges. Many of these 

areas are mowed and/or grazed, which facilitates nesting of bobolinks. Bobolinks eat grass and forb seeds 

as well as insects. During the breeding season, more insects are included in the diet, especially 

caterpillars. Keys to management are to provide large areas of suitable habitat (native and tame grasslands 

of moderate height and density with adequate litter, controlling succession, and protecting nesting habitat 

from disturbance during the breeding season (early May to mid-July) (Dechant et al. 2001).

Project Area Information - Limited habitat exists in areas that have grasslands, wet meadows, willows or 

other water-loving shrubs. Oregon GAP data was used to identify potential bobolink habitat, which 

includes all, grasslands, wetlands, wet meadows and willow bottoms. These areas total 17, 080 acres and 

50 acres of invasive plants are known to occur on these lands.

Lewis’ Woodpecker

Status and Habitat Description - Breeding habitat includes open forest and woodland, often logged or 

burned, including oak, coniferous forest (primarily ponderosa pine), riparian woodland and orchards and 

less commonly pinyon-juniper (Millen-McLean 2012d, NatureServe 2013). Important habitat features 

include an open tree canopy, a brushy understory with ground cover, large dead trees and downed woody 

debris (DWD). They prefer open ponderosa pine at high elevations and open riparian vegetation at low 

elevations (NatureServe 2013, Altman and Holmes 2000, Thomas et al. 2009).
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

187

Unlike other woodpeckers, this species seldom excavates its own cavity for nesting and greatest densities 

often occur in areas of high snag density, such as burned areas (Mellen-Mclean 2012a), In late summer, 

wandering flocks move from valleys into mountains and in winter this species uses oak woodlands and 

fruit orchards. Lewis’ woodpeckers feed on adult emergent insects in summer and ripe fruit and nuts in 

the fall and winter. Unlike other woodpeckers, this species does not bore for insects but will take insects 

aerially (hawking), glean insects from tree branches or trunks, or drop from perch to capture insects on 

the ground (NatureServe 2013). Within the Columbia Plateau, historical levels of source habitat have 

declined by 95 percent (Altman and Holmes 2000) and this species has been locally extirpated in parts of 

its range (Altman et al. 2000).

Project Area Information - While the Lewis’ woodpecker has been documented from three counties 

within the project area (Grant, Crook and Baker) (NatureServe 2013), most of the existing sightings have 

occurred in burned areas. However scattered sightings have also occurred within ponderosa pine 

woodland and cottonwood riparian communities in the northern portion of the project area. Habitat for 

this species was identified by looking at; dry ponderosa pine with large snags and open canopies, 

cottonwood/willow communities, and more recent post fire (since 1990) habitat.

Currently approximately 275 acres of invasive plants have been mapped within the 311,700 acres of postfire suitable habitat. Invasive plants are not considered a direct threat to forested habitat preferred by this 

species.

White-heated Woodpecker

Habitat and Threats - White-headed woodpeckers occur mainly in open ponderosa pine or mixed-conifer 

forests dominated by ponderosa pine, usually in old-growth or in stands with old-growth components.

They excavate cavities in snags and also stumps, logs, and dead tops of live trees. Pine seeds are a major 

part of its diet in the fall and winter, although they also probe, glean, and pry off loss bark for insects and 

catch insects in the air. Over the course of the year, pine seeds and insects make up 60 percent and 40 

percent of its diet respectively (NatureServe 2013). Populations in Oregon are decreasing due to 

fragmentation and a loss of forest cover (Audubon 2013).

Project Area Information - The white-headed woodpecker is currently documented from over 60 

locations across the forest with nesting confirmed in the ponderosa pine woodland community. Habitat for 

this species was identified by selecting dry ponderosa, Douglas fir and dry pine communities with an 

open canopy (10-40%) and tree sizes greater than or equal to 21 inches d.b.h. Using this criteria there are 

currently 21,509 acres of white-headed woodpecker habitat scattered across the project area. Of this 

acreage, invasive plants are known to occur on approximately 10 acres. Invasive plants are not considered 

a direct threat to forested habitat preferred by this species.

Columbia Spotted Frog

Status and Habitat Description - The Great Basin Distinct Population Segment (DPS) of the Columbia 

spotted frog is a federal candidate species and is found in Oregon, Idaho, and Nevada. It has been 

documented on the Malheur, Ochoco, Umatilla, and Wallowa-Whitman National Forests. Columbia 

spotted frogs are highly aquatic and usually stay near permanent, quiet water along the grass and sedge 

margins of streams, lakes, ponds, springs, and marshes. Breeding habitats include a variety of relatively 

exposed, shallow-water (less than two feet), emergent wetlands such as sedge fens, riverine over-bank 

pools, beaver ponds, and the wetland fringes of ponds and small lakes. Vegetation in the breeding pools 

generally is dominated by herbaceous species such as grasses, sedges and rushes and froglets and adults 

live in well-vegetated ponds, marshes or slow, weedy streams that meander through meadows (Corkran 

and Thomas 2006). Springs may be used as over-wintering sites for local populations (Hayes et al. 1997).

After breeding, adults often disperse into adjacent wetland, riverine and lacustrine habitats. Columbia 

spotted frogs are capable of long movements, including across uplands (Bull and Hayes 2001).
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

188

Larvae have a diet of algae, plant material, and other organic debris. Adults eat insects (ants, beetles, 

mosquito larvae, and grasshoppers), spiders, mollusks, tadpoles, crayfish, and slugs; arthropods, 

earthworms and other invertebrate prey (NatureServe 2013, Hayes et al. 1997, Csuti et al. 2001). Threats 

to the species include mining, livestock grazing, road construction, agriculture, and direct predation by 

bullfrogs and non-native fishes. Also environmental stressors such as pesticides, herbicides, fertilizers, 

and heavy metals may slow reactions or cause behavioral changes that make spotted frog tadpoles more 

vulnerable to predation (Lefcort et al. 1998, Rosenshield et al. 1999, Marco et al. 1999, Bridges 1999b, 

Bridges and Semlitsch 2000).

Project Area Information - Columbia spotted frogs are believed to be in all sub-basins of the project area 

and this species is often found in natural ponds and lakes, rock pits, old mining ponds, livestock 

stockponds, and slow moving streams that retain water year-round. Spotted frog surveys have been 

conducted periodically since the 1980’s, and although not all areas of the Forest were surveyed, they did 

confirm that the species is fairly well distributed, but occurs at low levels. Most spotted frog sites found 

on the Forest have been found in small pools along perennial streams or in mining ponds and small lakes.

Suitable breeding habitat was estimated using existing wetland habitat, sedge meadow habitat from 

Oregon GAP data and all lands within 300 feet of forest water bodies and springs. This totals 

approximately 58,700 acres and has 52 acres of documented invasive plants. This species could be 

affected by invasive plants, especially in wetland habitats.

Shortface Lanx

Status and Habitat Description - This species is sporadically distributed in the Columbia River and a few 

major tributaries in Oregon, Washington, Montana and Idaho. In Oregon, healthy populations of shortface 

lanx persist in the Deschutes River and smaller populations occur in the John Day and Imnaha Rivers 

(USDA Forest Service 2010a).

Shortface lanx are a non-migrant freshwater snail that can be found in the main channel of fast flowing 

streams and rivers. Habitat includes unpolluted, cold, well oxygenated streams and rivers between 

approximately 100 ft. and 300 ft. in width. They feed by scraping algae and diatoms from rock surfaces 

and require streams/rivers with a cobble/boulder substrate (USDA Forest Service 2010a). Habitat loss and 

pollution are the primary threats to this species. Populations have been lost from most tributaries and 

almost all the Columbia River due to impoundments and the loss of rocky substrate (USDA Forest 

Service 2010a)

Project Area Information - In Oregon the shortface lanx has been documented on the Wallowa Whitman 

National Forest and is suspected on the Malheur and Ochoco Forests (USDA Forest Service 2010a). 

Suitable habitat includes approximately 16 miles of river habitat associated with the John Day and 

Malheur Rivers. Invasive plants are not considered a direct threat to this species, and there are no 

documented invasive plants within 100 feet of suitable habitat.

Johnson Hairstreak

Status and Habitat Description - Scattered sightings have been reported in Oregon in the Cascades Coast 

Range, Siskiyou Mountains, Blue Mountains and Wallowa Mountains (USDA Forest Service 2011b) and 

are associated with old growth and mature forests. Habitats include clearings among conifer forests, 

especially mature ponderosa pine, although lodgepole pine, true fir, Douglas fir and western larch are also 

utilized (Pyle 2002). Larvae feed exclusively on aerial shoots of dwarf mistletoe (Arceuthobium species) 

and adults feed on the nectar of flowers in several families. All sightings in Washington and Oregon have 

been in coniferous forests (Pyle 2002).
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

189

Threats to this species include habitat loss, pesticides such as Bacillus thuringiensis and herbicides which 

are applied to flowering plants which this species visits. Also there is some evidence of hybridization with 

the thicket hairstreak (C. johnsoni) (USDA Forest Service 2011b). 

Project Area Information - While there have been no surveys on the Forest and this species has not been 

documented, Johnson’s hairstreak has been documented from Baker County (Oregon Biodiversity 2010) 

and use is possible. While suitable habitat for this species was not identified, it could occur in coniferous 

forest containing host plants. Invasive plants are not considered a direct threat to habitat for this species.

Silver Bordered Fritillary

In Oregon these butterflies have been found in Big Summit Prairie in Crook County, from the Strawberry 

Mountains in Grant County and from Baker County (USDA Forest Service 2010b, Oregon Biodiversity 

2010). Habitat for this species can be found in bogs, open riparian areas, and in marshes containing large 

amounts of Salix and larval food plants (Warren 2005 In USDA Forest Service 2010b). Adults lay eggs on 

or near violets, usually marsh violet (Viola palustris) and bog violet (V. nephrophylla), whereas adults 

feed on nectar of various composites including mint and Verbena. Sunny habitat encourage adult flight 

and in Baker County annual broods are likely to occur from mid to late May, whereas Grant County 

populations fly between early June and Mid-August (USDA Forest Service 2010b).

The silver-bordered fritillary is dependent upon maintenance of wet meadow habitat and its associated 

food plants. Downcutting of creeks and subsequent draining and drying out of meadow habitat, due in 

part to loss of beaver populations, loss of native plant species due to livestock grazing and invasion of 

non-native grasses are threats to this species.

Project Area Information - While not documented on National Forest System lands, silver-bordered 

fritillary have been documented on adjacent private land and use of suitable wet meadow habitat on the 

forest is likely. Suitable habitat includes riparian/wetland non-forest communities identified from the 

forest wetland and vegetation GIS layers, combined with Oregon GAP wet/sedge meadow habitat.

Currently there are approximately 22,100 acres of potentially suitable habitat and of this 34 acres are 

known to contain invasive plants.

Harney Basin Duskysnail

Status and Habitat Description - To date in Oregon this species is only documented from the Silvies 

River drainage in Harney County and from the Fremont Winema National Forest in Lake County (USDA 

Forest Service 2013). Little is known about the feeding habitats, growth, reproduction, or life span of this 

recently described species and hydrobiidae snails, in general feed on algae, diatoms, and detritus. Habitat 

includes shallow, cold springs and runs at elevations between approximately 4,480 ft./ and 4.670 ft. with

surrounding vegetation of sage scrub (Deixis MossuscDB 2009, Hershler 1999 In USDA Forest Service

2013). While abundance estimates of this species have not been conducted, the Forest Service noted very 

high abundance at one large spring site and most rocks had many snails attached, and thousands of 

individuals were thought to be present (2013).

Any modification of the cold-water spring environment where this species lives could be a potential threat 

to its survival. A number of habitat threats have been identified for this species including; livestock 

grazing, water and site degradation associated with recreation, and wildfire and retardant chemicals. 

Conservation strategies include protecting known sites and maintenance of water quality and substrate 

conditions (USDA Forest Service 2013).

Project Area Information - This species has been documented on the Malheur National Forest and is 

suspected on the Ochoco National Forest and on adjacent BLM land (USDA Forest Service 2013). The 

Malheur National Forest site (Spring Creek) where this species occurs is a large cold water perennial 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

190

spring flowing out of a lava cliff. The springs create a fast, cold flow, are about 15 ft. wide and one to 

eight inches deep. Fish are present and yellow monkey flower (Mimulus sp.) water cress (Nasturtium sp.) 

and other aquatic and riparian plants are prevalent. This relatively large spring is one of a series of smaller 

springs in the area, and appears to be a secure habitat for this species due to lava boulder field offering 

protection from grazing; however, part of the site is a favorite local recreational site that receives a high 

level of riparian disturbance and recreation in the creek (USDA Forest Service 2013).

There are no known invasive plants at the Spring Creek site, although invasive plants are mapped in the 

surrounding watershed. Invasive plants are not considered a direct threat to this species.

Columbia Clubtail

Status and Habitat Description - In Oregon the Columbia clubtail is known to occur over a somewhat 

short stretch (about 15 miles) of the John Day River in Wheeler and Grant Counties and from a single 

location on the Owyhee River near Rome in Malheur County. Although this dragonfly is fairly common 

in areas where it is found, it has one of the most restricted ranges of any North American odonate (USDA 

Forest Service 2012). This non-migratory dragonfly can be found in a variety of river habitats, which can 

range from sandy or muddy to rocky, shallow rivers with occasionally gravelly rapids. Water flow tends 

to be slow moving and larval river habitat is most critical. Eggs are laid in the water and after hatching;

larvae burrow in the mud and overwinter. After emerging from the water, adults forage among shrubs 

from mid-June to mid-August (USDA Forest Service 2012). Threats include activities that affect siltation 

or runoff and introduction of predatory fish (ibid.).

Project Area Information - While not documented on the Forest, it has been documented below the

Forest boundary in the John Day River and suitable habitat is present. Forestwide there are approximately 

100 miles of riverine habitat which may provide breeding and winter habitat. There are currently 51 acres 

of invasive plants within 300 feet of Forest riverine habitat. This species is not adversely affected by 

invasive plants.

Management Indicator Species

Management Indicator Species (MIS) are selected species whose welfare is believed to be an indicator of 

the welfare of other species using the same habitat, or a species whose condition can be used to assess the 

impacts of management actions on a particular area (Thomas et al. 1979). Management Indicator Species 

on the Forest are identified in table 51 and are grouped into three categories including 1) big game 

(commonly hunted species), 2) old growth, and 3) primary cavity excavators (PCE’s). The following 

section discusses MIS by the habits they represent

Table 51. Management Indicator Species on the Malheur NF and Ochoco NF

Species Representing Habitat/Indicator

Rocky Mountain Elk Big Game/commonly hunted 

species

General forest habitat conditions and winter 

range. 

Pileated Woodpecker

Old Growth, Primary Cavity 

Nester, snags

and downed wood

Late-successional coniferous forests with dense 

canopy, high basal area, and large diameter 

snags. 

Pine Marten Old Growth Mature and old growth mesic coniferous forest 

with high structural diversity in the understory.

Three-toed Woodpecker Old Growth Old Growth Lodgepole Pine

Primary Cavity 

Excavators Snags and downed wood Dead/down(snag) habitat.

Northern Flicker Primary Cavity Nester Old Growth juniper. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

191

Big Game

Rocky Mountain Elk - Rocky Mountain elk was selected as an indicator species in the Forest Plan to 

represent general forest habitat and winter ranges. Concern over this species arises from its status as an 

important game species. Habitat quality for elk is evaluated in terms of forage, cover (satisfactory and 

marginal), elk screening, and open road density. The Habitat Effectiveness Index (HEI) model, (Thomas 

et al. 1988) will not be applied here because the model is not a suitable tool for evaluating invasive plant 

management effects on elk. In addition, there would be no change in cover or road density; therefore the 

habitat effectiveness index would not change from the existing condition due to management of invasive 

species. There is the potential to increase forage; however no treatment area is large enough to 

meaningfully change the habitat effectiveness index. 

The quality of elk habitat is influenced by the presence of humans, which causes animal stress and 

hunting vulnerability. This is primarily associated with motorized use of open roads and the availability of 

vegetation (live and dead) to screen elk. Elk have been found to select habitats preferentially based on 

increasing distance from open roads (Rowland et al. 2000). Vulnerability and hunting mortality have been 

found to be higher in forested stands with greater road densities and less vegetation to provide screening 

(Weber et al. 2000).

Elk habitat on the Forest was mapped as part of a cooperative effort sponsored by the Rocky Mountain 

Elk foundation. This effort concluded that the project area contains an estimated 624,673 acres of elk 

winter range, whereas the entire forest is used during the summer. Invasive plants have been documented 

on approximately 582 acres of the forest winter range and 2,124 acres of elk summer range. Of this, 517 

acres (89 percent) of the winter range infestations and 1,860 acres (88 percent) of the summer range 

infestations are adjacent to roads. Approximately 500 acres of elk-calving habitat also occur on the 

Malheur National Forest, although there are currently no known invasive plants on these lands. 

Invasive plant management is not expected to impact Oregon State Management Objectives or hunting 

permits at this time. However, invasive plants probably affect deer and elk more than any other species 

analyzed in this section and can out-compete and replace native forage plants for these ungulates. 

Consequently eradicating, controlling and/or containing invasive plants would improve elk and deer 

habitat.

Old Growth

Forest LRMP management area 13 (MA-13) provides for the management of old growth through a 

network of dedicated old growth (DOG) areas and replacement old growth (ROG) areas. Forestwide, a 

total of 104,453 acres occur in the DOG/ROG network, which is managed in part to provide habitat for 

old growth MIS, including the pileated woodpecker, pine marten and three-toed woodpecker. There are 98 

acres of invasive plants known to occur within the Forest DOG/ROG network.

Pileated Woodpecker - Pileated woodpeckers prefer late successional stages of coniferous or deciduous 

forest. Because they nest in large diameter snags, roost in large diameter hollow trees and use large logs 

and snags for foraging, pileated woodpeckers are associated primarily with older stands. Approximately 

80 percent of the pileated woodpecker foraging in northeastern Oregon occurs in dead trees and dead and 

down logs (Mellen-Mclean 2012a).

The pileated woodpecker is fairly common throughout the Malheur National Forest in mature and latesuccessional mixed-conifer forest and this species is documented in suitable habitat across the Forest. 

Forest-wide pileated woodpecker habitat was identified using two sources including old growth stands 

that are being emphasized for pileated woodpecker habitat, as well as stands that have the species and 

structural conditions characteristic of nesting, roosting and foraging (i.e. multi-story stands (OFMS), 

including an average overstory diameter of 20 inches d.b.h. or greater. There are approximately 224,197 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

192

acres of suitable pileated woodpecker habitat forestwide and of this invasive plants are known to occur on 

247 acres. When looking only at pileated woodpecker habitat within MA 13 old-growth areas (e.g. DOGs 

and ROGs), suitable habitat exists on approximately 87,880 acres and of this, approximately 78 acres are 

known to contain invasive plants.

Pine Marten - Pine (American) marten have a wide distribution across the western and eastern portions of 

the Blue Mountains and are year-round residents of the Blue Mountains (Mellen-McLean 2012b). Pine 

marten are typically associated with late-seral coniferous forests characterized by closed canopies, large 

trees, and abundant standing and downed woody material. Of particular importance is the quantity of 

downed debris on the forest floor as it provides protection from predators, access to the under snow 

environment for hunting and resting, and thermal protection from heat and cold (Ruggiero et al. 1994). 

Marten also show a strong preference for riparian habitat (Baldwin and Bender 2008).

They eat a variety of small mammals, particularly squirrels, as well as voles, mice, pika, and rabbits and 

do not tolerate concentrated human use or habitat modification (Maser et al. 1981).

The historical and current density and distribution of marten in the Forest is unknown, but they are 

thought occur in low numbers. Suitable pine marten habitat occurs on 314,134 acres across the project 

area and includes primary habitat or multi-structure forest greater than 20 inches d.b.h., as well as 

secondary habitat, or multi-structure forest between 15 inches and 20 inches d.b.h. Of the total habitat, 

355 acres currently have invasive plants. Approximately 15,523 acres of old growth lands (DOGs and 

RPGs) within the project area are managed for pine marten, and invasive plants are known to occur on 

approximately 18 acres within these habitats. Invasive plants do not pose a direct threat to this species or 

its habitat.

Three-toed Woodpecker - The tree-toed woodpecker is an indicator for lodgepole pine and mixed conifer 

forests. Primary habitat includes higher elevation lodgepole pine, fir/hemlock and Douglas-fir mixed

(Marshall et al. 2003). They are associated with mature and overmature stands with elevated levels of 

dead and dying wood associated with insect and disease related mortality or stand replacing wildfire 

(Wisdom et al. 2000). They are locally abundant in areas of insect outbreaks and their populations are 

irruptive as they follow outbreaks across the landscape. When available post fire habitat is preferred, 

although numbers of nests decrease between three and five years post fire. They specialize on bark beetles 

(Scolytidae) versus the black-backed woodpecker which specializes on wood boring beetles 

(Cerambycidae) (Leonard 2001).

Potentially suitable habitat was identified by taking stands with a higher density of snags greater than 10 

inches d.b.h. of preferred nesting and foraging cover types (Mellon-Mcleanon 2012c) and recent post-fire 

habitat. Approximately 360,000 acres of suitable habitat exists and of this, 428 acres are currently infested 

with invasive plants. No invasive plants have been mapped within the 631 acres of old growth habitat 

managed for this species. Invasive plants do not pose a direct threat to this species.

Primary Cavity Nesters (Snags and Dead Wood)

Primary cavity excavators include Lewis’ woodpecker, yellow-bellied sapsucker, red-breasted sapsucker, 

Williamson’s sapsucker, downy woodpecker, hairy woodpecker, white-headed woodpecker, three-toed 

woodpecker, black-backed woodpecker pileated woodpecker and northern flicker. Table 52 identifies 

preferred habitat for those species not discussed above as MIS or sensitive species, whereas a discussion 

of suitable habitat for these species is below. Collectively these species utilize a variety of habitats, 

although they all depend upon dead trees and down logs for reproduction and foraging.

Virtually all of the forested land provides potentially suitable habitat because primary cavity nesting 

species utilize a wide variety of snag species and size classes. Although native plant infestations occur 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

193

within sites containing snags, because invasive plants don’t affect standing dead or downed wood habitat, 

they are not adversely affecting cavity nesting species or their habitat.

Table 52. Habitat for Cavity Nesters (MIS)

MIS Cavity Nesting 

Species Habitat

Red-naped Sapsucker Riparian habitat, especially aspen, cottonwoods and pine forest communities.

Red-breasted Sapsucker Mature moist coniferous and mixed deciduous-coniferous forest. Typically nest 

in large trees. 

Williamson’s Sapsucker

Open, late-successional lower montane forests (Douglas fir, western larch, 

grand fir, white fir and ponderosa pine) and aspen and cottonwood stands with 

high densities of snags. 

Downy Woodpecker Riparian habitat and lowland deciduous forest at low to mid elevations

consisting of a mixture of grasses, shrubs and hardwoods.

Hairy Woodpecker Ponderosa pine forest at low to mid elevations with trees 10 to 20 inches 

diameter.

Black-backed Woodpecker Post fire habitat and forest with insect and disease related mortality. 

Associated with high densities of smaller diameter snags (9 to 15 inches d.b.h.

Northern Flicker Habitat generalist that prefers open areas such as open woodlands, meadows, 

fields and regeneration sites. Nests in large snags.

Red-naped and Red-breasted Sapsucker - Source habitat for the red-naped sapsucker consists of riparian 

habitats, especially aspen, cottonwoods, alder and pine, although habitat is less abundant in mixed conifer 

forest (Marshall et al. 2003, Wahl et al 2005). Nest trees are most common aspen with heart rot, but 

ponderosa pine are also selected. Red-naped sapsuckers are considered common within suitable habitat 

across the Forest.

Williamson’s Sapsucker - In northeastern Oregon, this species occurs in mature and old-growth mixedconifer forests at approximately 3,500 to 6.500 ft. in elevation. Preferred habitat is comprised of open, 

later seral stages of montane and lower montane forest (Douglas fir, western larch, grand/white fir, 

ponderosa pine, aspen and cottonwood) (Wisdom et al 2000, Wahl et al 2005, Marshall et al 2003). Both 

live and dead trees are used for nesting, although snags are a critical component of breeding habitat (Bull 

et al. 1980). Williamson’s sapsuckers feed at sapwells in ponderosa pine and Douglas-fir and glean insects 

from the bark of trunks and limbs (Marshall et al 2003). Home range size is estimated at 10 to 22 acres 

(Johnson and O’Neil 2001). Williamson’s sapsuckers are fairly common across the Forest.

Downy Woodpecker - In Oregon the downy woodpecker is widely distributed in low to moderate 

elevation habitat deciduous riparian woodlands and lowland deciduous forest (Marshall et al 2003). These 

woodpeckers are also found in parks and orchards. Territory size ranges from five to nine acres and 

nesting occurs in trees and snags greater than eight inches d.b.h. Downy woodpeckers have been 

documented across the Forest.

Hairy Woodpecker - Habitat for this species includes dry and wet coniferous forest at low to midelevations, as well as deciduous forest and riparian areas. The hairy woodpecker uses all ages of forest, 

although older stands are often preferred for nesting. Nesting occurs in moderately decayed snags,

primarily in ponderosa pine trees between 10 and 20 inches d.b.h. Highest densities occur in un-salvaged 

forests and recent (1 to 5 years) post-fire habitat with moderate to high densities of snags. Older burns do 

no support high levels of wood-boring beetles used for foraging (Saab et al. 2007). Home range size has 

been reported at between 22 and 37 acres (Marshall et al. 2003). This species is frequently detected at 

point count surveys across the Forest.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

194

Black-backed Woodpecker - This species is largely restricted to post fire habitat (Saab and Dudley 1998).

In the Blue Mountains it is associated with high elevation boreal and montane coniferous forest, 

especially recent (less than five years) post-fire habitat (Dixon and Saab 2000). However it is occasionally 

observed in mixed conifer, lodgepole pine, and Douglas fir and spruce fir forests (Hutto 1995). 

Observations of this species on the Forest occur primarily in areas of large stand-replacing wildfires.

Northern Flicker - The northern flicker is a common resident woodpecker in Oregon. It is a habitat 

generalist, although is most abundant in open forests and forest edges. This species utilizes coniferous and 

deciduous forest, riparian woodlands and urban areas (Marshall et al. 2003, Wahl et al. 2005). Nesting 

typically occurs in open areas with snags that exhibit some decay and Marshall et al. (2003) found that 71 

percent of the nest trees had broken tops. Northern flickers are detected on a fairly regular basis during 

breeding bird surveys across the Forest, particularly in post-fire habitat.

Featured Species

Featured species identified in the Malheur and Ochoco Forest Plans include species that require special 

protection. These species and their preferred habitat are displayed in table 53. Some of these species have 

already been discussed and narrative affected environment discussion is not repeated here.

Table 53. Habitat for Featured Species

Featured 

Species Habitat

Northern 

Goshawk

Mature mixed conifer forest with predominantly closed-canopy conditions for nesting and a 

diversity of forest and non-forest conditions for foraging

Blue Grouse

Coniferous forests (Douglas-fir, grand fir, subalpine fir) with a mixture of deciduous trees and 

shrubs near edges and clumps, and mistletoe infected Douglas-fir located on ridge tops or 

upper slope positions 

Sage Grouse See Sensitive Species Section.

Osprey Large, old trees with dead tops or large snags suitable for nesting adjacent to large rivers or 

lakes. 

Pronghorn 

Antelope Open grasslands with low sagebrush being an important component.

California 

Bighorn Sheep Alpine desert grasslands associated with mountains, cliffs, foothills and river canyons. 

Upland 

Sandpiper See Sensitive Species Section. 

Northern Goshawk

The northern goshawk can be found in landscapes that contain large blocks of mature forest, large trees 

for nesting and abundant prey (squirrels, grouse, hares, larger songbirds). They use broad landscapes that 

incorporate multiple spatial scales including more closed-canopy stands for nesting and foraging and 

post-fledging habitat (PFA). Nest stands are typically composed of large trees, closed canopies and 

multiple canopy layers (McGrath et al. 2003, Reynolds et al. 1982), whereas PFAs typically include a 

variety of forest types and conditions, including young forest and openings (Reynolds et al. 1992).

Goshawks are classified as prey generalists (Squires and Reynolds 1997) and forage for small birds and 

mammals in open understories below the forest canopy and along small forest openings (Reynolds et al 

1992). Foraging areas are usually more open than nesting areas, but would contain large trees, snags, 

down logs, vegetative layering, and other structural elements important to prey species (Reynolds et al. 

1992).

There are 142 goshawk nests and associated post-fledgling areas across the Forest. Nesting and foraging 

habitat occurs on approximately 400,700 acres; invasive plants have been mapped within about 567 acres 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

195

of these habitats. Post-fledgling areas cover approximately 27,000 acres; invasive plants have been 

mapped within 18 acres of this habitat. Because of its preference for closed-canopy forest, invasive plants 

are not considered a direct threat to the goshawk.

Blue (Dusky) Grouse

Blue grouse prefer coniferous forest (Douglas fir, grand fir and sub-alpine fir) with a mixture of 

deciduous trees and shrubs near edges and openings and feed and nest in a variety of forest and shrub 

vegetation types. They utilize large, mistletoe infected Douglas fir trees, generally located within the 

upper third of slopes as winter roosts, whereas dense coniferous thickets of small trees, stumps, and down 

logs are used by blue grouse for resting, drumming and escape cover. They also utilize dense deciduous 

areas in riparian corridors. Blue grouse home ranges are typically 1.25 to 5 acres, and are usually 

associated with openings and rocky areas. The food items of blue grouse vary from a simple winter diet of 

primarily coniferous needles to a summer diet consisting of a variety of green leaves, fruits, seeds, 

flowers, animal matter and conifer needles. While vegetation makes up over 90 percent of their diet, 

young birds feed almost exclusively in insects (Schroeder 1984). 

Blue grouse occur across the Malheur National Forest. Winter roost habitat occurs on approximately 

6,800 acres. Invasive plants do not pose a direct threat to this species. Invasive plants have been mapped 

on approximately 1,870 acres of suitable coniferous forest habitat. One acre of invasive plants has been 

mapped within winter roost habitat. Invasive plants are not considered a direct threat to blue grouse.

Bighorn Sheep

Bighorn sheep generally inhabit open areas of rocky slopes, ridges, rim rocks, cliffs, and canyon walls 

with adjacent grasslands or meadows, and few trees (Verts and Carraway 1998). Dense forest 

communities are avoided. Their primary diet consists of bunchgrass, but also includes significant amounts 

of forbs and shrubs during the growing seasons. In the spring they will also utilize cheatgrass, which is an 

invasive annual plant. Most bighorn sheep use forage areas within one-half mile but up to 1 mile of 

escape terrain of escape terrain. Summer and winter range must provide freedom from disturbance and a 

proper juxtaposition of forage, escape terrain, and water.

California bighorn sheep were introduced into the Strawberry Mountain Wilderness and near Aldrich 

Mountain. Excellent summer range and adequate quality winter range have contributed to an expanding 

or stable population. The Aldrich Mountain herd unit totals 69,060 acres and contains 13 acres of known 

invasive plants, whereas less than an acre is known to occur in the 58,688 acres Strawberry Mountain 

unit. Based on known infestations, invasive plants are not currently impacting bighorn sheep or their 

habitat. 

Osprey

Osprey are highly migratory raptors that typically breed and nest along larger rivers, lakes and reservoirs. 

Osprey feed almost exclusively on fish and documented nests in Oregon are almost always located close 

to water with adequate fish populations. Osprey have been documented on the Forest and suitable nesting 

and foraging habitat exists along rivers and lakes. currently 67 acres of invasive plants are mapped within 

300 feet. of waterbodies or rivers that may be used for nesting or foraging. Invasive plants are not a direct 

threat to osprey.

Pronghorn Antelope

In Oregon habitat includes sagebrush steppe, as well as areas occupied by widely spaced juniper or 

ponderosa pine. For most of the year water is essential and animals are seldom found far from available 

sources, with most herds within 2.5 and 5 miles of water. In spring and summer, broad leaved herbaceous 

vegetation is the preferred food, although pronghorn will browse on tips of sagebrush in winter and 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

196

occasionally eat some grasses. Common food plants include longleaf phlox, wallflower and balsamroot. 

Pronghorn are fairly common in the open valley areas on the Forest and adjoining private, state and 

federal lands. Populations appear to be increasing slightly. 

Approximately 78,000 acres of pronghorn habitat occur adjacent to larger blocks of habitat on private 

lands. Approximately 122 acres of invasive plants are mapped within this habitat. Invasive grasses can 

reduce habitat for local populations of antelope (California Department of Fish and Game 2013).

Landbirds

Landbirds evaluated in this analysis include focal species associated with priority or unique habitats 

identified in the Partner in Flight (PIF) Conservation Strategy for Landbirds of the Northern Rocky 

Mountains of Eastern Oregon and Washington (Altman 2000), those identified in the PIF Conservation 

Strategy for the Columbia Plateau of Eastern Oregon and Washington (Altman and Holmes 2000). These 

focal species and their habitat are displayed in the following tables

Table 54. Northern Rocky Mountain Habitat Types - Landbird Focal Species and Their Habitats

Habitat Habitat Feature Focal Species

Priority Habitats

Dry Forests

Large patches of old forest with large trees/snags White-headed Woodpecker1

Old Forest with grassy openings an dense 

thickets Flammulated Owl

Open understory with regenerating pines Chipping Sparrow

Patches of burned old forest Lewis’ Woodpecker1

Mesic Mixed Conifer 

(Late Successional

Large Snags Vaux’s Swift

Overstory canopy closure Townsend’s Warbler

Structurally diverse, multi-layered Varied Thrush

Dense shrub layer in forest openings or 

understory MacGillivray’s Warbler

Edges and openings created by wildfire Olive-sided Flycatcher

Riparian Woodland

Large Snags Lewis’ Woodpecker1

Canopy foliage and structure Red-eyed Vireo

Understory foliage and structure Veery

Riparian Shrub Willow/alder shrub patches Willow Flycatcher

Unique Habitats

Sub-alpine Meadows Hermit Thrush

Montane Meadows (wet/dry) Upland Sandpiper1

Steppe Shrublands Vesper Sparrow

Aspen Red-naped Sapsucker

Alpine Gray-crowned Rosy Finch

1 – Also evaluated as an MIS or featured species
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

197

Table 55. Columbia Plateau Habitat Types - Landbird Focal Species and Their Habitats

Habitat Habitat Feature Focal Species

Priority Habitats

Steppe-Grassland Native bunchgrass cover Grasshopper Sparrow1

Steppe-Shrubland

Interspersion of tall shrubs and 

openings Loggerhead Shrike

Burrows Burrowing Owl

Deciduous trees and shrubs Sharp-tailed Grouse

Sagebrush

Large areas with diverse 

understory Sage Grouse1

Large contiguous patches Sage Sparrow

Sagebrush cover Brewer’ Sparrow

Sagebrush height Sage Thrasher

Shrublands

Ecotonal edges of herb, shrub 

and tree habitat Lark Sparrow

Upland sparsely vegetated desert 

shrub

Black-throated Sparrow (BR and 

OW only)

Juniper-Sage Steppe Scattered mature juniper trees 

(savannah) Ferruginous Hawk

Riparian Woodland

Large snags (cottonwood) Lewis’ Woodpecker1

Large canopy trees Bullock’s Oriole

Subcanopy foliage Yellow Warbler

Dense shrub layer Yellow-breasted Chat

Large structurally diverse 

patches Yellow-billed Cuckoo1

Riparian Shrub Dense shrub patches Willow Flycatcher

Shrub-herbaceous interspersion Lazuli Bunting

Unique Habitats

Aspen Large trees and snags with 

regeneration Red-naped Sapsucker

Agricultural Fields Mesic Conditions Bobolink

Cliffs and Rimrock Undeveloped foraging areas Prairie Falcon

Juniper Woodland Mature trees with regeneration Gray Flycatcher

Mountain Mahogany Large diameter trees with 

regeneration. Virginia’ Warbler

1 – Also evaluated as an MIS, sensitive or featured species

Nationwide Birds of Conservation Concern

In an effort to conserve bird species of concern and comply with the Migratory Bird Treaty Act, the 

United States Fish and Wildlife Service developed a Nationwide Birds of Conservation Concern (BCC) 

list in 2002. This BBC list was updated in 2008 (USFWS-2008) and identifies species, sub-species, and 

populations of migratory and non-migratory birds in need of additional conservation action. These species 

are deemed to be the highest priority for conservation actions and would be considered prior to taking 

management actions. Bird Conservation Regions (BCRs) were developed based on similar geographic 

parameters and each BCR identifies species of concern. The project area includes BCR 10, (Northern 

Rockies) and table 56 lists bird species of concern within this region.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

198

Table 56.Birds of Conservation Concern

Bird Species Preferred Habitat

Bald Eagle1 Forest with Large Trees Near Open Water

Swainson’s Hawk Elevated Nest Sites In Open Country

Ferruginous Hawk Elevated Nest Sites In Open Country

Peregrine Falcons1 Cliffs, Wide Range Of Habitats

Upland Sandpipers1 Grasslands

Long-Billed Curlew Grasslands

Yellow-Billed Cuckoos Dense Riparian Cottonwoods

Flammulated Owl Open Ponderosa Pine Forests

Black Swift Cliffs Associated With Waterfalls For Nesting, Forage In Forest 

and Open Areas

Calliope Hummingbird Open Forest And Shrubs At Higher Elevations And Riparian 

Areas.

Lewis’s Woodpeckers1 Mature Open Forest With Large Snags

Williamson’s Sapsucker1 Coniferous Forest and Aspen With Snags

White-Headed Woodpeckers1 Old Open Forest With Large Snags.

Olive-Sided Flycatcher Edges And Openings Within Forest

Willow Flycatcher Dense Shrub Patches

Loggerhead Shrike Grasslands, Open Woodlands, Juniper/Sage

Sage Thrasher Large Patches Of Sagebrush

Brewer’s Sparrow Dense Sagebrush

Sage Sparrow Large Patches Of Sagebrush

McCown’s Longspur Sparse Grasslands

Black Rosy-Finch Above Timberline In Bare Rock, Cirques, Cliffs

Cassin’s Finch Open Mature Coniferous Forest

1 – Also evaluated as an MIS, sensitive or featured species

Gamebirds below Desired Condition

This list includes species whose populations are below long-term averages or management goals, or for 

which there is evidence of declining population trends (USDI Fish and Wildlife Service 2013c). Table 51 

displays GBBDC species that may occur within the project area (Cornell Lab of Ornithology 2013), 

feeding strategies and preferred habitat. 

Table 57. Gamebirds below desired condition

Species Habitat

Canvasback Wetlands, ponds and lakes (plants and aquatic insects)

Mourning Dove Open forest and woodlands (seeds)

Ring-necked Duck Marshes and ponds, open water wetlands. (plants and aquatic invertebrates)

Wood Duck Swamps, ponds and wetlands with snags (insects, seeds and fruit, acorns)

Mallard Wetlands, ponds and lakes, roadside ditches (aquatic plants and insects)

Northern Pintail Open country with shallow wetlands (insects and seeds)

Redhead Lakes and ponds (plants)

Lesser Scaup Lakes and ponds feeds on insects (aquatic insects and plants)

American Wigeon Wetlands, ponds, marshes and rivers (aquatic insects and plants)
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

199

3.7.3 Environmental Consequences

This section evaluates effects to wildlife and wildlife habitat discussed in section 3.62 and includes an 

analysis for each of the alternatives considered as well as an evaluation of effects to threatened and 

endangered and regionally sensitive species, management indicator species, featured species and birds of 

conservation concern.

Analysis Methodology

The Forest Service contracts with Syracuse Environmental Research Associates, Inc. (SERA) to conduct 

ecological risk assessments for herbicides proposed for use on National Forest System lands. The 

information contained in this document relies on these risk assessments and interpretations from the R6 

2005 FEIS.

To determine potential effects, representative species groups of wildlife and data from existing laboratory 

and field studies were used to discover which groups of species might be at the greatest risk from 

herbicide use. The general categories analyzed, and exposure scenarios developed, depended upon 

available toxicity data and species of concern in Oregon. 

An exposure scenario was developed, when enough data was available, and a quantitative estimate of 

dose received by the animal type in the scenario was calculated (SERA, 2007). The scenarios used to 

calculate doses include direct spray of small mammals, birds and mammals eating vegetation or insects 

sprayed with herbicide, predatory mammals and birds eating small mammals or fish, and small mammals 

drinking contaminated water. The risk assessments prepared by SERA (2001a, b; 2003a-d; 2004a-f; 2007; 

2011a-d) contain detailed analysis of the potential effects of each herbicide. Portions of risk assessments 

pertaining to wildlife are summarized in Appendix P of the R6 2005 FEIS. 

The quantitative estimates of dose were compared to available toxicity data to determine potential adverse 

impacts. For this analysis, the most sensitive response (i.e., a sub-lethal effect that occurred at the lowest 

dose) from the most sensitive species was used to determine “toxicity indices” for each herbicide. When a 

calculated dose was greater than the toxicity index, the analysis stated that there was a potential for 

adverse effects. This approach assumes maximum potential effects of herbicides even though the pdfs and 

herbicide-use buffers would minimize potential exposure.

The toxicity index acts as a threshold; doses below the index would result in no known (or discountable) 

effect and doses substantially above a threshold would be considered to possibly pose some risk. The 

level of risk depends on how far above the threshold a particular dose is estimated to be. Due to the nature 

of the toxicity data, doses only slightly above the toxicity index would still be considered to pose no 

likely risk (Hazard Quotients of 2-10).

In order to analyze potential effects from proposed invasive plant treatments on the project area, each 

species of conservation concern was assigned to an exposure scenario category (e.g. small insectivorous

bird, large herbivorous mammal, etc.). Results of risk assessments for each herbicide and NPE surfactants 

were then applied to each species within the exposure scenario category to evaluate risk of each herbicide 

or surfactant.

Professional judgment was used to evaluate the life history traits (e.g., diet, habitat, activity patterns, 

seasonal occurrence, etc.) of each wildlife species evaluated to determine the likelihood of exposure to 

herbicides or surfactant used to treat invasive plants. The combinations of likelihood of exposure, dose 

estimated from exposure scenarios, and GIS wildlife location data for the Malheur National Forest was 

used to determine the risk of effect from herbicide treatments.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

200

Data Limitations

The data for amphibians is much more limited than that available for mammals and birds and for most 

herbicides, available data is not sufficient to conduct quantitative estimates of exposure and toxicity data 

for amphibians. The Forest Service/SERA Risk Assessments use information from the literature, when 

available, and the calculated concentrations of herbicide in water from runoff or accidental spill to 

determine risk to amphibians. When data on amphibians were not available, fish were used as surrogate 

species. Data suggest that amphibians may be as sensitive to herbicides as fish (Berrill et al. 1994; Berrill 

et al. 1997; Perkins et al. 2000). For the purposes of this analysis, herbicides that pose potential risk to 

fish (as determined by the quantitative estimates from exposure scenarios) were also considered to pose a 

risk to amphibians.

Data is limited regarding the potential effects of herbicides on mollusks. Only glyphosate and picloram 

have been tested on a terrestrial mollusk; the brown garden snail (Helix aspersa). Neither glyphosate nor 

picloram appeared to pose a risk to the snail (USDA Forest Service 2005e). Relyea (2005b) found no 

effect to three species of aquatic snails from the glyphosate formulation Roundup®.

Insufficient data is available in many cases to allow for a quantitative risk assessment. For instance, there 

is no quantitative scenario for a predatory bird that eats primarily other birds, such as the peregrine falcon, 

so the “fish-eating bird” scenario was used as a surrogate. This scenario likely overestimates the dose to 

the peregrine falcon because the hypothetical fish consumed are from a pond contaminated by a large spill 

of herbicide. These hypothetical fish likely have higher concentrations of herbicide in their bodies (and 

thus a higher dose to the predatory bird) than would a small bird that incidentally ingested herbicide 

before it was preyed upon. Data was insufficient to assess risk of chronic exposures for a large grasseating bird from NPE exposure, or insect-eating birds and mammals for several herbicides.

Direct spray of small mammals and consumption of small mammals that have been directly sprayed by 

predatory birds or mammals exceed the toxicity indices for a few herbicides. However, these scenarios, 

while possible, were determined to not be plausible. Small mammals are generally nocturnal and spend 

daylight hours either in burrows or in trees and would be very unlikely to be directly sprayed. In the case 

of predatory birds or mammals, the predator would have to consume an entire day’s diet worth of directly 

sprayed small mammals to receive the dose that exceeded the toxicity index.

Research has not been conducted on the effect of proposed herbicides to most free-ranging wildlife, so the 

relevant data to specifically evaluate effects to different wildlife species is incomplete or unavailable. 

Specific relevant data that is lacking includes:

♦ For several herbicide/species group combinations, both NOAEL and LOAEL values have not 

been determined.

♦ There is insufficient data to assess risk of chronic exposures for a large grass-eating bird or small 

insect-eating birds and mammals.

♦ The toxicity of the herbicides to amphibians, reptiles, terrestrial invertebrates, birds and other 

animals found in Region 6 is either unknown or limited, and cannot be fully characterized with 

the available data on surrogate species.

♦ Analysis of effects for any project involving herbicide use relies on extrapolations from 

laboratory animals to free-ranging wildlife and controlled conditions to the natural environment. 

♦ There is less data available for birds than mammals, so mammal toxicity values must be used in 

bird exposure scenarios for some of the herbicides considered. 

Limitations notwithstanding, a substantial amount of scientific data on the toxicity of proposed herbicides 

to birds and mammals, and some amphibians and invertebrates exist. The data is generated by 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

201

manufactures to meet EPA regulations before an herbicide may be registered for use, and by independent 

researchers that have published findings in peer-reviewed literature. So while some data is lacking, 

adequate information exists to assess potential impacts of the herbicides proposed on wildlife.

Effects of Alternative A (No Action)

Under alternative A, no proposed project activities would occur, and therefore no direct or indirect 

treatment-related effects would occur. While current levels of invasive plant control may continue on 

lands of other ownership, invasive plants would continue to establish and spread within the project area at 

the rate of approximately 8 to 12 percent per year (R6 2005 FEIS) (consistently applied prevention 

measures since 2005 assume this rate to be reduced by half (R6 2005 ROD)). Native plants and habitats 

would continue to be threatened by invasive plants. Effects on wildlife would vary. For closed-canopy 

forest species (e.g. goshawk) or species that are not affected by invasive plants (e.g. woodpeckers or 

bats), or species that occupy habitat away from invasive plant vectors (e.g. Wallowa rosy finch), there 

would be little effect to existing or future habitat. 

Due to their proximity to invasive plant vectors and more open canopy conditions, habitats such as 

grassland/meadows, sagebrush, open-canopied forest (e.g. savannah) and many wetland/riparian areas 

would continue to be affected by invasive plants. Effects to wildlife dependent on these communities 

would be a reduction in cover or forage as native habitat is replaced by non-natives. Infestations that 

become so well established that future treatment is cost-prohibitive could result in permanent loss of 

habitat (Asher 2002). For example, habitat loss via invasive plant infestation has been reported to occur in 

Oregon spotted frog habitat that is invaded by reed canarygrass (Hayes 1997). Sage grouse and pygmy 

rabbits could be displaced if invasive plants expand into native rangeland (Connelly et al. 2000, Weiss 

and Verts 1984) and foraging habitat for elk and other big game could decrease (Rice et al. 1997). The 

spread of invasive wetland plants can also reduce waterfowl nesting habitat (Blossey 1999).

Consequently under alternative A, the long-term loss of native vegetation and habitat due to continued 

encroachment of invasive plants would adversely affect species such as elk, antelope, grasshopper 

sparrow, greater sage grouse, upland sandpiper, bobolink, Columbia spotted frog, silver-bordered fritillary 

and several migratory birds of concern is increased.

Effects Common to all Action Alternatives

This section discusses general effects on wildlife that are common to all action alternatives and is based 

on effects of invasive plant treatments to wildlife that are evaluated in detail in the R6 2005 FEIS, the 

corresponding Biological Assessment (USDA Forest Service 2005c), project files, and SERA risk 

assessments.

General Effects of Treatment

All treatment methods have the potential to disturb, temporarily displace, or directly harm various wildlife 

species. Conversely, successful control of invasive plant infestations provides long-term benefits to 

wildlife, by restoring native habitats. Potential adverse effects to wildlife are determined largely by the 

potential for exposure to treatment. Because most invasive species are shade intolerant, the majority of 

treatments occur in openings, early structural habitat, or in forested habitat with a relatively open canopy.

Consequently species that occur primarily in closed-canopy forests are less likely to be affected by 

proposed treatments. Conversely, species that prefer or require relatively open habitats are more likely to 

be adversely affected by both plant infestation and treatment. 

The effects of the invasive plant treatments on wildlife are relative to the size and locations of existing 

and future invasive plant infestations, the type of treatment used, and the timing and duration of the 

treatments. Treatment of infestations along disturbed roadsides are not likely to substantially affect 

terrestrial wildlife populations, since this vegetation type does not provide essential habitat for native 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

202

wildlife species, and it consists of long, narrow areas spread over large distances. Treatment of large 

infested areas may create more disturbances for longer periods than treatment of small infestations.

Treatment of dense infestations can create bare ground, which may reduce cover and expose certain 

species to increased predation. However, dense infestations of invasive plants do not typically occur in 

areas of the Malheur National Forest that provide suitable habitat for most wildlife species.

For the most part, invasive plant treatments would not alter habitat structure or composition for terrestrial 

wildlife species. Most of the invasive plants on the Malheur National Forests are forbs, thus woody 

species, and shrubs and trees would not likely be affected by treatments. Impacts to non-target forbs and 

grasses would generally be minor and occur within treated areas or within short distances of treated areas 

(less than 100 feet, 15 feet for spot treatment). In some cases, removal of invasive plants could cause a 

localized decrease in the amount of vegetative cover provided. However due to the patchy nature of 

invasive plant infestations, there would be little cover lost. Unlike other management activities (i.e. timber 

harvest), invasive plant treatments are not likely to reduce available habitat or prey availability.

Manual and Mechanical Treatments

Disturbance from manual and mechanical treatments is likely to pose greater risks to terrestrial wildlife 

species than herbicide or cultural methods (USDA Forest Service 2005e). Small species that lack rapid 

mobility (e.g. amphibians, mollusks) and ground nesting birds are vulnerable to crushing or injury from 

people or equipment. Manual treatments can take longer to implement than other methods, increasing the 

length of time of disturbance. Manual treatments are often used at small sites, where the potential to 

impact wildlife would be minimal, but may also be used in large areas with scattered invasive plants. In 

these situations, crews of 3-5 people may be in an area for more than a day. Bare ground is likely to be 

patchy in distribution with this method and less likely to interfere with animal movement or dispersal. 

Mechanical methods can generate more noise disturbance than other methods. Hand held mechanical 

equipment like chainsaws and trimmers can be used very selectively on target plants and may be less 

likely than larger equipment to harm wildlife. Use of vehicle mounted equipment, like mowers, is less 

selective and more likely to directly impact small animals than use of hand operated equipment, such as 

string trimmers. 

Biological Control

Biological control is proposed on sites that are either too large to be sprayed with herbicides, where 

invasive plant species are so abundant that other methods would not be practical, or where the biological 

control agent is effective on the target plant species and treatment can reduce or eliminate the need for 

herbicides.

Biological control will not directly affect native wildlife species; however, recent studies have found that 

native rodents may take advantage of the food source provided by biological control agents (Pearson et al. 

2000). Effects include short-term disturbance similar to that described under manual treatment during 

release. Although some bio control agents available have adverse effects to non-target wildlife, only 

APHIS and State-approved biological control agents would be used. Also agents demonstrated to have 

direct negative impacts on non-target organisms would not be released. As a result there are no adverse 

effects to wildlife anticipated under any alternative. 

Due to the maintenance of native vegetation and habitat, indirect effects of biological control include 

reducing invasive plant populations and providing a supplemental food source, both of which can have 

long-term benefits to wildlife. 

Cultural/Restoration

Restoration or reclamation of sites infested with invasive plants follow treatment restoration standard 13 

(USDA Forest Service 2005b) and incorporate guidelines for re-vegetation of invasive weed sites and 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

203

other disturbed areas on National Forests and Grasslands in the Pacific Northwest (Erickson et al. 2003). 

On degraded sites where reproducing individuals of desirable species are absent or in low abundance, revegetation with well adapted and native competitive grasses, forbs and legumes can be used to direct and 

accelerate plant community recovery, reduce erosion, and restore native wildlife habitat conditions. 

Restoration treatments proposed under the action alternatives include mulching, seeding and planting, and 

grazing. Effects of mulching, seeding and planting on wildlife are similar to those described under manual 

treatments and include short-term avoidance of the site during treatment. Due to the small amount of 

treatment proposed, scattered nature of proposed sites, widespread availability of unaffected habitat, and 

with implementation of pdfs to protect species of conservation concern, effects to wildlife would be 

limited to short-term disturbance of the site during treatment.

Herbicide Effects to Wildlife

Results of numerous field studies indicate the likelihood for direct adverse effects to wildlife from 

herbicide use is low (Marshall and Vandruff 2002, Dabbert et al. 1997, Fagerstone et al. 1977, Rice et al. 

1997, Sullivan et al. 1998, Cole et al. 1997, Cole et al. 1998, Johnson and Hansen 1969, Nolte and 

Fulbright 1997, McMurry et al. 1993a, and McMurry et al. 1993b), however, use of herbicides to treat 

invasive plants does have the potential to harm free-ranging wildlife (USDA Forest Service 2005b p. 1-

11). Herbicides can also cause some malformation or mortality to amphibians that have been exposed to 

herbicides or surfactants in water (Relyea 2005).

Risk from herbicide exposure was determined using data and methods outlined in the SERA risk 

assessments. A quantitative estimate of dose was compared to toxicity indices (table 58 and table 59). If a 

dose exceeded the toxicity index, then it was determined to have potential for an adverse effect. 

Quantitative estimates of dose for each animal group for each herbicide are contained in the project file 

worksheets. Wildlife species evaluated were placed into groups based on taxa type (e.g. bird, mammal), 

body size, and diet (e.g. insect-eater, fish-eater, plant-eater). Exposure scenarios for the various groupings 

were used to quantitatively estimate dose and characterize risk at both the typical and highest application 

rate for each herbicide/surfactant. Exposure scenario results were evaluated in terms of whether or not 

they exceeded the NOAEL (No Observed-Adverse Effect Level) for an acute exposure (i.e. consumed 

exclusively contaminated prey during a 24 hour period) or chronic exposure (i.e. consumed nothing but 

contaminated prey for 90 days). Table 58 and table 59display the toxicity indices for birds and mammals 

used in this analysis, whereas table 60 displays exposure scenarios considered. Toxicity indices represent 

the most sensitive endpoint from the most sensitive species for which adequate data are available. 

Toxicity results are discussed in more detail in Appendix P of the R6 2005 FEIS.

Table 58. Toxicity indices for birds

Herbicide Duration Endpoint Dose Species Effects Noted at LOAEL

Aminopyralid

Acute NOAEL 14 mg/kg Quail Ruffled appearance at 23 mg/kg

Chronic NOEC 184 mg/kg/day* Mallard No adverse effects to adults or offspring 

at highest dose tested (184 mg/kg/day)

Chlorsulfuron

Acute NOAEL 1686 mg/kg Quail No significant effects at highest dose

Chronic NOAEL 140 mg/kg/day Quail No significant effects at highest dose

Clopyralid

Acute NOAEL 670 mg/kg Mallard & 

Quail

No signs of toxicity reported, LOAEL not 

determined

Chronic1 NOAEL 15 mg/kg/day Rat Thickening of gastric epithelium at 150 

mg/kg/day

Glyphosate

Acute NOAEL 562 mg/kg Mallard & 

Quail No effects at highest dose

Chronic NOAEL 100 mg/kg Mallard & No effects on reproduction at highest 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

204

Herbicide Duration Endpoint Dose Species Effects Noted at LOAEL

Quail dose

Imazapic

Acute NOAEL 1100 mg/kg Quail No effects at highest dose

Chronic NOAEL 113 mg/kg/day Quail Decreased weight gain in chicks at 170 

mg/kg/day

Imazapyr

Acute NOAEL 674 mg/kg Quail No effects at highest dose

Chronic NOAEL 200 mg/kg/day Mallard & 

Quail No effects at highest dose

Metsulfuron 

methyl

Acute NOAEL 1043 mg/kg Quail No significant effects at highest dose

Chronic NOAEL 120 mg/kg/day Mallard & 

Quail No significant effects at highest dose

Picloram

Acute NOAEL 1500 mg/kg Chicken & 

pheasant

No effect to reproduction. LOAEL not 

reported

Chronic1 NOAEL 7 mg/kg/day Dog Increased liver weight at 35 mg/kg/day

Sethoxydim

Acute NOAEL >500 mg/kg Mallard & 

Quail

No or low mortality at highest doses 

tested. LOAEL not available.

Chronic LOAEL2 10 mg/kg/day Mallard Decreased number of normal hatchlings 

at 10 mg/kg/day

Sulfometuron 

methyl

Acute NOAEL 312 mg/kg Mallard Decreased weight gain at 625 

mg/kg/day

Chronic1 NOAEL 2 mg/kg/day Rat Effects on blood and bile ducts at 20 

mg/kg/day

Triclopyr BEE

Acute LD50 388 mg/kg Quail 50% mortality at 388 mg/kg

Chronic NOAEL 10 mg/kg/day Mallard & 

Quail

Decreased survival of offspring, reduced 

eggshell thickness at 20 mg/kg/day

Triclopyr TEA

Acute LD50 535 mg/kg Quail 50% mortality at 535 mg/kg

Chronic NOAEL 10 mg/kg/day Mallard & 

Quail

Decreased survival of offspring, reduced 

eggshell thickness at 20 mg/kg/day.

NPE 

Surfactants3

Acute NOAEL 10 mg/kg Rat Slight reduction of polysaccharides in 

liver at 50 mg/kg/day

Chronic NOAEL 10 mg/kg/day Rat

Increased weights of liver, kidneys, 

ovaries, and decreased live pups at 50 

mg/kg/day

* The chronic toxicity index is higher than the acute toxicity index because the acute value is based on a gavage study and the 

chronic value is based on a dietary exposure study. There are substantial differences in effects from the different dose methods. 

Effects from gavage dosing were rapidly reversed, but are used in the assessment of risk to be conservative. This may lead to a 

gross overestimate of acute risk (SERA 2007, p. 96-97).

1 Chronic toxicity studies in birds are not available, so the value from mammal studies is used.

2 Based on one study in which a NOAEL was not determined, so the LOAEL is used.

3 Data on birds is not available in published literature so data from mammals is used.

Sources: SERA 1998, 2001, 2003, 2004, 2007; 2011, Bakke 2003;

Table 59. Toxicity indices for mammals

Herbicide Duration Endpoint Dose Species Effect Noted at LOAEL

Aminopyralid

Acute NOAEL 104 mg/kg Rabbit Weight loss and in coordination at 260 

mg/kg

Chronic NOAEL 50 mg/kg/day Rat Cecal enlargement at 500 mg/kg/day

Chlorsulfuron

Acute NOAEL 75 mg/kg Rabbit Decreased weight gain at 200 mg/kg

Chronic NOAEL 5 mg/kg/day Rat Weight changes at 25 mg/kg/day
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

205

Herbicide Duration Endpoint Dose Species Effect Noted at LOAEL

Clopyralid

Acute NOAEL 75 mg/kg Rat Decreased weight gain at 250 mg/kg

Chronic NOAEL 15 mg/kg/day Rat Thickening of gastric epithelium at 150 

mg/kg/day

Glyphosate

Acute NOAEL 175 mg/kg Rabbit Diarrhea at 350 mg/kg

Chronic NOAEL 175 mg/kg/day Rabbit Diarrhea at 350 mg/kg

Imazapic

Acute NOAEL 350 mg/kg Rabbit Decreased body weight at 500 mg/kg

Chronic NOAEL2 45 mg/kg Dog Microscopic muscle effects at 137 

mg/kg

Imazapyr

Acute NOAEL 250 mg/kg Dog No effects at highest doses tested

Chronic NOAEL 250 mg/kg/day Dog No effects at highest doses tested

Metsulfuron 

methyl

Acute NOAEL3 25 mg/kg Rat Decreased weight gain at 500 mg/kg

Chronic NOAEL 25 mg/kg/day Rat Decreased weight gain at 125 mg/kg

Picloram

Acute NOAEL 34 mg/kg Rabbit Decreased weight gain at 172 mg/kg

Chronic NOAEL 7 mg/kg Dog Increased liver weight at 35 mg/kg4

Sethoxydim

Acute NOAEL 160 mg/kg5 Rabbit Reduced number of viable fetuses, 

some dam mortality at 480 mg/kg

Chronic NOAEL 9 mg/kg/day Dog Mild anemia at 18 mg/kg/day

Sulfometuron 

methyl

Acute NOAEL 87 mg/kg Rat Decreased body weight at 433 mg/kg

Chronic NOAEL 2 mg/kg/day Rat Effects on blood and bile ducts at 20 

mg/kg/day

Triclopyr

Acute NOAEL 100 mg/kb Rat Malformed fetuses at 300 mg/kg

Chronic NOAEL 0.5 mg/kg/day Dog Effect on kidney at 2.5 mg/kg/day

NPE 

Surfactants

Acute NOAEL 10 mg/kg Rat Slight reduction of polysaccharides in

liver at 50 mg/kg/day

Chronic NOAEL 10 mg/kg/day Rat

Increased weights of liver, kidneys, 

ovaries, and decreased live pups at 50 

mg/kg/day

2 Imazapic – NOAEL calculated from a LOAEL of 137 mg/kg/day and application of a safety factor of 3 to extrapolate from a LOAEL 

to a NOAEL.

3 The acute NOAEL of 24 mg/kg is very close to the chronic NOAEL, so chronic value is used for acute exposures.

4 US EPA/OPP 1998

5 Source of the value used by EPA (180 mg/kg) is not well documented, so the lower value of 160 mg/kg from a rabbit study is used 

as the toxicity index for this analysis.

Source: SERA 1998, 2001, 2003, 2004, 2007, 2011 and Bakke, 2003.

Symbol meanings for the following table are as follows:

-- Exposure scenario results in a dose below or equivalent to the toxicity index.

× Exposure scenario results in a dose that exceeds the toxicity index at typical and highest application 

rates.

Exposure scenario results in a dose that exceeds the toxicity index at highest application rates only.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

206

Table 60. Exposure scenario results from FS risk assessments for mammals, birds, and honeybees, using 

the typical and highest application rates and assuming upper residue rates

Animal/Scenario

Aminopyralid

Chlorsulfuron

Clopyralid

Glyphosate

Imazapic

Imazapyr

Metsulfuron 

methyl

Picloram

Sethoxydim

Sulfometuron 

methyl

Triclopyr

NPE Surfactant

Acute Exposures

Direct spray, bee -- -- -- -- -- -- -- -- -- -- --

Direct spray, sm. mammal -- -- -- -- -- -- -- -- -- -- -- ×

Consume contaminated vegetation

small mammal -- -- -- -- -- -- -- -- -- -- --

large mammal -- -- -- -- -- -- -- -- -- ×

large bird -- -- -- -- -- -- -- -- -- -- × ×

Consume contaminated water

Spill, sm. mammal -- -- -- -- -- -- -- -- -- -- -- --

Consume contaminated insects

small mammal -- -- -- -- -- -- -- -- -- ×

small bird -- -- -- -- -- -- -- -- -- × ×

Consume contaminated prey

carnivore (sm. mammal) -- -- -- -- -- -- -- -- -- -- -- --

predatory bird (sm. mammal) -- -- -- -- -- -- -- -- -- -- --

predatory bird (fish) -- -- -- -- -- -- -- -- -- -- -- --

Chronic Exposures

Consume contaminated vegetation

small mammal, on site -- -- -- -- -- -- -- -- -- -- -- --

lg. mammal, on site -- -- -- -- -- -- -- -- -- × --

lg. bird, on site -- -- -- -- -- -- -- × --

Consume contaminated water

small mammal -- -- -- -- -- -- -- -- -- -- -- --

Consume contaminated insects#

small mammal -- -- unk unk* -- -- -- unk unk unk unk unk

small bird -- -- unk unk -- -- -- unk unk unk unk unk

Consume contaminated prey

carnivore (sm. mammal)# -- -- -- -- -- -- -- -- -- -- ×

predatory bird (sm. 

mammal)# -- -- -- -- -- -- -- -- + -- --

predatory bird (fish) -- -- -- -- -- -- -- -- -- -- -- --

# Data are lacking regarding chronic exposures, so effects are assumed by comparing acute dose vs. chronic NOAEL, which will 

likely over-estimate actual risk.

unk – unknown; insufficient data to assess risk.

*unknown only at highest rates; typical rates pose no apparent risk.

+ Previous versions of this table showed an exceedence at high application rate for a chronic scenario. That is not shown here, 

because the actual estimated dose is equivalent to the toxicity index, rather than an exceedence.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

207

While the amount of each herbicide/surfactant applied varies, many of the pdfs were specifically designed 

to ensure that any application rates used were below levels that would result in an exposure of a nontarget species that exceeded the NOAEL.

Standards in the Malheur National Forest LRMP require that adverse effects to wildlife from invasive 

plant treatment be minimized or eliminated through project design and implementation. All action 

alternatives were designed to comply with these standards. Project design features (pdfs) and herbicideuse buffers place restrictions on how and where herbicides are applied.

Results of the herbicide analysis indicate that birds and mammals consuming vegetation or insects that 

have been sprayed with some of the herbicides have the most potential to receive doses above the toxicity 

index, although other scenarios occasionally exceeded the toxicity index. While all proposed herbicides 

are considered low risk, in order to compare toxicity risks, proposed herbicides/surfactants were placed 

into the following four categories of “relative risk”. Adherence to invasive plant treatment standards and 

pdfs; actual animal behavior and feeding strategies, and/or seasonal presence/absence within treatment 

area reduce these risks. As a result and considering the limited spatial extent of infestation (over 80 

percent of sites are 0.25 acres or less), wildlife is not likely to be exposed to harmful levels of herbicides 

under the action alternatives. 

♦ Herbicides that Do Not Pose a Risk – These include herbicides that don’t pose a risk to wildlife 

at either typical or highest application rates and include aminopyralid, chlorsulfuron, imazapic, 

imazapyr and metsulfuron methyl. There are no exposure scenarios anticipated that would result 

in adverse effects to wildlife from application of these herbicides.

♦ Lower Risk Herbicides – These herbicides which include clopyralid, sethoxydim and 

sulfometuron methyl, did not pose a risk to wildlife at typical application rates, although 

sethoxydim and sulfometuron methyl posed a chronic risk to some species at the highest 

application rate. While data is lacking to fully assess chronic impacts to an insectivorous small 

mammal or bird, with implementation of pdf F2, these herbicides would not be applied above the 

typical application rate.

♦ Moderate Risk Herbicides – These herbicides, which include picloram and glyphosate do not

pose a risk at typical application rates, but do pose an acute and chronic risk for some groups at 

the highest application rate. Also picloram is more persistent in some soil types. While data is 

lacking to fully assess chronic impacts to an insectivorous small mammal or bird, with 

implementation of pdf 2, these herbicides would not be applied above the typical application rate.

♦ Higher Risk Herbicides– Of the herbicides/surfactants proposed only triclopyr and NPE-based

surfactants fall into this category because they exceeded the toxicity index for several species 

groups at both the typical and highest application rate. While data is lacking to fully assess 

chronic impacts to an insectivorous small mammal or bird, with implementation of the Malheur 

National Forest LRMP standard that limits use of triclopyr to selective techniques only, and pdf

F2 that requires that NPE-based surfactants only be broadcast at 0.5 lbs. active ingredient per 

acre, it is unlikely that these herbicides would pose a risk to wildlife. 

As described above, effects to wildlife vary depending on the type of herbicide application proposed or 

the use of non-herbicide treatments. Also the effectiveness of the action alternatives at controlling or 

containing invasive plants varies by treatment. Table 61 displays the first year/first choice treatments that 

would occur in each action alternative and identifies alternative treatments within wildlife habitats that are 

considered to be “at risk” from invasive plants. The information presented is used in the alternative

analysis to compare the extent and type of treatment within habitats affected and to help assess the 

effectiveness of each of the alternatives at controlling invasive plants.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

208

Table 61. First year/first choice treatments by habitat type and action alternative

Habitat

Invasive

Plant 

Acres

Alternative B

Acres

Alternative C

Acres

Alternative D

Acres

Herbicide No 

Herbicide

Herbicide No 

Herbicide

Herbicide No 

Bcast Spot Bcast Spot Bcast Spot Herbicide

Dry Forest4 1,386 845 541 0 0 532 854 390 996 0

Mesic Mixed 

Conifer 355 219 136 0 0 109 246 87 268 0

Riparian 

Woodland1,3 678 367 312 0 0 34 644 19 660 0

Riparian 

Shrub1,3 64 29 35 0 0 2 62 1 63 0

Montane 

Meadow 47 30 18 0 0 16 31 14 34 0

Steppe 

Shrubland2,3 72 43 29 0 0 27 45 19 53 0

Sagebrush3 79 14 65 0 0 22 57 14 65 0

Juniper 

Woodland 28 14 14 0 0 8 20 5 23 0

Grassland3 122 73 49 0 0 25 97 20 102 0

Wetland3 69 38 31 0 0 5 64 3 66 0

1 – Some of the riparian habitats are also included as other forest or non-forest communities

2 – Some inclusions of sagebrush are included in steppe shrublands

3 – Habitats that are considered to be most “at risk” from invasive plants

4 – Understory vegetation within open canopy dry forest can be adversely affected by invasive plants.

Effects of Alternative B

Direct and Indirect Effects

Under alternative B a total of 2,124 acres would be treated with herbicides, including 1,281 acres of 

broadcast application and 843 acres of spot treatments during the first year of treatment. Future treatments 

would be determined by the effectiveness of the initial herbicide treatments, and it is expected that as 

existing infestations are reduced, a combination of herbicide and non-herbicide methods would be used. 

Due to the ability to use aminopyralid and thus broadcast spray more area, Alternative B is expected to 

include less future manual and mechanical treatments than alternatives C or D. See chapter 3.1.4 for a 

discussion about how alternatives C and D may result in more repeated entries.

Effects of manual, mechanical and biocontrol treatments would be similar to those described previously 

in the Effects Common to All Action Alternatives section. Because alternative B would have fewer 

manual/mechanical treatments and considering these treatments pose a greater risk of disturbance to 

wildlife than herbicides, the likelihood of disturbance or mortality during treatment is reduced under this 

alternative. The likelihood of direct effects are further reduced, when you consider that 1 percent or less 

of the affected habitats would be treated (table 61), existing sites are small and scattered, and 

approximately 80 percent of known sites occur along roads, which provide less preferred habitat for many 

wildlife species. Finally, using the implementation process described under section 2.4.2., Forest Service 

personnel would develop annual treatment prescriptions for all existing and new (EDRR described below) 

invasive plant infestations. This would include identification of wildlife species of local interest or their 

habitats and implementation of appropriate pdfs, including modification of treatment methods/timing if 

necessary to reduce potential risks. Collectively for these reasons the likelihood of mortality for any 

wildlife species is low and any disturbance would be short-term in nature. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

209

Effects of herbicide application would be similar to those described previously in the Effects Common to

All Alternatives section. None of the first-choice herbicides used resulted in an acute or chronic dose that 

exceeded the toxicity index for any group of wildlife species. While other herbicides could be used in 

subsequent years to achieve objectives, with implementation of pdfs, Forest standards and treatment 

buffers, and considering annual treatment prescriptions would identify species/habitats of concern and 

modify treatment type and timing if necessary; there are no adverse effects from herbicide exposure 

anticipated under this alternative. 

Effects to habitat vary by the size of the infestation and effectiveness of treatment. For example, while 

bare ground can be created in dense patches of invasive plants, effects to wildlife would be reduced 

because these areas do not provide preferred habitat. Considering approximately 250 acres have 50 

percent infestation or more, cover would be retained on all sites. Alternative B includes a full range of 

treatment options, including broadcast spraying and use of aminopyralid near standing water, wetlands 

and across riparian areas; therefore, it is estimated that treatment effectiveness would be approximately 80 

percent. Also alternative B would be most effective at controlling larger infestations should they be 

detected in the future. As a result alternative B would effectively control invasive plants and promote the 

long-term maintenance of native vegetation and wildlife, including “at risk” habitat identified in chapter

3.7.2.

Malheur National Forest Land and Resource Management Plan (LRMP) Amendment

The proposed LRMP amendment to add aminopyralid would likely improve the effectiveness of treatment 

(chapter 3.1.4). This would result in neutral or positive impacts to wildlife on the Malheur National Forest 

because aminopyralid poses no likely risk to wildlife and would effectively treat invasive plants which 

can degrade habitat. 

Early Detection Rapid Response

In addition to proposed treatments, alternative B would allow treatment of new detections (EDRR), as 

long as the treatment method is within the scope of this EIS. The treatment of newly found sites adds 

additional risk factors to wildlife just by adding additional exposure areas. This also expands the 

treatment into areas that may not have been originally anticipated. However, the implementation planning 

process identified in chapter 2 would be used with each new infestation site to determine treatment. Also 

the pdfs provide layers of caution, so even if the exact locations are not known, the potential for adverse 

effects are minimized. Implementation of pdfs and herbicide-use buffers and treatment limits would work 

together to provide sideboards to deal with the uncertainty of treating new sites (USDA Forest Service 

2008b) and ensure that direct and indirect effects are consistent with those anticipated in the FEIS.

Alternative B would be most effective at controlling infestations detected in the future (see chapter 3.1.4).

Effects of Alternative C 

Direct and Indirect Effects

Under alternative C, non-herbicide treatments would be increased on 1,389 acres during the first year of 

treatment, and more repeated manual/mechanical treatments would occur in subsequent years (see chapter 

3.1.4 for discussion about why more repeated treatments would be necessary for alternative C). Effects of 

non-herbicide treatments would be similar to those discussed previously in the Treatment Effects 

Common to All Action Alternatives section. The likelihood of direct effects are increased somewhat under 

this alternative because manual/mechanical treatments can increase the likelihood of disturbance to less 

mobile species. Like alternative B, when you consider that 1 percent or less of the affected habitats would 

be treated (table 61), existing sites are small and scattered, and approximately 80 percent of the known 

sites occur along roads, which provide less preferred habitat for many wildlife species, the likelihood of 

direct effects are low. Potential for effects are further reduced when you consider implementation of pdfs
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

210

and that annual treatment prescriptions would be prepared for all new infestations that would identify 

wildlife species of local interest or their habitats, and treatment methods/timing would be modified if 

necessary to reduce potential risks. Treatment risks are increased somewhat under this alternative, but 

collectively for these reasons the likelihood of mortality for any wildlife species is low and any 

disturbance would be short term. 

Effects of herbicide treatments would be similar to those discussed previously in the Treatment Effects 

Common to All Action Alternatives section. Like alternative B, none of the first year/first choice

herbicides resulted in an acute or chronic dose that exceeded the toxicity index for any wildlife species. 

While other herbicides could be used in subsequent years to achieve objectives, with implementation of 

pdfs, Forest standards and treatment buffers, and considering annual treatment prescriptions would 

identify species/habitats of concern and modify treatment type and timing if necessary; there are no 

adverse effects to wildlife from herbicide exposure anticipated.

Like alternative B, cover would be retained on all treatment sites and there would be little change in 

wildlife habitat conditions in the short-term. However, requiring only non-herbicide treatments on much 

of the infested areas would reduce effectiveness compared to using herbicides in combination with nonherbicide treatments (see chapter 3.1.4), and overall treatment effectiveness would be reduced by almost 

half from that of alternative B. So while implementation of alternative C would help contain or control 

invasive plants, it would be less effective than alternatives B or D. 

Malheur National Forest Land and Resource Management Plan (LRMP) Amendment

The proposed LRMP amendment to add aminopyralid would likely improve the effectiveness of treatment 

(chapter 3.1.4). This would result in neutral or positive impacts to wildlife on the Malheur National 

Forest. 

Early Detection Rapid Response

Like alternative B, alternative C would allow treatment of new detections (EDRR) as long as the 

treatment method is within the scope of this EIS. The treatment of newly found sites adds additional risk 

factors to wildlife just by adding additional exposure areas. This also expands the treatment into areas that 

may not have been originally anticipated. However, the implementation planning process identified in 

chapter 2 would be used with each new infestation site to determine treatment. The pdfs provide layers of 

caution so that even if the exact locations are not known, the potential for adverse effects are minimized. 

Implementation of pdfs, buffers and treatment limits all work together to provide sideboards to deal with 

the uncertainty of treating new sites (USDA Forest Service 2008b) and ensure that direct and indirect 

effects are consistent as discussed in the alternative and species-specific analysis presented. Alternative C 

would be the least effective of the action alternatives at controlling future infestations due to the 

restrictions on treatment.

Effects on Alternative D 

Direct and Indirect Effects

Alternative D is similar to alternative B, except that aminopyralid would not be approved for use. As a

result, use of chlorsulfuron (a lowest risk herbicide) would increase and some moderate-risk herbicides 

(glyphosate and picloram) would be used as first year/first choice treatments. Use of herbicides other than 

aminopyralid would also require increased use of spot application within all habitats except sagebrush. 

Effects of treatment would be similar to those described previously in the Effects Common to All Action 

Alternatives section. While the increase in spot application would increase risks of direct effects from 

those of alternative B, when you consider that 1 percent or less of any of the affected habitats would be 

treated (table 61), existing sites are small and scattered, and approximately 80 percent of the known sites 

occur along roads, which provide less preferred habitat for many wildlife species, the likelihood of direct 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

211

effects are low. Potential for effects are further reduced when you consider implementation of pdfs and 

that annual treatment prescriptions would be prepared for all existing and new infestations that would 

identify wildlife species of local interest or their habitats, and treatment methods/timing would be 

modified if necessary to reduce potential risks. Treatment risks are increased somewhat under this 

alternative, however, like the other action alternatives, the likelihood of mortality for any wildlife species 

is low and any disturbance would be short term.

Use of moderate to higher risk herbicides would occur on approximately 788 acres or 37 percent of 

infested acres treated during the first year. Implementation of pdfs, Forest standards and treatment buffers 

and considering annual treatment prescriptions would identify species/habitats of concern and modify 

treatment type and timing if necessary, no adverse effects to wildlife from herbicide exposure anticipated.

Proposed treatments would reduce existing infestation of invasive plants across the project area and 

promote native wildlife habitat. Like alternatives B and C, reductions in cover would be small and 

scattered and there would be little change in the availability of wildlife habitat. Because aminopyralid is 

not approved under this alternative, treatment effectiveness of the sites would be approximately 66 

percent of the sites treated. Much of the reduction in effectiveness would occur along streamsides due to 

increased buffers if aminopyralid is not approved. While alternative D would be effective at reducing 

invasive plants, it would be less effective at promoting the long-term maintenance of native vegetation 

and wildlife habitat than alternative B.

Malheur National Forest Land and Resource Management Plan (LRMP) Amendment

No amendment is proposed for alternative D.

Early Detection Rapid Response

Like alternative B, alternative D would allow treatment of new detections (EDRR), as long as the 

treatment method is within the scope of this EIS. The treatment of newly found sites adds additional risk 

factors to wildlife just by adding additional exposure areas. This also expands the treatment into areas that 

may not have been originally anticipated. However, the implementation planning process identified in 

chapter 2 would be used with each new infestation site to determine treatment. The pdfs provide layers of 

caution so even if the exact locations are not known, the potential for adverse effects are minimized. 

Project design features, herbicide-use buffers and the implementation planning process all work together 

to provide sideboards to deal with the uncertainty of treating new sites (USDA Forest Service 2008b) and 

ensure that direct and indirect effects are consistent with discussed in the alternative and species specific 

analysis presented. Alternative D would be less effective in reducing invasive plants than alternative B

Cumulative Effects of the Action Alternatives

Potential cumulative effects to wildlife are assessed for each of the action alternatives evaluated in the 

EIS, as well as for the individual species evaluated. The cumulative effects analysis area includes all lands 

within the project area proclamation boundary. This area was selected because it contains a diversity of 

habitat conditions, is large enough to assess species with large home ranges as well as migratory species, 

and would allow for assessment of potential impacts on lands of other ownerships. Because future 

projects can only be reasonably predicted for the next 12 years, potential cumulative effects are evaluated 

out to the year 2025. 

Past management activities on the Forest in combination with a conservative approach to invasive plant 

treatment has resulted in an increase in invasive plant infestation across the Forest. On-going and 

foreseeable future actions will continue to promote the spread of invasive plants. Activities on NFS lands 

that could further increase the spread of invasive plants and affect wildlife habitat including prescribed 

burning, timber harvest and reforestation treatments, fuel reduction, plantation thinning, road closures and 

maintenance and decommissioning, facility/recreation projects, and grazing. These activities will occur 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

212

Forest-wide, are spread out over 60 sub-watersheds (HUC6), and would be implemented over the next 10 

years. A complete list of future activities can be found in the project file. Treatments that don’t result in 

disturbance would result in little increase in the spread of invasive plants. Also with implementation of 

Forest standards that require re-seeding with native vegetation, use of weed free hay and equipment 

cleaning provisions, the likelihood invasive plants would spread due to recreation/facility construction 

activities is reduced. Consequently of the anticipated future activities, timber harvest, fuel reduction, 

recreation, burning and grazing have the most potential to increase the spread of invasive plants.

While future management activities would comply with Forest standards designed to reduce the spread of 

invasive plants (e.g. equipment cleaning clauses and use of weed-free seed during re-vegetation), 

disturbance and increased levels of light would promote establishment of invasive plants on many of the 

lands affected by management. While it is not anticipated that grazing use would change, on-going 

grazing would also continue to promote the spread of invasive plants, particularly in dry forest and shrubsteppe habitats. Continued grazing would also reduce wildlife cover and forage, although with 

implementation of allotment management plans and allowable use standards, it is expected that habitat 

would be maintained. Recreational activity on NFS land is expected to increase and on-going activities 

across all ownerships would continue to cause ground disturbances that can contribute to the introduction, 

spread and establishment of invasive plants on NFS lands (USDA Forest Service 2005a). 

In addition to activities on NFS lands, herbicides are commonly applied on lands of other ownerships for 

a variety of agricultural, landscaping and invasive plant management purposes. Herbicide use occurs on 

tribal lands, state and county lands, private forestry lands, rangelands, utility corridors, road rights-ofway, and private property. The Bureau of Land Management has also proposed invasive plant treatments 

using herbicides on lands in Oregon, although their proposals are not site specific and cannot be used to 

model cumulative effects at the watershed scale. 

Under all action alternatives, some level of invasive plant control would occur on 2,124 acres and of this, 

1,067 acres occur within watersheds where some future management activity is anticipated. Watersheds 

that contain both invasive plant treatments and future management activities are displayed in table 62.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

213

Table 62. Watersheds containing planned future activities and invasive plant treatments

Watershed Future

Activity1

Invasive Plant

Treatments2

Birch Creek P 1

Bosenberg Creek G 4

Bridge Creek T, R,G 26

Crane Creek T,B, 12

Deardorff Creek T 11

Dry Cr. John Day River P <1

Elk Creek T,B 24

Emigrant Creek T,R 44

Granite Boulder Creek R,P 120

Long Creek P 1

Indian Creek P 1

Lake Creek G 3

Lick Creek G 8

Little Boulder Creek T,B,R 139

Long Creek P 18

Lower Bear Creek T,B 1

Lower Deer Creek T, 1

Lower Scotty Creek T,B 3

Middle Bear Creek T,B 2

Middle Silvies River R 6

Mill Creek R 145

North Basin T,B,F,R 15

Pine Creek B,R, 79

Slide Creek P 6

Starr Creek T,F,B 16

Summit Creek T,B,G 15

Upper Big Creek G 5

Upper Camp Creek G 14

Upper Deer Creek P 1

Upper Fox Creek P 22

Upper Long Creek P 18

Upper Malheur River P 45

Upper South Fork John Day River T 46

Upper Silver Creek T,B,R 20

Upper Silvies River T,B,F,R,P 56

Van Aspen-Silvies River T,B 15

Vinegar Creek T,B,R 81

Wiley Creek P,B,R 2

Wolf Creek T 38

Total Invasive Plant Treatment 1,067

1 – Activity Codes (T)-Timber harvest, (B)-Burning, (F)-Fuel Reduction, (R)-Recreation/facility, (P)-Plantation thinning, (G)-Grazing

improvements. 2 – Invasive plant treatments that don’t occur in watersheds with future treatments are not displayed.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

214

Thirty-nine watersheds would receive invasive plant treatments, as well as future management. Of these, 

20 would receive harvest, burning or fuel treatments that are most likely to promote the spread of invasive 

plants. One percent or less of all watersheds are proposed for treatments. As a result unaffected habitat is 

widely available and implementation of anticipated future activities combined with proposed actions is 

not expected to reduce the availability of wildlife habitat or significantly affect wildlife. Additionally, 

implementation of the action alternatives would reduce the seed source within many of the watersheds.

In addition to proposed treatments, all action alternatives would allow treatment of new detections 

(EDRR), as long as the treatment method is within the scope of this EIS. The treatment of newly found 

sites adds additional risk factors to wildlife just by adding additional exposure areas. This also expands 

the treatment into areas that may not have been originally anticipated., The decision process identified in 

the EIS would be used with each new infestation site to determine treatment. In addition, pdfs have been 

set up to provide layers of caution so that even if the exact locations are not known, the potential for 

adverse effects are minimized. Implementation of pdfs, buffers and treatment limits (i.e. leaving stream 

corridors untreated) all work together to provide sideboards to deal with the uncertainty of treating new 

sites (USDA Forest Service 2008b).

Since wildlife move and migrate, some species could be exposed to herbicides on NFS lands, as well as 

adjacent lands that are within their home range or along travel corridors. Consequently species could be 

exposed to the same herbicide on multiple ownerships, or a combination of different herbicides. Wildlife

could also be exposed to other chemicals, such as insecticides, rodenticides, fungicides, and others. While 

potential for multiple herbicide exposures to wildlife exists, the risk that adverse effects would occur 

depends on a number of factors such as feeding strategy, seasonal activity, and the types and amounts of 

herbicides used. The following considerations collectively reduce potential impacts from herbicide 

exposure on wildlife: 

While total acres of herbicides proposed on lands of other ownerships are not available, counties are 

responsible for controlling noxious weeds along county roads and other county property outside of 

and within the Forest. They also work with conservation districts, weed management areas, and 

watershed councils to control noxious weeds on private property. So while additive herbicide 

exposures are possible if herbicide is used on neighboring lands during the same day as NFS land are 

treated, activities occurring on the Forest Service, other federal agencies, states, and counties would 

be coordinated, making treatment overlaps unlikely.

The herbicides proposed for use a do not significantly bio-accumulate (R6 2005 FEIS). For additive 

doses to occur, two exposures would have to occur at approximately at the same time. At proposed 

application rates and with implementation of pdfs, it is unlikely that any species would receive 

additive doses beyond those evaluated for chronic and acute exposures in the USDA Forest Service 

risk assessments. 

The likelihood that wildlife would receive a toxic level of herbicides are reduced because herbicides 

used are excreted within 48 hours and herbicide persistence is reduced through implementation of 

pdfs.

While pdfs add a measure of protection for non-target wildlife on NFS lands, wildlife may be more 

vulnerable on lands of other ownerships where protective measures are unknown. However 

treatments are spread out over 100 HUC 6 watersheds, which vary in size between 10,000 and 38,000 

acres and 1 percent or less of all affected watersheds would be proposed for treatment. The widely 

scattered nature of proposed treatments, combined with the small size of infestations (over 80 percent 

less than one-quarter acre), reduce the likelihood that any wildlife species that utilizes multiple 

ownerships would exposed to toxic levels of herbicide due to proposed treatments.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

215

The management direction included in all action alternatives as well as the environmental conditions 

and animal behavior would tend to minimize actual impacts for EDRR. Prior to implementation 

choices could be made to avoid situations that could cause harm to wildlife. For example, certain 

herbicides could be avoided in specific areas or times of the year where/when species that utilize 

grass such as amphibians may be at risk, or more specific application methods could be used. These 

factors would be evaluated prior to treatment and pdfs applied that modify treatment methods/timing

if necessary to reduce potential impacts to wildlife. Effects of treatments each year under early 

detection-rapid response, by definition, would not exceed those predicted for the most ambitious 

conceivable treatment scenario. This is because the pdfs do so much to control the potential for 

adverse effects and because if the most ambitious treatment scenario were implemented, the potential 

for spread into new areas would be greatly reduced.

Collectively for the above reasons, and due to the small amount of habitat affected within any watershed 

and widespread availability of unaffected habitat, it is unlikely that any proposed treatments would 

measurably contribute to any other activities on private land that would result in significant effects to 

wildlife.

Effects to Federally Listed Species

Effects determinations for federally listed species are shown in the following table.

Table 63. Draft findings and determinations for ESA-listed wildlife species in the project area

Species Action Alternative

Determination Reason

Canada Lynx No Effect Lynx have not been documented on the Forest and 

suitable habitat would be unaffected by treatments.

North American Wolverine No Effect Wolverine use of the project area is low and use would 

not occur within treatment sites.

Canada Lynx

Direct and Indirect Effects and Determination

The Malheur National Forest is categorized as a “peripheral area” based on the Draft Lynx Recovery 

Outline (USDI FWS 2005a) and there is no documentation of lynx reproducing in the state of Oregon.

The Forest has not had a verified lynx observation since 1999, therefore the Forest is considered 

“unoccupied” habitat (USDI FWS 2006a). Currently only eight acres of foraging and den habitat are 

proposed for treatment. Due to the small amount of suitable habitat affected and considering the project 

area is not considered occupied lynx habitat, there would be no direct, indirect or cumulative effects and 

implementation of the action alternatives would have No Effect on lynx.

North American Wolverine

Direct and Indirect Effects and Determination

Wolverines occur in remote areas and have not been recently documented on the Forest. Also there is less 

than an acre of invasive plants proposed for treatment within potential den habitat. Wolverine utilize 

higher elevations during the snow free period to avoid high temperatures and human activity (Ruggiero et 

al 1999), thus direct effects to wolverine from proposed treatments are not anticipated.. Similarly, because 

they prefer closed-canopy forest habitat at upper elevations, wolverine habitat would not be adversely 

affected by invasive plants. As a result there are no direct, indirect, or cumulative effects to this species 

anticipated and implementation of alternatives B through D would have No Effect on the wolverine. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

216

Effects to Forest Service Sensitive Species

Table 64. Sensitive Species determinations and rationale

Species Action Alternative 

Determination Rationale

Gray Wolf MIIH1 Unlikely to be present in treatment areas. Future den 

and rendezvous sites protected. 

Pygmy Rabbit MIIH1

Not documented within the project area and unlikely to 

be present in treatment areas. Project design features 

minimize potential effects from herbicide exposure and 

treatment. Treatment would promote native habitat.

Townsend’s Big-eared Bat No Impact

This species would not be present during treatment. 

Foraging behavior and project design features make 

herbicide exposure highly unlikely.

Pallid Bat No Impact

Not present during treatment. Foraging behavior and 

project design features make herbicide exposure

highly unlikely

Fringed Myotis No Impact

Not present during treatment. Foraging behavior and 

project design features make herbicide exposure

highly unlikely

Bald eagle No Impact

Few invasive plant acres near suitable nesting, 

foraging or roost habitat. Project design features 

effectively reduce potential impacts to nesting or 

roosting birds. At proposed application rates and 

methods, no adverse effects from herbicide exposure 

anticipated.

American peregrine falcon No Impact

No known nests within the project area. Project design 

features make disturbance or exposure to herbicides 

unlikely. 

Grasshopper Sparrow No Impact

Not documented within the project area. Project design 

features restrict activities within occupied habitat and 

make herbicide exposure unlikely. Suitable habitat 

maintained.

Wallowa Rosy Finch No Impact Not present in treatment areas. Suitable habitat not 

proposed for treatment.

Greater sage grouse MIIH1

Nesting not documented within the project area. 

Project design features restrict activities to breeding 

birds and reduce the likelihood of disturbance or 

herbicide exposure. Suitable habitat maintained.

Bufflehead No Impact

Not present in treatment areas. Project design features 

make herbicide exposure highly unlikely. Suitable 

habitat maintained.

Upland sandpiper MIIH1

Nesting not recently documented on the Forest.

Project design features reduce treatment and herbicide 

exposure effects within occupied habitat. Suitable 

habitat maintained. 

Bobolink No Impact

Not documented within the project area. Project design 

features minimize potential for effects and make 

herbicide exposure highly unlikely. Suitable habitat 

maintained.

Lewis’ and white-headed 

woodpeckers. MIIH1 Nest habitat would not be affected. Foraging behavior 

and project design features make herbicide exposure 

unlikely. Low likelihood of disturbance. 

Columbia spotted frog MIIH1 Low likelihood of disturbance. Project design features 

restrict treatment in suitable breeding habitat and make 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

217

Species Action Alternative 

Determination Rationale

herbicide exposure unlikely. Suitable breeding habitat 

maintained.

Shortface lanx No Impact Not present in treatment areas.

Johnson’s hairstreak No Impact Not present in treatment areas.

Silver-bordered fritillary MIIH1

Occurrence within the project area is unlikely. Project 

design features restrict treatment within occupied 

habitat and make herbicide exposure unlikely. Suitable 

habitat maintained. 

Haney basin duskysnail No Impact

Not present in treatment areas. Project design features 

protect future sites and make herbicide exposure 

highly unlikely. 

Columbia clubtail No Impact

Not documented in the project area. Project design 

features restrict treatment within breeding habitat and 

herbicide exposure highly unlikely.

1 – MIIH – May impact individuals or habitat (MIIH), but are not likely to lead to a trend toward federal listing”

Gray Wolf

Direct and Indirect Effects

Treatment - No known denning or rendezvous sites on or near the Malheur National Forest. While no 

packs have become established, transient individuals may occasionally travel through looking for new 

territory or mates, and there is potential for wolves to become established on the project area in the future.

Direct effects from invasive plant treatments include disturbance caused by noise, people and vehicles.

However, invasive plant projects involve very short-term disturbance with few people and might only be 

repeated once in the same growing season. Although wolves will travel over large distances, they are most 

likely to occur in wilderness and roadless areas, away from human disturbance. These areas tend to have 

minimal invasive plant infestations so the likelihood of disturbance is low. Additionally project design 

features are in place that prevents invasive plant treatments to occur in close proximity to den or 

rendezvous sites. As a result it is unlikely individual animals would be affected by treatment and if 

disturbance were to occur, it would be limited to short-term avoidance by foraging or transient 

individuals.

While proposed treatments would help maintain habitat for elk, deer or other prey species, there would be 

little change in gray wolf habitat.

Herbicides - None of the proposed herbicides would result in an acute exposure that exceeds the toxicity 

index, however chronic exposures to carnivores could occur at the typical and highest application rate 

with triclopyr or at the highest application rate of NPE-based surfactants. First-choice herbicides under 

alternatives B and C would pose no risk to wolves. While alternative D would use first-choice herbicides 

with NPE-based surfactants, with implementation of F2, application would be restricted to 0.5 lbs. of 

active ingredient per acres and there are no adverse effects from herbicide exposure anticipated. pdf F2

limits the use of NPE-based surfactants, and a Malheur National Forest LRMP standard limits triclopyr to 

selective applications (no broadcast). Triclopyr is not a first-choice herbicide in any alternative. 

Few treatments are proposed within preferred wolf habitat. Wolves forage over large areas and would not 

forage exclusively on contaminated prey; there are no adverse effects from herbicide exposure anticipated 

under any alternative. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

218

Cumulative Effects

While on-going and future activities could result in disturbance to wolves, it is expected any future den 

and rendezvous sites would be protected from treatment. Also many of the anticipated future treatment 

would be expected to promote habitat for big game. So while future treatments could result in short-term 

disturbance to foraging or transient individuals, because proposed treatments would help to maintain 

native big game range, and considering adverse effects from herbicide exposure are not anticipated, none 

of the alternatives would measurably contribute to any other past, on-going or foreseeable future activity 

and result in significant effects to the wolf.

Summary and Determination 

To date gray wolves have not been confirmed on the Malheur National Forest, although use is likely and 

it is possible that short-term disturbance could occur due to proposed treatments. As a result, and based on 

the above analysis and the following rationale, implementation of alternatives B through D “may impact 

individuals or habitat (MIIH), but are not likely to lead to a trend toward federal listing” the gray wolf.

♦ Project design features would prevent disturbance to any den or rendezvous sites established on 

the Forest.

♦ At proposed application rates and with implementation of pdfs, there are no adverse effects from 

herbicide exposure anticipated. 

♦ Invasive plants and invasive plant treatments are less likely to occur in preferred remote habitat. 

♦ Any disturbance from invasive plant treatment would be short-term in nature. 

♦ Treatment would help maintain native plant communities and preferred big game habitat.

Pygmy Rabbit

Direct and Indirect Effects

Treatment - All proposed treatments have the potential to result in disturbance during implementation. 

Because less mobile young would be in burrows underground there is no direct mortality anticipated. 

Should rabbits occupy the forest in the future, with implementation of pdf J-6c, the timing, location and 

method of treatment be coordinated with a biologist in suspected use areas and any direct effects would 

be limited to short-term disturbance during treatment. 

Loss of habitat for the pygmy rabbit could occur with expansion of invasive plants on rangelands (Weiss 

and Verts 1984), therefore, proposed invasive plant treatments would result in a beneficial effect to pygmy 

rabbit habitat by reducing the future spread of invasive plants and a possible loss of habitat. 

Herbicides - There are no chronic exposures of concern with any of the proposed herbicides; although 

NPE-based surfactants applied at the highest rate could result in adverse effects from herbicide exposure. 

With implementation of F2, NPE-based surfactants would be applied below typical application rates. As a 

result and with implementation of pdf J6-a, which restricts treatment within sites suspected to contain 

burrows; there are no adverse effects from herbicide exposure anticipated. 

Cumulative Effects

Anticipated cumulative effects are discussed by alternative above. Because of the small size of their home 

range (Heady and Laundre 2005), it is unlikely they would be affected by herbicide treatment on lands of 

other ownerships. Also except for continued grazing and allotment improvements, future activities occur 

away from suitable habitat. As a result and considering grazing use is not expected to change, and that 

treatment is expected to help maintain suitable habitat, none of the alternatives would measurably 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

219

contribute to any other past, on-going or foreseeable future activity and result in significant effects to the 

pygmy rabbit.

Summary and Determination

The pygmy rabbit has not been documented on the forest. While short-term effects from treatment are

possible should they become established in the future, based on the above analysis and the following 

rationale, implementation “may impact individuals or habitat” (MIIH), but are not likely to lead to a trend 

toward federal listing.” for the pygmy rabbit.

♦ First-year treatment proposes 10 acres of suitable habitat.

♦ At proposed application rates and with implementation of pdfs, there are no adverse effects from 

herbicide exposure anticipated. 

♦ Should use on the forest occur in the future, project design features would modify treatment if 

necessary to reduce potential impacts. 

♦ Proposed treatments would contain or control invasive weed infestations and help to maintain 

native sagebrush habitat over the long-term. 

Townsend’s Big-eared Bat, Pallid Bat and Fringed Myotis

Direct and Indirect Effects

Treatment - While suitable habitat would be treated across the Forest, because bats either roost in 

structures or in the recessed crevices in snags during the day, and forage at a time when treatment would 

not occur, the likelihood that a bat would be affected by treatment is remote. 

Herbicides - Acute exposures of concern to insectivorous mammals could occur with NPE-based 

surfactants applied at the typical or highest application rate, or with use of picloram or glyphosate at the 

highest application rate. With implementation of pdf F2, NPE-based surfactants would be applied below 

the typical application rate and picloram and glyphosate would not be broadcast sprayed at the highest 

application rate. As a result, and considering bat foraging behavior (i.e., forage over large areas in a single 

evening) further reduces the likelihood of exposure, there are no adverse effects anticipated. 

Cumulative Effects

Anticipated cumulative effects are discussed by alternative above and include increased exposure to 

herbicides on land ownerships and reduction of suitable habitat due to future timber harvest. Less than 1

percent of the watersheds where future treatments would occur are proposed for management.

Consequently, suitable unaffected habitat would be available within all affected watersheds. As a result,

and considering that bats forage over large areas and would not be exposed to toxic levels of herbicides,

none of the alternatives would measurably contribute to any other past, on-going or foreseeable future 

activity and result in significant effects to the pallid bat, fringed myotis or Townsend’s big-eared bat.

Summary and Determination

All alternatives would treat invasive plants in suitable bat habitat. However roosting bats would be 

unaffected and it is unlikely foraging bats would occur in treatment sites or be adversely affected by 

herbicides. As a result implementation of the action alternatives would have No Impact on the pallid bat, 

fringed myotis or on Townsend’s big-eared bat. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

220

Bald Eagle

Direct and Indirect Effects

Treatment - Bald eagles are sensitive to human disturbance during the breeding season, particularly 

within sight distance of nest sites. Consequently human and vehicle presence can cause the birds to leave 

nests or stay away from the nest long enough to have detrimental effects to eggs or young (USDI FWS 

1986). Mechanical methods are more likely to cause effects at greater distances than other treatment 

methods, because machinery creates louder noise than other methods. 

While there are 3 acres of invasive plants proposed within winter roost habitat and 9 acres fall within onehalf mile of an eagle’s nest, implementation of the following pdfs would reduce or eliminate noise and 

disturbance to nesting, roosting and foraging eagles.

♦ pdf J2a – Invasive plant treatments would not occur within 0.25 miles during the nesting season 

(January 1st through August 31st).

♦ pdf J2b – Activities above ambient levels would not occur between October 31st and March 31st

during early morning or late afternoon near known winter roosts and concentrated foraging areas. 

Distance to daytime foraging areas would also be avoided. 

With implementation of these pdfs there are no direct impacts to eagle nests or reproduction anticipated. 

While disturbance to roosting or foraging eagles is possible, given the small amount of land along 

waterbodies proposed for treatment (67 acres), the likelihood of disturbance is remote.

Herbicides - The results of exposure scenarios indicate that no herbicide or surfactant proposed for use 

poses a plausible risk to birds from eating contaminated fish. All expected doses to fish-eating birds for 

all herbicides and NPE are well below any known no-observable-adverse-effect-level (NOAEL) (see 

Appendix P of the R6 2005 FEIS). Herbicide would not reach the upper canopies of mature trees where 

bald eagles nest, and with implementation of pdf J2-a, eagles would not be directly sprayed or encounter 

vegetation that has been sprayed. As a result there are no adverse effects from herbicide exposure 

anticipated. 

Cumulative Effects

Anticipated cumulative effects are discussed by alternative above and include possible herbicide exposure 

on all land ownerships, or modification of nest habitat due to proposed timber harvest. All future activities 

would be in compliance with bald eagle and golden eagle management guidelines (USDI Fish and 

Wildlife Service 2007b) and no impacts to nesting birds or reproduction are anticipated. While it is 

possible that eagles could be exposed to herbicides on lands of other ownerships, even if a bird fed for a 

lifetime upon fresh water fish that had been contaminated by an accidental spill of herbicide, they would 

not receive a dose that exceeded any known NOAEL. As a result, and considering that that the risk of 

adverse effects from proposed treatment have been effectively eliminated through implementation of pdfs, 

no alternative would measurably contribute to any other past, on-going or future activity and result in 

significant effects to the bald eagle. 

Summary and Determination

Invasive plant treatments are proposed in 3 acres of eagle winter roost habitat and on 9 acres within onehalf mile of known nests. Based on the above analysis and the following rationale, implementation of the 

action alternatives will have No Impact to bald eagles:

♦ Implementation of project design features would effectively eliminate the likelihood that nesting 

or winter roosting eagles would be affected by disturbance associated with invasive plant 

treatment. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

221

♦ Invasive plant treatments would not result in the removal of bald eagle nests or roost trees, or 

affect foraging habitat.

♦ With implementation of pdfs there are no adverse effects to eagles from herbicide exposure 

anticipated. 

♦ Projects conducted that are more than a quarter-mile from a nest, or a half-mile line of sight 

distance from a nest, and do not result in the modification of eagle habitat, or result in noise 

above ambient levels, should have no effect on bald eagles (FWS 2003a).

American Peregrine Falcon

Direct and Indirect Effects

Treatment - While suitable habitat exists, there are no known peregrine falcon nests on the Malheur 

National Forest. Because peregrine falcons nest on cliffs away from any known invasive plants, future 

nests would not be impacted by any of the proposed treatments. The following pdfs were designed to 

reduce the possibility that nesting birds or their young would be affected by proposed activities:

♦ J3- a - Seasonal restrictions, which are based on elevation and proximity to the nest will be 

applied near known nests sites and will be implemented until at least 2 weeks after all young have 

fledged, including;

♦ J3-b – All invasive plant treatments would be restricted within 0.5 miles of peregrine falcon nest 

during the nesting season (based on J3-a).

♦ J3-c – Invasive plant treatments involving motorized equipment or vehicles would be seasonally 

prohibited between 0.5 miles and 1.5 miles of known nests during the nesting season (based on 

J3-a).

♦ J3-d- Non-mechanized or low-disturbance invasive plant treatment activities may occur between 

0.5 miles and 1.5 miles of known nests during the nesting season, but would be coordinated with 

a wildlife biologist to identify mitigation measures, if necessary. 

With implementation of the above pdfs there are no effects to nesting birds or their young from proposed 

treatments anticipated. Also, due to the small amount of habitat proposed for treatment, and widespread 

availability of unaffected habitat, the likelihood that foraging birds would be affected is remote. 

Herbicides - The “fish-eating bird” scenario and the “mammal-eating bird” were used as surrogate 

scenarios to determine potential herbicide effects. No herbicide or NPE dose exceeded the toxicity indices 

for fish eating birds. Under the small mammal eating bird scenario, only NPE exceeded the NOAEL at the 

highest application rate. With implementation of pdf J2, applications would not exceed 0.5 lbs. of active 

ingredient per acre. As a result and considering that a peregrine falcon feeding on birds would not likely 

receive a chronic dose of herbicide from its prey, because the herbicides proposed for use are rapidly 

excreted from animals and do not bio-accumulate, it is unlikely birds would be exposed to harmful levels 

of herbicides under any alternative.

Cumulative Effects

Anticipated cumulative effects are discussed under the alternative section above and include possible 

herbicide exposure on lands of other ownerships. Also hexachlorobenzene (HCB), the contaminant in 

picloram (alternative D), and to a lesser extent clopyralid, does bio-accumulate in animal tissue; however 

it is present in very small amounts (picloram, 8 parts per million and clopyralid, less than 2.5 parts per 

million). The risk of bio-accumulation of HCB from picloram and clopyralid use is therefore very low.

The R6 2005 FEIS states that HCB is a ubiquitous and persistent chemical in the environment and the 

amount released from Forest Service use would be inconsequential in comparison to existing background 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

222

levels and annual releases from manufacturing. However, use of picloram and clopyralid in remote 

locations could constitute the primary source of HCB in those areas. Monitoring of peregrine falcons in 

the Pacific Northwest has revealed HCB in their blood samples, and peregrine populations in the PNW 

appear to continue to be affected by contaminants, although not HCB specifically. Eggshell thinning 

induced by DDE, the metabolite of DDT, affect populations in the Pacific Northwest and elsewhere, and 

residual levels of DDE continue to be detected in some peregrines (Henny et al. 1996). Reproductive 

failure at peregrine nests has also occurred in Oregon due to eggshell thinning (Peterson 2006). However 

with implementation of pdf J3-e the use of picloram and clopyralid is limited to one application per site 

per year within secondary nest zones. As a result and because broadcast application is restricted to the 

typical application rate, the likelihood for HCB contamination is remote and discountable. 

Analysis in the R6 2005 FEIS found that no herbicide dose exceeded the toxicity indices for fish eating or 

mammal eating birds at highest application rates in the maximum exposure scenarios. As a result, and 

with implementation of pdfs, none of the herbicides proposed would result in a level of concern and no 

alternative would measurably contribute to any other past, on-going or future activity and result in 

significant effects to the peregrine falcon. 

Summary and Determination

There are currently no known nest sites on the Forest. Should a nest become established in the future, 

implementation of project design features would ensure that nesting peregrine falcons would be not be 

adversely affected by treatments or be exposed to toxic levels of herbicide. Implementation of the action 

alternatives would have No Impact to peregrine falcons.

Grasshopper Sparrow

Direct and Indirect Effects

Treatment - Grasshopper sparrows are not known to occur within the project area. Should they become 

established in the future, pdf J9-a restricts treatment within occupied habitat and there are no impacts to 

nesting birds or young anticipated. It is unlikely that foraging or migrating birds would be affected

because of the small amount of habitat proposed for treatment (71 acres).

Invasive plants can adversely affect habitat for some grassland birds such as the grasshopper sparrow 

(Scheiman et al 2003). Treatments under the action alternatives would help to contain or control existing 

as well as future infestations and maintain native grassland habitat. 

Herbicides - Risk of effects from herbicide exposure was evaluated using the insectivorous bird scenario.

For an acute exposure at typical and highest application rates triclopyr and NPE-based surfactants 

exceeded a dose of concern, whereas glyphosate exceeded the NOAEL at the highest application rate. 

Data was lacking to evaluate a chronic exposure of clopyralid, glyphosate, picloram, sethoxydim, 

sulfometuron methyl, triclopyr and NPE-based surfactants on small birds consuming insects. The Malheur 

National Forest LRMP restricts use of triclopyr to selective methods only, whereas pdf F2 restricts 

broadcast application of clopyralid, glyphosate, picloram, sethoxydim and sulfometuron methyl to typical 

application rates. With implementation of these design features and considering the small size and 

scattered nature of proposed treatments sites (scattered across 40 watersheds), unaffected suitable habitat 

is available and it is highly unlikely that a bird would receive an acute or chronic exposure. As a result 

there are no adverse effects from herbicide exposure anticipated under any alternative. 

Cumulative Effects

Anticipated cumulative effects are discussed by alternative above. With the exception of continued 

grazing, there are few future management activities that would occur within suitable grasshopper sparrow 

habitat. While they could be exposed to herbicides applied on lands of other ownerships, due to the small 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

223

and scattered nature of treatment sites and small amount of habitat proposed for treatment, it is unlikely a 

bird would receive multiple exposures. As a result, and considering treatment would not occur within 

occupied habitat during the nesting season, none of the alternatives would measurably contribute to any 

other past, on-going or future activity and result in significant effects to the grasshopper sparrow.

Summary and Determination

Proposed treatment would contain and control existing and future infestations of invasive plants and help 

maintain native grassland communities and suitable grasshopper sparrow habitat over the long term. 

While suitable grasshopper sparrow habitat is proposed for treatment, nesting has not been documented 

on the forest and project design features are in place that restricts treatment within occupied habitat

should they become established in the future, therefore, implementation of the action alternatives would 

have No Impact on the grasshopper sparrow. 

Wallowa Rosy Finch

Direct, Indirect and Cumulative Effects 

The Wallowa rosy finch occupies upper elevation sites away from primary invasive weed vectors. As a 

result there are no treatments proposed within suitable habitat and it is unlikely they would be affected by 

future treatments. As a result there are no direct, indirect effects or cumulative effects from treatment 

anticipated under any alternative.

Summary and Determination

The Wallowa rosy finch has not been documented on the Forest and it is unlikely that high elevation 

habitat would be affected by invasive plants, or treatment. As a result implementation of the action 

alternatives would have No Impact to this species. 

Greater Sage Grouse

Direct and Indirect Effects

Treatment - While there are no known leks or brood rearing habitat on the Forest, sage grouse are known 

to use the project area. Documentation of use is incidental and scattered. About 79 acres of mapped 

infestations are within the 139,500 acres of suitable habitat for sage grouse within the project area. 

Sage grouse are sensitive to disturbance caused by noise, people and vehicles. All treatment methods 

could cause some disturbance to sage grouse. Should a lek be discovered any time during the life of the 

project, the following project design features would reduce adverse impacts to nesting birds. 

♦ pdf J4-b - Human activities within 0.3 mile of leks will be prohibited from the period of one hour 

before sunrise until four hours after sunrise and one hour before sunset until one hour after sunset 

from February 15 – May 15.

♦ pdf J4-c - Do no conduct any vegetation treatments or improvement projects in breeding habitats 

from February 15 – June 30.

With implementation of these pdfs and considering the marginal nature of sage grouse breeding habitat on 

NFS lands, no effects to breeding birds or reproduction is expected. 

Disturbance to foraging birds could occur. However due to the small size and widely scattered nature of 

treatment sites, and widespread availability of adjacent unaffected habitat, disturbance effects would be 

minimal and short-term (one day). Sage grouse would likely avoid of the site during treatment. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

224

Loss of habitat for sage grouse by invasive plant expansion on rangelands can occur (Connelly et al. 

2000). Because all alternatives would contain or control existing and future invasive plant infestations, 

native sagebrush communities and suitable sage grouse habitat would be maintained. 

Herbicides - Adult sage grouse consume vegetation and chicks rely heavily on insects, thus, herbicide 

exposure was evaluated using a large vegetation-eating bird, as well as a small bird consuming insects. 

For adult birds and chicks at typical application rates, only triclopyr (if broadcast sprayed) and NPE 

surfactants exceeded the acute toxicity thresholds, whereas glyphosate exceeded a dose of concern at the 

highest rate for small birds consuming insects. A Malheur National Forest LRMP standard restricts 

application to triclopyr to selective techniques or spot treatment and with implementation of pdf F2, NPEbased surfactants would only be applied at a rate of 0.5 lbs. active ingredient per acre and glyphosate 

would not be broadcast sprayed above typical application rate. Additionally, pdf J4-a restricts the use of 

NPE-based surfactants in areas where sage grouse may forage Collectively for these reasons it is unlikely 

that adult birds or chicks would receive an acute exposure of concern. 

Chronic exposures were also evaluated and at the typical application rate for large birds consuming 

vegetation triclopyr exceeded a dose of concern, whereas sethoxydim, sulfometuron methyl, glyphosate 

and triclopyr exceeded the toxicity threshold at the highest application rate. Data is lacking to evaluate a 

chronic exposure of clopyralid, glyphosate, picloram, sethoxydim, sulfometuron methyl, triclopyr and 

NPE-based surfactants on small birds consuming insects. While exposure from these 

herbicides/surfactants are possible, when you consider that; 1) pdf J4-a restricts use of NPE in areas 

where sage grouse may forage, 2) pdf F2 restricts broadcast application of clopyralid, glyphosate, 

picloram, sethoxydim and sulfometuron methyl to typical application rates, 3) The Malheur National 

Forest LRMP prevents broadcast application of triclopyr, 4) Only 79 acres of invasive plant treatment are 

proposed in suitable habitat and sites are small and scattered across 20 watersheds, and 5) the use of the 

project area by sage grouse is scattered and incidental, it is unlikely that birds would consume 100 percent 

of their diet from contaminated insects/vegetation for 90 days and receive a chronic dose of concern. As a 

result, there are no adverse effects from herbicide exposure anticipated under any alternative. 

Cumulative Effects

Anticipated cumulative effects are discussed by alternative above. Other than continued grazing, there are 

few future management activities anticipated within suitable sage grouse habitat. Because suitable habitat 

occurs on NFS lands, as well as adjacent private and BLM lands, potential cumulative effects include 

possible herbicide exposure or disturbance on all ownerships. Due to the small amount of habitat 

proposed for treatment, treatment restrictions within breeding habitat, and reduced risk of herbicide 

exposure, none of the alternatives would measurably contribute to any other past, on-going or future 

activity and result in significant effects to sage grouse.

Summary and Determination

While no sage grouse leks have been documented in the project area, use has been documented and birds 

could be affected by treatment. Based on the above analysis and following rationale, implementation of 

the action alternatives “may impact individuals or habitat” (MIIH), but are not likely to lead to a trend 

toward federal listing.”

♦ There are no sage grouse leks known to occur on the Forest and National Forest System lands do 

not provide quality nesting habitat similar to that on adjacent lands. Should a lek be established in 

the future, pdfs would restrict treatment during the nesting season

♦ Sage grouse would not be exposed to toxic levels of herbicides.

♦ Disturbance-related effects to grouse will be short term and unaffected habitat is widely available. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

225

♦ Proposed treatment would contain and control existing and future infestations of invasive plants 

and help maintain native sagebrush habitat.

Bufflehead

Direct and Indirect Effects

Treatment - Bufflehead nest in tree cavities and rarely breeds in Oregon. Considering the small amount of 

habitat proposed for first-year treatments, there are no direct effects from treatment anticipated.

Herbicides - These ducks eat aquatic invertebrates and fish, so risk from herbicide exposure was 

evaluated using a “fish-eating bird” scenario. Based on available data, no herbicide or NPE-based 

surfactant exceeded a dose of concern for any exposure (acute or chronic) at any application rate. As a 

result, no adverse effects from herbicide exposure are anticipated under any alternative.

Cumulative Effects

There are no direct or indirect effects associated with treatment; therefore, none of the alternatives would 

measurably contribute to any other past, on-going or future activity and result in significant effects to 

bufflehead. 

Summary and Determination

Buffleheads have not been documented breeding within the project area and are unlikely to occur within 

treatment sites. As a result, and considering that none of the herbicides or surfactants exceeded a dose of 

concern, implementation of the action alternatives would have No Impact to the Bufflehead. 

Upland Sandpiper

Direct and Indirect Effects

Treatment - Approximately 79,000 acres of potentially suitable upland sandpiper habitat occurs on the 

Malheur National Forest and of this, 72 acres are currently known to contain invasive plants. Broadcast

application would occur on 50 percent and 25 percent of the sites under alternatives B and D respectively, 

whereas manual/mechanical treatments would occur on 68 percent of the sites under alternative C. 

Potential effects of invasive plant treatment on upland sandpipers are mainly associated with disturbance 

that may occur during the nesting season caused by noise, people and vehicles. If birds were to be in the 

immediate vicinity of treatment, they could be temporarily displaced. Also the cryptic nests of upland 

sandpipers are susceptible to crushing or trampling by people or vehicles. In order to reduce the 

likelihood that nests, eggs our young are harmed, the following design feature would be implemented:

♦ pdf J8-a - No treatment would occur on sites that have historic or recent documentation of Upland 

Sandpipers during the nesting season (April 1st to August 1st), unless the site has been surveyed 

and no nesting is occurring.

Upland sandpiper would not receive a toxic dose of herbicide under any alternative. While all action 

alternatives would reduce invasive weeds, alternative B would provide the most effective control of 

invasive plants (see chapter 3.14).

With implementation of the above pdf, there are no impacts to nesting birds or their young anticipated. 

However short-term disturbance to foraging birds outside the nesting season is possible. 

Herbicides - Effects of herbicides are the same as those described under grasshopper sparrow and there 

are no adverse effects anticipated under any alternative 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

226

Cumulative Effects

With the exception of continued grazing, there are few future management activities that would occur 

within suitable upland sandpiper habitat. While they could be exposed to herbicides applied on lands of 

other ownerships, due to the small and scattered nature of treatment sites and small amount of habitat 

proposed for treatment, it is unlikely a bird would receive multiple exposures. The proposed herbicides do 

not bio-accumulate or bio-magnify, thus none of the alternatives would measurably contribute to other 

past, on-going or future activity and result in significant effects to the upland sandpiper.

Summary and Determination

Upland sandpipers have not been documented breeding on the Forest, but use on adjacent private lands 

does occur and use of suitable habitat on the Forest is possible. Based on the above analysis and the 

following rationale, implementation of the action alternatives “may impact individuals or habitat” (MIIH), 

but are not likely to lead to a trend toward federal listing.”

♦ Breeding upland sandpipers have not been documented on the Forest

♦ Should a nest be documented, project design features are in place that restricts treatment during 

the breeding season. 

♦ Herbicide use in any alternative is not likely to result in toxic does to upland sandpiper given the 

types of herbicides proposed and the pdfs. Lewis and White-Headed Woodpeckers

♦ Proposed treatment would contain and control existing and future infestations of invasive plants 

and help maintain native grassland habitat required by upland sandpipers.

Lewis and White-headed Woodpeckers 

Direct and Indirect Effects

Treatment - Approximately 275 acres of Lewis’s woodpecker and 10 acres of suitable white-headed 

woodpecker habitat are proposed for treatment. No snags or trees would be removed; so nest habitat 

would be unaffected. Foraging birds, particularly the Lewis woodpecker, which frequently forages on the 

ground, could be affected by the noise and disturbance associated with herbicide or non-herbicide 

treatments under all alternatives. Both species forage over large areas and considering the availability of 

unaffected habitat, direct effects would be limited to short-term disturbance. 

Herbicides - At typical application rates triclopyr and NPE-based surfactants pose an acute risk to birds 

eating insects. Glyphosate poses an acute risk at the highest application rate, whereas data is lacking to 

fully assess chronic exposures of clopyralid, glyphosate, picloram, sethoxydim, sulfometuron methyl, 

triclopyr and NPE-based surfactants on small birds consuming insects. With implementation of Malheur 

National Forest LRMP standards and pdf F2; application of triclopyr is limited to selective techniques, 

NPE-based surfactants cannot be applied above 0.5 lbs. active ingredient per acre, and clopyralid, 

glyphosate, picloram, sethoxydim and sulfometuron methyl cannot be broadcast sprayed above typical 

application rates. As a result, the likelihood that a bird would be exposed to toxic levels of herbicide is 

reduced. 

The likelihood of exposure is further reduced when you consider that birds forage over large areas and 

that many of the insects utilized occur within dead wood, under bark or are taken from areas not exposed 

to herbicides. As a result, birds are not likely to consume an entire day’s diet of contaminated insects 

(acute exposure) or forage exclusively on contaminated insects for 90 days (chronic exposure) and there 

are no adverse effects from herbicide exposure anticipated under any alternative. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

227

Cumulative Effects

These species could be affected by any activity that reduces snags or downed wood, or modifies the 

overstory, particularly timber harvest and prescribed burning. As discussed under alternative cumulative 

effects, timber harvest and invasive plant treatments would occur within 39 watersheds, which include 

approximately 1,100 acres of treatment. While timber harvest would reduce habitat for some species due 

to reductions in the overstory, with implementation of Forest standards, a component of snags and 

downed wood would be retained on all sites. As a result, and considering that proposed treatments would 

not modify suitable habitat and the low risk of herbicide exposure, none of the alternatives would 

measurably contribute to any other past, current or foreseeable activity and there are no significant 

cumulative effects to snag- or downed-wood- dependent species anticipated.

Summary and Determination

Lewis Woodpecker - Approximately 275 acres of suitable habitat is proposed for first-year treatment. No 

direct effects to nesting birds or reproduction are anticipated and suitable habitat would be unchanged.

Because treatment could result in short-term disturbance to foraging birds, implementation of the action 

alternatives may impact individuals or habitat” (MIIH), but are not likely to lead to a trend toward federal 

listing”.

White-headed Woodpecker - Approximately 10 acres of suitable habitat proposed for treatment. No 

direct effects to nesting birds or reproduction are anticipated and suitable habitat would be unchanged.

Because treatment could result in short-term disturbance to foraging birds, implementation of the action 

alternatives may impact individuals or habitat” (MIIH), but are not likely to lead to a trend toward federal 

listing”.

Columbia Spotted Frog

Direct and Indirect Effects

Treatment – Invasive plants have been mapped within 52 acres of suitable breeding habitat. Broadcast

application of herbicides is proposed on 23 and 4 acres under alternatives B and D respectively, whereas 

48 acres of manual treatment would occur under alternative C.

Adult frogs, eggs, and larvae are not likely to be disturbed by invasive plant treatments during the 

breeding season because they are restricted to aquatic habitat. After breeding however, adults will 

disperse into adjacent wetland and riparian/upland habitats utilized by frogs. While trampling and direct 

mortality could occur under all alternatives, with implementation of pdf J5-a, treatment methods, timing 

and location be coordinated with a biologist prior to implementation when working in occupied habitat. 

As a result, and considering that frogs are less likely to inhabit areas infested with invasive plants, the 

likelihood of mortality or short-term disturbance is low. 

Herbicides - Data on herbicide effects to amphibians is limited. There is some data to suggest that 

amphibians may be as sensitive to herbicides as fish (Berrill et al. 1994, Berrill et al. 1997, Perkins et al.

2000), so for the this analysis herbicides that pose potential risk to federally listed fish (as determined by 

the quantitative estimates from exposure scenarios) will also be considered to pose a risk to amphibians. 

Results from exposure scenarios indicate that aminopyralid, chlorsulfuron, clopyralid, imazapic, 

imazapyr, metsulfuron methyl and picloram pose a very low risk to amphibians. While toxicity risks 

associated with sethoxydim, sulfometuron methyl, glyphosate, triclopyr and NPE-based surfactants are 

higher, with implementation of Malheur National Forest LRMP standards and pdfs, the likelihood that 

breeding frogs, eggs and larvae would be exposed to herbicides is reduced. 

The likelihood of exposing amphibians depends on the application method, habitat treated, and season of 

application. Although potential for exposure to toxic levels of herbicide exist, adverse effects to 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

228

amphibians are greatly reduced by implementation of pdfs that restrict herbicide application rates, restrict 

use of moderate to high risk herbicides and require herbicide-use buffers. More specifically 1) project 

design features (F2, H1, H2, H5, and H8-H10) reduce the likelihood for herbicides to be delivered to 

waterways in a concentration of concern, 2) herbicide restrictions on certain soil types (H3 and H6) 

reduce potential for runoff and leaching, 3) restrictions on extent of treatment in a given site (H4, H5 and 

H7) ensure that herbicides would not be delivered in amounts greater than the SERA risk assessment 

scenarios and that unsprayed areas provide refugia, 4) spills are extremely unlikely to occur given the 

many safety precautions in place and 5) when working within occupied or suitable spotted habitat, use of 

herbicides that pose a risk be restricted and that the treatment methods, timing and location be 

coordinated with a wildlife biologist. Collectively these pdfs in combination with the use of low risk first 

year/first choice herbicides will ensure that the Columbia spotted frog is not adversely affected by 

herbicides. 

Adult frogs could be dermally exposed to herbicides by moving through treated vegetation or soil. There 

is insufficient data to quantify the dose received from exposure to contaminated vegetation or soil, but it 

is likely to be much less than if the frog was in contaminated water and could easily absorb the solution 

through its skin. The herbicide-use buffers restrict broadcast application of herbicides within breeding 

habitat where necessary and require that unsprayed areas be provided to serve as refugia for amphibians 

(H7 and H8) when treating lakes, ponds or wetlands, and H9 restricts herbicide use nears wells, springs 

and stockponds. 

Cumulative Effects

There would be few if any effects to breeding habitat from ongoing or future timber harvest, burning or 

fuel treatments. However activities, such as grazing, road maintenance, or recreation can result in 

disturbance to frog habitat. While proposed treatments could further disturb individuals, effects would be 

limited to short-term disturbance. Project design features limit the potential for any action alternative to 

contribute to cumulative adverse effects. Due to their restricted movement, frogs are unlikely to be 

exposed to herbicides on lands of other ownerships. Also because the herbicides proposed for use are 

rapidly excreted (even by aquatic organisms), do not bio-accumulate or bio-magnify, there are no adverse 

effects from herbicide exposure anticipated. As a result, none of the alternatives would measurably 

contribute to any other past, on-going or future activity and result in significant effects to the Columbia 

spotted frog. 

Summary and Determination

Disturbance to Columbia spotted frog eggs, larvae, or adults during invasive plant treatment would be 

minor and short term. Implementation of any action alternative “may impact individuals or habitat” 

(MIIH), but are not likely to lead to a trend toward federal listing.” Adult frogs, eggs, and larvae are not 

likely to be disturbed by invasive plant treatments during the breeding season because they are restricted 

to aquatic habitat. Due to the relatively low toxicity of most herbicides proposed, the low concentrations 

in water that would occur under normal operations, and implementation of pdfs, it is unlikely frogs, eggs 

or larvae would be exposed to toxic levels of herbicide. If occupied habitat is proposed for treatment, the 

site would be reviewed by a local biologist and treatment methods modified if necessary to avoid adverse 

impacts. Proposed treatment would contain and control existing and future infestations of invasive plants 

and help maintain riparian/wetland habitat.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

229

Shortface Lanx and Harney Basin Duskysnail

Direct and Indirect Effects

Treatment - The shortface lanx is a non-migrant freshwater snail that can be found in the main channel of 

fast flowing streams and rivers. There would be no mortality or disturbance to the shortface lanx because 

it is aquatic and inhabits larger streams and rivers. 

The Harney basin duskysnail (HBD) inhabits cold springs and runs, as well as adjacent sagebrush habitat. 

There are no treatments proposed within the Spring Creek watershed that contains the only known 

documentation of the Harney basin duskysnail within the project area. While it is possible that a site could 

be affected in the future, with implementation of the following pdf, and considering that treatment would 

not likely occur within a cold water spring habitat where this species would be found, it is not expected 

that the Harney basin duskysnail would be directly affected by treatment under any alternative. 

♦ pdf J10-a - If an occupied site is proposed for treatment, a local biologist would be consulted to 

determine protection measures, if necessary. These measures may include limitations on vehicle 

entry, modifications to treatment type or timing, or implementation of herbicide-use buffers.

Invasive plant treatments would not remove or alter habitat at the site, nor would treatments result in 

changes to the hydrologic regime. As a result suitable habitat would be unchanged. 

Herbicides - As described above, data on the effects of herbicides to mollusk species is limited. Those 

evaluated included moderate risk herbicides (picloram and glyphosate), which were not found to pose a 

risk. The likelihood is further reduced with implementation of pdf J10a, which restricts treatment within 

occupied Harney basin duskysnail habitat. With implementation of this pdf and considering there are no 

first-year treatments proposed near the Spring Creek site where this species has been documented there 

are no adverse effects from herbicide exposure to the Harney basin duskysnail anticipated. 

Cumulative Effects

While future grazing may adversely affect the Harney basin duskysnail or its habitat, because proposed 

treatments would not alter existing habitat, or likely result in exposure to harmful levels of herbicide, 

none of the alternatives would measurably contribute to any other past, on-going or future activity and 

result in significant effects to these species.

Summary and Determination

Shortface lanx has not been documented on the Forest, It occupies large fast flowing streams and rivers, it 

is not adversely affected by invasive plants or treatment. As a result implementation of the action 

alternatives would have No Impact on the shortface lanx. No treatments are proposed at the site where the 

Harney basin duskysnail has been documented and pdfs would modify treatment or timing if necessary 

should an occupied site be proposed for treatment in the future. As a result and considering pdfs would 

further protect spring and seeps, the action alternatives would have No Impact to the Harney basin 

duskysnail.

Johnson Hairstreak

Direct, Indirect, Cumulative Effects and Determination

Johnson hairstreak has not been documented within suitable coniferous-forest habitat within the project 

area, and it is unlikely they would occur within treatment areas. Consequently there would be no direct, 

indirect or cumulative effects anticipated ,and implementation of the action alternatives would have No 

Impact on this species. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

230

Silver-bordered Fritillary

Direct and Indirect Effects

Treatment - Of the approximately 22,000 acres of potentially suitable habitat, approximately 34 acres of 

riparian/wet meadow habitat are known to contain invasive weeds and are proposed for treatment. These 

sites are generally small in size and scattered across 45 watersheds.

Mechanical, manual and herbicide treatment could harm eggs or larvae, due to physical disturbance on 

the site. In order to reduce potential impacts pdf J6-b requires that a local wildlife biologist be contacted if 

treatment is proposed on sites where the silver-bordered fritillary has been documented. Since the 

butterfly populations fluctuate wildly among meadows and between years, the local biologist can provide 

advice on where to prioritize treatments and to modify timing/treatment methods if necessary to reduce 

impacts. Consequently the potential for adverse effects would be reduced. With implementation of this 

pdf and considering the small amount of habitat proposed for treatment, the likelihood that treatments 

would directly affect the silver-bordered fritillary is reduced.

The silver-bordered fritillary is dependent upon maintenance of wet meadow habitat and invasive plants 

can reduce the abundance and/or cover of larval food plants as well as nectar plants (violet). As a result,

and because treatment would help to contain or control invasive plants, all alternatives would help to 

promote native plant communities and help sustain silver-bordered fritillary habitat over the long term. 

Herbicides - Information on the effects of herbicides on butterflies is limited, but some field studies have 

attempted to determine the effects of herbicide use on butterfly populations. Bramble et al (1997) 

investigated butterfly diversity and abundance on electric transmission right-of-ways (ROW) treated with 

herbicides versus those treated with only mechanical methods. Herbicides used in the ROW treatments 

included a mixture of picloram and triclopyr, triclopyr and metsulfuron methyl, glyphosate and fosamine, 

triclopyr and imazapyr and glyphosate alone. They evaluated effects on 15 species and found no 

significant difference in diversity or abundance of butterflies between herbicide and non-herbicide units. 

Sucoff et al. (2001) studied effects of herbicides on host plants, eggs and larvae of the Karner blue 

butterfly (Lycaeides Melissa) from treatments with glyphosate, glyphosate-sulfometuron methyl mix and 

glyphosate-triclopyr mix. Treatment did not inhibit flowering of the larval food plant, whereas 

glyphosate, triclopyr, and glyphosate-sulfometuron methyl mix treatments did not significantly reduce 

egg hatching, pupation of larvae, and emergence of adults, pupae size, or rate of development of percent 

of eggs that produced adults. While glyphosate-triclopyr mix did significantly reduce egg hatching, with 

implementation of pdfs (F2) restricting application rates of these herbicides, no toxic exposures are 

anticipated. Currently, triclopyr is not among the first-choice herbicides in any alternative.

Although data is limited, existing information (SERA 2007, Bramble 1997, USDA Forest Service 2005a) 

and extent of treatment (less than1 percent of the suitable habitat affected) indicates that preferred 

herbicides under alternatives B and C (aminopyralid, chlorsulfuron and metsulfuron methyl) are not likely 

to result in toxic levels to this species. Implementation of the following pdfs would greatly reduce the 

likelihood that adverse effects from herbicide exposure would occur, or that host plants would be affected 

by treatment:

♦ pdf J6-a – Buffers for vascular plant species of concern would be implemented on sites that 

contain host/nectar plants, reducing the likelihood of herbicide exposure to these species.

♦ pdf J6-b Treatment type and timing in occupied habitat would be coordinated with a biologist, so 

that the type or timing of treatment can be modified if necessary to reduce potential impacts. Also 

use of ester formulations of herbicide and NPE-based surfactants in known silver-bordered 

fritillary habitat would be prohibited.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

231

♦ pdf F2 – The least amount of any given herbicide needed to effectively meet site objectives would 

be used, NPE-based surfactants cannot be applied at levels above 0.5 lbs./ac and broadcast 

application of glyphosate or picloram, will not exceed typical application rates.

With implementation of these design features and considering the small amount of habitat proposed for 

first-year treatment, it is unlikely that adverse effects from herbicide exposure would occur to adults, 

pupae or eggs under any alternative. 

Cumulative Effects

This species occupies non-forested riparian/wetland habitat, so other than continued grazing and 

recreational use, few of the anticipated ongoing and future activities would occur within suitable habitat. 

Since they are known to occupy adjacent private land, it is possible that adults could be exposed to 

herbicides on all ownerships. The toxicity of proposed herbicides to invertebrates is low and pdfs further 

reduce the likelihood of herbicide exposure. As a result and considering the small amount of habitat 

proposed for treatment within any watershed, it is unlikely that treatment on National Forest System land 

would result in toxic levels of herbicides to adult butterflies or measurably contribute to any other past, 

on-going or future activity and result in significant effects to this species.

Summary and Determination

Silver bordered fritillary is not documented within the project area, although it is documented adjacent to 

the Malheur National Forest so use on the Forest is likely. Invasive plant treatments in any of the action 

alternatives “may impact individuals or habitat” (MIIH), but are not likely to lead to a trend toward 

federal listing” for the silver-bordered fritillary.

♦ Within occupied habitat, project design features are in place that would protect host/nectar plants, 

and minimize the likelihood of adverse effects from treatment.

♦ Based on available data and with implementation of project design features, proposed herbicides 

would not result in a dose of concern for terrestrial invertebrates.

♦ Approximately 35 acres of preferred habitat are proposed for treatment and it is unlikely an 

occupied site would be affected. 

♦ Proposed treatments would reduce invasive plants and help to maintain native riparian grassland 

habitat.

Management Indicator Species

Table 65. Treatment effects determinations for management indicator species (MIS)

Species Treatment Effects Determination

Rocky Mountain Elk

Treatment effects limited to short term disturbance. Herbicide exposure 

unlikely. Grassland habitat and local elk populations maintained. 

Implementation of any of the action alternatives would not contribute to a 

negative trend in viability for this species within the Malheur National Forest.

Pileated woodpecker

No treatment or herbicide effects to nesting birds. Disturbance to foraging 

birds possible. No herbicide exposure anticipated. Suitable habitat and local 

populations maintained. Implementation of any of the action alternatives 

would not contribute to a negative trend in viability for this species within the 

Malheur National Forest.

Pine (American) marten

Not likely to occur in treatment areas. Suitable habitat and local populations 

maintained. Implementation of any of the action alternatives would not 

contribute to a negative trend in viability for this species within the Malheur 

National Forest.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

232

Species Treatment Effects Determination

Three-toed woodpecker

No treatment effects to nesting birds. Disturbance to foraging birds possible. 

No herbicide exposure anticipated. Suitable habitat and local populations 

maintained. Implementation of any of the action alternatives would not 

contribute to a negative trend in viability for this species within the Malheur 

National Forest.

MIS cavity excavators

No treatment effects to nesting birds. Disturbance to foraging birds possible. 

No herbicide exposure anticipated. Suitable habitat and local populations 

maintained. Implementation of any of the action alternatives would not 

contribute to a negative trend in viability for this species within the Malheur 

National Forest.

Rocky Mountain Elk

Approximately 2,124 acres of elk summer range are known to contain invasive plants. Of this, 

approximately 1,860 acres (88 percent) are adjacent to roads. While there are no invasive plant treatments 

proposed within elk calving areas, approximately 517 acres of the elk winter range is currently known to 

contain invasive plant species. Treatment would occur across 100 watersheds (HUC 6) ranging in size 

from 10,000 to 40,000 acres. While six watersheds have 100 acres or more proposed for treatment (120 to 

170 acres), one percent or less of all watersheds would be treated.

Direct and Indirect Effects

Treatment - Elk are sensitive to human disturbance, so proposed treatments can adversely affect big game 

due to disturbance and increased human access. About 88 percent of proposed treatments are close to 

open roads, which are less likely to be used as habitat (Thomas 1979). Also treatment within any drainage 

would be short term (a few days) and unaffected habitat is widely available. As a result, disturbance 

would likely result in animals avoiding areas during treatment. Also with implementation of the following 

design features, the likelihood of disturbance during sensitive or key periods would be reduced:

♦ pdf J12-a –To reduce stress during the winter, restrict off-highway vehicle use within MA 41 (big 

game winter range) between December 1st and April 1st.

♦ pdf J12-b – To prevent harassment in designated calving areas, restrict off-highway vehicles and 

other motorized traffic use to designated roads and trails from May 1st to June 31st. 

Invasive plants can reduce the ability of an area to support elk and result in a loss of forage quality and 

quantity for big game (Rice et al. 1997, Bedunah and Carpenter 1989, Trammel and Butler 1996). As a 

result treatment of invasive plants would beneficially affect elk (and deer) by preserving native forage 

species and maintaining the long-term suitability of foraging habitat.

Herbicides - Mammals such as elk that eat vegetation (primarily grass) that has been sprayed with 

herbicide have relatively greater risk for adverse effects because herbicide residue is higher on grass than 

it is on other herbaceous vegetation or seeds (Kenaga 1973, Fletcher et al. 1994, Pfleeger et al. 1996). 

At the highest application rates, glyphosate and picloram exceeded levels of concern at acute exposures 

and NPE-based surfactants exceeded acute and chronic levels of concern at the typical and highest 

application rates. A chronic exposure of concern resulted from sethoxydim applied at the highest rate and 

triclopyr at the typical and highest rates. The likelihood of exposure is reduced due to implementation of 

Malheur National Forest LRMP standards which restrict use of triclopyr to selective techniques/spot 

treatment and with implementation of pdf F2 that prevents glyphosate and picloram from being broadcast 

sprayed above typical application rates and restricts NPE-based surfactants from being applied above 0.5 

lbs. active ingredient per acre. The likelihood of exposure is further reduced when considering that elk 

forage over large areas and are not likely to consume an entire days diet of contaminated vegetation 

(acute exposure) from forage exclusively on contaminated vegetation for 90 days (chronic exposure). As a 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

233

result and considering that 88 percent of the proposed treatments occur close to open roads which are less 

likely to be used by elk (Thomas 1979) it is unlikely that elk would be adversely affected by herbicide 

exposure

Cumulative Effects

Anticipated cumulative effects are discussed under the alternative evaluation above and ongoing and 

future activities would be implemented on 60 watersheds forestwide. Proposed timber harvest would 

reduce elk cover, so Forest LRMP standards related to habitat effectiveness and hiding and thermal cover 

would be adhered to. Also much of the harvest, as well as prescribed fire and plantation thinning would 

improve elk forage on summer, winter and transition ranges. As a result and considering that proposed 

treatments would help to maintain native forage over the long term, elk habitat would be maintained in all 

affected watersheds. While proposed treatments could increase disturbance to elk on summer range, 

effects would be short term. As a result and considering that 88 percent of proposed treatments occur 

close to roads where elk are less likely to occur, there are no long-term disturbance related effects 

anticipated. 

Because elk utilize all ownerships, anticipated cumulative effects include possible exposure to herbicides 

on state, private and BLM land. For adverse effects from herbicide exposure to occur, the two exposures 

would have to occur at approximately the same time. This is unlikely since the herbicides proposed are 

rapidly eliminated and do not significantly bio-accumulate (USDA Forest Service 2005a). The risk of

herbicide exposure over a level of concern would be avoided by implementation of pdfs that restrict 

herbicide application rates, provide herbicide-use buffers along streams, waterbodies and riparian areas, 

and minimize drift from broadcast application. The risk of exposure is further reduced when you consider 

that 1 percent or less of any watershed would be affected by treatment and that most treatment occurs in 

less preferred habitat adjacent to open roads. Collectively for these reasons, none of the alternatives 

would measurably contribute to any other past, current or foreseeable activity related to herbicide 

exposure and there are no significant cumulative effects to elk anticipated. 

Summary and Determination

There are no adverse effects from herbicide exposure anticipated. Proposed treatments may result in 

short-term disturbance during treatment; ultimately treatment would reduce invasive plants and help to 

maintain native big game range. As a result, local populations of elk and hunting opportunities would be 

maintained. Implementation of the action alternatives would not contribute to a negative trend in viability 

for elk on the Malheur National Forest. 

Pine (American) Marten

Direct, Indirect and Cumulative Effects

Marten prefer closed-canopy forest away from open roads (where 88 percent of proposed treatment sites 

are); therefore, it is unlikely they would be found in treatment sites. Also invasive plant treatments would 

not alter forested habitat. As a result, and considering no herbicide or NPE-based surfactant exceeded a 

level of concern for carnivores eating contaminated small mammals, proposed treatments would not 

adversely affect marten or alter their habitat under any alternative. 

Summary and Determination

There are no direct, indirect or cumulative effects to marten anticipated and implementation of the action 

alternatives would not contribute to a negative trend in viability for this species on the Malheur National 

Forest. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

234

Cavity Nesters and Species Dependent on Downed Wood

Because they occupy similar habitats and have similar threats, cavity nesting species or species that 

require standing dead (snags) and downed woody debris are discussed collectively.21 These species 

include; pileated woodpecker, northern three-toed woodpecker, northern flicker, red-naped sapsucker, redbreasted sapsucker, Williamson’s sapsucker, downy woodpecker, hairy woodpecker, and black-backed 

woodpecker.

Direct and Indirect Effects

Treatment - No snags or trees would be removed, therefore nest habitat would be unaffected. Disturbance 

to foraging birds would occur, particularly to species such as the pileated woodpecker or northern flicker 

that forage on the ground or in more open canopy conditions. Sites are small and scattered, so unaffected 

habitat is available and effects would be limited to short-term disturbance during treatment. Cavity 

nesting species are not at risk from herbicides and existing habitat would be unchanged.

Herbicides - Species that forage and nest in trees are not likely to be exposed to herbicides because no 

trees would be treated and no aerial application is proposed. Species such as the pileated woodpecker and 

northern flicker that feed on the ground or in low shrubs may consume contaminated insects. 

Effects of herbicide exposure are the same as those described under the Lewis’ and white-headed 

woodpecker. As described, with implementation of pdfs the likelihood of herbicide exposure is reduced. 

The likelihood of exposure is further reduced when you consider that birds forage over large areas and 

that many of the insects utilized occur within dead wood, under bark or are taken from areas not exposed 

to herbicides. As a result birds are not likely to consume exclusively contaminated insects and there are no 

adverse effects from herbicide exposure anticipated under any alternative.

Cumulative Effects - These species could be affected by any activity that reduces snags or downed 

wood, or modify the overstory, particularly timber harvest and prescribed burning. Timber harvest and 

invasive plant treatments would occur within 39 watersheds, which include approximately 1,100 acres of 

treatment. While timber harvest would reduce habitat for some species, habitat for others would be 

improved. Also with implementation of Forest standards, a component of snags and downed wood would 

be retained on all sites. As a result, and considering the proposed treatments would not modify suitable 

habitat and that there are no adverse effects from herbicide exposure anticipated, none of the alternatives 

would measurably contribute to any other past, current or foreseeable activity and there are no significant 

cumulative effects to snag or downed wood dependent species anticipated.

Summary and Determination

Suitable habitat for MIS and sensitive cavity nesting species overlap with mapped infestations proposed 

for treatment. It is unlikely nesting birds would be affected and any disturbance to foraging birds would 

be short-term (usually one day or less). Suitable nesting habitat would be unaffected by treatment and 

implementation of the action alternatives would not contribute to a negative trend in viability for cavity 

nesting or downed wood dependent species on the Malheur National Forest. 

 21 Findings and determinations for the Lewis and white-headed woodpeckers were discussed previously in the Forest 

Service Sensitive Species section.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

235

Effects to Featured Species

California Bighorn Sheep

Direct and Indirect Effects

Treatment - Less than 14 acres of bighorn sheep habitat is proposed for treatment and the likelihood of 

disturbance is remote. Should future treatments be proposed within occupied habitat, treatment 

modifications/timing would be made if necessary during preparation of annual prescriptions to ensure 

sheep are not disturbed and all alternatives are in compliance with LRMP standard 55. Due to the small 

amount of habitat known to contain invasive plants, suitable habitat would be unchanged.

Herbicides - Effects from herbicide exposure would be similar to those described under elk, and with 

implementation of pdfs the likelihood of exposure is reduced. The likelihood of exposure is further 

reduced when you consider the small amount of habitat proposed for first-year treatment and that sheep 

are not likely to consume exclusively contaminated vegetation. As a result, there are no adverse effects 

from herbicide exposure anticipated under any alternative. 

Cumulative Effects

Other than grazing and recreation, there are few on-going/future activities within suitable habitat 

anticipated. As a result, and considering the small amount of habitat proposed for treatment, none of the 

alternatives would measurably contribute to any other past, current or foreseeable activity and there are no 

significant cumulative effects anticipated.

Summary and Determination

Due to the small amount of habitat proposed for treatment and considering that are no adverse effects 

from herbicide exposure, local populations of bighorn sheep and there habitat would be maintained under 

all alternatives. 

Northern Goshawk

Direct and Indirect Effects

Treatment - There are 567 acres of goshawk nesting/foraging habitat and 18 acres within post fledgling 

habitat proposed for treatment. The northern goshawk prefers closed-canopy mature forest for nesting and 

foraging, therefore, its habitat is not at risk from invasive plants. As a result, and with implementation of 

pdf J11-a that restricts activity within 0.50 mile of known nest sites, there are no effects to nesting 

goshawks anticipated. There would be no changes to existing habitat from proposed treatment.

Herbicides - At the typical application rate, no herbicide or surfactant exceeded the toxicity index for an 

acute or chronic exposure, whereas NPE exceeded the NOAEL and sethoxydim equaled the NOAEL at 

the highest application rate. Project design feature F2 restricts broadcast application of sethoxydim to the 

typical application rate and prevents NPE from being applied above 0.5 lbs. active ingredient per acres. 

As a result and considering that goshawk forage over large areas and are unlikely to feed exclusively on 

contaminated prey, there are no adverse effects from herbicide exposure anticipated. 

Cumulative Effects

While ongoing and future activities would modify goshawk nesting and foraging habitat, Forest Plan

standards would protect nest sites and PFA areas. As a result and considering proposed actions would not 

modify habitat or result in adverse effects from herbicide exposure, none of the alternatives would 

measurably contribute to any other past, current or foreseeable activity and there are no significant 

cumulative effects anticipated.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

236

Summary and Determination

Suitable goshawk habitat would be maintained and any effects from treatment would be minor and short 

term Local populations of northern goshawk and their habitat would be maintained under all alternatives. 

Blue Grouse

Direct and Indirect Effects

Treatment - Blue grouse winter at upper elevations, and winter habitat is largely unaffected by invasive 

plants or treatment. They breed within openings at lower elevations and treatments within open canopy 

forest and grassland/shrub habitats near forest could disturb grouse, or result in mortality to nests or 

chicks. There are approximately 125 acres proposed for treatment in mountain meadow, step shrublands 

or riparian/shrub habitats. Due to the small size of treatment sites and widespread availability of 

unaffected habitat the likelihood of adverse impacts is low. This species is not at risk from invasive plants 

and suitable winter and summer habitat would be unchanged. 

Herbicides - Adult blue grouse forage primarily on shrubs and herbaceous vegetation during the summer 

months and chicks consume large quantities of insects, thus, risk of effects from herbicide exposure was 

evaluated using the insectivorous bird scenario, as well as a large bird consuming vegetation. 

For adult birds and chicks at typical application rates, only triclopyr (if broadcast sprayed) and NPE 

surfactants exceeded the acute toxicity thresholds, whereas glyphosate exceeded a dose of concern at the 

highest rate for small birds consuming insects. The Malheur National Forest LRMP restricts application to 

triclopyr to selective techniques/spot treatment and with implementation of pdf F2, NPE based surfactants 

would only be applied at a rate of 0.5 lbs. active ingredient per acre and glyphosate would not be 

broadcast sprayed above typical application rate. As a result, it is unlikely that adult birds or chicks would 

receive an acute exposure of concern. 

Chronic exposures were also evaluated and at the typical application rate for large birds consuming 

vegetation triclopyr exceeded a dose of concern, whereas sethoxydim, sulfometuron methyl, glyphosate 

and triclopyr exceeded the toxicity threshold at the highest application rate. With implementation of pdf

F2 that restricts broadcast application of clopyralid, glyphosate, picloram, sethoxydim and sulfometuron 

methyl to typical application rates and the Malheur National Forest LRMP Plan standard that prevents 

broadcast application of triclopyr, the likelihood of exposure is reduced. Triclopyr is not a first-choice

herbicide in any alternative. As a result and considering the small size and scattered nature of treatments 

sites, birds would not be expected to forage exclusively on contaminated insects or plants and be exposed 

to herbicides at levels of concern. 

Cumulative Effects

Approximately 125 acres of summer habitat could be affected by treatment. Future timber harvest is 

unlikely to adversely affect forested riparian and upland shrub habitats due to changes in overstory and 

understory vegetation. While prescribed burning could result in short-term impacts to understory 

vegetation, treatment would promote the maintenance of shrub diversity over the long-term. Similarly, 

proposed treatments would help to reduce invasive plants and maintain native shrub, grass and forb 

diversity. None of the alternatives would measurably contribute to any other past, current or foreseeable 

activity and result in significant cumulative effects.

Summary and Determination

Proposed activities would not modify suitable habitat and no long-term effects from treatment are 

anticipated. As a result, suitable habitat and local populations of blue grouse would be maintained. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

237

Osprey

Direct and Indirect Effects

Treatment - There are no known osprey nests on the Forest and considering pdf J11-a protects osprey 

nests should one become established, thus there would be no effects to nesting birds or reproduction. 

Osprey forage and nest over standing water, so neither birds or their habitat would not be affected by 

treatment. 

Herbicides - While osprey would not be directly sprayed, they could consume fish exposed to herbicides. 

Doses were estimated assuming that birds ate nothing but fish contaminated by a spill of 200 gallons into 

a 0.25 acre pond, over a lifetime. All expected doses to fish-eating birds for all herbicides and NPE are 

well below any known no-observable-adverse-effect-level (NOAEL) and the weight of evidence suggests 

that adverse effects to this species group from NPE or the herbicides included in the action alternatives 

are not plausible.

Cumulative Effects

Ongoing and future activities on NFS lands are not expected to adversely affect osprey. While birds could 

be exposed to herbicides on lands of other ownerships, for adverse effects from herbicide exposure to 

occur, the two exposures would have to occur at approximately the same time. This is unlikely since the 

herbicides proposed are rapidly eliminated and do not significantly bio-accumulate (USDA Forest Service

2005a). Also with implementation of pdfs that limit the application rate and method for higher-risk 

herbicides, provide herbicide buffers along streams, waterbodies and riparian areas, and minimize drift 

from broadcast application, the risk of herbicide exposure is further reduced. As a result, none of the 

alternatives would measurably contribute to any other past, current or foreseeable activity related to 

herbicide exposure and there are no significant cumulative effects to osprey anticipated. 

Summary and Determination

Osprey and their habitat would be unaffected by invasive plants or proposed treatments and local 

populations would be maintained. 

Pronghorn Antelope

Direct and Indirect Effects

Treatment - Approximately 122 acres of invasive plants would be treated within sagebrush habitat 

adjacent to private lands and suitable pronghorn habitat. This would occur across 25 watersheds with 70 

(alternative B) to 83 (alternative D) percent of the herbicide application occurring as spot treatment.

Under alternative C, 75 percent of the treatments would be with manual/mechanical methods. 

Although pronghorn occupy more open habitat, the potential effects of invasive plant treatment to 

pronghorns would be similar to those discussed under the rocky mountain elk. Both species graze 

herbaceous plants, graze over large areas and are sensitive to human disturbance. Direct effects would be 

limited to minor short-term disturbance during treatment and all alternatives are in compliance with 

LRMP standard 52. Because treatments would contain or control invasive plants, pronghorn habitat would 

be maintained under all action alternatives. 

Herbicides - Effects of herbicide use would be the same as those described for elk. While exposures of 

concern are possible, with implementation of the Malheur National Forest LRMP standard that restricts 

use of triclopyr to selective techniques and pdf F2 that prevents glyphosate and picloram from being 

broadcast sprayed above typical application rates and restricts NPE based surfactants from being applied 

above 0.5 lbs. active ingredient per acre, the likelihood of exposure is reduced. As a result and 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

238

considering that pronghorn forage over large areas are not likely to consume exclusively contaminated 

vegetation, it is unlikely that antelope would be adversely affected by herbicide exposure.

Cumulative Effects

Although future grazing would continue to affect pronghorn, existing use is not expected to change and 

with compliance of LRMP standards, suitable pronghorn habitat would likely be maintained. While 

animals could be exposed to herbicides on lands of other ownerships, none of the alternatives would 

measurably contribute to past, current or foreseeable activity and result in significant cumulative effects.

Summary and Determination

While proposed treatments may result in short-term disturbance during treatment, habitat would be 

maintained or improved and there are no adverse effects from herbicide exposure anticipated. As a result, 

local populations of pronghorn would be maintained.

Effects to Birds of Conservation Concern

This section evaluates effects to landbirds, birds of conservation concern and game birds below desired 

condition identified in section 3.72. Table 66 displays species not evaluated previously and groups species 

into similar feeding strategies for analysis. 

Table 66. Exposure groups, habitat and species included in each group

Animal/Diet Group Habitat Species

Predatory Birds

(small mammal)

Grassland, Shrub-steppe, Dry 

Forest, Juniper-steppe, Rimrock-cliff

Swainson’s hawk, Prairie falcon, Burrowing Owl, 

Ferruginous hawk, Flammulated Owl

Insectivorous Birds

Dry Forest, Mesic Mixed Conifer, 

Riparian Woodland and Shrub, 

Shrub-steppe, Alpine, Sagebrush, 

Juniper Woodland, open 

water/wetland.

Chipping sparrow, Vaux’s swift, Townsend’s warbler, 

varied thrush, MacGillivay’s warbler, red-eyed vireo, 

veery, willow flycatcher, hermit thrush, vesper 

sparrow, gray-crowned rosy finch, loggerhead shrike, 

lark sparrow, black-throated sparrow, Bullock’s oriole, 

yellow warbler, yellow-breasted chat, yellow-billed 

cuckoo, Lazuli bunting, gray flycatcher, Virginia’ 

warbler, Yellow-billed cuckoo, Olive-sided flycatcher, 

sage sparrow, Brewer’ sparrow, sage thrasher, sage 

sparrow, Black swift, Calliope hummingbird, 

Williamson’s sapsucker, McCown’s longspur, Black 

rosy finch, Cassins finch, Long billed curlew.

Herbivorous

bird Shrub-steppe Sharp-tail Grouse,

Waterfowl Wetlands, riparian areas and open 

water habitats

Canvasback, ring-necked duck, wood duck, mallard, 

northern pintail, redhead, lesser scaup, American 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

239

Animal/Diet Group Habitat Species

wigeon

Predatory Birds 

Direct and Indirect and Cumulative Effects

With implementation of pdf J11-a, raptor nests would be protected and there are no adverse effects to 

nesting birds or reproduction anticipated under any alternative. While foraging birds could be affected, 

the short-term (one day or less), low magnitude, and limited extent (usually 1 acre or less scattered over 

larger areas) of disturbance that will occur with invasive plant treatments would not adversely affect 

species in this group.

First-choice herbicides under alternatives B and C do not pose a risk these species. Also picloram and 

glyphosate (alternative D) did not exceed the toxicity index at typical or highest application rates. Only 

NPE-based surfactants exceeded the reported NOAEL (no observable adverse effect level) at the highest 

application rate. As a result, and with implementation of F2 that restricts the use of NPE-based surfactants 

to 0.5 lbs. of active ingredient per acre, there are no adverse effects from herbicide exposure under any 

alternative.

Cumulative effects would be similar to those described under northern goshawk 

Insectivorous Birds 

Direct, Indirect and Cumulative Effects

Effects to these species will vary and there would be little effect to forested species such as the 

Townsend’s warbler that utilize closed-canopy forest and nest off the ground. However for species such as 

the veery or Brewer’s sparrow which nests on or near the ground or in shrubs, effects include possible 

mortality associated with trampling of the nest. Due to the small size of treatment sites and widespread 

availability of unaffected habitat, the likelihood of mortality is low and direct effects would include shortterm disturbance of some species during treatment.

Risk of effects from herbicide exposure was evaluated using the insectivorous bird scenario and effects 

would be similar to those described for the grasshopper sparrow. While use of some herbicides and NPE 

could result in an adverse effect, implementation of the Malheur National Forest Plan standard that 

restricts use of triclopyr to selective methods only, and pdf F2 that restricts broadcast application of 

clopyralid, glyphosate, picloram, sethoxydim and sulfometuron methyl to typical application rates, the 

likelihood of herbicide exposure is minimal. Exposure is further reduced when you consider the small and 

scattered nature of the treatment sites and availability of unaffected habitat, which would reduce the 

likelihood that birds would forage exclusively on contaminated insects. As a result, there are no adverse 

effects from herbicide exposure anticipated under any alternative.

Cumulative effects would be similar to those described under grasshopper sparrow.

Herbivorous Birds 

Direct, Indirect and Cumulative Effects

The Columbia sharptail grouse has not been documented on the Forest and there are no direct effects from 

treatment anticipated. Should future use within treatment sites be documented, necessary treatment 

modification would be made as part of the annual review and monitoring process and it is unlikely that 

the Columbia sharp-tailed grouse would be directly affected by treatment. While all alternatives would 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

240

control invasive plants within sagebrush communities, because it has the widest range of treatment 

options, alternative B would be the most effective, particularly with larger infestations.

Should documentation of the sharp-tailed grouse occur in the future, effects would be similar to those 

described under sage grouse and there are no adverse effects from herbicide exposure anticipated under 

any alternative. 

Cumulative effects would be similar to those described under sage grouse and upland sandpiper 

Waterfowl

Direct, Indirect and Cumulative Effects

While all alternatives would help to contain and control invasive plants, treatments proposed under 

alternatives C and D are less effective (see chapter 3.1.4); therefore, treatment effectiveness of invasive 

plants within wetland and riparian habitat would best be achieved under alternative B. Risk of disturbance 

is also greater under alternatives C and D because more repeated treatments may be necessary increasing

use of spot herbicide application and manual/mechanical treatments.

Disturbance to waterfowl could occur under any alternative from herbicide or non-herbicide methods. 

With implementation of herbicide-use buffers, retention of untreated areas near water (H7-H9) and 

considering the small and scattered nature of treatment sites within suitable habitat, it is unlikely nests 

would be affected and the likelihood of direct effects is low. 

The diet of these species varies; species such as the redhead eat primarily plant material, and the 

canvasback, ring-necked duck, mallard, pintail, lesser scaup and American widgeon eat a combination of 

plants and insects. Also some species such as the wood duck and pintail eat vegetation or insects away 

from water within woodlands or open habitat. As a result, effects of herbicide exposure to waterfowl were 

evaluated using the insectivorous and herbaceous eating bird scenarios, as well as by evaluating the 

likelihood aquatic organisms would be affected.

Effects to aquatic invertebrates and plants were evaluated under the fisheries analysis and as described, 

concentrations of herbicides potentially delivered to any water body on the Malheur National Forest 

would remain well below levels capable of measurably affecting aquatic organisms, including: fish, 

amphibians, or aquatic invertebrates. Herbicide exposures to birds consuming insects or plant material 

would be similar to those described above (i.e. insectivorous and herbivorous birds) and the following 

pdfs reduce the likelihood that waterfowl would be exposed to toxic levels of herbicide. 

♦ The Malheur National Forest Plan restricts use of triclopyr to selective and spot techniques only.

♦ pdf F2 restricts broadcast application of NPE-based surfactant to 0.5 lbs. of active ingredient per 

acre and restricts broadcast application of clopyralid, glyphosate, picloram, sethoxydim and 

sulfometuron methyl to typical application rates.

♦ Project design features (H1, H2, H5, and H8-H10) would greatly reduce the likelihood for 

herbicides to be delivered to wetlands, lakes, ponds, wells, springs or stock tanks.

♦ Restrictions on extent of treatment in a given site (H4, H5 and H7) ensure that herbicides would 

not be delivered in amounts greater than the SERA risk assessment scenarios and that unsprayed 

areas around wetlands, lakes and ponds would be retained.

The likelihood of exposure to herbicide would be further reduced because of herbicide-use buffers and the 

application of pdfs around streams, wetlands, lakes, ponds, intermittent and ephemeral streams (table 10). 

Collectively, these measures in combination with the use of low risk first year/first choice herbicides will 

greatly reduce the likelihood that waterfowl would be exposed to toxic levels of herbicide. As a result,
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

241

and considering that birds would unlikely forage exclusively on contaminated prey/plant material, there 

are no adverse effects from herbicide exposure anticipated. 

Cumulative effects would be similar to those discussed under bufflehead and osprey. 

Migratory Bird Summary

Migratory birds and their habitats including species with viability concern (TES), regional landbirds, 

birds of conservation concern and gamebirds below the desired condition were evaluated. While shortterm effects to some migratory bird species may occur, the likelihood of mortality is low. Mitigation 

measures have been included to reduce effects and there are no long-term adverse effects from treatment 

anticipated, nor is it likely that migratory birds would be exposed to toxic levels of herbicide. There 

would be no reduction in native vegetation, and all alternatives would help to reduce invasive plants and 

maintain migratory bird habitat. All action alternatives are consistent with the Migratory Bird Treaty Act 

and Executive Order 13186. 

3.8 Range

3.8.1 Introduction

This section discusses the effects of alternatives on range resources, with emphasis on the herbicide 

treatments proposed. The analysis addresses effects of the alternatives on livestock and the need for 

specific grazing administration during and after herbicide use.

Regulatory Framework and Compliance

Several of the goals, objectives, standards and guidelines from the R6 2005 ROD are about grazing and 

range management. This invasive plant treatment project complies with the treatment and restoration 

standards and assumes compliance with the prevention standards. Prevention of invasive plants on 

grazing allotments is part of grazing projects and compliance with prevention standards is assumed for 

this analysis.

Table 67. Standards from the R6 2005 ROD and the relationship to Range Management

R6 2005 ROD 

Standard Relationship to Range Management Implementation

Prevention Standard 

1

Prevention of invasive plant introduction, 

establishment and spread will be addressed in 

grazing allotment and vegetation management 

plans.

Direction from Forest LRMP, the 

2001 Guide to Noxious Weed 

Prevention Practices, and the 2005 

ROD addressed in all projects.

Prevention Standard 

2

Actions conducted or authorized by written 

permit by the Forest Service that will operate 

outside the limits of the road prism . . . require 

the cleaning of all heavy equipment ... prior to 

entering National Forest System Lands.

Private lands associated with 

permittees are periodically surveyed 

to determine the presence of 

invasive species and the need for 

washing of vehicles such as water 

trucks and ranch vehicles before 

entry onto National Forest System 

Lands. Water trucks are generally 

restricted to roads or “haul routes” 

that like roads are compacted and 

disturbed. Destinations are water 

set areas used year after year.

Prevention Standard 

3

Use weed-free straw and/or mulch for all 

projects, conducted or authorized by the 

Forest Service, on National Forest System 

lands. If state certified straw and/or mulch is 

not available, individual Forests should require 

Where straw and/or mulch may be 

used as bedding for livestock 

operations and/or restoration 

projects. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

242

R6 2005 ROD 

Standard Relationship to Range Management Implementation

sources certified to be weed-free using the 

North American Weed Free Forage Program 

standards (see Appendix O) or a similar 

certification process.

Prevention Standard 

4

Use only pelletized or certified weed free feed 

on all National Forest System Lands. If State 

certified weed free feed is not available, 

individual Forests should require feed certified 

to be weed free using the North American 

Weed Free Forage Program standards or a 

similar certification processes Choose weedfree project staging areas, livestock and 

packhorse corrals, and trailheads.

Would phase in the use of weed 

free feed by permittees on all 

allotments over time including hay.

Hay and other feeds are 

occasionally used to gather or 

attract livestock, generally in 

preparation for a move. Would have 

permittees avoid those areas that 

become infested with invasive 

plants for livestock operations such 

as gather, herding, the staging of 

vehicles and livestock watering. The 

bigger concern would be where the 

permittee transports horses onto the 

allotment and brings hay products in 

with the trailer or if the permittee 

stays overnight and feeds horses at 

a line camp.

Prevention Standard 

5

Retain native vegetation consistent with site 

capability and integrated resource 

management objectives to suppress invasive 

plants and prevent their establishment and 

growth.

Compliments CDO. Land and 

resource management plans 

standards and guidelines that call 

for maintaining or improving 

vegetation conditions on allotments.

Prevention Standard 

6

Use available administrative mechanisms to 

incorporate invasive plant prevention practices 

into rangeland management. Examples of 

administrative mechanisms include, but are 

not limited to, revising permits and grazing 

allotment plans, providing annual operating 

instructions, and adaptive management. Plan 

and implement practices in cooperation with 

the grazing permit holder.

Accomplished long term through 

environmental analysis projects that 

lead to new allotment management 

plans and grazing permits.

Cooperate with grazing permittee 

on an annual basis to incorporate 

invasive species prevention 

practices in annual operation plans 

and use adaptive management to 

recognize changing science and 

ecosystem conditions.

Treatment

Restoration

Standard 11

Prioritize infestations of invasive plants for 

treatment at the landscape, watershed or 

larger multiple forest/multiple owner scale.

Provides an opportunity to focus on 

local problem areas and establish 

“community” based solutions that 

might include, but is not limited to, 

multiple ranches, state and/or BLM 

lands.

Treatment 

Restoration

Standard 23

Prior to implementation of herbicide treatment 

projects, National Forest system staff will 

ensure timely public notification. Treatment 

areas will be posted to inform the public and 

forest workers of herbicide application dates 

and herbicides used. If requested, individuals

will be notified in advance of spray dates.

Permittees will be notified upon 

request of specific treatments dates.

Permittees will be notified of 

invasive plant treatment areas and 

the potential for treatment by 

herbicides as needed on an annual 

basis. The most appropriate method 

would be during annual operating 

meetings.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

243

3.8.2 Affected Environment

Currently, more than 99 percent of the Malheur National Forest is incorporated into cattle grazing range 

allotments (1,695,228 acres, based on GIS data for the Malheur National Forest). The Malheur National 

Forest administers 106 grazing allotments, of which 98 are active and 8 are vacant. There are currently 

invasive plant infestations mapped on 86 of these allotments (81%) including on five of the vacant 

allotments. Infested sites range in size from one plant to numerous plants scattered over large acreages.

Over 90 percent of inventoried sites are less than 1 acre in size and an additional one percent of the sites 

are less than 5 acres in size. See table 68 below showing the extent of mapped invasive species within 

each allotment. 

Certain invasive plants are known to be toxic to various classes of permitted livestock. Canada thistle has 

the potential to concentrate nitrates and cause nitrate poisoning in ruminants. Russian knapweed and 

yellow starthistle both produce a unique poisoning of horses that is generally fatal. Leafy spurge can 

cause excessive salivation and diarrhea in cattle; however it does not appear to affect sheep and goats 

(USDA Forest Service 2012c). Houndstongue and tansy may cause liver problems in livestock, 

particularly cattle and horses.

Table 68. Invasive plant species information by allotment

Allotment Name

Status

Active (A)

Vacant (V)

District

Forest land 

allotment 

acres

Number of 

invasive 

species 

sites 

mapped

Number of 

target 

invasive 

species 

mapped in 

allotment

Invasive plant 

species acres*

Aldrich A BM 20572 1 1 8

Alkali A EC 26753 106 5 71

Allison A EC 21156 11 4 1.5

Antelope (Silvies) A BM 29381 7 5 1

Antelope (Upper 

Malheur)

A PC 5512 2 1 0.14

Austin V BM 672 4 3 9

Balance Creek A BM 365 0 0 0

Bear Creek A BM 1532 9 3 18

Beech Creek A BM 3756 10 3 14

Biggs On/Off A BM 166 0 0 0

Big Sagehen A EC 21612 56 8 8

Blue Creek A EC 16738 39 7 6

Blue Mountain V BM 22709 196 8 243

Bluebucket A PC 23436 11 3 5

Bridge Creek A 8354 13 3 1.5

Buck Mountain A EC 41479 2 2 0.14

Calamity A BM 23204 66 6 25

Camp Creek (Silvies) A BM 14958 10 4 13

Central Malheur A EC 11377 22 3 5

County Road A BM 0 0 0 0

Crooked Creek A BM 5076 10 3 1

Dark Canyon A BM 31808 40 9 5.29

Deadhorse A BM 15527 5 4 0.52
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

244

Allotment Name

Status

Active (A)

Vacant (V)

District

Forest land 

allotment 

acres

Number of 

invasive 

species 

sites 

mapped

Number of 

target 

invasive 

species 

mapped in 

allotment

Invasive plant 

species acres*

Deardorff A PC 11927 24 4 11

Deer Creek A BM 2998 2 2 0.21

Devine A EC 25390 146 6 26

Dixie A BM 26875 14 5 2

Dollar Basin A PC 16396 5 3 5

Donaldson A BM 8008 14 5 10

Donnelly A EC 56083 30 4 24

Emigrant Creek V EC 1609 2 1 0.20

Fawn Spring A BM 6615 18 6 4

Ferg A BM 478 1 1 0.10

Fields Peak A BM 30735 47 7 6

Flag Prairie A PC 28775 33 6 18

Flagtail A BM 14978 19 6 32

Fox A BM 26589 63 7 30

Frenchy A BM 525 0 0 0

Green Butte A EC 45265 9 4 2

Hamilton A BM 3410 7 4 0.71

Hanscomb A BM 9105 4 3 0.74

Herberger V BM 553 0 0 0

Highway A BM 905 0 0 0

Hot Springs A PC 4693 0 0 0

House Creek A EC 3252 15 3 1

Hughet Valley A EC 1877 0 0 0

Hunter Cabin A BM 15892 0 0 0

Indian Creek A PC 2593 1 1 0.10

Indian Ridge A BM 3440 20 8 2.50

Izee A EC 22219 22 5 15

Jack Creek A BM 10358 55 8 17

Joaquin A BM 38 0 0 0

Justice A BM 825 0 0 0

Keeney Meadows A BM 450 1 1 0.08

Koehler A BM 1002 0 0 0

King A BM 2237 0 0 0

Lake Creek V PC 10195 15 5 7

Lewis Creek A BM 2604 0 0 0

Little Mowich A EC 317 0 0 0

Logan Valley A PC 3780 6 3 0.61

Lonesome A EC 32085 30 4 32

Long Creek A BM 50241 83 10 57
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

245

Allotment Name

Status

Active (A)

Vacant (V)

District

Forest land 

allotment 

acres

Number of 

invasive 

species 

sites 

mapped

Number of 

target 

invasive 

species 

mapped in 

allotment

Invasive plant 

species acres*

Lower Middle Fork A BM 59120 195 12 247

Lower Nicoll A EC 3966 0 0 0

Mcclellan A BM 2814 1 1 0.10

Mccoy Creek A PC 980 1 1 0.10

Mccullough V BM 627 5 2 13

Mt. Vernon / John Day A BM 50466 58 7 27

Muddy A EC 6621 13 3 1

Murderers Creek A BM 67075 20 11 53

Myrtle A EC 29407 32 5 7

Ninety Six A BM 300 0 0 0

North Fork A PC 31044 109 9 38

Ott A PC 29991 158 7 25

Pearson A BM 190 0 0 0

Pine Creek A 40328 222 4 81

Poison A BM 74 0 0 0

Rail Creek A PC 27135 2 2 0.20

Rainbow A 30707 25 6 8

Reynolds Creek A PC 24028 261 7 42

Rosebud A BM 6912 34 5 44

Roundtop A BM 13708 44 7 12.5

Sawmill A EC 21461 2 2 0.09

Sawtooth A 17724 43 7 237.1

Scatfield A EC 2327 0 0 0

Scotty Creek A BM 35817 7 2 13

Seneca A BM 19321 23 6 2

Silver Creek A EC 34716 6 3 1

Silvies A EC 8789 5 2 8

Slide Creek A BM 25540 32 5 27

Smoky A BM 9264 1 1 0.11

Snow Mountain A EC 12362 26 7 2

Snowshoe A BM 6386 2 1 0.20

Spring Creek A PC 57772 60 6 39

Star Glade A PC 1999 0 0 0

Story-Fry A EC 619 3 2 0.22

Sugarloaf A 39879 43 10 6

Sullens V PC 46426 316 7 171

Summit Prairie A PC 25369 42 7 15

Upper Middle Fork A BM 54808 218 13 338

Van A 6684 15 3 11
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

246

Allotment Name

Status

Active (A)

Vacant (V)

District

Forest land 

allotment 

acres

Number of 

invasive 

species 

sites 

mapped

Number of 

target 

invasive 

species 

mapped in 

allotment

Invasive plant 

species acres*

War Canyon A BM 541 0 0 0

West Malheur A 22938 52 4 7

West Myrtle A EC 8541 25 4 6.50

Williams Pasture A BM 1146 0 0 0

Windy Point V BM 1306 0 0 0

Wolf Mountain A 31608 28 6 12

York A BM 929 5 2 1

Table 69. Allotment use and invasive plants

Allotment 

Use

Allotment 

Acres

Invasive Plant

Target Species

Acres

Percent of Allotment 

Acreage Occupied by 

Target Species Plants

Percent of Total Forest 

Land Base Infested with 

Invasive Plants

Active 1,614,599 1682 0.1 0.09

Vacant 80,629 442 0.5 0.03

Total 1,695,228 2124 0.60 0.12

Grazing and Invasive Plant Spread

Seed dispersal for many species, including diffuse knap weed,, Canada thistle. scotch thistle and whitetop, 

is largely by wind (Bullock and Clarke 2000, CWMA 2007, USDA Forest Service 2012a, USDA Forest 

Service 2012b, Zouhar 2004), however, these seeds and seeds of other invasive plants present in the 

Malheur National Forest range allotments can also be spread by vehicles, water transport and animals 

(fur, hooves, and gastrointestinal ingestion and redistribution).

In areas where invasive species are interspersed with desirable forage, it is likely that seeds would either 

attach to fur or mud on hooves or be ingested and dispersed in feces. Some weed seeds are destroyed 

within the gastrointestinal tract; however, leafy spurge and spotted knapweed seeds can pass through 

sheep, goats, and mule deer and some of the seeds remain viable (Lacey et al. 1992). Leafy spurge seed 

was shown to be viable in feces 10 days post ingestion by mule deer. Long-lived seeds and hard seeded 

species of dicots and grasses consumed by grazers have been reported to survive passage through 

gastrointestinal tracts of cows and grizzly bears (Janzen 1984).

Cattle behavior along fence lines and around water developments can result in disturbed areas for 

invasive species to establish. According to available information, there are fewer than 3 miles of fenceline 

on allotments and just over 4 acres of invasive plants within 10 feet of fencelines. This would indicate 

that there is a high potential for weed spread from cattle trailing along fencelines on 3.25 acres. Five 

water developments are mapped as having invasive plants within 25 feet. Cattle disturbance around these 

water developments may be estimated to result in less than one acre of weed spread. These estimates 

suggest that cattle grazing have a lower potential to affect the spread of invasive plants than some other 

vectors. Also see the Cumulative Effects section for a discussion of the relative importance of various 

vectors. (Not all fencelines and water developments are mapped, so these estimates may be lower than 

actual potentials).
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

247

3.8.3 Environmental Consequences 

Introduction

This section addresses the effects of the alternatives on grazing allotment administration and range 

resources (livestock and forage). The effect of invasive plant treatments on range administration is not a 

significant issue identified in chapter 1. 

As project design feature N2 suggests (see table 9), range administration adjustments to protect range 

resources from invasive plant treatments could be necessary and would be addressed through existing 

administrative mechanisms such as grazing allotment management plans and grazing permits. Potential 

adjustments that could be used to address invasive plants or potential introductions may include:

♦ Changes in livestock movement patterns that require additional labor or may reduce outputs for 

certain allotments 

♦ Alterations to season of use (length, turn-on, turn-off, etc.) and intensity of use that could reduce 

outputs and could include resting of pastures resulting in reduction of livestock use and output 

♦ Passive restoration of native plant communities could require allotment resting for one to two 

seasons potentially reducing livestock use and output. In some cases fencing can be used to 

mitigate impacts. 

♦ Delayed reintroduction of livestock following wildfires resulting in reduced livestock use and 

outputs over time

The effects spatial area is the project area and nearby adjacent private, state and other federal lands. The 

time frame of the analyses includes the past 20 years and the next 15 years which is expected to be the life 

expectancy of this document. Invasive species have been present and programs existed on the Forest for 

the past 20 years. However, most Land Resource Management Plans in the late 1980s and early 1990s did 

not recognize specific details of the ecologic implications of invasive plants.

Effects Common to Action Alternatives on the Range Resource by Treatment Method

Herbicide Use

Compared to the no-action alternative, more chemicals would be used in the environment while 

effectively treating invasive species in the three action alternatives. The potential for a spill to occur 

during herbicide operations would be greater than under the no-action alternative based on the additional 

number of acres that would be treated. Minimal to no effects are anticipated to grazers or operators due to 

strict adherence to label handling directions and spill containment protocols in the unlikely event of a 

spill. 

Livestock grazing is a known cause of invasive plant spread (DiTomaso 2000). Removal of livestock 

would reduce one of the vectors of invasive species spread but is not proposed as a part of this treatment 

project. No studies have rigorously tested this hypothesis or the effects of wild ungulates in spreading 

non-native plant species. Scientific support is growing for the hypothesis that large herbivores facilitate 

the invasion and establishment invasive plants; however, substantial controversy exists about the specific 

process in time and space and the associated predictions of effects. See the Introduction to Cumulative 

Effects section in chapter 3.1.5 for a discussion of the relative influence of grazing compared to other 

potential vectors on the Malheur National Forest.

Label Restrictions Relative to Range

Table 70 describes the herbicide label restrictions relevant to grazing management. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

248

Table 70. Herbicide label restrictions relevant to range

Herbicide Brand Name Restriction Remarks

Aminopyralid Milestone

Milestone VM

Grasses treated in the preceding 18 months CAN 

NOT be moved off the farm or ranch where 

harvested unless allowed by supplemental labeling.

Hay treated in the preceding 18 months CAN NOT 

be used for silage, hayfage, baylage and green 

chop unless allowed by supplemental labeling.

Do not use hay or straw from areas treated within 

the preceding 18 months or manure from animals 

feeding on treated hay in compost.

Do not use grasses treated within the preceding 18 

months for seed production.

May be used up to 

the edge off water.

Chlorsulfuron

Telar, Glean, 

Corsair, 

Landmark 

(oust + telar)

None for grazing or range administration --

Clopyralid

Transline, 

Redeem 

(Clopyralid + 

Triclopyr)

Redeem: Do not graze treated areas until 

poisonous plants are dry and no longer palatable to 

livestock. Withdraw livestock from grazing treated 

grass at least 3 days prior to slaughter.

See label for 

cropland grazing 

restrictions post 

treatment in 

pastures. Redeem: 

Herbicide application 

may increase 

palatability of 

poisonous plants.

Glyphosate RoundUp, 

Rodeo, etc. None for grazing or range administration

RoundUp: ingestion 

of this product or 

large amounts of 

freshly sprayed 

vegetation may 

cause temporary 

gastrointestinal 

irritation.

Imazapic Plateau Plateau: None.

Plateau DG: Do not use on areas to be grazed. --

Imazapyr

Arsenal, 

Chopper, 

Stalker

Arsenal: none.

Chopper: none.

Stalker: none.

--

Metsulfuron 

methyl

(Escort)/Sulfon

ylurea None for grazing or range administration --

Picloram Tordon

Tordon 101/22K/K: allow one week of 

grazing/feeding in non-exposure area before 

moving livestock onto broadleaf cropland. Tordon 

22K: herbicide application may increase palatability 

of poisonous plants. Don’t graze treated areas until 

poisonous plants are dry and no longer palatable.

Meat grazing animals should be removed from 

treated areas 2 weeks after treatment and 3 days 

prior to slaughter.

--

Effects on Mammals from Herbicide Exposure

Other herbicides could be used in later years if the first-choice herbicides are not effective (table 13 and 

table 5 in the project EIS). Some of these herbicides have label use restrictions that would be followed 

with reference to livestock grazing and/or slaughtering after herbicide treatment and subsequent exposure.

Treating pastures that are currently in rest due to grazing management rotations would eliminate any 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

249

potential effects. If movement of livestock is not possible and pastures or allotments require treatment 

while animals are present, all label use restrictions would be followed in addition to pdfs that require 

permittee notification prior to any proposed application. In addition, timely notification and coordination 

would occur during annual operating instruction/plan meetings and by posting/signing areas to be treated 

prior to and after treatment (R6 FEIS 2005).

With all herbicide use, effects on non-target vegetation may lead to secondary effects on terrestrial 

animals. Herbicides that may directly affect grazing animals (clopyralid, triclopyr and picloram) have 

label restrictions on grazing after herbicide treatment (table 70). These herbicides would have more 

potential for adverse effects to livestock than the first-choice herbicides, but use of label restrictions and 

pdfs would eliminate potential effects.

Below is information about effects of each herbicide that could be used in any of the action alternatives. 

The information is derived from SERA risk assessments. In the risk assessment methodology, hazards to 

target organisms are measured as a hazard quotient (HQ). A hazard quotient of 1 or greater is considered 

to be of concern. 

Aminopyralid (SERA 2007): Non-target forage plants may be killed by direct spray or spray drift. There is 

no indication that tolerant species of terrestrials plants (such a grasses), aquatic plants (algae or 

macrophytes), mammals, birds, aquatic or terrestrial invertebrates, terrestrial microorganisms, fish, and 

amphibians will by adversely affected by aminopyralid (SERA 2007).

Clopyralid (SERA 2004b): Appears to be relatively non-toxic to terrestrial or aquatic animals; it is highly 

selective in its toxicity to terrestrial plants, and relatively non-toxic to aquatic plants. Thus, the potential 

for substantial effects on non-target species appears to be remote. However, some decreased body weight 

has occurred in rats at lowest dose levels. Effects on liver and kidney weight as well as changes in gastric 

epithelial tissue have also been noted at dose levels similar to those associated with changes in body 

weight.

Chlorsulfuron (SERA 2004): Non-target forage plants could be killed by drift or runoff. Off-site runoff of 

chlorsulfuron could be substantial in conditions that favor runoff. The available data are sufficient to 

assert that no adverse effects are anticipated in terrestrial animals that do not directly depend on the weeds 

that are targeted (SERA 2004).

Glyphosate (SERA 2011b): There are numerous formulations of glyphosate. In the risk assessment, 

distinctions are made between more and less toxic formulations. At the unit application rate of 1 lb.

a.e./acre, none of the hazard quotients for mammals exceed the level of concern (HQ=1). At application 

rates of 2.5 lb. a.e./acre or less, worst-case exposure assessments indicate that mammals are not at risk. As 

discussed in Section 4.1.2.1, this risk characterization is supported by well-documented field studies that 

failed to identify adverse effects in populations of small mammals following applications of Roundup as 

well as another unidentified formulation of glyphosate 

Less toxic formulations of glyphosate pose no apparent risks to mammals. At the unit application rate of 1 

lb. a.e./acre, the highest HQ for any mammalian receptor is 0.005, which is associated with the 

consumption of contaminated water following an accidental spill. At the maximum aquatic application 

rate of 3.75 lb. a.e./acre, the HQ for the accidental spill would be about 0.02 [(0.005/1 lb. a.e. per acre) x 

3.75 lb. a.e./acre = 0.01875], which is below the level of concern by a factor of 50.

Imazapic (SERA 2004d): The weight of evidence suggests that no adverse effects in mammals or birds are 

plausible using typical or worst-case exposure assumptions at the typical application rate of 0.1 lb./acre or 

the maximum application rate of 0.1875 lb./acre. The available data are sufficient to assert that no adverse 

effects are anticipated in terrestrial mammals or birds. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

250

Imazapyr (SERA 2011c): For aquatic applications, none of the HQs approaches a level of concern. The 

highest HQ of 0.009 is associated with the upper bound of the HQ for a canid consuming contaminated 

fish following an accidental spill. This HQ is below the level of concern (HQ=1) by a factor of over 100.

None of the hazard quotients for terrestrial applications exceed the level of concern. The highest HQs are 

associated with consumption of contaminated grass by a small mammal—i.e., HQs of 0.2 (0.02 to 0.9).

All exposure scenarios for all larger mammals are no greater than 0.2, below the level of concern by a 

factor of 5.

Metsulfuron Methyl: Non-target forage plants could be killed by drift or runoff. Off-site runoff of 

metsulfuron methyl could be substantial in conditions that favor runoff. The available data are sufficient 

to assert that no adverse effects are anticipated in terrestrial animals that do not directly depend on the 

weeds that are targeted (SERA 2005).

Picloram (SERA 2011d): There are no clear organ-specific pathological effects are associated with 

picloram, and the most sensitive endpoints appear to be nonspecific alterations in the staining properties 

of liver tissue with altered liver and kidney weights noted at higher doses.

Surfactants: Surfactants are one type of adjuvant that makes herbicides more effective by increasing 

absorption into the plant. Many of the inert ingredients are proprietary in nature and have not been tested 

on laboratory species. However, confidential business information (i.e. the identity of proprietary 

ingredients) was used in the preparation of the herbicide risk assessments. Surfactants are discussed in 

chapter 2 of the project EIS and limitations for their use are listed in the pdfs.

Triclopyr (SERA 2011): The only exposure scenario of concern is the ingestion of contaminated 

vegetation. Aquatic applications of triclopyr do not present apparent or identifiable risks to humans. The 

HQs for mammals increase as body weight increases. While small mammals may consume more than 

larger animals, the higher sensitivity of larger mammals to triclopyr suggest they are at greater risk. At the 

unit application rate of 1 lb. a.e./acre, the acute HQs for a large (70 kg) mammal consuming contaminated 

short grass are 2 (0.2 to 11). The corresponding chronic HQs are 5 (0.2 to 53). 

Based on relatively standard methods used to estimate risks to mammals from well-conducted toxicity 

studies as well as reasonably well- documented estimates of exposure, it is likely when using triclopyr 

that mammals would be exposed to doses that exceed the level of concern (Hazard Quotient, HQ=1). In 

extreme cases, adverse effects could be anticipated in some mammals, particularly larger mammals, at 

application rates as low as 1 lb. a.e./acre. These effects, however, might not involve overt signs of toxicity 

that would be observed in field studies. 

Chronic HQs for mammals are substantially higher than the acute HQs. This suggests that while overt 

signs of toxicity might not be evident shortly after triclopyr applications, longer-term adverse effects on 

mammalian populations, possibly involving changes in reproductive rates, could occur. While these 

effects are not reported or otherwise noted in field studies, available field studies focus on small 

mammals, and the available literature does not include longer-term studies on populations of larger 

mammals (carnivores or herbivores). 

Exposure scenarios not involving the consumption of contaminated vegetation—i.e., direct spray and the 

consumption of contaminated water and fish—lead to HQs for triclopyr that are far below the level of 

concern. The only residual concern with mammals following aquatic applications of triclopyr involves the 

treatment of emergent vegetation. It seems reasonable that mammals could feed on treated emergent 

vegetation shortly after triclopyr was applied. Methods to estimate doses from this type of exposure are 

not available. By analogy to the consumption of terrestrial vegetation by mammals, mammals consuming 

treated emergent aquatic vegetation could be exposed to triclopyr at levels which might exceed the level 

of concern.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

251

Adjuvants/Surfactants (Bakke 2002, 2003): Surfactants are one type of adjuvant that makes herbicides 

more effective by increasing absorption into the plant. Many of the inert ingredients are proprietary in 

nature and have not been tested on laboratory species. However, confidential business information (i.e. 

the identity of proprietary ingredients) was used in the preparation of the herbicide risk assessments. 

Surfactants are discussed in chapter 2 of the project EIS and limitations for their use are listed in the pdfs.

Other Treatment Methods

Manual treatments would be used in small areas and would not likely affect livestock except to remove 

the invasive plants including potentially toxic species and potentially increase the amount of forage.

Mechanical treatment would most likely involve mowing along roadsides. Mechanical treatments would 

not likely affect livestock use. It would temporarily remove invasive plants, but would not eliminate them. 

Biological controls would reduce amounts of invasive plants and allow for native species to expand.

Cultural controls would be used in very small areas and would not likely affect livestock.

An actual reduction in Animal Unit Month (AUM) attributed to invasive plant management cannot be 

quantified at the project scale due to unavailable data, variability between allotments, and the ongoing 

process of Allotment Management Plan revision. All action alternatives would include restoration, where 

needed, to facilitate recovery of native plants.

Early Detection and Rapid Response

In addition, new or previously undiscovered infestations could be treated using the range of methods 

described in this EIS. An early detection and rapid response (EDRR) approach is needed because (1) the 

precise location of individual target plants, including those mapped in the current inventory, are subject to 

rapid and/or unpredictable change, and (2) the typical NEPA process does not allow for rapid response to 

new detections; infestations may grow and spread into new areas during the time it usually takes to 

prepare NEPA documentation. The intent of the project early detection and rapid response approach is to 

treat new infestations when they are small so that the likelihood of successful treatment is maximized and 

adverse effects are minimized. 

The action alternatives would allow treatment of new detections (EDRR), as long as the treatment method 

is within the scope of this EIS. The treatment of newly found sites adds additional risk factors to wildlife 

just by adding additional exposure areas. This also expands the treatment into areas that may not have 

been originally anticipated. However, the implementation planning process identified in chapter 2 would 

be used with each new infestation site to determine treatment. The pdfs have been set up to provide layers 

of caution so that even if the exact locations are not known, the potential for adverse effects are 

minimized. Implementation of pdfs and herbicide-use buffers and treatment limits would work together to 

provide sideboards to deal with the uncertainty of treating new sites (USDA Forest Service 2008b).

Direct, Indirect and Cumulative Effects of Alternative A

Implementation of alternative A means there would be no treatment and no direct, indirect, or cumulative

effects on range. Invasive plants would continue to degrade livestock forage and could spread into 

neighboring rangelands. Alternative A would limit our ability to meet the purpose and need and would not 

comply with current management direction relative to invasive plants and range. 

Direct and Indirect Effects of Alternative B

Effective invasive plant treatments on grazing allotments would help retain and increase the native 

vegetation that provides livestock forage. Livestock exposure to toxic weed species would be reduced.

First-choice herbicides proposed for alternative B are expected to have no adverse effects to livestock.

Other herbicides that may be used have some potential impacts on livestock as discussed above but 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

252

impacts would be eliminated due the pdfs that keep rates low and the coordination with permittees that 

ensures pdfs and label requirements for moving livestock during spraying are followed (table 9, N 

Group).

There are no restrictions on livestock use for the first-choice herbicides. There are restrictions on uses of 

grass, hay and straw sprayed with aminopyralid, but none for livestock grazing. There are grazing 

restrictions with use of clopyralid, imazapic, picloram and triclopyr.

Project design features would be adequate to prevent effects to livestock. 

Given the relatively short half-lives, the low rates of application proposed and the minimal effects of the 

first-choice herbicides proposed under alternative B, it is not likely that repeated applications in the same 

areas would have effects to livestock. Herbicide risk assessments considered chronic exposure, and even 

under those scenarios, effects were below the established thresholds.

Management such as timing and duration of grazing, patterns of use, requirements to use only weed-free 

feed, and the potential of quarantine periods if these activities are implemented on allotments. Operators 

may experience a slight loss of grazing opportunity; however, many of the grazing strategies within 

allotments have deferred rotations and by focusing invasive weed treatments to the pastures during the 

resting phase would avoid most or all potential impacts to operators.

Alternative B would be more effective at reducing invasive plants (80 percent) than the other alternatives 

and restoration may begin sooner, so benefits of invasive weed treatment would be experienced earlier 

under alternative B.

Direct and Indirect Effects of Alternative C

This alternative would result in fewer acres of herbicide use and would allow only spot herbicide use 

within 100 feet of streams and within 200 feet of wells. Picloram would not be used. Impacts to livestock 

operators would be similar to those described in alternative B. The potential for exposure of livestock and 

livestock managers would be slightly decreased as less chemical would be used within riparian areas. 

Livestock would not be exposed to effects from picloram.

Manual and mechanical treatments would increase. Approximately1,389 acres would need to be treated 

solely with non-herbicide methods. Non-herbicide treatments would not affect livestock, but treatments in 

riparian areas where cattle congregate could result in short periods of bare soils that could result in 

increased erosion and sedimentation with cattle use. As noted in chapters 3.4 and 3.5, sediment delivery 

from this project would be minimal. 

Direct and Indirect Effects of Alternative D

Compared to alternative B, more chlorsulfuron, glyphosate, metsulfuron methyl, and picloram, would be 

used instead of aminopyralid. The herbicide use rates, pdfs and herbicide-use buffers associated with 

aminopyralid would become non-applicable. Alternative D would have less broadcast spraying and more 

spot spraying, so there would be less potential for damaging or destroying non-target vegetation and 

forage. Alternative D would use picloram on 27 acres. Picloram has the potential for adverse effects to 

livestock, but project design features and label restrictions would lower risks. When picloram is used, 

grazing would be eliminated during herbicide treatment until poisonous plants are dry and no longer 

palatable. Grazing animals used for meat would be removed from treated areas for 2 weeks after 

treatment and 3 days prior to slaughter. Project design features are adequate to prevent harmful herbicide 

exposure to livestock. Permittees would be notified of herbicide application and would be required to 

move cattle to follow pdfs and herbicide label restrictions.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

253

Cumulative Effects of Action Alternatives

Long-term effects of the action alternatives would be beneficial to range resources. Implementation of 

action alternatives would gradually reduce the extent and abundance of invasive plant species on range 

allotments. Coordination with neighbors would increase weed control effectiveness on adjacent land 

ownerships because aggressive treatment would reduce invasive infestations on National Forest system 

land and less weed seeds and fewer invasive plants would spread onto neighboring lands. As the spread of 

invasive species on National Forest System lands decreases, the likelihood of weeds spreading onto 

private, tribal, state and lands of other ownerships would also decrease. Over time, this could reduce 

herbicide use on National Forest and adjacent land ownerships.

Since grazing allotments cover essentially the entire Malheur National Forest, any activities that produce 

ground disturbance on the Forest may increase the spread of invasive plants and reduce the amount of 

forage available for livestock. Therefore, although treatments proposed under alternative B would reduce 

invasive infestations and all management activities follow guidelines to prevent or reduce the spread of 

weeds, new infestations or spread of remaining infestations would continue to occur. As a result, herbicide 

applications would likely continue to be needed over time. We expect, however, that after current 

infestations are reduced or eradicated with initial treatments, follow-up treatments and treatments of new 

infestations would require less herbicide over smaller areas. Herbicide treatment of invasive species on 

lands near or adjacent to the Forest would likely continue, and amounts, types, and methods of application 

cannot be anticipated.

The action alternatives all include the EDRR component allowing treatment of newly detected 

infestations; however, other landowners may or may not have the flexibility, funds or staffing to 

implement EDRR. Because the extent of future treatment programs on lands of other ownerships is 

unknown, the effect this would have on invasive plants migrating onto National Forest System lands is 

also unknown. 

Table 25 and table 26 list projects and activities that are ongoing or foreseeable for the Malheur National 

Forest. The other projects do not involve weed treatment or herbicide use. Since no direct or indirect 

effects to livestock or range management are expected, this project would not add to any effects from 

those projects and activities. Therefore, there would be no adverse cumulative effects to range resources 

from this project. In the long term, all action alternatives would favor re-establishment of desirable plant 

communities within the project area and across ownership boundaries, especially where coordinated 

treatments occur.

3.9 Recreation and Special Places

3.9.1 Introduction

Introduction of invasive species can have notable impact on recreation resources and activities. These 

affects may have a range of effects depending on species, plant architecture, plant chemical composition, 

and/or associated environmental alteration.

Invasive species may be introduced at developed campgrounds, dispersed camp sites, trailheads, snow 

parks i.e., recreation parking areas for unloading/loading snow machines, boat launch areas, visitor 

centers or interpretive sites. Even more insidious is when invasive species are introduced along trails or at 

remote wild and scenic, wilderness, or other back country areas. In these special designated areas 

detection, mapping, and treatments may often presents a greater challenge. Wilderness or Wild River 

special areas typically prohibit use of motorized equipment for treatment, and often may restrict other 

treatments commonly used in other areas such as biological control.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

254

The section of the EIS discusses potential herbicide effects on people and animals when used in areas 

frequented by recreationists such as campgrounds, dispersed camping sites, interpretive sites, and trail 

systems. It also addresses the effects of herbicide use changing the wild character of roadless areas 

(IRAs), Wildernesses, Wild and Scenic Rivers (WSR), National Scenic Areas (NSA), National Scenic 

Trails (NST), and Research Natural Areas (RNA).

The public has expressed concerns about herbicide use in these special areas, as well as preventing or 

controlling invasive species vectors associated with recreational uses including OHV travel, recreation 

stock use, and other traditional recreation uses such as site seeing, recreational driving, hiking, camping, 

and picnicking.

The Forest Service uses a nationally recognized classification system called the Recreational Opportunity 

Spectrum (ROS) to describe different recreation settings, opportunities, and experiences that help guide 

recreation management decisions and activities on National Forest lands (USDA Forest Service 1986).

ArcGIS 9.3.1 geographic information system (GIS) was used to analyze the proposed activities in regards 

to recreation use and facilities, dispersed recreation sites, and the recreation opportunity spectrum (ROS) 

classes within the project area. The recreation analysis considered the area within the project area, unless 

otherwise noted. Estimates of recreation use are derived from the National Visitor Use Monitoring

(NVUM) inventories done on the Malheur NF in 2003-04 and 2009-10. These inventories are conducted 

for all national forests on a 5-year cycle. These two NVUM surveys are the basis for estimating present 

recreation use and demand and for projecting the growth of recreation use on the Malheur NF.

Data Gaps and Limitations

The NVUM inventory process has limitations that should be understood. Visitor use is measured at 

specific predetermined recreation sites falling into high, medium, or low use categories. Small or little 

used sites are not included in the inventories. However, they may represent a significant contribution to a 

given recreation pursuit and not be adequately represented in the data. In addition, participation is 

voluntary and some visitors, or activities, may better lend themselves to interviewing. For example, a 

party pulling a pack string may be less inclined to participate because the disruption may provide 

opportunity for the string to get into trouble. Consequently, the data is collected from a segment that is 

willing or able to participate and extrapolated to represent visitor use as a whole.

Invasive species survey data for Wilderness Areas, Wild portions of the Wild and Scenic Rivers, and for 

the Scenic Area are limited. Invasive species surveys in these more remote areas with limited access 

makes surveying for invasive species a more time and funding intensive workload.

3.9.2 Affected Environment

Recreation Uses

Recreation use was inventoried on the Malheur National Forest during the years 2004 and 2010. There 

was a dramatic decrease in the total number of forest visitors between the two sample dates. In 2004 

Forest visits were estimated at 422,666 person days compared to only 261,400 person days in 2010, 

nearly a 40% decline in the number of forest visits between the two sample years.

The NVUM system was used to capture the data. The Recreation Report provides detailed data showing

that hunting is a major use on the Forest, along with driving for pleasure, camping, hiking, relaxing and 

viewing wildlife. Most of these activities necessitated the use of motorized vehicles to access all or part of 

the activity. This consistent association between recreation activities and motorized use is an important 

consideration for successful invasive species management on the Forest.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

255

Wilderness

The Forest contains two Wilderness Areas, Strawberry Mountain (68,700ac.) and Monument Rock 

(12,620 acres, see maps in the recreation report). The Wilderness Act prohibits motorized or mechanized 

use, major invasive species vectors, within wilderness area boundaries. However, recreationist, pets, pack 

stock, livestock grazing, wildlife, and natural seed dispersal have successfully introduced invasive species 

into these wilderness areas.

Current invasive species surveys have documented 2.2 acres of invasive plant infestations at 8 locations in 

the wildernesses. The wilderness surveys are not considered to be complete and ongoing awareness and 

additional surveying will be essential for managing invasive species within these special areas. In 

addition, invasive plant sites occur at or near some of the wilderness trail heads and on roads leading to, 

and adjacent to, the wilderness areas. It is likely more infestations will arise in the future. Higher use 

levels such as near trail heads, along trails, in riparian areas, in recent burns, or in concentrated use 

campsites are known vectors for spread (see chapter 3.1).

Wild and Scenic Rivers

Two congressionally designated wild & scenic rivers (WSR) lie within the Forest, the Malheur River 

WSR and the North Fork of the Malheur WSR (see maps in the recreation report). The Malheur River 

WSR is 12 miles long with 6 miles designated as Wild and 6 miles designated as Scenic. The WSR 

corridor is comprised of 2,961 acres designated wild and 797 acres designated scenic totaling 3,758 acres.

The North Fork of the Malheur River WSR is designated a scenic WSR for 22.9 miles with the corridor 

encompassing 7,034 acres. ) The Malheur Forest Plan, as amended by their respective Malheur and North 

Fork Malheur WSR Plans, generally prohibits motorized use off Forest system roads and trails within 

both the Scenic and Wild boundaries of both of rivers. These motorized access restrictions will aid in 

reducing the risk of introducing invasive plant species. There remain other vectors associated with 

recreational uses, e.g. dispersed campsites, hiking, horseback riding, and livestock grazing in some areas, 

which may serve as vectors for invasive plant species. Current invasive plant surveys in the WSRs 

indicate infestations totaling 0.9 acres. Additional infestation will most likely be associated with areas of 

heavier use, such as near trail heads, along the river riparian zones, along trail, in concentrated campsites, 

and in recent burns.

Inventoried Roadless areas (IRA)

Inventoried Roadless Areas (IRA) were identified under the 2001 Roadless Area Conservation Rule.

Nineteen IRAs are designated on the Malheur National Forest (maps in the recreation report). These IRAs 

have a total of 188 acres of Forest lands. The Forest Plan recognizes these special areas as a combined 

portions of the Semi-Primitive Non-Motorized, Semi-Primitive Motorized, and Wild and Scenic River 

Management Areas (MAs 10, 11, and 22). The motorized vehicle restrictions in portions of the IRAs, are 

somewhat similar to restrictions in Wild and Scenic Rivers corridors and Semi-Primitive Non-Motorized 

management areas. This will aid in reducing the likelihood of invasive species introduction and spread 

within IRAs via motorized recreation activities. The Semi-Primitive motorized IRA would have reduced 

motorized access, and hence less potential for infestation spread by motor vehicle access but not quite to 

the extent enjoyed by Wilderness and Wild Rivers areas. Current IRA invasive plant infestations total 25 

acres comprised of 50 known location. Additional infestations will most likely occur in areas receiving 

heavier visitor use, such as along trail, in riparian zones, in concentrated campsites, and in recent burns.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

256

Table 71. Acres of Inventoried Roadless Areas

Inventoried Roadless Area Acres

Aldrich Mountain 4,924.72

Baldy Mountain 6,415.93

Cedar Grove 113.98

Dixie Butte 12,207.98

Dry Cabin 12,273.64

Flag Creek 7,716.41

Fox Creek 5,845.93

Glacier Mountain 19,568.38

Greenhorn Mountain 15,927.16

Jumpoff Joe 3,889.62

Malheur River 7,282.54

Mcclellan Mountain 21,213.02

Myrtle Silvies 11,678.69

Nipple Butte 11,353.90

North Fork Malheur 18,068.60

Pine Creek 5,461.57

Shaketable 6,763.89

Silver Creek 7,948.20

Utley Butte 9,699.11

Total IRA Acreage 188,353.26

National Scenic Areas

The Malheur National Forest has one National Scenic Area, the Vinegar Hill – Indian Rock Scenic Area 

comprised of 17,234 acres (see map in recreation report). The management direction for Scenic Areas is 

to manage this area to preserve and protect outstanding natural esthetics. Current known invasive plant 

infestations total 2.4 acres. Motorized travel is restricted within the NSA to winter use only. As with other 

special areas that prohibit or restrict motorized access, a major source of invasive introductions, the 

likelihood of introducing or spreading invasive species is commensurately reduced. Additional 

infestations will most likely occur in areas receiving heavier visitor use, such as along trail, in riparian 

zones, in concentrated campsites, and in recent burns.

Other Semi-Primitive Areas

Recreation opportunities on the Malheur NF are focused toward meeting forest management objectives as 

identified in the Malheur Forest Plan. However, the rise in motorized activity over the past two decades 

represents a substantial change with profound potential toward affecting opportunities within the full 

(recreation opportunity spectrum) ROS. An increase in motorized activity in the more primitive ROS 

holds the potential for introducing and spreading invasive species into less frequented areas, hence 

decreasing the likelihood of implementing EDRR (early detection and rapid response).

Maintaining a road infrastructure in the face of shrinking budgets is increasingly problematic and has 

resulted in an increase in the number of “challenging” and rugged roads on the Forest, e.g. Deer Creek or 

Crane Crossing. In addition, management presence has diminished generally across the Forest as budgets 

for field going personnel and signing has diminished. When considered in combination, the extensive 

road system, predominant importance of road based recreation activities, and low forest service presence 

increase the opportunity for invasive species establishment and overall diminish the success of 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

257

implementing and effective EDRR strategy. Protection of primitive areas are of particular interest and 

concern.

3.9.3 Environmental Consequences

Introduction 

Table 72 below shows the number of invasive plant sites currently within recreation resource areas and 

how many acres are proposed for herbicide treatment based on the current inventory. 

Table 72. Number of invasive plants by Recreation Resource Area and Alternative

Recreation Resource Areas Number of 

known sites Alt. A Alt. B Alt. C Alt. D

Wilderness Acres 8 0 2.2 2.2 2.2

Wild and Scenic Rivers Acres 15 0 0.9 0 0.9

Scenic Areas Acres 4 0 2.4 2.4 2.4

Other Semi-Primitive Areas (ROS)

Acres 15 0 4.2 4.2 4.2

IRAs Acres 50 0 61.2 61.2 61.2

Acres Within 500 meters of 

developed recreation Sites 108 0 121 121 121

The analysis area encompasses these types of recreation areas.

Alternative A – No Action

Under the no-action alternative there would be no direct effects to the Malheur National Forest recreation 

resource areas of Wilderness, Wild and Scenic Rivers, Scenic Areas, Semi-Primitive Non-Motorized ROS 

areas, IRAs, and developed and dispersed recreation sites.

The current infestation would most likely continue to expand and new infestation sites would be expected 

to be established. Over time it would be expected that the Wilderness character and values would be 

negatively affected by expanding infestations. The Wild and Scenic River Outstanding Remarkable 

Values (ORV) would be negatively affected by expanding infestations. The Scenic Area outstanding 

natural esthetics would be negatively affected by expanding invasive species infestations. Over time, the 

SPNM and IRA area’s biological and botanical environments would be negatively affected by expanding 

infestations. Degradation of the biological and botanical environments would further degrade the natural 

beauty and character of the SPNM and IRA areas. 

Dispersed recreation also occurs throughout the Malheur National Forest. Dispersed recreation includes a 

wide variety of activities including hunting, fishing driving for pleasure, firewood cutting, horseback

packing and riding, road and mountain biking, camping, picnicking, wild plant collecting (mushrooms, 

camas, ferns, and etc.), and OHV riding. Over time it would be expected that the scenic and natural 

appearing forest character of dispersed recreation sites would be impaired depending on the particular 

recreation activity and the nature of the invasive infestation.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

258

Direct and Indirect Effects of Action Alternatives

All action alternatives provide for some level of effective invasive species treatments. These alternatives 

differ in that alternative C imposes strict limitations on herbicide application and alternative D, while 

similar to alternative B, would not provide for application of aminopyralid. Alternative C would eliminate 

broadcast spraying, eliminate picloram, prohibit herbicide application in Riparian Habitat Conservation 

Areas, i.e. including the Wild and Scenic River corridors, and establish herbicide free buffers of 100 feet 

from creeks, lakes, ponds, and wetlands.

Wilderness Areas

Invasive species would continue to be pulled by hand or hand tools where practical. Cultural, mechanical 

and motorized control methods would not be utilized in Wilderness areas. Herbicide application would be 

used in accord with the pdf prescribed using non-motorized methods such as spot spraying with backpack 

or mule packed application equipment.

Infestations that would impact wilderness character and values would be evaluated for treatment and if 

suitable given a high priority for treatment. New sites would be evaluated for suitable treatment(s) using 

the EDRR process. In order to conduct treatments other than hand pulling a minimum decision analysis 

would be conducted and documented.

The use of herbicides in Wilderness Areas may reduce the wilderness experience for some users in the 

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

purpose and need for invasive plant treatment is not driven primarily by convenience or administrative 

cost. In addition Invasive plants have an adverse effect by disrupting natural processes. Invasive species 

may alter native plant communities and have indirect effects with wildlife species that rely on the native 

plant communities. Invasive species may also alter fire regimes that may ultimately alter wilderness 

ecological processes.

By utilizing the appropriate pdf it is anticipated invasive species infestations would be eliminated, 

reduced, and the rate of spread retarded. This would result in recovery or protection of wilderness 

character and values. It is likely that most sites discovered in wilderness in the future would be relatively 

small infestations and the effects of treatment would be minor. The visual impact of the short lived blue 

dye may result in visual impacts to the recreation experience of some visitors. However, these effects 

would be short term and limited to the vicinity of the treated site. Compared with implementing 

alternative B, alternative D is estimated to decrease cost effectiveness; and alternate C is estimated to be 

provide less effective and be less cost effective.

Wild and Scenic Rivers

Infestation sites in the Wild and Scenic River corridors would be treated. Depending on the chosen 

alternative the treatment method would vary among alternative by the method and herbicide used.

Compared with implementing alternative B, alternative D is estimated to decrease cost effectiveness.

Under alternative C no herbicide would be used in the WSR corridor and treatment would consist of hand 

pulling, cultural, and mechanical methods. It is estimated using alternative C would be less effective 

overall in treating infestations.

The use of herbicides in Wild and Scenic Rivers may reduce the ‘wild’ experience for some users in the 

short term especially in the Wild designated corridor, but active treatment provides the best protection of 

the outstanding and remarkable values. Treating Wild and Scenic River infestations would have short 

term adverse effects by introducing human manipulation, but would result in long term beneficial effects 

to wilderness character and values by restoring natural conditions.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

259

By utilizing the appropriate pdf treatment methods it is anticipated invasive species infestations would be 

eliminated, reduced, and the rate of spread retarded. This would result in recovery or protection of Wild 

and Scenic ORVs. It is likely that most sites discovered within the Wild and Scenic River corridors in the 

future would be relatively small infestations and the effects of treatment would be minor. The visual 

impact of the short lived blue dye may result in visual impacts to the recreation experience of some 

visitors. However these effects would be short term and limited to the vicinity of the treated site.

Scenic Areas

Infestation sites in the Scenic Area would be treated by hand pulling, mechanical, motorized (where 

accessible), cultural, and herbicide application. Depending on the chosen alternative the treatment method 

would vary among alternative by the method and herbicide used. Under alternative C no herbicide would 

be used in RHCAs and treatment would consist of hand pulling, cultural, and mechanical methods. It is 

estimated using alternatives C and D would be less effective overall in treating infestations due to the 

limitations on herbicide type and allowed use.

By utilizing the appropriate pdf treatment methods it is anticipated invasive species infestations would be 

eliminated, reduced, and the rate of spread retarded. This would result in recovery or protection of the 

outstanding natural esthetics of the Scenic Area. It is likely that most sites discovered within the Scenic 

Area in the future would be relatively small infestations and the effects of treatment would be minor. The 

visual impact of the short lived blue dye may result in visual impacts to the recreation experience of some 

visitors. However these effects would be short term and limited to the vicinity of the treated site.

ROS Semi-Primitive Non-Motorized (SPMN) and Inventoried Roadless IRAs

Infestation sites in the SPMN and IRA areas would be treated by hand pulling, mechanical, motorized 

(where accessible), cultural, and herbicide application. Depending on the chosen alternative the treatment 

method would vary among alternative by the method and herbicide used. Under alternative C no herbicide 

would be used in RHCAs and treatment would consist of hand pulling, cultural, and mechanical methods.

It is estimated using alternative C and D would be less effective overall in treating infestations due to the 

limitations on herbicide type and allowed use.

By utilizing the appropriate pdf treatment methods it is anticipated invasive species infestations would be 

eliminated, reduced, and the rate of spread retarded. This would result in recovery or protection of the 

native biological and botanical environments. It is likely that most sites discovered within the SPNM and 

IRA areas in the future would be relatively small infestations and the effects of treatment would be minor.

The visual impact of the short lived blue dye may result in visual impacts to the recreation experience of 

some visitors. However these effects would be short term and limited to the vicinity of the treated site.

Recreation Sites

Infestation sites in and near recreation sites would be treated by hand pulling, mechanical, motorized 

(where accessible), cultural, and herbicide application. Depending on the chosen alternative the treatment 

method would vary among alternative by the method and herbicide used. Under alternative C no herbicide 

would be used in RHCAs and treatment would consist of hand pulling, cultural, and mechanical methods.

It is estimated using alternative C and D would be less effective overall in treating infestations due to the 

limitations on herbicide type and allowed use.

By utilizing the appropriate pdf treatment methods it is anticipated invasive species infestations would be 

eliminated, reduced, and the rate of spread retarded. This would result in recovery or protection of the

scenic and natural appearing forest character. It is likely that most sites discovered within and near the 

recreation sites in the future would be relatively small infestations and the effects of treatment would be 

minor. The visual impact of the short lived blue dye may result in visual impacts to the recreation 

experience of some visitors. However these effects would be short term and limited to the vicinity of the 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

260

treated site. Recreation sites undergoing treatment would be marked and forest visitors would be 

discouraged from recreating in the vicinity of sites recently treated and may choose to relocate to 

alternative recreation sites. However this effect would be of short duration.

Dispersed Recreation

Infestation sites in and near dispersed recreation sites would be treated by hand pulling, mechanical, 

motorized (where accessible), cultural, and herbicide application. Depending on the chosen alternative the 

treatment method would vary among alternative by the method and herbicide used. Under alternative C 

no herbicide would be used in RHCAs and treatment would consist of hand pulling, cultural, and 

mechanical methods. It is estimated using alternative C and D would be less effective overall in treating 

infestations due to the limitations on herbicide type and allowed use.

Dispersed recreation occurs throughout the Malheur National Forest. Dispersed recreation includes a wide 

variety of activities including hunting, fishing driving for pleasure, firewood cutting, horseback packing 

and riding, road and mountain biking, camping, picnicking, wild plant collecting (mushrooms, camas, 

ferns, and etc.), and OHV riding. Dispersed recreation most likely will occur in all of the treatment areas 

to some extent. By utilizing the appropriate pdf treatment methods it is anticipated invasive species 

infestations would be eliminated, reduced, and the rate of spread retarded. This would result in recovery 

or protection of the scenic and natural appearing forest character. It is likely that most sites discovered 

within and near dispersed recreation sites in the future would be relatively small infestations and the 

effects of treatment would be minor. The visual impact of the short lived blue dye may result in visual 

impacts to the recreation experience of some visitors. However these effects would be short term and 

limited to the vicinity of the treated site. Dispersed recreation sites undergoing treatment would be 

temporarily marked and forest visitors would be discouraged from recreating in the vicinity of sites 

recently treated and consequently may choose to relocate to alternative recreation sites. However this 

effect would be of short duration.

Cumulative Effects

There are some foreseeable projects in recreation special uses that most likely will have additional 

invasive species effects. In 2011 the Forest completed implementation of the 2007 revised Outfitter-Guide 

policy. It is likely the Malheur National Forest will issue a minor number of special use permits for 

providing recreation services on Forest lands. The public has expressed interest or obtained temporary 

special permits in the recent past in obtaining special use permits for such activities as back packing trips 

in the Wilderness areas, ice climbing, road biking tourism, mountain biking tours, hunting, and horse day 

rides. As with current recreational activities, these additional services have the potential to act as invasive 

species infestation vectors.

It is also likely the Malheur National Forest will implement the 2005 Travel Management Rule in the 

foreseeable future. Two likely effects of addressing former Chief Bosworth’s four threats including 

“unmanaged recreation” (http://www.fs.fed.us/projects/four-threats/) are an increased use of OHVs on 

some Forest System roads and a dramatic reduction in cross country OHV use. It is likely any increased 

recreation use on roads will commensurately increase the likelihood of invasive species infestations.

However, eliminating uncontrolled cross country travel is anticipated to significantly reduce the risk of 

invasive species infestations along closed roads and in the general forest area (GFA) no longer accessible 

to unmanaged OHV travel.

Because the effects of invasive plant treatments on recreation and scenic resources are minimal, limited, 

localized, and short-term, there is very little chance the effects would accumulate with effects brought on 

by past, present or future management activities. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

261

3.10 Archeological Resources

3.10.1 Introduction

This section focuses on archaeological resources 

The USDA Forest Service Advisory Council on Historic Preservation (ACHP) and the Oregon State 

Historic Preservation Office (SHPO), have a 2004 programmatic agreement addressing the management 

of cultural resources on national forests in the State of Oregon. There are several actions that were 

determined to have no potential to affect historic properties (appendix C). Examples of these actions 

include invasive plant species eradication through the application of herbicides and hand removal 

(including hand tools such as shovels to dig up roots); recurrent brushing (hand, machine, chipping) 

activities to control vegetation within clearing limits of existing roads, trails, parking lots, and power line

corridors; mulching and re-vegetating bare, erosion-prone surfaces such as cuts and fills; and reintroduction of endemic or native floral species into their historic habitats.

Specific treatments that would be classified as actions with no potential to affect cultural resources, and 

therefore subject to Forest Specialist approval, on behalf of SHPO, include the following:

♦ Herbicide Application Methods (selective/hand, spot, and broadcast spray)

♦ Cultural Methods limited to stock grazing

♦ Manual/Mechanical Methods (mowing, weed whipping, and hand pulling)

♦ Manual/Mechanical Methods (grubbing and wrenching) in areas that occur on landslides, flood 

deposits, previously surveyed areas where no archaeological sites occur, skid trails, landings, and 

road cuts and fill.

3.10.2 Affected Environment

The Malheur National Forest lies at the interface between the Columbia Plateau and Great Basin Culture 

Areas, and has been used by native peoples for thousands of years. To date, more than 5,000 

archaeological sites have been identified within the Forest. Site-specific information regarding 

archaeological, historical, and traditional cultural resources is not presented in this document. The 

potential for impact is minor and short term to non-existent so site-specific archaeological information is 

not needed to make an informed decision. Comprehensive Archaeological Resource information is on file 

at the Malheur National Forest Headquarters in John Day, Oregon. 

3.10.3 Environmental Consequences

Introduction

Effects to archaeological resources are assessed for each treatment method: manual, mechanical, cultural, 

and herbicide. Most of the proposed treatment areas have been previously disturbed by present day human 

activities such road construction and use (shoulders, cuts and fills). Archaeological sites are sometimes 

bisected by high use areas such as road and thus could overlap invasive plant infestations. Geographic 

areas proposed for treatment include roadsides, quarries, administrative sites, campgrounds, parking 

areas, artificial clearings, meadows, and forested areas. Archaeological resources may occur in all of these 

locations although they may not be affected by the project, depending on the ground-disturbing potential 

of the action.
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

262

Alternative A – No Action

No action means that no treatments would take place and thus, no direct, indirect or cumulative impacts 

on archaeological resources would occur.

Action Alternatives

Most of the treatment methods are not ground disturbing and therefore would have no direct or indirect 

effect on archaeological (cultural) resources. The sole exception may be weed wrenching and grubbing, 

manual techniques that have potential to disturb archaeological resources to a minor degree.

Should any action alternative be implemented, project design features would minimize or eliminate 

potential impacts, which are already of a minor nature. If weed wrenching and grubbing with a shovel is 

planned in areas that are outside landslides, flood deposits, previously surveyed areas, skid trails, 

landings, road shoulders, cut and fills, the Forest Service archaeologist would have an opportunity to 

review treatment locations to determine if archaeological resources could be affected. Weed wrenching 

and grubbing techniques will not be used in known archaeological sites. Alternative treatment methods 

will be selected from those that would have low potential to affect archaeological resources. With 

application of the pdf, no significant direct or indirect adverse effects to archaeological resources are 

anticipated, and no contribution to cumulative adverse effects would occur.

Tribal Consultation and Treaty Rights

The Forest Service has communicated by letter with three affected tribes: The Confederated Tribes of the 

Warm Springs, the Confederated Tribes of the Umatilla Indian Reservation, and the Burns Paiute Tribe.

The Forest Service outlined the project details and potential effects to archaeological resources.

The Warm Springs and Umatilla tribes signed treaties with the federal government in 1855 and later 

ratified by Congress. These treaties ceded to the United States legal title to millions of acres of land, and 

reserved and guaranteed certain rights exercised by Indian people to fishing, hunting, gathering roots and 

berries, and other activities. An 1868 treaty with the Burns Paiute Tribe was never ratified by Congress.

Executive Order 12898 directs federal agencies to consider patterns of subsistence hunting and fishing if 

an action will affect fish and wildlife. Under the proposed action, no adverse effects to treaty fishing sites, 

traditional cultural plant gathering areas, traditional plants, or subsistence related activities would occur.

The risk associated with direct herbicide contact and with ingesting contaminated fish, berries, or other 

plants is discussed in Section 3.2 Human Health. Given the types of treatments considered and the project 

design features (pdf), no direct, indirect, or cumulative adverse effects on tribal or treaty rights would 

occur.

3.11 Specifically Required Disclosures

3.11 1 Irreversible or Irretrievable Impacts

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

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

accordance with the alternatives would have relatively short-lived impacts; effects on non-target species 

would be minimized; such effects would not be permanent. No adverse impacts on roadless areas or 

degradation of roadless area quality would occur. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 3

263

3.11.2 Long-term Productivity

Soils would be protected in this project and no loss of long-term productivity is predicted. The no-action 

alternative could have negative impacts on long-term productivity if invasive plants become so dense as 

to change soil characteristics, and capacity for restoration to desirable plant communities is lost. 

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

design feature (pdfs) that reduce or eliminate the potential for adverse effects. However, some adverse 

effects are inherent to invasive plant treatments and cannot be avoided. These include:

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

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

large herbicide spill. The pdfs make the potential for a large spill extremely unlikely.

♦ Minor to moderate physical injuries during forestry work are possible.

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

to certain herbicides. However, the pdfs address the potential for long-term impact to soil 

organisms or productivity. 

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

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

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

potential for adverse effects of treatment.

3.11.3 Energy Requirements and Conservation Potential

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

3.11.4 Non-significant Land and Resource Management Plan (LRMP) 

Amendment

An amendment to the Malheur National Forest LRMP is proposed in Alternatives B and C in order to 

allow the use of aminopyralid. This is a non-significant amendment based on the National Forest 

Management Act implementing regulation. It would add one word to the existing standard 16 from the R6 

2005 ROD that approved use of ten other herbicides. The risk assessment for aminopyralid was 

completed after a decision was made on the R6 2005 ROD. 

The Forest Service Land and Resource Management Planning Manual (Forest Service Manual 1926.51) 

lists the changes to the land management plan that are not significant can result from: 

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

resource management. 

2. Adjustments of management area boundaries or management prescriptions resulting from further onsite analysis when the adjustments do not cause significant changes in the multiple-use goals and 

objectives for long-term land and resource management. 

3. Minor changes in standards and guidelines 

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

management prescription. 

Multiple Use Goals and Objectives

The proposed LRMP amendment does not affect multiple use goals and objectives and is intended to help 

the Forest Service achieve these goals on the Malheur National Forest. 
Chapter 3 – Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

264

Management Areas 

The proposed amendment does not affect the boundaries or management direction for any management 

areas outlined in the LRMP. 

Standards and Guidelines

The proposed LRMP amendment would approve us of an herbicide, aminopyralid, that is not currently 

listed among the ten approved by the Regional Forester in 2005 (R6 2005 ROD). The Risk Assessment 

(SERA 2007) for aminopyralid demonstrates that use of this herbicide would not pose new or significant 

risks compared to the ten already approved. Table 18 (chapter 3.2) shows a comparison between 

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

the proposed use would pose additional risks to human health or the environment. 

Additional Project Opportunities

The proposed LRMP amendment would allow more effective and efficient treatment of invasive plants by 

adding aminopyralid, an herbicide that is very effective most of the invasive species found in the project 

area. It was developed specifically for wildland use and is effective at low rates. It requires less 

restrictions than most of the other herbicides already approved in the LRMP (for instance it can be 

broadcast sprayed to the water’s edge, which would improve treatment effectiveness and efficiency 

relative to other herbicides). 

Regardless of whether or not a non-significant amendment is approved, all alternatives would follow the 

management direction in the Malheur National Forest LRMP and comply with the National Forest 

Management Act. 

3.11.5 Floodplains and Wetlands

Floodplains and wetlands would not be adversely affected by this project. As discussed in chapters 3.4, 

adverse effects to water quality and the beneficial uses of water would be negligible. The extent of 

treatment and potential for water contamination is low, and all alternatives are designed to protect water 

resources on the Malheur National Forest. 

3.11.6 Prime Farmlands

No prime farmlands would be adversely affected by this project. There could be a beneficial impact to the 

extent that the alternatives reduce the potential for invasive plant spread from the Malheur National Forest 

to prime farmlands. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

265

Chapter 4. Consultation and Coordination

List of Preparers and Consultation

Archer, Vince – Soils Scientist

Bautista, Shawna – Pesticide Use Coordinator; Herbicide Toxicology Analyst

Brooks, Paula J – Botanist

Carsey, Kathy S – Invasive Plant Specialist; Range Specialist 

Desser, Rochelle - Interdisciplinary Team Leader; Treatment Cost-effectiveness Analyst

Laliberte, John - Engineer

McClure, Rick – Archaeologist

Mease, Christopher S – Fisheries Biologist

Moser, Eric - Hydrologist

Rausch, Joseph H – Invasive Plant Program Manager

Reitz, Scott – Wildlife Biologist

Schultz, Janice N – Writer/Editor

St. John, Rob – Recreation Specialist

A variety of specialists and managers from the Malheur National Forest and the Pacific Northwest 

Regional Office contributed information and reviewed an internal draft of the Draft Environmental 

Impact Statement. Local invasive plant management information was obtained from Oregon State 

Department of Agriculture and local county invasive plant management staff. Consultation is ongoing 

with Native American Indian tribes including the Confederated Tribes of the Warm Springs, the 

Confederated Tribes of the Umatilla Indian Reservation, and the Burns Paiute Tribe; the United States 

Fish and Wildlife Service; and the National Marine Fisheries Service. Several individuals and interest 

groups submitted comments during scoping periods in 2006 and 2011 (see chapter 1).

List of People to Whom This EIS has been Sent

Agencies and members of the public expressing interest in the project all received notice that the Draft 

EIS is available on request and on the web 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=35614 for comment. Hard copies or CD-ROM 

versions of the document were mailed directly to:

Individuals

B. Sachau

M. Greg Smith

Matt Carter

Walt Gentis

Dick Artley

John D. George
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

266

Organizations, Industry, and Local Agencies

Executive Director Northwest Coalition for Alternatives to Pesticides

Doug Heiken Oregon Wild

Kristin Ruether Oregon Natural Desert Association

Phil Turrell Rocky Mountain Elk Foundation, Harney County Chapter

Harold Shepard Center for Tribal Water Advocacy

Oregon Eastside Forest Committee Juniper Group Sierra Club

Dan Bishop Prairie Wood Products

John Day, Snake Resource Advisory Committee

Karen Coulter League of Wilderness Defenders, Blue Mountains Biodiversity 

Project

Jason Kehrberg Grant Soil and Water Conservation District

Oregon State Agencies

Oregon Department of Fish and Wildlife

Tribal Contacts

Honorable Les Minthorn Confederated Tribes of the Umatilla Indian Reservation

Honorable Diane Teeman Burns Paiute Tribe

Honorable Ron Suppah Confederated Tribes of Warm Springs

Honorable Stanley ‘Buck’ Smith Confederated Tribes of Warm Springs

Federal Agencies

Director, Planning and Review Advisory Council on Historic Preservation

Acquisitions and Serials Branch National Agriculture Library

Chief of Naval Operations (N45) Energy and Environmental Readiness Division

Northwest Power Planning Council

Deputy Director APHIS PPD/EAD

Habitat Conservation Division, NOAA Fisheries Service NW Region

U.S. Environmental Protection Agency, Region 10, EIS Review Coordinator

U.S. Coast Guard, Commandant CG-47, Department of Homeland Security

Director, NEPA Policy and Compliance, Department of Energy

U.S. Fish and Wildlife Service

Local Officials

Judge Steve Grasty Harney County Court

Judge Scott Meyers Grant County Court
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

267

References

Allison, S.D. and P.M. Vitousek. 2004 Rapid nutrient cycling in leaf litter from invasive plants in Hawaii. 

Oceologia 141:612-619.

Altman, B. 2000. Conservation strategy for landbirds in the northern Rocky Mountains of eastern Oregon 

and Washington. Version 1.0. May. Oregon-Washington Partners in Flight. 121pp.

Altman, R and A Holmes 2000. Conservation Strategies for Landbirds in the Columbia Plateau of Eastern 

Oregon and Washington. 131 pp. 

Anderson, J.J. and J.J. Dulka. 1985. Environmental fate of sulfometuron methyl in aerobic soils. J. Agric. 

Food Chem. 33: 596-602

Archer, A. J. 2001. Taeniatherum caput-medusae [Online]. Available: http://www.fs.fed.us/database/feis. 

[Accessed Aug 11, 2003].

Arora, David. 1986. Mushrooms Demystified. A comprehensive guide to the fleshy fungi. Second edition. 

Ten speed press, 1986.

Asher , J. 2000. War on weeds: winnig it for wildlife. Paper presented at North American Wildlife and 

Naturall Resources conference. Rosemont, Illinois. March 27. 17 pp. 

Aubry, K.B., G.M. Koehler, J.R. Squires. 2000. Ecology of Canada lynx in southern boreal forests. Pages 

373-369. In Ruggiero, Leonard F.; Aubry, Keith B.; Buskirk, Steven W.; Koehler, Gary M.; 

Krebs, Charles J.; McKelvey, Kevin S.; Squires, John R. 1999. Ecology and conservation of lynx 

in the United States. General Technical Report RMRS-GTR-30WWW. Fort Collins, CO: United 

States Department of Agriculture, Forest Service, Rocky Mountain Research Station. Available at: 

http://www.fs.fed.us/rm/pubs/rmrs_gtr030.html

Audobon 2013. White-headed Woodpecker. Available at: http://www.audubon.org/. Accessed 5/23/2013.

Bakke, D. 2001. A Review and Assessment of the Results of Water Monitoring for Herbicide Residues for 

the Years 1991 to 1999, Unpublished report by the Forest Service Pacific Southwest Regional 

Pesticide Use Specialist. 

Bakke, David. 2002. Analysis of issues surrounding the use of spray adjuvants with herbicides. 

Unpublished report by the Forest Service Pacific Southwest Regional Pesticide Use Specialist. 

Bakke, David. 2003. Human and Ecological Risk Assessment of Nonylphenol Polyethoxylate-based 

(NPE) Surfactants in Forest Service Herbicide Applications. Unpublished report by the Forest 

Service Pacific Southwest Regional Pesticide Use Specialist. 

Banci, V.A. 1994. Fisher (Pages 44 and 47) and Wolverine (Pages 99-127). In L.F. Ruggiero, K.B. Aubry, 

S.W. Buskirk, L.J. Lyon, and W.J. Zielinski, eds. 1994. The scientific basis for conserving forest 

carnivores, American marten, fisher, lynx and wolverine in the western United States. United 

States Department of Agriculture For. Serv. Rocky Mt. For. and Range Exp. Stn., Gen. Tech. Rep. 

RM-254, Fort Collins, CO.

Barrows, C. W. 1996. Tamarisk control and common sense. In: Proceedings of the California Exotic Pest 

Plant Council; October 4-6; San Diego, CA. 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

268

Bashkin, M., T.J. Stohlgren, Y. Otsuki, m. Lee, P. Evangelista, and J. Belnap. 2003. Soil characteristics 

and plant exotic species invasions in the Grand Staircase-Escalante national Monument, Utah, 

USA. Applied Soil Ecology. 22(1): 67-77

Bautista, S. 2008. Climate Change and Invasive Plants: Information for PNW Invasive Plant NEPA. 

Unpublished report.

Bautista, S.L., and S.P. Bulkin. 2008. Herbicide Information Summary and Project Design Criteria 

Crosswalk. Forest Service Unpublished Internal Report. United States Department of Agriculture 

Forest Service, Region 6. Portland, OR. 36p.

Beck. 2008. Diffuse and Spotted Knapweed. Colorado State Extension Service. Fact Sheet 3.111.

Bedunah, D.; Carpenter, J. 1989. Plant community response following spotted knapweed (Centaurea 

maculosa) control on three elk winter ranges in western Montana. 1998 Knapweed Symposium; 

Bozeman, MT.: Plant & Soil Department and Extension Service, Montana State University.

Benefield, C.B., J. DiTomaso, G.B. Kyser, S. Orloff, K.R. Churches, D.B. Marcum and G.A. Nader. 1999. 

Success of mowing to control yellow starthistle depends on timing and plant’s branching form. 

California Agriculture 53:17-21. Available online at: 

http://californiaagriculture.ucanr.org/landingpage.cfm?article=ca.v053n02p17&fulltext=yes

Berg, N. 2004. Unpublished. Assessment of Herbicide Best Management Practices: Status of Our 

Knowledge of BMP Effectiveness. Pacific Southwest Research Station, United States Department 

of Agriculture Forest Service, Albany CA.

Berrill, M., S., Bertram, and B., Pauli. 1997. Effects of Pesticides on Amphibian Embryos and Larvae. 

Herpetological Conservation 1: p.233-45.

Berrill, M., S., Bertram, L., McGillivray, M., Kolohon, and B., Pauli . 1994. Effects of low concentrations 

of forest-use pesticides on frog embryos and tadpoles. Environmental Toxicology and Chemistry 

13(4): p.657-64. 

Blossey, B. 1999. Before, during, and after: the need for long-term monitoring in invasive plant species 

management. Biological Invasions 1:301-311. - Deschutes

Blus, L.J., C.S. Staley, C.J. Henny, G.W. Pendleton, T.H. Craig, E.H. Craig, and K.K. Halford. 1989. 

Effects of organophosphorus insecticides on sage grouse in southeastern Idaho. Journal of 

Wildlife Management 53: 1139-1146.

Bollag, J.M., and S.Y. Liu. 1990. Biological Transformation Processes of Pesticides. In Pesticides in the 

Soil Environment. H.H. Cheng. (ed.) Soil Science Society of America book series, no. 2. 

Madison, Wis., USA: Soil Science Society of America. p. 169-211 

Bramble, W.C., R.H. Yahner, and W.R. Byrnes. 1997. Effect of herbicides on butterfly populations of an 

electric transmission right-of-way. Journal of Arboriculture 23(5) 11 pp. 

Braun, C.E. 1987. Current issues in sage grouse management. Proceedings of the Western 

Association of Fish and Wildlife Agencies 67: 134-144.

Braun, C.E. 1998. Sage grouse declines in western North America: what are the problems? 

Proceedings of the Western Association of Fish and Wildlife Agencies 78: 139-156.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

269

Bridges, C.M. & Semlitsch, R.D. (2000) Variation in pesticide tolerance of tadpoles among and within 

species of Ranidae and patterns of amphibian decline. Conservation Biology 14: 1490-1499. 

Bridsall, J.L., W. McCaughey and J.B. Runyon. 2011. Roads impact the duistribution of noxious weeds 

more than restoration treatments in a lodgepole pine forest in Montana, United StatesA. 

Restoration Ecology: 1-7.

Brooks, H.C. 1979. Plate Tectonics and Geologic History of Blue Mountains. Oregon Geology, Volume 

41, Number 5.

Brotherson, J. D.; Field, D. 1987. Tamarix: impacts of a successful weed. Rangelands. 9: 110-112.

Brown, C.E. and T.P. Thayer. 1966. The Geologic Map of the Canyon City Quadrangle, Oregon. USGS

Miscellaneous Geologic Investigations Map I-447.

Brown, M.L., Duncan, C.A., and Halstvedt, M.B. 2001. Cost and efficacy of spotted knapweed 

management and with integrated methods. Techline (May): p. 2-5.

Bull, E.L. and M.P. Hayes. 2001. Post-breeding season movements of Columbia spotted frogs (Rana 

luteiventris) in northeastern Oregon. Western North American Naturalist 61(1): 119-123. –

Deschutes EIS

Bull, Evelyn L. 1980. Resource partitioning among woodpeckers in northeastern Oregon. Ph.D. 

Dissertation, Univ. Idaho, Moscow. 109 pp. In Mellen-McLean, Kim 2012d. MIS Information 

Sheet. Primary Cavity Nesters/Excavators. 29 pp. 

Bullock, J.M. and R.T. Clarke. 2000. Long distance seed dispersal by wind: measuring and modeling the 

tail of the curve. Oecologia 124:506-521.

Buonopane, M., G. Snider, B.K. Kerns, and P.S. Doescher. 2013. Complex restoration challenges: weeds, 

seeds, and roads in a forested Wildland Urban Interface. Forest Ecology and Management. 295: 

87-96

Busse, M.D., A.W. Ratcliff, C.J. Shestak, and R.F. Powers. 2001. Glyphosate toxicity and the effects of 

long-term vegetation control on soil microbial communities. Soil Biology & Biochemistry (33) 

1777-1789.Callaway, R., G.C. Thelen, A. Rodriguez, and W.E. Holben. 2004. Soil biota and 

exotic plant invasion. Nature. 427: 431-433

Carlson, G. 1974. Malheur National Forest Soil Resource Inventory. Unpublished In-Service Report.

United States Department of Agriculture Forest Service, Pacific Northwest Region, Malheur 

National Forest. John Day, OR. 137p.

Castelle, A.J., A.W. Johnson, and C. Conolly. 1994. Wetland and Stream Buffer Size Requirements—A 

Review. Journal of Environmental Quality 23:878-882

Castelle, A.J., And A.W. Johnson. 2000. Riparian Vegetation Effectiveness. National Council for Air and 

Stream Improvement. Technical Bulletin 799.

Cattle, S. I. Cousin, F. Darboux and Y. Le Bissonnais. The Effect of Soil Crust ageing, Through Wetting 

and Drying, on Some Surface Structural Properties. SuperSoil 2004: 3rd Australian New Zealand 

Soils Conference, 5-9 December 2004, University of Sydney Australia. www.regional 

.org.au/au/asssi/ 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

270

Cerdan, O., V. Souchere, V. Lecomte, A. Couturier, and Y. Le Bissonnais. 2001. Incorporating Soil 

Surface Crusting Process in an Expert-Based Runoff Model: Sealing and Transfer by Runoff and 

Erosion Related to Agricultural Management. Catena 46 189-205. 

Chew, F. S. 1981. Coexistence and local extinction in two Pieris butterflies. American Naturalist. 118: 

655-672.

Clements, J. F., T. S. Schulenberg, M. J. Iliff, B.L. Sullivan, C. L. Wood, and D. Roberson. 2012. The 

eBird/Clements checklist of birds of the world: Version 6.7. Downloaded from 

http://www.birds.cornell.edu/clementschecklist/downloadable-clements-checklist. Accessed 

4/22/2013.

Cole, E.C., W. C. McComb, M. Newton, , C.L. Chambers and J.P. Leeming. 1997. Response of 

amphibians to clearcutting, burning, and glyphosate application in the Oregon Coast Range. 

Journal of Wildlife Management. 61:p.656-64.

Cole, E.C., W. C. McComb, M. Newton, J.P. Leeming, and C.L. Chambers. 1998. Response of small 

mammals to clearcutting, burning, and glyphosate application in the Oregon Coast Range. Journal 

of Wildlife Management. 62(4): p. 1207-16. 

Colorado Weed Management Associations (CWMA) 2007. Diffuse knapweed. 

http://www.cwma.org/nx_plants/diff.htm

Connelly J.W., H.W. Browers, R.J. Gates. 1988. Seasonal movements of sage grouse in southeastern 

Idaho. J. Wildl. Manage. 52:116–122.

Connelly, J. W., JR. 1982. An ecological study of sage grouse in southeastern Idaho. Dissertation, 

Washington State University, Pullman, USA.

Connelly, J. W., M. A. Schroeder, A. R. Sands, C. E. Braun. 2000. Guidelines to manage sage grouse 

populations and their habitats. Wildlife Society Bulletin 28(4): 967-985.

Connelly, J.W. and O.D. Markham. 1983. Movements and radio nuclide concentrations of sage grouse in 

southeastern Idaho. Journal of Wildlife Management 47:169-177.

Connelly, J.W.; M.A. Schroeder; A.R. Sands; and C.E. Braun. 1991. Sage grouse use of nest sites in 

southeastern Idaho. Journal of Wildlife Management 55: 521-524.

Copeland, J.P. 1996. Biology of the Wolverine in Central Idaho. Master’s Thesis. 152 pp. 

Corkran, C. C., and C. R. Thoms. 2006. Amphibians of Oregon, Washington, and British Columbia. Lone 

Pine Publishing, Auburn, WA.

Crawford, J.A.; R.A. Olson; N.E. West; J.C. Mosley; M.A. Schroeder; T.D. Whitson; R.F. Miller; M.A. 

Gregg; and C.S. Boyd. 2004. Ecology and management of sage-grouse and sage-grouse habitat. 

Journal of Range Management 57: 2-19.

Csuti, B., A. J. Kimerling, T. A. O’Neil, M. M. Shaughnessy, E. P. Gaines, and J. C. Hak 2001. Atlas of 

Oregon wildlife: distribution, habitat, and natural history. Oregon State University Press, 

Corvallis, OR. 492 pp.

Dabbert, C.B., R.B. Mitchell, and D. Oberheu. 1997. Northern bobwhite egg hatchability and chick 

immunocompetence following field application of clopyralid. Bulletin of Environmental 

Contamination and Toxicology. 58: 801-806
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

271

Daly, M. Halbleib, J.I. Smith, W.P. Gibson, M.K. Doggett, G.H. Taylor, J. Curtis, and P.P. Pasteris. 2008. 

Physiographically sensitive mapping of climatological temperature and precipitation across the 

conterminous United States. International Journal of Climatology. 34p.

D'Antonio, C. M.; Vitousek, P. 1992. Biological invasions by exotic grasses, the grass/fire cycle, and 

global change. Annual Review of Ecological Systems. 23: 63-87.

Dassonville, N., S. Vanderhoeven, V. Vanparys, M. Hayez, W. Gruber, and P. Meerts. 2008. Impacts of 

alien invasive plants on soil nutrients are correlated with initial site conditions in NW Europe. 

Oecologia. 157(1) : 131-140

Davidson, E.A., E. Belk, and R.D. Boone. 1998. Soil water content and temperature as independent or 

confounded factors controlling soil respiration in a temperate mixed hardwood forest. Global 

Change Biology. 4: 217-227.

Dechant, J.A., M.F. Dinkins, D.H. Johnson, L.D. Igl, C.M. Goldade. B.D. Parkin, and B.R. Euliss. 2002b. 

Effects of management practices on grassland birds.: Upland Sandpiper. Northern Prairie Wildlife

Research Center, Jamestown, ND. 34 pp. 

Dechant, J.A., M.L. Sondreal, D.H. Johnson, L.D. Igl, C.M. Goldade, M.P. Nenneman, and B.R. Euliss. 

2002a. Effects of management practices on grassland birds: Grasshopper Sparrow. Northern 

Prairie Wild Research Center, Jamestown, ND. 28 pp. 

Dechant, J.A., M.L.Sondreal, D.H.Johnson, L.D.Igl, C.M. Goldae, A.L. Zimmerman, and B.R. Euliss. 

1999. (revised 2001). Effects of management practices on grassland birds: Bobolink. Northern 

Prairie Wildlife Research Center, Jamestown, ND 24 pp. 

Deixis MolluscDB database. 2009. Unpublished collection of mollusk records maintained by Ed 

Johannes. In United States Department of Agriculture Forest Service. 2013. Species Fact Sheet. 

Harney Basin Duskysnail (Colligurus depressus). 17 pp. 

Desser, Rochelle. 2007. Rationale for 80% annual effectiveness estimate in cost analysis for invasive 

plant projects. Unpublished report by the R6 Invasive Plant NEPA and Monitoring Coordintaor. 

Desser, Rochelle. 2008. Source and Effectiveness of Project Design Features/Criteria for Herbicide Use in 

Invasive Plant Treatment Projects Forest Service Region Six

Desser, Rochelle. 2012. Declaration NRS-#934106-v2-Desser for Case No. CV-10-1397-SI

DiTomaso 2001 – herbicide tolerant plant species selection – add to “repeated spraying discussion

DiTomaso, J.M. 1999. Prescribed burning for control of yellow starthistle (Centaurea solstitialis) and 

enhanced native plant diversity. Weed Science 47: 233 – 242.

DiTomaso, J.M. 2000. Invasive plants in rangelands: Species, impacts, and management. Weed Science 

48: 255-265. 

Dixon, R. D. and V. A. Saab. 2000. Black-backed woodpeckers. In The birds of North America. ed. Poole, 

A. and F. Gill, Cornell, New York: Cornell Laboratory of Ornithology and the Academy of 

Natural Science.

Dooley, S. and J. Beckstead. 2010. Characterizing the interaction between a fungal seed pathogen and a 

deleterious rhizobacterium for biological control of cheatgrass, Biological Control. 53: 197-203
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

272

Dudley, T. L. 2000. Noxious wildland weeds of California: Arundo Donax. In: Bossard, C. C.; Randall, J. 

M.; Hoshousky, M. C., eds. Invasive plants of California wildlands. Berkeley, CA: Univ. of 

California Press: 53-58.

Durkin and Durkin, 2005. A Note on Plausible Initial Pesticide Residues on Selected Mushrooms: Hen of 

the Wood, Shiitake, and Portabello. Unpublished Internal Forest Service review of residues on 

mushrooms and associated health risks.

Ehrenfeld, J.G. 2003. Effects of exotic plant invasions on soil nutrient cycling processes. Ecosystems 6: 

503-523.

Ehrenfeld, J.G., P. Kourtev, and W. Huang. 2001. Changes in soil functions following invasions of exotic 

understory plants in deciduous forests. Ecological Applications 11(5) 1287-1300.

Ehrenfield, J.G. 2003. Effects of exotic plant invasions on soil nutrient cycling processes. Ecosystems. 6: 

503-521Eviner and Firestone 2007

Elliot, W.J. 2004. WEPP internet interfaces for forest erosion prediction. Journal of the American Water

Erickson 2006. Personal communication, effectiveness of manual and mechanical treatments on the 

Umatilla National Forest

Erickson, Vicky, Scott Wood and Jean A Riley. 2003. Draft Guidelines for Revegetation of Invasive plant 

Sites and Other Disturbed Areas on National Forests and Grasslands in the Pacific Northwest. 

Unpublished internal Forest Service document.

Esteves, M. X. Faucher, S. Galle, and M. Vauclin. 2000. Overland Flow and Infiltration Modeling for 

Small Plots During Unsteady Rain: Numerical Results Versus Observed Values. Journal of 

Hydrology 228 265-282.Fischer, R.A., and J.C. Fischenich, 2000. Design recommendations for 

riparian corridors and vegetated buffer strips. United States Army Engineer Research and Design 

Center. ERDC-TN-EMRRP-SR-24.

Fagerstone, K.A., H.P. Tietjen, and G..K. LaVoie. 1977. Effects of range treatment with 2,4-D on prairie 

dog diet. Journal of Range Management 30(1): 57-60.

Fieldler, C.E., E.K. Dodson, and K.L. Metlen. 2010. Invasive plant response to forest disturbance in the 

western United States. In: S. Jose and H.P. Singh, eds. Invasive Plant Ecology CRC Press, Boca 

Raton, FL. In review.

Fischer, R.A., and J.C. Fischenich, 2000. Design recommendations for riparian corridors and vegetated 

buffer strips. United States Army Engineer Research and Design Center. ERDC-TN-EMRRP-SR24.

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA foodchain (Kenaga) nomogram, and instrument for estimating pesticide residue on plants. Environ. 

Toxicol. And Chemistry 13(9):p.1383-91.

Flory, S.L., and K. Clay. 2009. Effects of roads and forest successional age on experimental plant 

invasions. Biological Conservation. 142: 2531-2537

Ganapathy, C. 1997. Environmental Fate of Triclopyr. Environmental Monitoring and Pest Management 

Branch, Department of Pesticide Regulation, Sacramento California. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

273

Gelbard, J.L. and J. Belnap. 2003. Roads as conduits for exotic plant invasions in a semiarid landscape. 

Conservation Biology 17: 420-432.

Germaine, S. S.; Rosenstock, S. S.; Schweinsburg, R. E; Richardson, W. S. August 1998. Relationships 

among breeding birds, habitat, and residential development in greater Tucson, Arizona. 

Ecological Applications. 8(3): 680-691.

Greene, R.C., G.W. Walker, and R.E. Corcoran. 1972. The Geologic Map of the Burns Quadrangle, 

Oregon. USGS Miscellaneous Geologic Investigations Map I-680.

Grismer, M.E., and M.P. Hogan. 2005. Simulated rainfall evaluation of revegetation /mulch erosion 

control in the lake tahoe basin: 2. Bare soil assessment. Land Degradation & Development. 16: 

397-404

Gundale, M.J., S. Sutherland, and T.H. DeLuca. 2008. Fire, native species, and soil resource interactions 

influence the spatio-temporal invasion pattern of Bromus tectorum. Ecography. 31: 201-210

Guo, D., P. Mou, R.H. Jones, and R.J. Mitchell. 2004. Spatio-temporal patterns of soil available nutreints 

following experimental disturbance in a pine forest. Oecologia. 138: 613-621

Hansen, M.J. and A.P. Clevenger. 2005. The influence of disturbance and habitat on the presence of nonnative plant species along transport corridors. Biological Conservation 125:249-259.

Hanula, J.L. and S. Horn. 2011. Removing an exotic shrub from riparian forests increases butterfly 

abundance and diversity. Forest Ecology and Management 262:674-680. 

Hart, S. C., T. H. DeLuca, G. S. Newman, M. D. MacKenzie, and S. Boyle. 2005. Post-fire vegetative 

dynamics as drivers of microbial community structure and function in forest soils. Forest Ecology 

Manual. 230: 166-184

Hatler, D.F. 1989. A Wolverine Management Strategy for British Columbia. Wildlife Bulletin No. B-60. 

May 1989. Prepared for Ministry of Environment. 140 pp. 

Hawkes, C.V., I.F. Wren, D.J. Herman, and M.K. Firestone. 2005. Plant invasion alters nitrogen cycling 

by modifying the soil nitrifying community. Ecology Letters. 8: 976-985

Hayes, Marc, J.D. Engler, , R.D. Haycock, D.H. Knopp, W.P. Leonard, K.R. McAllister, and L.L. Todd. 

1997. Status of the Oregon spotted frog (Rana pretiosa) across its geographical range. In The 

Spotted Frog of Oregon. Oregon Chapter of The Wildlife Society, Corvallis, OR. August 15.

Heady, L.T. and J.W. Laundre 2005. Habitat use patterns within the home range of pygmy rabbits 

(Brachylagus idahoensis) in southeastern Idaho. North American Naturalist, Vol. 65, No. 4. pp. 

490-500.

Henny, C.J., W.S. Seegar, and T.L. Maechtle. 1996. DDT decreases inplasma of spring migrant peregrine 

falcons, 1978-1994. J. Wildl. Manage. 60: 342-349. 

Holmes, A.L. and R.F. Miller 2010. State and Transition Models for Accessing Grasshopper Sparrow

Habitat Use. Journal of Wildlife Management. 74(8): 1834-1840. 

Hornocker, Maurine G. and Howard S. Hash. 1981. Ecology of the wolverine in northwestern Montana. 

Canadian Journal of Zoology 59, (September 1980): 1286-1301.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

274

Horton, J. S. 1977. The development and perpetuation of the permanent tamarisk type in the phreatophyte 

zone of the southwest. Gen. Tech. Rep. 43. United States Department of Agriculture, Forest 

Service, Rocky Mountain Forestry and Range Experiment Station. p. 124-127.

Houston, A.P.C., S. Visser, and R.A. Lautenschlager. Response of microbial processes and funal 

community structure to vegetation management in mixedwood forest soils. Canadian Journal of 

Botany. 76: 2002-2010

Hutto, Richard L. 1995. Composition of bird communities following stand-replacement fires in northern 

Rocky Mountain (United StatesA.) conifer forests. Conservation Biology 9, 1041–58.

Inman, R.M., K.H. Inman, A.J. McCue, and M.L. Packila. 2007. Wolverine harvest in Montana: survival 

rates and spatial considerations for harvest management. Pages 85-96 in Wildlife Conservation 

Society. Greater Yellowstone Wolverine Program, Cumulative Report, May 2007. Ennis, MT.

Jakle, M. D.; Gatz, T. A. 1985. Herpetofaunal use of four habitats of the middle Gila River drainage, 

Arizona. Paper Presented at the North American Riparian Conference; April 16-18, 1985; Tucson, 

AZ. 

James, J.J., B.S. Smith. E.A. Vasquez, and R.L. Sheley. 2010. Principles for ecologically based invasive 

plant management. Invasive Plant Science and Management. 3: 229-239

Janes, S.W. 1983. Status. Distribution, and Habitat Selection of the Grasshopper Sparrow in Morrow 

County, Oregon. The Murrelet, Vol 64, No 2. pp. 51-54.

Janzen, D. 1984. Dispersal of Small Seeds by Big Herbivores: Foliage is the Fruit 

Jepsen, S., LaBar, C., Zarnoch, J. 2010. Gonidea angulata (Lea, 1838) Western ridged mussel Bivalvia: 

Unionidae. Xerces Society for Invertebrate Conservation. 19 pps.

Johnson, D. H., and T. A. O’Neil, Managing Directors. 2001. Wildlife-habitat relationships in Oregon and 

Washington. Oregon State University Press, Corvallis, OR. 736 pp. In Mellen-McLean, Kim 

2012d. MIS Information Sheet. Primary Cavity Nesters/Excavators. 29 pp. 

Johnson, D.R., and Hansen, R.M. 1969. Effects of range treatment with 2,4-D on rodent populations. 

Journal of Wildlife Management 33: 1125-132.

Johnson, M. L. 1995. Reptiles in the state of Washington (1954). Northwest Fauna 3:5-80. The Society of 

Northwestern Vertebrate Biology, Olympia, WA.

Kenaga, E.E. 1973. Factors to be considered in the evaluation of the toxicity of pesticides to birds in their 

environment. In: Environmental Quality and Safety: Global Aspects of Chemistry, Toxicology 

and Technology as Applied to the Environment. Vol. II. New York, NY: George Thieme 

Publishers, Stutgart Academic Press, Inc.

Kiviat, E. 1996. Short communications: American goldfinch nests in purple loosestrife. Wilson Bulletin. 

108(1): 182-186.

Korb, J.E., N.C. Johnson, and W.W. Covington. 2004. Slash pile burning effects on soil biotic and 

chemical protperies and plant establishment: recommendations for amelioration. Restoration

Ecology. 12(1): 52-62

Kulmatiski, A., K.H. Beard, J.R. Stevens, and S.M. Cobbold. 2008. Plant-soil feedbacks: a metaanalytical review. Ecology Letters. 11: 980-992
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

275

Lacey J. R., R. Wallender, and K. Olson-Rutz. 1992. Recovery, germinability, and viability of leafy 

spurge (Euphorbia esula) seeds ingested by sheep and goats. Weed Technol. 6:559–602. 

Lacey, J. R., Olson, B. E. 1991. Environmental and economic impacts of noxious range weeds. In: James, 

L. F.; Evans, J. O.; Ralphs, M. H.; Child, R. D., eds. Noxious range weeds. Boulder, CO: 

Westview Press

Lacey, R.C., C.B. Marlow and J.R. Lane. 1989. Influence of spotted knapweed (Centaurea maculosa) on 

surface runoff and sediment yield. Weed Technology (3) 627-631. 

Lauenroth, W.K., D.G. Milchunas, J.L. Dodd, R.H. Hart, R.K. Heitschmidt, and L.R. Rittenhouse. 1994 . 

Effects of grazing on ecosystems of the Great Plains . Pages 69 - 100 in Vavra, M., W.A. 

Laycock, and R.D. Pieper Editor(s). Ecological implications of livestock herbivory in the West. 

Society for Range Management, Denver, CO.

Laufman, J. 2007. Umatilla National Forest Invasive Plants Treatment Project, Botany Report and 

Biological Evaluation.

Lefcort, H., R. A. Meguire, L. H. Wilson, W. F. Ettinger. 1998. Heavy metals alter the survival, growth, 

metamorphosis, and antipredatory behavior of Columbia spotted frog ( Rana luteiventris) 

tadpoles. Archives of Environmental Contamination and Toxicology 15:447–456.

Lejeune, K. and T. Seastedt (2001). "Centaurea Species: the Forb That Won the West." Conservation 

Biology 15(6): 1568-1574.

Leonard, Jr., David L. 2001. American Three-toed Woodpecker (Picoides dorsalis), The Birds of North 

America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of 

North America Online: http://bna.birds.cornell.edu/bna/species/588doi:10.2173/bna.588

Lloyd, R.A., K.A. Lohse, and TPA Ferré. Influence of road reclamation techniques on forest ecosystem 

recovery. Front. Ecol. Environ. 11(2): 75-81 

Lor, S.K. 2000. Habitat use and population status of marsh birds in western New York. Ithaca, NY: 

Department of Natural Resources, Cornell University. 135 p. Thesis.

Mack, R. N. 1981. Invasion of Bromus tectorum L. into western North America: an ecological chronicle. 

Agro-Ecosystems. 7: 145-165.

Magoun, A.J. and J.P. Copeland. 1998. Characteristics of Wolverine Reproductive Den Sites. Journal of 

Wildlife Management. 62(4): 1313-1320.

Marco, A., C. Quilchano, and A. R. Blaustein. 1999. Sensitivity to nitrate and nitrite in pond breeding 

amphibians from the Pacific Northwest, USA. Environmental Toxicology and Chemistry 

18:2836–2839.

Marrs, R., C. Williams, A. Frost, and R. Plant. 1989. Assessment of the effects of herbicide spray drift on 

a range of plant species of conservation interest. Environmental Pollution. 59: 71-86.

Marshall, D. B., M. G. Hunter, and A. L. Contreras, Eds. 2003. Birds of Oregon: a general reference. 

Oregon State University Press, Corvallis, OR. 768 pp.

Marshall, J.S., and L.W. Vandruff. 2002. Impact of Selective Herbicide Right-of-Way Vegetation on 

Birds. Environmental Management 30(6): p. 801-6.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

276

Maser, Chris; Mate, Bruce R.; Franklin, Jerry F.; Dyrness, C. T. 1981. Natural history of Oregon coast 

mammals. Gen. Tech. Rep. PNW-133. Portland, OR.: United States Department of Agriculture 

Forest Service, Pacific Northwest Range and Experiment Station. 496 p.

Mazzacano, C. 2008. Fisherola nuttalli (Haldeman 1841) Giant Columbia River limpet; shortface lanx 

Gastropoda: Lymnaeidae. Xerces Society for Invertebrate Conservation. 5 pps.

McAdoo, J.K.; S.R. Swanson; B.W. Schultz; and P.F. Brussard. 2004. Vegetation management for 

sagebrush-associated wildlife species. P. 189-193 in United States Department of Agriculture 

Forest Service Proceedings RMRS-P-31. – Deschutes Weed eis

McAllister, K. R., and W. P. Leonard. 1997. Washington state status report for the Oregon Spotted Frog. 

Washington

McGrath, Michael T., Stephen DeStefano, Robert A. Riggs, Larry L. Irwin, and Gary J. Roloff. 2003. 

Spatially explicit influences on northern goshawk nesting habit in the Interior Pacific Northwest. 

Wildlife Monographs 154, 1–63. In Samson, Fred B. 2006a. A conservation assessment of the 

northern goshawk, black-backed woodpeckers, flammulated owl, and pileated woodpecker in the 

Northern Region. United States Department of Agriculture, Forest Service.

McKelvey, K.S., K.B. Aubry, and Y.K. Ortega. 2000 History and distribution of lynx in the contiguous 

United States. Pages 207-264 In Ruggiero, L.F., K.B. Aubry, S.W. Buskirk, G.M. Koehler, C.J. 

Krebs, K.S. McKelvey, and J.R. Squires. (Tech. Eds). 1999. Ecology and conservation lf lynx in 

the United States. Univ. Press of Colorado. Boulder, Co. 480 pp. 

McMurray, S.T., R.L. Lochmiller, J.F. Boggs, D.M. Leslie Jr., Engle and others. 1993a. Woodrat 

Population Dynamics Following Modification of Resource Availability. American Midland 

Naturalist (129): p. 48-56.

McMurray, S.T., R.L. Lochmiller, J.F. Boggs, D.M. Leslie Jr., Engle and others. 1993b. Opportunistic 

Foraging of Eastern Woodrats (Neotoma floridana) in Manipulated Habitats. American Midland 

Naturalist (130): p. 325-37..

Mellen-McLean, Kim 2012c. MIS Information Sheet. American Tree-toed Woodpecker (Picoides 

dorsalis), Three-toed Woodpecker (Picoides tridactylus) and Northern Three-toed Woodpecker 

(Picoides tridactylus dorsalis). 16 pp. 

Mellen-McLean, Kim 2012d. MIS Information Sheet. Primary Cavity Nesters/Excavators. 29 pp. 

Mellen-McLean, Kim, 2012b. MIS Information Sheet. American Marten (Martes Americana). 20 pp. 

Mellen-McLean, Kim. 2012a. MIS Information Sheet. Pileated Woodpecker (Dryocopus pileatus). 18 pp. 

Meyer, N. 2009. Soil and Plant Response to Slash Pile Burning in a Ponderosa Pine Forest. M.S. Thesis, 

Department of Land Resources and Environmental Sciences. Montana State University, MT. 

98pp.

Mills, G.. S.; Dunning Jr., J. B.; Bates, J. M. 1989. Effects of urbanization on breeding bird community 

structure in Southwestern desert habitats. The Condor. (91): 416-28.

Moore, D.C. and M.J. Singer. 1990. Crust Formation on Soil Erosion Processes. Soil Sci. Soc. AM J., 

54:1117-1123.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

277

Morse, R.A. and N.W. Calderone. 2000. The value of honey bees as pollinators of United States crops in 

2000. Bee Culture Magazine 128: 1-14. 

Mosley JC, Bunting SC, Manoukian ME. 1999. Cheatgrass. In: Sheley RL, Petroff JK, editors. Biology 

and Management of Rangeland Weeds. Corvallis (OR): Oregon State University Press. p 175-

188. In: http://www.fws.gov/invasives/stafftrainingmodule/methods/chemical/review.html. 

Accessed 5/26/13

NatureServe Explorer: An online encyclopedia of life [web application]. 2013. Version 1.6. Arlington, 

VA, USA: NatureServe. Available: http://www.natureserve.org/explorer/.

NatureServe. 2013. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. 

NatureServe, Arlington, Virginia. Available http://www.natureserve.org/explorer. (Accessed: May 

29, 2013 ).

Newmaster, S.G., F.W. Bell, and D.H. Vitt. 1999. The effects of glyphosate and triclopyr on common 

bryophytes in northwestern Ontario. Canadian Journal Forest Research 29: 1101-1111.

Nolte, K. R.; Fulbright, T. E. 1997. Plant, small mammal, and avian diversity following control of honey 

mesquite. Journal of Range Management. 50(2): 205-212.

Norton, J.B., T.A. Monaco, and U. Norton. Mediterranean annual grasses in western North America: kids 

in a candy store. Plant Soil. 1-5

Olson, B. E., 1999. Impacts of noxious weeds on ecologic and economic systems. Pages 4-18 in Biology 

and Management of Noxious rangeland weeds. R. L. Sheley and J. K. Petroff (Eds.). Oregon 

State University Press, Corvallis, Oregon.

Olson, B.E. 1999. Impacts of noxious weeds on ecologic and economic systems. In: Sheley, R.L.; Petroff, 

J.K., eds. Biology and management of noxious rangeland weeds. Corvallis, Oregon: Oregon State 

Univ. Press. p. 4-18.

Oregon Biodiversity. 2010. Rare, Threatened and Endangered Species of Oregon. Oregon Biodiversity 

Information Center. October 2010. 109 pp. 

Oregon Department Of Environmental Quality. 2010. Water Pollution. Division 41. Water Quality

Standards: Beneficial Uses, Policies, and Criteria For Oregon. 340-041-0001 to 0350

Oregon Department of Fish and Wildlife. 2005. Oregon Wolf Conservation and Management Plan. 116 

pp. 

Oregon Department of Fish and Wildlife. 2006. Oregon Conservation Strategy. Available at: 

http://www.dfw.state.or.us/conservationstrategy/read_the_strategy.asp. Accessed 4/15/2013.

Oregon Department of Fish and Wildlife. 2009. Richard W. Carmichael. Conservation and Recovery Plan 

for Oregon Steelhead Populations in the Middle Columbia River Steelhead Distinct Population 

Segment 

Oregon Department of Fish and Wildlife. 2013. http://dfw.state.or.us/Wolves/population.asp (Accessed 

04/10/2013)

Oregon State University. 2013. Oregon Explorer. Available at: 

http://oregonexplorer.info/wildlife/ThreatenedandEndangeredSpecies/DecliningandAt-Risk. 

Accessed 4/19/2013.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

278

Ortega, Y.K., D.E. Pearson. 2005. Weak vs. strong invaders of natural plant communities: assessing 

invisibility and impact. Ecological Applications. 15(2): 651-661

Pacific Bioversity Institute. 2013. Columbia clubtail species profile. 

http://www.pacificbio.org/initiatives/ESIN/OtherInvertebrates/LynnsClubtail/LynnsClubtail_pg.ht

ml (Accessed: May 29, 2013 ).

Pagel, J. unpublished data. 2006. Peregrine falcon nest site data, 1983-2006 collected for PNW 

Interagency Peregrine Falcon Program, Ashland OR

Partners in Flight. 2000. Conservation Strategy for Landbirds in the Columbia Plateau of Eastern Oregon 

and Washington. Version 1.0. March 2000. 144 pp. 

Pasitschniak, Arts, M., and S. Larivière. 1995. Gulo gulo, Mammalian Species. Amer. Soc. of 

Mammalogists, 499: 1-10.

Perkins, Peggy J., Boermans, Jerman H., Stephenson, Gerald R. 2000. Toxicity of Glyphosate and 

Triclopyr using the frog embryo. Teratogenesis Assay-Xenopus. Environmental Toxicol and 

Chemistry 19(4): p.940-5.

Peterson, David L. 2006. Biological Status Assessment and Petition to Remove the Peregrine Falcon from 

Oregon’s List of Endangered Species. Oregon Department of Fish and Wildlife Commission. 

Pfleeger, T.G.., A. Fong, R. Hayes, H. Ratsch, and C. Wickliff. 1996. Field evaluation of the EPA 

(Kenaga) nomogram, a method for estimating wildlife exposure to pesticide residue on plants. 

Environmental Toxicology and Chemistry 15(4): p. 535-43.

Pyle, R.M. 2002. The Butterflies of Cascadia, A Field Guide to All the Species of Washington, Oregon, 

and Surrounding Territories. Seattle Audubon Society, Seattle, Washington. 420 pp. In United 

States Department of Agriculture Forest Service. 2011b. Species Fact Sheet. Johnson’s Hairstreak

(Callophrys johnsoni). 8 pp. 

Quigley, T.M., and S.J. Arbelbide. Tech Eds., 1997. An Assessment of Ecosystem Components in the 

Interior Columbia Basin and Portions of the Klamath and Great Basins. Gen. Tech. Rep. PNWGTR-405. Portland, OR. United States Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. Vol. 4. 

Raloff, J. 1998. Botanical 'velcro' entraps hummingbirds- burrs cause bird fatalities. [Online]. Available: 

http://www.findarticles.com/p/articles/mi_m1200/is_n16_v154/ai_21250276. Accessed July 

2004.

Randall, J.M. 1996. Weed control for the preservation of biological diversity. Weed Technology. 10: 370-

383.

Ratcliff, A.W., M.D. Busse, and C.J. Shestak. 2006. Changes in microbial community structure following 

herbicide (Glyphosate) additions to forest soils. Applied Soil Ecology. 34: 114-124

Rawinski T. J. 1982. The ecology and management of purple loosestrife (Lythrum salicaria L.) in central 

New York. Ithaca, N.Y.: Cornell University, ix: 88.

Rawinski, T. J.; Malecki, R. A. 1984. Ecological relationships among purple loosestrife, cattail and 

wildlife at the Montezuma National Wildlife Refuge. New York Fish and Game Journal. 31(1): 

81-87.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

279

Reames, Clark, 2013a. Personal communication with Scott Reitz. Townsend’s big-eared bat. 

documentation. March 6, 2013. 

Reames, Clark. 2013b. Personal communication with Howard Richburg. Bald Eagle Nest Locations. May 

22, 2013.

Rees, J. and P. Lee. 1990. Management of bald eagles, Haliaeetus leucocephalus, and their habitats on 

National Forests of the Pacific Northwest. United States Department of Agriculture Forest 

Service, Portland, OR. 61 pp. + appendices. – Deschutes EIS

Relyea, R.A. 2005. The impact of insecticides and herbicides on the biodiversity and productivity of 

aquatic communities. Ecological Applications 15(2): p. 618-27.

Reynolds, R. T., R. T. Graham, M. H. Reiser; and others. 1992. Management recommendations for the 

northern goshawk in the southwestern United States. General Technical Report RM-217. Ft. 

Collins, CO: United States Department of Agriculture, Forest Service, Rocky Mountain Forest 

and Range Experiment Station. 184 p.

Rice, P. 2000. Restoration of native plant communities infested by invasive weeds – Sawmill Creek 

Research Natural Area. United States Department of Agriculture Forest Service Proceedings 

RMRS-P-17: 29-30. 

Rice, P. M.; Toney, C.; Bedunah, D. J.; Carlson, C. E. 1997. Plant community diversity and growth form 

responses to herbicide applications for control of Centaurea maculosa. Journal of Applied 

Ecology. 34: 1397-1412.

Rinella, M.J., B.D. Maxwell, P.K. Fay, T. Weaver, and R.L. Sheley. 2009. Contorl effort exacerbates 

invasive-species problem. Ecological Applications. 19(1): 155-162

Rosenshield, M.L., Jofre, M.B., and W.H. Karasov. 1999. Effects of polychlorinated biphenyl 126 on 

green frog (Rana clamitans) and leopard frog (Rana pipiens) hatching success, development, and 

metamorphosis. Environmental Toxicology and Chemistry 18:2478-2486.

Rowland, M.M, and Wisdom, M.J. 2002. Research problem analysis for Greater Sage-grouse in Oregon. 

Final Report. Oregon Department of Fish and Wildlife; United States Department of the Interior, 

Bureau of Land Management, Oregon/Washington State Office; and United States Department of 

Agriculture, Forest Service, Pacific Northwest Research Station: 75 p. – Deschutes EIS

Rowland, M.M., M.J. Wisdom, B.J. Johnson, and J.G. Kie. 2000. Elk distribution and modeling in 

relation to roads. J. Wildl. Manage. 64(3): 672-684.)

Ruediger, B., J. Claar, S. Gniadek, B. Holt, L. Lewis, S. Mighton, B. Naney, G. Patton, T. Rinaldi, J. 

Trick, A. Vandehey, F. Wahl, N. Warren, D. Wenger, and A. Williamson. 2000. Canada lynx 

conservation assessment and strategy. United States Department of Agriculture Forest Service, 

United States Department of the Interior Fish and Wildlife Service, United States Department of 

the Interior Bureau of Land Management, and United States Department of the Interior National 

Park Service. Forest Service Publication #R1-00-53, Missoula, MT. 142 pp. 

(http://www.fs.fed.us/r1/wildlife/carnivore)

Ruediger, Bill, Jim Claar, Steve Mighton, Bob Naney, Tony Rinaldi, Fred Wahl, Nancy Warren, Dick 

Wenger, Al Williamson, Lyle Lewis, Bryon Holt, Gary Patton, Joel Trick, Anne Vandehey, and 

Steve Gniadek. 2000. Canada lynx conservation assessment and strategy. United States 

Department of Agriculture Forest Service, United States Department of the Interior Bureau of 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

280

Land Management, United States Department of the Interior Fish and Wildlife Service and United 

States Department of the Interior National Park Service. 120 pp.

Ruggiero, Leonard F., K. B. Aubry, S. W. Buskirk, G. M. Koehler, C. J. Krebs, K. S. McKelvey, and J. R. 

Squires. 1999. Ecology and Conservation of Lynx in the United States. Univ. Press of Colorado. 

Boulder, CO and United States Department of Agriculture, Forest Service, Rocky Mountain 

Research Station. General Technical Report, RMRS-GTR-30WWW, October. 480p

Ruggiero, Leonard F., Keith B. Aubry, Steven W. Buskirk, L. Jack Lyon, and William J. Zielinski. 1994. 

The scientific basis for conserving forest carnivore’s American marten, fisher, lynx, and 

wolverine in the western United States. General Technical Report RM-254. Fort Collins, CO: 

United States Department of Agriculture, Forest Service.

Saab, Victoria A., Robin E. Russell, and Jonathan G. Dudley. 2007. Nest densities of cavity-nesting birds 

in relation to postfire salvage logging and time since wildfire. Condor 109:97-108. 

http://www.rmrs.nau.edu/publications/rmrs_2007_Saab_et_al/rmrs_2007_Saab_et_al.pdf

Saab, Victoria, and Jonathan Dudley. 1998. Responses of cavity-nesting birds to stand-replacement fire 

and salvage logging in ponderosa pine/Douglas-fir forests of southwestern Idaho. United States 

Department of Agriculture Forest Service, Rocky Mnt. Res. Sta., Ogden, UT. Res. Paper RMRSRP-11. 17 p. http://www.rmrs.nau.edu/publications/saab_dudley_1998/saab_dudley_1998.pdf

Samson, Fred B. 2006a. A conservation assessment of the northern goshawk, black-backed woodpeckers, 

flammulated owl, and pileated woodpecker in the Northern Region. United States Department of 

Agriculture, Forest Service.

Scheiman, D.M., Bollinger, E.K., and D.H. Johnson. 2003. Effects of Leafy Spurge Infestations on 

Grassland Birds. USGS. Northern Prairie Wildlife Research Center. Paper 230. Available at: 

http://digitalcommons.unl.edu/usgsnpwrc/230. 

Schmidt, K.A., and C.J. Whelan. 1999. Effects of exotic Lonicera and Rhamnus on songbird nest 

predation. Volume 13.6. p. 1502-6.

Schroeder, R.L. 1984. Habitat suitability index models. Blue grouse. United States Fish and Wildlife

Service. FWS/OBS-82/10.81. 19 pp. 

Schwartz, C.C., J.P. Copeland, N.J. Anderson, J.R. Squires, R.M. Inman, K.S. McKelvey, K.L. Pilgrim, 

L.P. Waits, and S.A. Cushman. 2009. Wolverine gene flow across a narrow climatic niche. 

Ecology, 90(11), pp. 3222-3232.

Seastedt, T.R., R.J. Hobbs, and K.N. Suding. 2008. Management of novel ecosystems: are novel 

approaches required? Front. Ecol. Environ. 6(10): 547-553

Sheley RL, Jacobs JS, Martin JM. 2004. Integrating 2,4-D and sheep grazing to rehabilitate spotted 

knapweed infestations. Journal of Range Management 57(4):371-375. In: 

http://www.fws.gov/invasives/stafftrainingmodule/methods/chemical/review.html. Accessed 

5/26/13

Sheley, R.L. and J.K. Petroff, eds. 1999. Biology and management of noxious rangeland weeds. Oregon 

State University Press, Corvallis, OR. 

Sheley, R.L., B.E. Olson, and L.Larson. 1997. Effect of weed seed rate and grass defoliations level on 

diffuse knapweed. Journal of Range Management 50: 39-43. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

281

Sheley, R.L., J.K. Petroff, and M.M. Borman. 1999a. Introduction. In R.L.Sheley and J.K. Petroff, eds. 

Biology and Management of Noxious Rangeland Weeds. Oregon State University Press, 

Corvallis, OR.

Sheley, R.L., S. Kedzie-Webb, and B.D. Maxwell. 1999b. Integrated Weed Management on Rangeland. In 

R.L.Sheley and J.K. Petroff, eds. Biology and Management of Noxious Rangeland Weeds. 

Oregon State University Press, Corvallis, OR.

Sheley, R.L., T.J. Scejcar and B.D. Maxwell. 1996. A Theoretical Framework for Developing 

Successional Weed Management Strategies onRangeland. Weed Technology: 10:. 766-773. 

Slater, G.L. 2004. Grasshopper Sparrow (Ammodramus savannarum) A Technical Conservation 

Assessment. Prepared for United States Department of Agriculture Forest Service Rocky 

Mountain Region, Species Conservation Project. October 2004. 46 pp. 

Smith, G.R. 2001. Effects of Acute Exposure to a Commercial Formulation of Glyphosate on the 

Tadpoles of Two Species of Anurans. Bull. Environ. Contam. Toxicol. 67:483-8.

Squires, J. R., and P. L. Kennedy. 2006. Northern goshawk ecology: an assessment of current knowledge 

and information needs for conservation management. Studies in Avian Biology 31: 8-62.

Squires, J. R., and R. T. Reynolds. 1997. Northern Goshawk. No. 298. In The birds of North America. The 

Academy of Natural Sciences, Philadelphia, Pennsylvania, and The American Ornithologists' 

Union, Washington, DC, USA. Available at; 

http://bna.birds.cornell.edu/bna/species/298doi:10.2173/bna.298 

Stalmaster, M.V. and J.R. Newman. 1978. Behavioral responses of wintering bald eagles to human 

activity. J. Wildl. Manage. 43:506-513. – Deschutes EIS

State of Oregon. 2004. Pipeline, Oregon Drinking Water News; Oregon Drinking Water Standards, 19(4) 

Fall 2004. Drinking Water Program, Oregon Health Division. 

www.dhs.state.or.us/publichealth/dwp

Stebbins, R. C. 1985. The Peterson Field Guide Series: A Field Guide to Western Reptiles and 

Amphibians. Houghton Mifflin Company, Boston, MA. 336 pp.

Steinlein, T. 2013. Invasive alien plants and their effects on native microbial soil communities. Progress 

in Botany. 74: 293-319

Sucoff , E., Nichols, T.& Lu, EY. 2001. Herbicide effects on host plants of Karner Blue butterfly and on 

butterfly development from egg to adult. Department of Forest Resources Staff paper Series 

Number 151. University of Minnesota College of Natural Resources: St. Paul Minnesota 47 pp. 

In . United States Department of Interior Fish and Wildlife Service. 2012. Federal Register 

proposed rule to list the Mardon Skipper as federally threatened or endangered. Volume 77 

Number 171. 27 pp. 

Suding, K.N., K.D. LeJeune, T.R. Seastedt. 2004. Competitive impacts and responses of an invasive 

plant: dependencies on nitrogen and phosphorus availability. Oecologia. 141: 526-535

Sullivan, T.P., C. Nowotny, and R.A. Lautenschlager. 1998. Silvicultural use of herbicide in sub-boreal 

spruce forest: implications for small mammal population dynamics. Journal of Wildlife

Management 62(4): p. 1196-206.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

282

Sullivan, T.P/ and D.S. Sullivan. 2003. Vegetation management and exosystem disturbance: impact of 

glyphosate hervicide on plant and animal diversity in terrestrial systems. Environmental Review 

11:37-59.

Sutherland, S. 2004. What makes a weed a weed: life history traits of native and exotic plants in the USA. 

Oecologia. 141: 24-39

Swenson, J.E.; C.A. Simmons, and C.D. Eustace. 1987. Decrease of sage grouse Centrocercus 

urophasianus after ploughing of sagebrush steppe. Biological Conservation 41: 125-132.

Syracuse Environmental Research Associates (SERA), Inc. 2001. Sethoxydim [Poast] - Human Health

and Ecological Risk Assessment. Fayetteville, New York. October 31, 2001. 

Syracuse Environmental Research Associates (SERA), Inc. 2003. Glyphosate Human Health and 

Ecological Risk Assessment. Fayetteville, New York. March 1, 2003. 

Syracuse Environmental Research Associates (SERA), Inc. 2003. Picloram - Revised Human Health and 

Ecological Risk Assessment. Fayetteville, New York. June 30, 2003. 

Syracuse Environmental Research Associates (SERA), Inc. 2003. Triclopyr - Revised Human Health and 

Ecological Risk Assessment. Fayetteville, New York. March 15, 2003. 

Syracuse Environmental Research Associates (SERA), Inc. 2004. Chlorsulfuron Human Health and 

Ecological Risk Assessment. Fayetteville, New York. November 21, 2004. 

Syracuse Environmental Research Associates (SERA), Inc. 2004. Clopyralid Human Health and 

Ecological Risk Assessment - Final Report. Fayetteville, New York. December 5, 2004. 

Syracuse Environmental Research Associates (SERA), Inc. 2004. Imazapic Human Health and Ecological 

Risk Assessment. Fayetteville, New York. December 23, 2004. 

Syracuse Environmental Research Associates (SERA), Inc. 2004. Imazapyr Human Health and 

Ecological Risk Assessment. Faytetteville, New York. December 18, 2004.

Syracuse Environmental Research Associates (SERA), Inc. 2004. Metsulfuron Methyl Human Health and 

Ecological Risk Assessment. Fayetteville, New York. December 9, 2004. 

Syracuse Environmental Research Associates (SERA), Inc. 2004. Sulfometuron methyl Human health 

and ecological risk assessment. Fayetteville, New York. December 14, 2004. 

Syracuse Environmental Research Associates (SERA), Inc. 2007. Aminopyralid Human health and 

Ecological Risk Assessment. Fayetteville, New York. Jun. 28, 2007

Syracuse Environmental Research Associates (SERA), Inc. 2007. GLEAMS Driver User Guide, Version 

1.8. Fayetteville, New York.

Syracuse Environmental Research Associates (SERA), Inc. 2011. Glyphosate Human health and 

Ecological Risk Assessment. Fayetteville, New York 13066-0950. March 25, 2011.

Syracuse Environmental Research Associates (SERA), Inc. 2011. Imazapyr Human Health and Ecological 

Risk Assessment. Fayetteville, New York.

Syracuse Environmental Research Associates (SERA), Inc. 2011. Picloram Human health and Ecological 

Risk Assessment. Fayetteville, New York 13066-0950. Sep. 29, 2011.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

283

Syracuse Environmental Research Associates (SERA), Inc. 2011. Triclopyr Human health and Ecological 

Risk Assessment. Fayetteville, New York 13066-0950. May 24, 2011.

The American Naturalist,123:338-353. 

Thomas, J. W., H. Black, Jr., R. J. Scherzinger, and R. J. Petersen. 1979. Wildlife Habitats in Managed 

Forests: The Blue Mountains of Oregon and Washington. [United States Department of 

Agriculture Agriculture Handbook 553]. Washington, D.C. (Pages 60-77).

Thomas, J.W., D.A. Leckenby, M.Henjum, R.J. Pedersen and L.D. Bryant. 1988. Habitat-Effectiveness 

Index for Elk on Blue Mountain Winter Ranges. Pacific Northwest Research Station. General 

Technical Report PNW-GTR-218. Portland, OR. 28 pp. 

Thompson, D. Q., Stuckey, R. L.; Thompson, E. B. 1987. Spread, impact, and control of purple 

loosestrife (Lythrum salicaria) in North American wetlands. Washington, D.C.: United States 

Department of the Interior Fish and Wildlife Service; Research Report No. 2. 55 p. 

http://www.npwrc.usgs.gov/resource/plants/loosstrf/index.htm

Trammell, M. A.; Butler, J. L. 1995. Effects of exotic plants on native ungulate use of habitat. Journal of 

Wildlife Management. 59(4): 808-816. Shawna’s 2011 summary

Tu, C.M. 1994. Effects of herbicides and fumigants on microbial activities in soil. Bulletin of 

Environmental Contamination and Toxicology. 52(1): 12-17

Tu, M., C. Hurd, and J.M. Randall. 2001. Weed Control Methods Handbook: Tools & Techniques for Use 

in Natural Areas. The Nature Conservancy.

United States Deparment of the Interior, Fish and Wildlife Service. 2013. Federal Register. Proposal to list 

the distinct population segment of North American wolverine occurring in the contiguous United 

States as a threatened species under the Endangered Species Act. 28 pp.

United States Deparment of the Interior, Fish and Wildlife Service. 2012. Fedeally listed, proposed, 

candidate species and species of concern within Grant County, Oregon. August 11, 2012. 3 pp. 

United States Deparment of the Interior, Fish and Wildlife Service. 2010. Federal Register. 12 month 

Finding on a Petition to List the North American Wolverine as Endangered or Threatened.

United States Deparment of the Interior, Fish and Wildlife Service. 2006. Final Environmental 

Assessment: Designation of Critical Habitat for the Contiguous United States Distinct Population 

Segment of the Canada Lynx. Denver, Colorado. 74 pp. 

United States Deparment of the Interior, Fish and Wildlife Service. 2003. Endangered and threatened 

wildlife and plants; 90-day finding on a petition to list the western sage grouse. February 7, 2003. 

Federal Register 68(26): 6500-6504. 

United States Department of Agriculture, Agricultural Research Service. 2007. Colony Collapse Disorder

(CCD) Steering Committee. Colony collapse disorder action plan. Downloaded June 6, 2008 

from: http://www.ars.usda.gov/is/br/ccd/ccd_actionplan.pdf

United States Department of Agriculture, Forest Service 2010. Species Fact Sheet. Silver-bordered 

Fritillary (Boloria selene). 3 pp. 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

284

United States Department of Agriculture, Forest Service and Animal and Plan Health Inspection Service.

2012. Gypsy Moth Management in the United Sateas, a Cooperative Approach - Final 

Environmental Impact Statement. NA-MB-01-12. Newtown Square, Pennsylvania. 

United States Department of Agriculture, Forest Service. 1989. Land and Resource Management Plan for 

the Ochoco NF/Crooked River NG. and Appendices. Pacific Northwest Region. 2,054 pp. 

United States Department of Agriculture, Forest Service. 1990. Land and Resource Management Plan for 

the Malheur National Forest and Appendices. Pacific Northwest Region. Available at: 

http://www.fs.usda.gov/detail/malheur/landmanagement/?cid=fsbdev3_033814. 

United States Department of Agriculture, Forest Service. 1993. Malheur Wild and Scenic River 

Management Plan. 

United States Department of Agriculture, Forest Service. 1993. North Fork of the Malheur Scenic River 

Management Plan.

United States Department of Agriculture, Forest Service. 1995. Forest Service Manual (FSM) 2600, 

Wildlife, Fish and Sensitive Plant Habitat Management. R-6 Supplement 2600-95-3, effective 

6/29/95.

United States Department of Agriculture, Forest Service. 1995. Regional Forester’s Forest Plan

Amendment #2. Interim Management Direction Establishing Riparian, Ecosystem and Wildlife

Standards for Timber Sales. Revised. 11 pp. 

United States Department of Agriculture, Forest Service. 1998. Watershed Protection and Management. 

Forest Service Manual. R6 Supplement 2500-98-1, Chapter 2520. United States Department of 

Agriculture Forest Service, Region 6, Portland, OR. 7p.

United States Department of Agriculture, Forest Service. 1999. Noxious Weed Strategy, Pacific 

Northwest Region, Portland, OR

United States Department of Agriculture, Forest Service. 2001. Guide to Noxious Weed Prevention 

Practices. www.fs.fed.us/rangelands/ftp/invasives

United States Department of Agriculture, Forest Service. 2001. Special Areas; Roadless Area

Conservation Rule 36 CFR Part 294.

United States Department of Agriculture, Forest Service. 2003. Malheur National Forest National Visitor 

Use Monitoring Report. United States Forest Service, Malheur National Forest, John Day, OR.

United States Department of Agriculture, Forest Service. 2004. Implementing the National Fire Plan 

Using Livestock Grazing to Manage Vegetation (Official Letter). 

United States Department of Agriculture, Forest Service. 2005. Biological Assessment for the United 

States Department of Agriculture Forest Service, Pacific Northwest Region, Invasive Plant 

Program. Pacific Northwest Region, Portland, OR. June 17, 2005. 452pp + appendices.

United States Department of Agriculture, Forest Service. 2005. Fisheries Biological Assessment for 

United States Department of Agriculture Forest Service, Pacific Northwest Region, Invasive Plant 

Program, Environmental Impact Statement. United States Department of Agriculture Forest 

Service, Pacific Northwest Region, Portland, OR. 221pp.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

285

United States Department of Agriculture, Forest Service. 2005. Pacific Northwest Region Invasive Plant 

Program: Preventing and Managing Invasive Plants. Final Environmental Impact Statement. 

Volumes I, II, and III. (R6-NR-FHP-PR-02-05). Pacific Northwest Region. Oregon (R6 2005 

FEIS).

United States Department of Agriculture, Forest Service. 2005. Pacific Northwest Region Invasive Plant 

Program Record of Decision. Pacific Northwest Region, Portland, OR. October 2005, R6-NRFHP-PR-02-05. 39 pp. + appendices. (R6 2005 ROD). 

United States Department of Agriculture, Forest Service. 2005. Pacific Northwest Region Invasive Plant 

Program Appendix J. The Effects of Non-herbicidal Methods of Invasive Plant Treatments on 

Wildlife, Fish and Plants. Pacific Northwest Region, Portland, OR.27 pp.

United States Department of Agriculture, Forest Service. 2005. Pacific Northwest Region Invasive Plant 

Program Appendix P. Summary of Herbicide Effects to Wildlife. United States Department of 

Agriculture Forest Service, Pacific Northwest Region, Portland, OR. February 2005. 141 pp. 

United States Department of Agriculture, Forest Service. 2006. Lynx Conservation Agreement between 

United States Department of Agriculture Forest Service and United States Department of the 

Interior Fish and Wildlife Service. 9 pp. 

United States Department of Agriculture, Forest Service. 2007. Spotted Knapweed. Prepared by Alaska 

Region. R10-TP125. 2 pp. 

United States Department of Agriculture, Forest Service. 2008. Malheur National Forest. Environmental 

Assessment Balance Thinning and Fuels Project. John Day, Oregon. 

United States Department of Agriculture, Forest Service. 2008. Memorandum of Understanding between 

the United States Department of Agriculture and the United States Fish and Wildlife Service to 

Promote the Conservation of Migratory Birds. 13 pp. 

United States Department of Agriculture, Forest Service. 2008. Umatilla and Wallowa-Whitman National 

Forests Invasive Plant Biological Assessment. Pendleton and Baker City, Oregon. 

United States Department of Agriculture, Forest Service. 2009. Malheur National Forest National Visitor 

Use Monitoring Report. United States Forest Service, Malheur National Forest, John Day, OR.

United States Department of Agriculture, Forest Service. 2010. Gifford Pinchot National Forest and 

Columbia River Gorge National Scenic Area (Washington Portion) FEIS

United States Department of Agriculture, Forest Service. 2010. Species Fact Sheet. Shortface Lanx

(Fisherola nuttalli) 6 pp. 

United States Department of Agriculture, Forest Service. 2011. Regional Roresters Sensitive Species List. 

Pacific Northwest Region, Portland Oregon. December, 2011.

United States Department of Agriculture, Forest Service. 2011. Species Fact Sheet. Johnson’s Hairstreak

(Callophrys johnsoni). 8 pp. 

United States Department of Agriculture, Forest Service. 2012. Field Guide for Managing Canada Thistle 

in the Southwest. Southwest Region. TP-R3-16-14.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

286

United States Department of Agriculture, Forest Service. 2012. Field Guide for Managing Knapweeds in 

the Southwest. United States Department of Agriculture Forest Service Southwest Region. TPR3-16-14.

United States Department of Agriculture, Forest Service. 2012. Field Guide for Managing Leafy Spurge 

in the Southwest. United States Department of Agriculture Forest Service Southwest Region. TPR3-16-14.

United States Department of Agriculture, Forest Service. 2012. National Best Management Practices for 

Water Quality Management on National Forest System Lands. Volume 1: National Core BMP 

Technical Guide.

United States Department of Agriculture, Forest Service. 2012. National Best Management Practices for 

Waer Quality Management on National Forest Service Lands. Volume 1 National Core BMP 

Technical Guide. F2-990a.

United States Department of Agriculture, Forest Service. 2012. Species Fact Sheet. Columbia Clubtail

(Gomphus lynnae). 3 pp. 

United States Department of Agriculture, Forest Service. 2013. Disturbed WEPP 2.0. Available 

[ONLINE] @ http://forest.moscowfsl.wsu.edu/cgi-bin/fswepp/wd/weppdist.pl [May 23, 2013]

United States Department of Agriculture, Forest Service. 2013. Natural Resource Manager Database.

National Forest Service database for sensitive plant data management. Formerly known as NRIS.

United States Department of Agriculture, Forest Service. 2013. Species Fact Sheet. Harney Basin 

Duskysnail (Colligurus depressus). 17 pp. 

United States Department of Agriculture, Forest Service.1990. ROS Primer and Field Guide.

United States Department of the Interior, Fish and Widlife Service. 2007. Biological Opinion on the 

effects of the Northern Rocky Mountain Lynx Amendment on the Distinct Population Segment 

(DPS) of Canada Lynx (Lynx canadensis) in the contiguous United States. 85 pp. 

United States Department of the Interior, Fish and Widlife Service. 1999. Bald and Golden Eagle

Protection Act. Title 16. Conservation. Chapter 5A. Protection and Conservation of Wildlife. 4 

pp. 

United States Department of the Interior, Fish and Wildlife Service. 2013. Pygmy Rabbit Fact Sheet. 

Pacific Region. Available at; http://www.fws.gov/oregonfwo/Species/Data/PygmyRabbit/. 

Accessed 4/19/2013.

United States Department of the Interior, Fish and Wildlife Service. 2012. Fedeally listed, proposed, 

candidate species and species of concern within Harney County, Oregon. August 11, 2012. 4 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2012. Fedeally listed, proposed, 

candidate species and species of concern within Crook County, Oregon. August 11, 2012. 3 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2012. Fedeally listed, proposed, 

candidate species and species of concern within Malheur County, Oregon. August 11, 2012. 4 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2012. Fedeally listed, proposed, 

candidate species and species of concern within Baker County, Oregon. August 11, 2012. 3 pp. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

287

United States Department of the Interior, Fish and Wildlife Service. 2011. Federal Register. Reissuance of 

Final Rule to Identify the Northern Rocky Mountain Population of Gray Wolf as a Distinct 

Population Segment and to Revise the List of Endangered and Threatened Wildlife. Pp. 25590-

25592. 

United States Department of the Interior, Fish and Wildlife Service. 2009. Federal Register Revised 

Designation of Critical Habitat for the Contiguous United States Distinct Population Segment of 

the Canada Lynx. Vol. 74. No 36, 87 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2008. Birds of Conservation Concern. 

Division of Migratory Bird Management, Arlington, Virginia. 93 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2007. National Bald Eagle

Management Guidelines. United States Fish and Wildlife Service. 23 p.

United States Department of the Interior, Fish and Wildlife Service. 2006. Amendment to the Canada 

Lynx Conservation Agreement determining occupied lynx habitat. 17 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2005. Federal Register 90 Day 

Finding ona Petition to List the Pygmy Rabbit as Threatened or Endangered. Vol. 70, No. 97. 

May 20, 2005. 13 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2005. Federal Register Final Rule to 

Identify the Northern Rocky Mountain Population of Gray Wolf as a Distinct Population Segment 

and to Revise the List of Endangered and Threatened Wildlife. Vol. 74, No. 62, April 2, 2009. 66 

pp. 

United States Department of the Interior, Fish and Wildlife Service. 2005. Lynx Recovery Outline. 

Contiguous United States Distinct Population Segment of the Canada Lynx. 21 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2005. Lynx Conservation Agreement 

between the United States Forest Service and United States Fish and Wildlife Service. 9 pp. 

United States Department of the Interior, Fish and Wildlife Service. 2003. Endangered and Threatened 

Wildlife and Plants; Removing the Western Distinct Population Segment of Gray Wolf From the 

List of Endangered and Threatened Wildlife. Federal Register: April 1, 2003, Volume 68. No. 62.

United States Department of the Interior, Fish and Wildlife Service. 2002. Chapter 1, Introduction. In: 

Bull Trout (Salvelinus confluentus) Draft Recovery Plan. United States Fish and Wildlife Service, 

Portland, Oregon. 137 pps.

United States Department of the Interior, Fish and Wildlife Service. 1999. Proposed rule: delist bald eagle 

(Haliaeetus leucocephalus) in the lower 48 states. Federal Register 64:36453-36464.

United States Department of the Interior, Fish and Wildlife Service. 1995. Endangered and Threatened 

Wildlife and Plants. Reopening of Comment Period on Proposed Rule to Reclassify the Bald 

Eagle from Endangered to Threatened. Federal Register 50 CFR Part 17. 15280-15281.

United States Department of the Interior, Fish and Wildlife Service. 1987. Northern Rocky Mountain 

Wolf Recovery Plan. Denver, Colorado. 119 pp.

United States Department of the Interior, Fish and Wildlife Service. 1986. Recovery Plan for the Pacific 

Bald Eagle. Portland, OR. 160 pp.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

288

United States Department of the Interior, Fish and Wildlife Service. 1981. Bald Eagle Management 

Guidelines for Oregon and Washington. 10 pp. 

United States Department of the Interior, Geological Service. 2013. Daily Flow Statistics. Website: 

http://waterdata.usgs.gov/usa/nwis/sw 

United States Department of the Interior, Geological Survey. 2007. Pygmy Rabbit Surveys on State Lands 

in Oregon. Open-File Report 2007-1015. Reston, Virginia. 27 pp. 

United States Department of the Interior. Fish and Wildlife Service. 2003. Biological Opinion and Letter 

of Concurrence for Effects to Bald Eagles, Marbled Murrelets, Northern Spotted Owls, Bull 

Trout, and Designated Critical Habitat for Marbled Murrelets and Northern Spotted Owls. from 

Olympic National Forest Program of Activities for August 5, 2003 to December 31, 2008. Lacey 

Washington. 288 pp. 

United States Departmtent of the Interior, Fish and Wildlife Service. 2007. Removing the bald eagle in the 

lower 48 states from the list of endangered and threatened wildlife. Final Rule. Federal 

Register/Vol. 72, No. 130. July 9, 2007. 28 pp. 

United States Environmental Protection Agency, Office of Pesticide Programs. 2005. Imazapyr: Revised 

HED Chapter of the Reregistration Eligibility Document (RED). December 8, 2005. United 

States EPA E-Docket EPA-HQ-OPP-2005-0495

United States Environmental Protection Agency. 2005. Milestone Fact Sheet. 

US P.L. 100-577. Omnibus Oregon Wild and Scenic Rivers Act of 1988.

US P.L. 90-542, 1968. Wild and Scenic Rivers Act. 

Utah State University. 2013. The Great Basin and Inavsive Weeds. Yellow Starthistle. 1 pp. 

Verts, B. J., and L. N. Carraway. 1998. Land Mammals of Oregon. University of California Press, 

Berkeley, CA. 668 pp.

Wahl, T. R., B. Tweit, and S. G. Mlodinow, editors. 2005. Birds of Washington: status and distribution. 

Corvallis, OR, United StatesA Oregon State Univ. Press. 436 pp. In Mellen-McLean, Kim 2012d. 

MIS Information Sheet. Primary Cavity Nesters/Excavators. 29 pp. 

Wangemann, S.A. R.A. Kohl, and P.A. Molumeli. 2000. Infiltration and Percolation Influenced by 

Antecedent Soil Water Content and Air Entrapment. Transactions of the ASAE Vol 43(6): 1517-

1523.

Wardle, D. A., Bardgett, R. D., Klironomos, J. N., Setälä, H., Van der Putten, W. H. and Wall, D. H. 2004. 

Ecological linkages between aboveground and belowground biota. Science 304: 1629-1633

Warren, A.D. 2005. Lepidoptera of North America 6, Butterflies of Oregon: Their Taxonomy, 

Distribution, and Biology. Contributions of the C.P. Gillette Museum of Arthropod Diversity. 

Colorado State University, Fort Collins, Colorado. 405 pp. In United States Department of 

Agriculture Forest Service 2010b. Species Fact Sheet. Silver-bordered Fritillary (Boloria selene). 

3 pp. 

Weber, K. T., C. L. Marcum, M. G. Burcham, and L. J. Lyon. 2000. Landscape influences on elk 

vulnerability to hunting. Intermountain Journal of Science 6:86-94.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

289

Weihe, P. E.; Neely, R. K. 1997. The effects of shading on competition between purple loosestrife and 

broad-leaved cattail. Aquatic Botany. 59:127-138.

Weiher, E., Wisheu, I.C., Keddy, P.A., and Moore, D.R.J. 1996. Establishment, Persistence, and 

Management Implications of Experimental Wetland Plant Communities. Wetlands 16(2): p.208-

18.

Weiss, N.T. and B.J. Verts. 1984. Habitat and distribution of the pygmy rabbit (Sylvilagus idahoensis) in 

Oregon. Great Basin Naturalist 44: 563-571 – Deschutes NF Weed EIS

Western Bat Working Group. 2005. Species Accounts, Townsend’s big-eared bat. Available at 

http://www.wbwg.org/speciesinfo/species_accounts/vespertilonidae/coto.pdf. Accessed 9/11/11. 

Western Regional Climate Center. 2012. Website: http://www.wrcc.dri.edu/

Western Regional Climate Center. 2013. Website: http://www.wrcc.dri.edu/

Whisenant, S.G. 1990. Changing fire frequencies on Idaho's Snake river plains: ecological and 

management implications. In: McArthur, E.D.; Romney, E. M.; Smith, S. D.; Tueller, P. T. eds. 

Proceedings of a Symposium on Cheatgrass Invasion, Shrub Die-off, and Other Aspects of Shrub 

Biology and Management. United States Forest Service Gen. Tech. Rep. INT-276. Ogden, UT.: 

Intermountain Forest and Range Experiment Station: 4-10.

Wilde, S.B., T.M. Murphy, C.P. Hope, S.K. Habrun, J. Kempton, A. Birrenkott, F. Wiley, W.W. 

Bowerman, and A.J. Lewitus. 2005. Avian vacuolar myelinopathy linked to exotic aquatic plants 

and a novel cyanobacterial species. Environmental Toxicology 20 (3) 348-353.

Williamson, J., and S. Harrison. 2002. Biotic and abiotic limits to the spread of exotic revegetation 

species. Ecological Applications. 12(1): 40-51 

Wisdom, M.J., R.S. Holthausen, B.C. Wales, C.D. Hargis, V.A. Saab, D.C. Lee, W.J. Hann, T.D. Rich, 

M.M. Rowland, W.J. Murphy and M.R. Earnes. 2000. Source habitats for terrestrial vertebrates of 

focus in the Interior Columbia Basin: Broad-scale trends and management implications, Volume 2 

– Group level results. Gen. Tech. Rep. Threatened and Endangered Species, Sensitive Species and 

Management Indicator Species and the level of analysis required. PNW-GTR-485. pp. 181-190; 

199-208; 219-223; 237-241; 242-248; 258-265; 293-297.

Witmer, G. W., S. K. Martin, and R. D. Sayler. 1998. Forest carnivore conservation and management in 

the interior Columbia Basin: Issues and environmental correlates. General Technical Report 

GTR-PNW-420. Portland, OR: United States Department of Agriculture Forest Service, Pacific 

Northwest Research Station, Portland, OR. 51 pp.

Wolfe, B.E. and J.N. Klironomos. 2005. Breaking new ground: soil communities and exotic plant 

invasion. Bioscience. 55(6): 477-487

Wood, Tamara. 2001. Herbicide Use in the Management of Roadside Vegetation, Western Oregon, 1999-

2000: Effects on the Water Quality of Nearby Streams, USGS, Water Resources Investigations 

Report 01-4065.

Yu, Y.L., X. Wang, Y.M. Luo, J.F. Yang, J.Q. Yu, and D.F. Fan. 2005. Fungal degradation of metsulfuronmethyl in pure cultures and soil. Chemosphere. 60: 460-466
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

290

Zavaleta, E. 2000. Valuing ecosystems services lost to Tamarix invasion in the United States. In: H.A. 

Mooney, R.J. Hobbs, eds. Invasive species in a changing world. Washington, D.C.: Island Press: 

261-300.

Zielinski, W. J., K. M. Slauson, C. R. Carroll, C. J. Kent, and D. G. Kudma. 2001. Status of American 

martens in coastal forests of the Pacific states. Journal of Mammalogy 82:478-490. In MellenMcLean, Kim, 2012b. MIS Information Sheet. American Marten (Martes Americana). 20 pp.

Zouhar, K. 2004. Cardaria spp. In: Fire Effects Information System, [Online]. United States Department 

of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory 

(Producer). Available online at: http://www.fs.fed.us/database/feis/ [ 2013, June 1].

Zouhar, K., J.K. Smith, S. Sutherland, and M. Brooks. 2008. Wildland fire in ecosystems: fire and 

nonnative invasive plants. Gen. Tech. Rep. RMRS-GTR-42-vol. 6. Ogden, UT: United States 

Department of Agriculture Forest Service, Rocky Mountain Research Station. 355 p.

Glossary 

Active ingredient (a.i.) - In any pesticide product, the component (a chemical or biological substance) 

that kills or otherwise controls the target pests - Pesticides are regulated primarily on the basis of active 

ingredients. The remaining ingredients are called “inerts.”

Acute effect - An adverse effect on any living organism in which severe symptoms develop rapidly and 

often subside after the exposure stops.

Acute exposure - A single exposure or multiple brief exposures occurring within a short time (e.g., 24 

hours or less in humans). The classification of multiple brief exposures as “acute” is dependent on the life 

span of the organism. (See also, chronic exposure and cumulative exposure.)

Acute toxicity - Any harmful effect produced in an organism through an acute exposure to one or more 

chemicals.

Additive effect - A situation in which the combined effects of exposure to two chemicals simultaneously 

is equal to the sum of the effect of exposure to each chemical given alone. The effect most commonly 

observed when an organism is exposed to two chemicals together is an additive effect.

Adaptive management - A continuing process of action-based planning, monitoring, researching, 

evaluating, and adjusting with the objective of improving implementation and achieving the goals of the 

standards and guidelines

Adjuvant(s) - Chemicals that are added to pesticide products to enhance the toxicity of the active 

ingredient or to make the active ingredient easier to handle or mix.

Adsorption - The tendency of one chemical to adhere to another material such as soil. 

Affected Environment - Existing biological, physical, social, and economic conditions of an area subject 

to change, both directly and indirectly, as the result of a proposed human action.

Agent - Any substance, force, radiation, organism, or influence that affects the body. The effects may be 

beneficial or injurious.

Agency for Toxic Substances and Disease Registry (ATSDR) - Federal agency within the Public Health 

Service charged with carrying out the health-related analyses under Comprehensive Environmental 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

291

Response, Compensation, and Liability Act (CERCLA) and Superfund Amendments and Reauthorization 

Act (SARA).

Alluvial deposits may occur after a heavy rain storm.

Ambient - Usual or surrounding conditions.

Amphibian - Any of a class of cold-blooded vertebrates (including frogs, toads, or salamanders) that are 

intermediate in many characteristics between fishes and reptiles and having gilled aquatic larvae and airbreathing adults.

Anadromous - Fish that spend their adult life in the sea but swim upriver to fresh water spawning 

grounds to reproduce.

Anaerobic - Life or process that occurs in, or is not destroyed by, the absence of oxygen. (See also, 

aerobic.)

Anions - Negatively charged ions in solution e.g., hydroxyl or OH- ion. (See also, cations.)

Annual - A plant that endures for not more than a year. A plant which completes its entire life cycle from 

germinating seedling to seed production and death within a year.

Annual and Life of the Project Caps – The project caps are limitations on the acreage that may be 

treated annually and over the life of the project. 

Bacteria - Microscopic living organisms that metabolize organic matter in soil, water, or other 

environmental media. Some bacteria can also cause human, animal and plant health problems.

Best Management Practices (BMP) - A practice or combination of practices determined by a state or an 

agency to be the most effective and practical means (technological, economic, and institutional) of 

controlling point and non-point source pollutants at levels compatible with environmental quality.

Bioaccumulation - The increase in concentration of a substance in living organisms as they take in 

contaminated air, water, or food because the substance is very slowly metabolized or excreted (often 

concentrating in the body fat.)

Bioconcentration - The accumulation of a chemical in tissues of a fish or other organism to levels greater 

than in the surrounding water or environment.

Bioconcentration Factor (BCF) - The concentration of a compound in an aquatic organism divided by 

the concentration in the ambient water of the organism.

Biological control - The use of natural enemies, including invertebrate parasites and predators (usually 

insects, mites, and nematodes,) and plant pathogens to reduce populations of nonnative, invasive plants.

Biological magnification - The process whereby certain substances such as pesticides or heavy metals 

increase in concentration as they move up the food chain.

Broadcast application - Herbicide treatment method generally used along roads; boom truck spray is 

directed at target species. Broadcast methods are used for larger infestations where spot treatments would 

not be effective.

Bryophytes - Plants of the phylum Bryophyta, including mosses, liverworts, and hornworts; 

characterized by the lack of true roots, stems, and leaves.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

292

Herbicide Use Buffer - A strip of land near a waterway or other environmentally sensitive area where a 

particular chemical and method of application is restricted, depending on the herbicide ingredient. 

Candidate species - Those plant and animal species that, in the opinion of the Fish and Wildlife Service 

(FWS) or National Oceanic and Atmospheric Administration (NOAA) Fisheries, may qualify for listing 

as “endangered” or “threatened.” The FWS recognizes two categories of candidates. Category 1 

candidates are taxa for which the FWS has on file sufficient information to support proposals for listing. 

Category 2 candidates are taxa for which information available to the FWS indicates that proposing to list 

is possibly appropriate, but for which sufficient data are not currently available to support proposed rules.

Carcinogen - A chemical capable of inducing cancer.

Categorical Exclusion – A category of actions which do not individually or cumulatively have a 

significant effect on the human environment and which have been found to have no such effect in 

procedures adopted by a Federal agency in implementation of these regulations (§1507.3) and for which, 

therefore, neither an environmental assessment nor an environmental impact statement is required. (40 

CFR 1508.4)

Cations - Positively charged ions in a solution. (See also, anion.)

Cation Exchange Capacity (CEC) - An indicator for fertility and adsorption of applied herbicides. The 

Cation Exchange Capacity (CEC) is an index of available sites for solutes/ions to attach to soil particles. 

A higher CEC represents increased ability to hold and release various chemical elements – a relative 

higher capacity for holding nutrients

Characteristic Landscape - The naturally established landscape within a scene or scenes being viewed.

Chemical Control - The use of naturally derived or synthetic chemicals called herbicides to eliminate or 

control the growth of invasive plants.

Chronic exposure - Exposures that extend over the average lifetime or for a significant fraction of the 

lifetime of the species (for a rat, chronic exposure is typically about two years). Chronic exposure studies 

are used to evaluate the carcinogenic potential of chemicals and other long-term health effects. (See also, 

acute and cumulative exposure.)

Chronic Reference Dose (RfD) - An estimate of a lifetime daily exposure level (in mg/kg/day) for the 

human population, including sensitive subpopulations, that is likely to be without an appreciable risk of 

deleterious effects. Chronic RfDs are specifically developed to be protective for long-term exposure to a 

compound (seven years to lifetime.)

Chronic toxicity - The ability of a substance or mixture of substances to cause harmful effects over an 

extended period, usually upon repeated or continuous exposure sometimes lasting for the entire life of the 

exposed organism

Code of Federal Regulations (CFR) - Document that codifies all rules of the executive departments and 

agencies of the federal government. It is divided into fifty volumes, known as titles. Title 40 of the CFR 

(referenced as 40 CFR) lists all environmental regulations, including regulations for EPA pesticide 

programs (40 CFR Parts 150-189).

Competitive Seeding – A treatment method that is intended to reduce the potential for invasive plants to 

become introduced or to reoccupy a site once target populations have been reduced. This method is often 

combined with other treatment methods.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

293

Common Control Measures – Integrated weed treatment methods used for a given target invasive plant 

species. The R6 2005 FEIS contains Appendix N, “Common Control Measures,” a compendium of 

treatment methods for invasive plants known in Oregon and Washington. These methods were updated as 

a part of development of the Malheur Invasive Plant Treatment EIS. 

Congressionally Designated Areas - Areas that require Congressional enactment for their establishment, 

such as National Parks, Wild and Scenic Rivers, National Recreation Areas, National Monuments, and 

Wilderness. Also referred to as Congressional Reserves. Includes similar areas established by Executive 

Order, such as National Monuments.

Connected Actions – An action that would occur at the same time and place, or would be required to 

occur, in order to implement a proposed action, and therefore would be analyzed in a single NEPA 

document. 

Contaminants - For chemicals, impurities present in a commercial grade chemical. For biological agents, 

other agents that may be present in a commercial product.

Cultural control - The establishment or maintenance of competitive vegetation, use of fertilizing, 

mulching, prescribed burning, or grazing animals to control or eliminate invasive plants.

Cumulative Effect (CE) - The impact on the environment that results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future actions—regardless of what 

agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result 

from individually minor, but collectively significant, actions taking place over a period of time (40 CFR 

1508.7). 

Cumulative exposure - Exposure resulting from one or more activities that are repeated over a period of 

time. (See also, acute and chronic exposure.)

Detritus - Loose fragments, particles, or grains formed by the disintegration of organic matter or rocks.

Disturbance - An effect of a planned human management activity, or unplanned native or exotic agent or 

event that changes the state of a landscape element, landscape pattern, or regional composition.

Dosage/Dose - (1) The actual quantity of a chemical administered to an organism or to which it is 

exposed. (2) The amount of a substance that reaches a specific tissue (e.g. the liver). (3) The amount of a 

substance available for interaction with metabolic processes after crossing the outer boundary of an 

organism. 

Dose Response - Changes in toxicological responses of an individual (such as alterations in severity of 

symptoms) or populations (such as alterations in incidence) that are related to changes in the dose of any 

given substance.

Drift - The portion of a sprayed chemical that is moved by wind off of a target site.

Early Detection and Rapid Response (EDRR) – Treatment of invasive plants over the life of the project 

according to the implementation planning process. 

Endangered Species - Any species listed in the Federal Register as being in danger of extinction 

throughout all, or a significant portion, of its range.

Endangered Species Act (ESA) - A law passed in 1973 to conserve species of wildlife and plants, 

determined by the Director of the U.S. Fish and Wildlife Service or the NOAA Fisheries to be endangered 

or threatened with extinction in all or a significant portion of its range. Among other measures, ESA 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

294

requires all federal agencies to conserve these species and consult with the Fish and Wildlife Service or 

NOAA Fisheries on federal actions that may affect these species or their designated critical habitat.

Endemic - A species or other taxonomic group that is restricted to a particular geographic region due to 

factors such as isolation or response to soil or climatic conditions. (Compare to “Indigenous” and 

“Native.”)

Environmental justice - Executive Order 12898 of February 11, 1994 requires federal agencies, to the 

greatest extent practicable and permitted by law, to make achieving environmental justice part of its 

mission by identifying and addressing, as appropriate, disproportionately high and adverse human health 

or environmental effects of its programs, policies, and activities on minority populations and low-income 

populations in the United States and its territories and possessions, the District of Columbia, the 

Commonwealth of Puerto Rico, and the commonwealth of the Mariana Islands.

Exposure assessment - The process of estimating the amount of contact with a chemical or biological 

agent that an individual or a population of organisms will receive from a pesticide application conducted 

under specific, stated circumstances.

Exotic – Non-native species; introduced from elsewhere, but not completely naturalized. (See also alien 

and introduced species.)

Federal Insecticide and Rodenticide Act (FIFRA) Pesticide Ingredient - An ingredient of a pesticide 

that must be registered with EPA under the Federal Insecticide, Fungicide, and Rodenticide Act. Products 

making pesticide claims must submit required information to EPA to register under FIFRA and may be 

subject to labeling and use requirements.

Fertilization - Treatment method involving adding of nutrients that could improve the success of 

desirable species; may be limited, depending on species/soil characteristics.

First-choice Herbicides – First-choice herbicides are those that would be used during the first year of 

treatment of a given primary target species. It is likely be most effective, given the options associated 

with a given action alternative. First-choice herbicides are often used in combination with non-herbicide 

methods. 

Flora - Plant life, especially all the plants found in a particular country, region, or time regarded as a 

group. Also, a systematic set of descriptions of all the plants of a particular place or time. 

Forage - Food for animals. In this document, term applies to both availability of plant material for 

wildlife and domestic livestock.

Formulation - A commercial preparation of a chemical including any inerts and/or contaminants.

Fungi - Molds, mildews, yeasts, mushrooms, and puffballs, a group of organisms that lack chlorophyll 

and therefore are not photosynthetic. They are usually non-mobile, filamentous, and multi-cellular. 

Game fish - Species like trout, salmon, or bass, caught for sport. Many of them show more sensitivity to 

environmental change than non-game fish.

Geographical Information System (GIS) – Maps and data showing location and attributes for natural 

resources found within a project area. 

Grazing animals - Treatment method which requires matching the invasive species with the appropriate 

grazer for best success. 
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

295

Groundwater - The supply of fresh water found beneath the Earth's surface, usually in aquifers, which 

often supply wells and springs.

Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) - A model that 

displays herbicide concentrations in streams under a variety of soil, climate, and vegetative conditions.

Habitat - The place where a population (e.g., human, animal, plant, microorganism) lives and its 

surroundings, both living and non-living.

Half-life - The time required for the concentration of the chemical to decrease by one-half.

Hand/Selective application - Herbicide treatment of individual plants through wicking, wiping, injecting 

stems, etc., with low likelihood of drift or delivery of herbicides away from treatment sites. This method 

ensures no herbicide directly contacts soil.

Hand-pulling/Grubbing - Treatment method which is labor-intensive but effective on single plants or on 

small, low-density infestations.

Hazard Quotient (HQ) - The ratio of the estimated level of exposure to a substance from a specific 

pesticide application to the RfD for that substance, or to some other index of acceptable exposure or 

toxicity. A HQ less than or equal to one is presumed to indicate an acceptably low level of risk for that 

specific application.

Hazard identification - The process of identifying the array of potential effects that an agent may induce 

in an exposed of humans or other organisms.

Herbaceous - A plant that does not develop persistent woody tissue above the ground (annual, biennial, 

or perennial.) Herbaceous vegetation includes grasses and grass-like vegetation, and broadleaved forbs.

Herbicide - A chemical preparation designed to kill plants, especially weeds, or to otherwise inhibit their 

growth. May or may not include an additive (adjuvant) such as a surfactant. 

Herbicide Application Rate – The amount of herbicide active ingredient that would be used on a treated 

acre. The maximum rate is the amount allowed by an herbicide label. Typical rate is the average rate used 

by the Forest Service for invasive plant treatment projects. Lowest rate (or lowest effective rate) is the 

least amount of herbicide that could be used to reach treatment objectives. 

Herbicide Treatment – Any use of herbicide to meet treatment objectives. Herbicide treatments are part 

of the integrated weed management toolbox. Herbicide treatment may be combined with non-herbicide 

treatments to meet treatment objectives. 

Herbicide Use Buffer – An area adjacent to a stream or other water body where herbicide ingredient or 

application methods are restricted. 

Humus - Organic portion of the soil remaining after prolonged microbial decomposition.

Tribal and Treaty Rights - Native American treaty and other rights or interests recognized by treaties, 

statutes, laws, executive orders, or other government action, or federal court decisions.

Indian Tribe - Any American Indian or Alaska Native tribe, band, nation, pueblo, community, rancheria, 

colony, or group meeting the provisions of the Code of Federal Regulations Title 25, Section 83.7 (25 FR 

83.7), or those recognized in statutes or treaties with the United States. 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

296

Indigenous - An indigenous species is any which were or are native or inherent to an area. (See also, 

native.)

Inerts - Anything other than the active ingredient in a pesticide product; not having pesticide properties.

Infested area or site - A contiguous area of land occupied by, in this case, invasive plant species. An 

infested area of land is defined by drawing a line around the actual perimeter of the infestation as defined 

by the canopy cover of the plants, excluding areas not infested. Generally, the smallest area of infestation 

mapped will be 1/10th (0.10) of an acre or 0.04 hectares.

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

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

management activities to achieve optimum management goals and objectives.

Interdisciplinary Team (IDT) - A group of individuals with varying areas of specialty assembled to 

solve a problem or perform a task. The team is assembled out of recognition that no one scientific 

discipline is sufficiently broad enough to adequately analyze the problem and propose action.

Introduced species - An alien or exotic species that has been intentionally or unintentionally released 

into an area as a result of human activity. (See also exotic, invasive, and noxious.)

Introduction - “The intentional or unintentional escape, release, dissemination, or placement of a species 

into an ecosystem as a result of human activity” (Executive Order 13122, 2/3/99).

Invasive plant species - An alien plant species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health (Executive Order 13122, 2/3/99) (See also exotic and 

introduced species)

Irreversible effect - Effect characterized by the inability of the body to partially or fully repair injury 

caused by a toxic agent.

Irritant - Non-corrosive material that causes a reversible inflammatory effect on living tissue by 

chemical action at the site of contact as a function of concentration or duration of exposure.

LC50 (Lethal Concentration50) - A calculated concentration of a chemical in air or water to which 

exposure for a specific length of time is expected to cause death in 50 percent of a defined experimental 

animal population.

LD50 (Lethal Dose50) - The dose of a chemical calculated to cause death in 50 percent of a defined 

experimental animal population over a specified observation period. The observation period is typically 

14 days.

Label - All printed material attached to, or part of, the pesticide container.

Land allocation – An management area designated in a Land and Resource Management Plan associated 

with certain desired conditions, objectives and standards. 

Landscape - An area composed of interacting ecosystems that are repeated because of geology, land 

form, soils, climate, biota, and human influences throughout the area. Landscapes are generally of a size, 

shape, and pattern which is determined by interacting ecosystems. 

Landscape Character - Particular attributes, qualities, and traits of a landscape that give it an image and 

make it identifiable or unique.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

297

Landscape Setting - The context and environment in which a landscape is set; a landscape backdrop. It 

is the combination of land use, landform, and vegetation patterns that distinguish an area in appearance 

and character from other areas.

Leaching - The process by which chemicals on or in soil or other porous media are dissolved and carried 

away by water, or are moved into a lower layer of soil.

Level of Concern (LOC) - The concentration in media or some other estimate of exposure above which 

there may be effects.

Lichens - Complex thallophytic plants comprised of an alga and a fungus growing in symbiotic 

association on a solid surface (such as a rock.)

Littoral zone - (1) That portion of a body of fresh water extending from the shoreline lakeward to the 

limit of occupancy of rooted plants. (2) The strip of land along the shoreline between the high and low 

water levels.

Lowest-Observed-Adverse-Effect Level (LOAEL) - The lowest dose of a chemical in a study, or group 

of studies, that produces statistically or biologically significant increases in frequency or severity of 

adverse effects between the exposed and control populations.

Manual Control - The use of any non-mechanized approach to control or eliminate invasive plants (i.e. 

hand-pulling, grubbing)

Material Safety Data Sheet (MSDS) - A compilation of information required under the OSHA 

Communication Standard on the identity of hazardous chemicals, health and physical hazards, exposure 

limits, and precautions.

Mechanical Control - The use of any mechanized approach to control or eliminate invasive plants (i.e. 

mowing, weed whipping).

Microorganisms - A generic term for all organisms consisting only of a single cell, such as bacteria, 

viruses, protozoa and some fungi.

Minimum tool - Use of a weed treatment alternative that would accomplish management objectives and 

have the least impact on resources

Modification - A visual quality objective meaning human activities may dominate the characteristic 

landscape but must, at the same time, utilize naturally established form, line, color, and texture. It should 

appear as a natural occurrence when viewed in foreground or middleground.

Mollusks - Invertebrate animals (such as slugs, snails, clams, or squids) that have a soft, un-segmented 

body, usually enclosed in a calcareous shell; representatives found on National Forest System land 

include snails, slugs, and clams.

Monitoring - A process of collecting information to evaluate if objectives and anticipated or assumed 

results of a management plan are being realized or if implementation is proceeding as planned.

Morbidity - Rate of disease, injury or illness.

Most Ambitious Treatment Scenario – The most ambitious treatment scenario would treat all known 

infestations during the first year of implementation and then retreated until management objectives are 

met. It includes treatments, re-treatments over a series of years, and passive or active restoratino. It is an 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

298

assumption that allows for a consistent analysis comparing alterantives given that Forest Service ability 

funding over the life ofthe project is unknown. 

Mowing - Invasive plant treatment method which is limited to level/gently-sloping smooth-surface 

terrain. Treatment timing is critical, and must be conducted for several consecutive years.

National Environmental Policy Act (NEPA) - An Act passed in 1969 to declare a national policy that 

encourages productive and enjoyable harmony between humankind and the environment, promotes efforts 

that prevent or eliminate damage to the environment and biosphere, stimulates the health and welfare of 

humanity, enriches the understanding of the ecological systems and natural resources important to the 

nation, and establishes a Council on Environmental Quality.

National Forest Management Act (NFMA) - A law passed in 1976 as an amendment to the Forest and 

Rangeland Renewable Resources Planning Act, requiring preparation of Forest Plans and the preparation 

of regulations to guide that development.

National Marine Fisheries Service (NMFS) - The federal agency that is the listing authority for marine 

mammals and anadromous fish under the ESA.

National Pollutant Discharge Elimination System (NPDES) - As authorized by the Clean Water Act, 

the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution 

by regulating point sources that discharge pollutants into waters of the United States. Point sources are 

discrete conveyances such as pipes or man-made ditches. Individual homes that are connected to a 

municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; 

however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to 

surface waters. 

National Visitor Use Monitoring (NVUM) - A permanent, ongoing sampling system which measures 

national forest visitor demographics, experiences, preferences, and impressions. A stratified random 

sample is done for 25 percent of the National Forest System each year according to a national research 

protocol. NVUM responds to the need to better understand the use and importance of, and satisfaction 

with, National Forest System recreation opportunities.

National Wilderness Preservation System (NWPS) - The Wilderness Act of 1964 established the 

national Wilderness Preservation System to ensure that certain federally owned areas in the United States 

would be preserved and protected in their natural condition. The Act defines a wilderness area, in part, as 

an area which generally appears to have been affected primarily by the forces of nature, with the imprint 

of man’s work substantially unnoticeable. Areas included in the system are administered for the use and 

enjoyment of the American people in such manner as to leave them unimpaired for future use and 

enjoyment as wilderness.

Native species - With respect to a particular ecosystem, a species that, other than as a result of an 

introduction, historically occurred or currently occurs in that ecosystem (Executive Order 13122, 2/3/99).

Naturalized - Applied to a species that originally was imported from another country but that now 

behaves like a native in that it maintains itself without further human intervention and has invaded native 

populations.

Non-target species - Any plant or animal that is not the intended organism to be controlled by a pesticide 

treatment.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

299

No-Observed-Adverse-Effect level (NOAEL) - Exposure level at which there are no statistically or 

biological significant differences in the frequency or severity of any adverse effect in the exposed or 

control populations

No-Observed-Effect-Level (NOEL) - Exposure level at which there are no statistically or biological 

significant differences in the frequency or severity of any effect in the exposed or control populations.

Noxious weed - “Any living stage (including but not limited to, seeds and reproductive parts) of any 

parasitic or other plant of a kind, or subdivision of a kind, which is of foreign origin, is new to or not 

widely prevalent in the United States, and can directly or indirectly injure crops, other useful plants, 

livestock, or poultry or other interests of agriculture, including irrigation, or navigation or the fish and 

wildlife resources of the United States or the public health” (Public Law 93-629, January 3, 1975, Federal 

Noxious Weed Act of 1974).

Outstandingly Remarkable Value (ORV) - A characteristic of rivers or sections of rivers in the national 

Wild and Scenic River System. In order for a river to be included in the system, it must possess at least 

one “outstandingly remarkable” value, such as scenic, recreational, geologic, fish, wildlife, historic, 

cultural, or other similar features. Outstandingly Remarkable Values are values or opportunities in a river 

corridor which are directly related to the river and which are rare, unique, or exemplary from a regional or 

national perspective.

Partial Retention - A visual quality objective which in general means human activities may be evident 

but must remain subordinate to the characteristic landscape.

Pathogen - A living organism, typically a bacteria or virus that causes adverse effects in another 

organism.

Percolation - Downward flow or filtering of water through pores or spaces in rock or soil.

Perennial Plant- A plant species having a life span of more than 2 years.

Persistence - Refers to the length of time a compound, once introduced into the environment, stays there.

Personal Protective Equipment (PPE) - Clothing and equipment worn by herbicide mixers, loaders and 

applicators and re-entry workers worn to reduce their exposure to potentially hazardous chemicals and 

other pollutants.

Pest - An insect, rodent, nematode, fungus, weed or other form of terrestrial or aquatic plant or animal life 

that is classified as undesirable because it is injurious to health or the environment.

Pesticide - Any substance used for controlling, preventing, destroying, repelling, or mitigating any pest. 

Includes fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, desiccants, defoliants, 

plant growth regulators, etc.

pH - The negative log of the hydrogen ion concentration. A high pH (greater than 7) is alkaline or basic 

and a low pH (less than 7) is acidic.

Population - A group of individuals of the same species in an area.

Project “Caps” – Limitations on the acreage that may be treated annually and through the life of the 

project. 
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

300

Project Design Features (pdf) – Measures that are part of project implementation to ensure that the 

project is done according to environmental standards and adverse effects are within the scope of those 

predicted in this Environmental Impact Statement.

Proposed species - Any plant or animal species that is proposed by the Fish and Wildlife Service or 

NOAA Fisheries in a Federal Register notice to be listed as threatened or endangered.

Recreational Rivers - A classification within the national Wild and Scenic River System. Recreational 

rivers are those rivers, or sections of rivers, that are readily accessible by road or railroad, that may have 

some development along their shorelines, and that may have undergone some impoundment or diversion 

in the past.

Reference Dose (RfD) - The RfD is a numerical estimate of a daily exposure to the human population, 

including sensitive subgroups such as children, that is not likely to cause harmful effects during a lifetime. 

RfDs are generally used for health effects that are thought to have a threshold or minimum dose for 

producing effects.

Registered Pesticides - Pesticide products which have been approved for the uses listed on the label.

Registration - Formal licensing with EPA of a new pesticide before it can be sold or distributed. Under 

the Federal Insecticide, Fungicide, and Rodenticide Act, EPA is responsible for registration (pre-market 

licensing) of pesticides on the basis of data demonstrating no unreasonable adverse effects on human 

health or the environment when applied according to approved label directions.

Restoration - Ecological restoration is the process of assisting the recovery and management of 

ecological integrity. Ecological integrity includes a critical range of variability in biodiversity, ecological 

processes and structures, regional and historical context, and sustainable cultural practices. Restoration 

may be passive (passing of time to allow for site recovery) or active (in this project, active restoration 

includes seeding, mulching and planting after invasive plants are removed). 

Retention - A visual quality objective which in general means human activities are not evident to the 

casual forest visitor.

Revegetation - The re-establishment of plants on a site - The term does not imply native or nonnative; 

does not imply that the site can ever support any other types of plants or species and is not at all 

concerned with how the site ‘functions’ as an ecosystem.

Riparian Area - A geographic area containing an aquatic ecosystem and adjacent upland areas that 

directly affect it.

Riparian Habitat Areas - Areas along live and intermittent streams, wetlands, ponds, lakes, and unstable 

and potentially unstable areas where riparian-dependent resources receive primary emphasis. Riparian 

Habitat Areas are important to the terrestrial ecosystem as well, serving as dispersal habitat for certain 

terrestrial species.

Risk - The chance of an adverse or undesirable effect, often measured as a percentage.

Risk Assessment - The qualitative and quantitative evaluation performed in an effort to estimate the risk 

posed to human health and/or the environment by the presence or potential presence and/or use of specific 

chemical or biological agents.

Scenery Management - The art and science of arranging, planning, and designing landscape attributes 

relative to the appearance of places and expanses in outdoor settings.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

301

Scenic - Of or relating to landscape scenery; pertaining to natural or natural-appearing scenery; 

constituting or affording pleasant views of natural landscape attributes or positive cultural elements.

Scenic Rivers - A classification within the national Wild and Scenic River System. Scenic rivers are 

those rivers, or sections of rivers, that are free of impoundments, with shorelines or watersheds still 

largely primitive and shorelines largely undeveloped, but accessible in places by roads.

Seen Area - The total landscape area observed based upon landform screening. Seen-areas may be 

divided into zones of immediate foreground, foreground, middleground, and background. Some 

landscapes are seldom seen by the public.

Sensitive Species – Sensitive species are identified by a Regional Forester for which population viability 

is a concern, as evidenced by significant current or predicted downward trends in population numbers or 

density and habitat capability that would reduce a species’ existing distribution (FSM 2670.5). 

Management of sensitive species “must not result in a loss of species viability or create significant trends 

toward federal listing” (FSM 2670.32).

Species of Conservation Concern - Threatened, endangered and proposed species; Regional Forester’s 

Sensitive species, management indicator species, and other identified native species.

Species - “A group of organisms, all of which have a high degree of physical and genetic similarity, 

generally interbreed only among themselves, and show persistent differences from members of allied 

groups of organisms.” (Executive Order 13122, 2/3/99).

Spot application - Herbicide treatment involving use of a backpack sprayer or other means. Application 

is aimed at specific target species, with methods of prevention (such as barriers,) to control damage to 

non-target species.

Standards and guidelines - The rules and limits governing actions, as well as the principles specifying 

the environmental conditions or levels to be achieved and maintained

Sub-chronic exposure - An exposure duration that can last for different periods of time (5 to 90 days), 

with 90 days being the most common test duration for mammals. The sub-chronic study is usually 

performed in two species (rat and dog) by the route of intended use or exposure.

Sub-chronic toxicity - The ability of one or more substances to cause effects over periods from about 90 

days but substantially less than the lifetime of the exposed organism. Sub-chronic toxicity only applies to 

relatively long-lived organisms such as mammals.

Surface water - All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, 

impoundments, seas, estuaries, etc.) and all springs, wells, or other collectors which are directly 

influenced by surface water.

Surfactant - A surface active agent; usually an organic compound whose molecules contain a hydrophilic 

group at one end and a lipophilic group at the other. Promotes solubility of a chemical, or lathering, or 

reduces surface tension of a solution. 

Synergistic effect - Situation in which the combined effects of exposure to two chemicals simultaneously 

is much greater than the sum of the effect of exposure to each chemical given alone.

Take - "The term 'take' means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, 

or to attempt to engage in any such conduct." (Title 16, Chapter 35, Section 1532, Endangered Species 

Act of 1973)
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

302

Threatened species - Plant or animal species likely to become endangered throughout all, or a significant 

portion of, its range within the foreseeable future. A plant or animal identified and defined in accordance 

with the 1973 Endangered Species Act and published in the Federal Register.

Threshold - The maximum dose or concentration level of a chemical or biological agent that will not 

cause an effect in the organism.

Tolerances - Permissible residue levels for pesticides in raw agricultural produce and processed foods. 

Whenever a pesticide is registered for use on a food or a feed crop, a tolerance (or exemption from the 

tolerance requirement) must be established. EPA establishes the tolerance levels, which are enforced by 

the Food and Drug Administration and the Department of Agriculture.

Toxicity - The inherent ability of an agent to affect living organisms adversely. Toxicity is the degree to 

which a substance or mixture of substances can harm humans or animals.

Toxicology - The study of the nature, effects, and detection of poisons in living organisms. Also, 

substances that are otherwise harmless but prove toxic under particular conditions. The basic assumption 

of toxicology is that there is a relationship among the dose (amount), the concentration at the affected site, 

and the resulting effects.

Treatment Objectives: Treatment objectives reflect the desired outcome depending on the extent, 

distribution and priority for treating a given invasive plant species. 

Eradicate: Eliminate an invasive plant species from a site. This objective generally applies to species 

that are difficult to control and cover small areas. Some occurrences may be on roadsides (Russian 

knapweed, squarrose knapweed) and others may occur in intact native vegetation (yellow starthistle, 

small occurrences of thistles or knapweed, new invaders). This is generally our first priority for 

treatment.

Control: Reduce the size of the infestation over time; some level of infestation may be acceptable. 

This objective applies to most of the target species (houndstongue, leafy spurge, perennial 

pepperweed, sulfur cinquefoil, whitetop) and large infestations of thistles and knapweeds. This is 

generally our second priority for treatment.

Contain: Prevent the spread of the weed beyond the perimeter of patches or infestation areas mapped 

from current inventories. This objective applies to target species such as common St. Johnswort. This 

is generally our third priority for treatment.

Suppress: Prevent seed production throughout the target patch and reduce the area coverage. Prevent 

the invasive species from dominating the vegetation of the area; low levels may be acceptable. This 

objective applies to target species such as toadflax that would be treated mainly with biocontrol 

agents. This is generally our fourth priority for treatment.

Tolerate: Accept the continued presence of established infestations and the probable spread to 

ecological limits for certain species. This category is for species that are so widespread and abundant 

that other objectives would be extremely difficult to meet. This category includes species such as 

cheatgrass, medusahead, North Africa grass, dandelion, mullein, and bulbous bluegrass. These 

invasive plants have low priority for treatment and would likely only be treated if they happen to be 

near one of the primary target species.

U.S. Fish and Wildlife Service (United States Department of the Interior Fish and Wildlife Service, 

USDI FWS, USFWS) - The federal agency that is the listing authority for species other than marine 

mammals and anadromous fish under the Endangered Species Act.
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

303

USDA Forest Service (United States Department of Agriculture Forest Service, FS or USFS) - The 

federal agency responsible for management of the Nation’s National Forest System lands

Viability - Ability of a wildlife or plant population to maintain sufficient size to persist over time in spite 

of normal fluctuations in numbers, usually expressed as a probability of maintaining a specific population 

for a specified period.

Viable Population - A wildlife or plant population that contains an adequate number of reproductive 

individuals appropriately distributed on the planning area to ensure the long-term existence of the species.

Viewshed - Total visible area from a single observer position, or the total visible area from multiple 

observer position. Viewsheds are accumulated seen-areas from highways, trails, campgrounds, towns, 

cities, or other viewer locations. Examples are corridor, feature, or basin viewsheds.

Visual Quality Objective - A desired level of excellence based on physical and sociological 

characteristics of an area. Refers to degree of acceptable alteration of the characteristic landscape.

Well-distributed - Distribution sufficient to permit normal biological function and species interactions, 

considering life history characteristics of the species and the habitats for which it is specifically adapted.

Wetland - An area that is regularly saturated by surface or ground water and subsequently is 

characterized by a prevalence of vegetation that is adapted for life in saturated soil conditions. Examples 

include swamps, bogs, fens, marshes, and estuaries.

Wild and Scenic River System - The Wild and Scenic Rivers Act of 1968 established a system of 

selected rivers in the United States, which possess outstandingly remarkable values, to be preserved in 

free-flowing condition. Within the national system of rivers, three classifications define the general 

character of designated rivers: Wild, Scenic, and Recreational. Classifications reflect levels of 

development and natural conditions along a stretch of river. Classifications are used to help develop 

management goals for the river.

Wilderness - Areas designated by Congressional action under the 1964 Wilderness Act. Wilderness is 

defined as undeveloped federal land retaining its primeval character and influence without permanent 

improvements or human habitation. Wilderness areas are protected and managed to preserve their natural 

conditions, which generally appear to have been affected primarily by the forces of nature with the 

imprint of human activity substantially unnoticeable; have outstanding opportunities for solitude or for a 

primitive and confined type of recreation; include at least 5,000 acres, or are of sufficient size to make 

practical their preservation, enjoyment, and use in an unimpaired condition; and may contain features of 

scientific, educational, scenic, or historical value as well as ecological and geologic interest.

Wild Rivers - A classification within the national Wild and Scenic River System. Wild rivers are those 

rivers, or sections of rivers that are free of impoundments and generally inaccessible except by trail, with 

watersheds or shorelines essentially primitive and waters unpolluted.
Chapter 4 – Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

304

Index

A

Amphibian, 268, 291

Antelope, 135, 194, 195, 237, 243, 335, 336, 342, 343

B

Bat, 177, 179, 180, 216, 219, 289

Beneficial Uses, 277

Best Management Practices, ix, 132, 143, 268, 286, 291

Big Game, 9, 190, 191

Bighorn Sheep, 194, 195, 234

Biological Control, 9, 22, 109, 202, 271

Bobolink, 177, 186, 197, 216, 271

Botany, 99, 274, 275, 281, 289

Broadcast, 12, 24, 33, 34, 43, 53, 54, 58, 70, 91, 111, 225, 

227, 291

Bryophytes, 112, 291

Bufflehead, 177, 185, 216, 224, 225

Bull Trout, 150, 158, 287, 288, 321

C

Cavity Nesters, 192, 193, 233, 269, 274, 276, 288

Chinook Salmon, 152

Clean Water Act, ix, 6, 10, 11, 134, 298

Climate, 106, 119, 125, 132, 268, 289

Climate Change, 268

Clubtail, 177, 190, 286

Colony Collapse Disorder, 105, 112, 283

Common Control Measures, 28, 293

Cultural, 4, 6, 23, 28, 41, 90, 97, 109, 114, 202, 250, 257, 

260, 293

Culturally Significant Plants, 105, 113

Cutthroat Trout, 151

D

Dispersed Recreation, 259

Duskysnail, 40, 177, 189, 228, 271, 286

E

Eagle, 38, 178, 181, 219, 279, 286, 287, 288

Early Detection and Rapid Response, 45, 56, 114, 116, 117, 

155, 167, 251, 293

Elk, 84, 88, 164, 190, 191, 213, 231, 232, 265, 279, 283, 

317, 332, 333

Endangered Species Act, ix, 6, 9, 10, 99, 107, 147, 149, 

170, 172, 177, 178, 283, 293, 301, 302

Endocrine Disruption, 94

Environmental Justice, 96

ESA, ix, 8, 23, 146, 147, 148, 149, 150, 166, 169, 170, 172, 

177, 215, 293, 298

F

Falcon, 38, 182, 197, 221, 278

Federally Listed, 99, 166, 172, 215

Fisheries, x, 10, 142, 146, 147, 148, 150, 152, 166, 265, 

266, 284, 292, 293, 298, 300

Flicker, 190, 193, 194

Floodplains and Wetlands, 263

Foreseeable Projects, 82

Forest Plan, ix, 10, 2, 3, 5, 6, 8, 9, 33, 40, 52, 53, 106, 132, 

148, 191, 194, 235, 239, 240, 254, 255, 256, 284, 298

Frog, 39, 187, 227, 273, 276

G

GLEAMS, ix, 111, 125, 126, 136, 137, 138, 140, 142, 143, 

144, 145, 146, 155, 157, 160, 167, 168, 282, 295

Goshawk, 194, 235, 281

Grasshopper Sparrow, 40, 177, 183, 197, 216, 222, 271, 

273, 274, 281

Gray Wolf, 38, 172, 177, 178, 216, 217, 287

Grazing, 24, 80, 84, 85, 88, 115, 213, 246, 252, 284, 294, 

312, 313, 315, 316, 317, 319, 321, 322, 323, 324, 325, 

326, 328, 329, 330, 332, 333, 335, 336, 337, 338, 339, 

341, 342, 343, 344, 345, 346, 348, 349, 350, 352, 353, 

355

Grouse, 194, 195, 197, 235, 238

H

Habitat Indicators, 158

Hairstreak, 177, 188, 229, 278, 285

Herbicide Toxicity, 67

Human Health, 13, 12, 61, 89, 91, 262, 282

Hydrology, 90, 127, 159, 161, 272

I

Implementation Planning, 48, 53, 54

Integrated Weed Management, 6, 48, 281, 296

Invasive Plant Spread, 79, 246

Invertebrate, 274, 276, 297

L

Land and Resource Management Plan, ii, 9, 5, 6, 7, 22, 99, 

134, 147, 167, 209, 210, 211, 262, 263, 284, 296

Landbirds, 196, 267, 278

Lanx, 188, 228, 285

Lichens, 112, 297

Life of the Project, 11, 13, 61, 74, 291

Long-term Productivity, 262

LRMP, ii, x, 9, 10, 11, 5, 6, 7, 8, 9, 11, 12, 14, 17, 21, 22, 23, 

44, 53, 54, 57, 89, 90, 118, 126, 146, 147, 170, 171, 182, 

191, 207, 209, 210, 211, 217, 222, 223, 224, 226, 227, 

232, 234, 236, 237, 241, 262, 263

LRMP Amendment, 53

Lynx, x, 172, 173, 174, 215, 280, 283, 285, 286, 287

M

Management Area, 9, 182, 255, 263

Management Indicator Species, x, 148, 166, 167, 177, 190, 

231, 289

Management Objectives, x, 1, 17, 147, 191

Manual, ix, 7, 3, 6, 23, 31, 36, 37, 47, 90, 99, 101, 107, 108, 

113, 129, 138, 146, 161, 170, 177, 202, 250, 252, 260, 

263, 273, 284, 297

Marten, 190, 192, 233, 276, 290

Matrix of Pathways and Indicators, x, 158

Mechanical, 6, 23, 30, 108, 112, 202, 219, 229, 250, 260, 

297

Monitoring, x, 37, 49, 51, 53, 54, 108, 111, 221, 253, 267, 

271, 272, 284, 285, 297, 298

Multiple Chemical Sensitivity, 94

Myotis, 177, 180, 216, 219

N

Native Vegetation, 100
Malheur National Forest, Invasive Plants Treatment Draft Environmental Impact Statement – Chapter 4

305

O

Osprey, 40, 194, 195, 236, 237

P

Pesticide Study, 77, 78

Pollinators, 15, 13, 62, 105, 112

Prime Farmlands, 264

Project Area, 3, 147, 174, 176, 177, 178, 179, 180, 181, 182, 

183, 184, 185, 186, 187, 188, 189, 190

Project Design Features, 10, 9, 32, 49, 52, 53, 97, 271, 300

R

Recreation, x, 10, 48, 82, 83, 84, 87, 88, 97, 213, 253, 254, 

256, 259, 265, 293, 312, 313, 315, 316, 317, 319, 321, 

322, 323, 324, 325, 326, 328, 329, 330, 332, 333, 335, 

336, 337, 338, 339, 341, 342, 343, 344, 345, 346, 348, 

349, 350, 352, 353, 355

Recreation Opportunity Spectrum, x

Regulatory Framework, 89, 99, 118, 132, 147, 170, 241

Restoration, 5, 7, 23, 44, 52, 54, 72, 73, 83, 84, 85, 86, 87, 

113, 202, 242, 269, 274, 279, 300, 312, 313, 315, 316, 

317, 319, 321, 322, 323, 324, 325, 326, 328, 329, 330, 

332, 341

RHCA, x, 147

RMO, x

Roadless Area, x, 176, 255, 284

Rosy Finch, 177, 183, 196, 216, 223

S

Sage Grouse, 39, 173, 177, 184, 194, 197, 223

Sandpiper, 40, 177, 185, 194, 225, 271

Sapsucker, 193, 196, 197

Sensitive Plants, 101, 108, 117

Sensitive Species, 99, 101, 166, 177, 194, 216, 233, 285, 

289, 301

Soil Organisms, 111, 126

Special Forest Products, 41, 105, 112

Species of Conservation Concern, 149, 166, 167, 172, 301

Spot, 12, 15, 16, 24, 36, 43, 53, 54, 58, 62, 64, 70, 73, 111, 

114, 117, 208, 301

Steelhead, 149, 150, 158, 277, 313, 319, 321

Stream Flow, 133

T

Target Species, 1, 2, 4, 17, 18, 20, 28, 55, 245

Toxicity, 138, 146, 203, 204, 278, 302

Treatment Cost-Effectiveness, 12

Treatment Methods, 23, 33, 52, 53, 250

W

Water Quality, 51, 65, 77, 131, 134, 159, 160, 168, 277, 286, 

289

Watershed, ix, 9, 83, 88, 101, 150, 153, 157, 159, 161, 162, 

164, 169, 213, 284, 307, 308, 309, 312, 313, 315, 316, 

317, 318, 319, 321, 322, 323, 324, 325, 326, 328, 329, 

330, 332, 333, 335, 336, 337, 338, 339, 341, 342, 343, 

344, 345, 346, 348, 349, 350, 352, 353,355

wetlands, 303

Wild and Scenic Rivers, 10, 32, 253, 254, 255, 256, 257, 

258, 288, 293, 303

Wilderness Act, 10, 33, 254, 298, 303

Wilderness Area, 33, 254, 257

Wildlife, ix, x, 16, 10, 14, 38, 63, 67, 99, 106, 147, 166, 170, 

171, 172, 173, 174, 175, 176, 177, 178, 179, 181, 184, 

185, 197, 198, 203, 214, 220, 265, 266, 267, 268, 270, 

271, 273, 274, 275, 276, 277, 278, 279, 280, 281, 283, 

284, 285, 286, 287, 288, 292, 293,300, 302

Wolverine, 172, 174, 175, 176, 215, 267, 270, 273, 274, 275, 

280, 283

Woodpecker, 186, 187, 190, 191, 192, 193, 194, 227, 267, 

275, 276
Chapter 4-Malheur National Forest Site-Specific Invasive Plant Treatment Draft Environmental Impact Statement

306

This page left blank intentionally
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement – Appendix A

307

Appendix A – Invasive Plant Inventory Watershed

Analysis for the Malheur National Forest

Prepared by Joseph H. Rausch

December 3, 2012

This report presents an analysis of known invasive plants sites by watershed (HUC 5). Also included are 

other important attributes or concerns about the watersheds that may be associated with the treatment of 

invasive plants. The analysis is presented in watershed groups of the same basin (HUC 3), sub-basin 

(HUC4), or portions of sub-basins. 

The map that follows and the corresponding figures on the following pages show the geographic extent of 

the watershed groups and the levels of infestations, respectively.
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

308

Figure A- 1. Watershed Groups
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

309

Summary of Invasive Plant Infestations by Watershed

In figure A- 2 that follows, Colors represent the watershed group as presented in figure A- 1on the 

previous page; the first column indicates the watershed group (by basin, sub-basin, or a portion thereof), 

and the second column indicates the 5th field HUC. The individual watershed summaries that follow are 

generally presented in the order shown above.
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

310

Figure A- 2. Invasive plants infestation summary
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

311

North Fork John Day Sub-basin (17070202)

Cottonwood Creek (1707020209)

Lower North Fork John Day River (1707020210)

Figure A- 3. North Fork John Day Sub-basin (17070202)
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

312

Cottonwood Creek (1707020209)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 32,994

Special land uses: none

Major streams and water bodies: Fox Creek

Recreation: dispersed campsites

Grazing allotments: Fox, Highway, King, Indian Ridge, Donaldson, Beech Creek, Mt. 

Vernon/John Day, Ferg, Deep Creek

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: US-395, 3945, 3940, 3970, 3950

TES species of concern: steelhead

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 31 28

Scotch thistle 1 0.1

Dalmatian toadflax 4 0.5

St. Johnswort 5 1

leafy spurge 10 9

sulphur cinquefoil 2 0.2

spotted knapweed 4 0.4

diffuse knapweed 4 2

squarrose knapweed 1 0.1

TOTAL 62 41

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 8 4 6 1

Leafy spurge 2 0.1 1 0.07

TOTAL 10 4 7 1 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

313

Lower North Fork John Day River (1707020210)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 3,632

Special land uses: None

Major streams and water bodies: Deer Creek

Recreation: Dispersed Campsites

Grazing allotments: Hamilton, Deep Creek, King

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: None

TES species of concern: Steelhead

Comments: None

Species Watershed Total

Sites Acres

Canada thistle 4 0.4

diffuse knapweed 1 0.1

TOTAL 5 0.5

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2 1 0.07

TOTAL 2 0.2 1 0.07 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

314

Middle Fork John Day Sub-basin (17070203)

Bridge Creek- Middle Fork John Day River (1707020301)

Camp Creek- Middle Fork John Day River (1707020302)

Big Creek- Middle Fork John Day River (1707020303)

Long Creek (1707020304)

Figure A- 4. Middle Fork John Day Sub-basin (17070203)
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

315

Bridge Creek- Middle Fork John Day River (1707020301)

Ranger district: Blue Mountain RD, Prairie City RD

County: Grant

Total FS acreage: 75,877

Special land uses: None

Major streams and water bodies: Middle Fork John Day River, Crawford Creek, Clear Creek, Lunch Creek, 

Bridge Creek, Summit Creek, Crawford Creek

Recreation: Dixie CG, Sumpter Valley Interpretive Site, Dispersed Campsites

Grazing allotments: Sullens, Blue Mountain, Austin, Upper Middle Fork

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads:

US-26, OR-7, 2620, 2622, 1940, 1940-275, 1940-220, 1940-281, 1940-

552, 2645, 2645-019, 2645-017, 2645-025, 2645-011, 2645-299, 2646, 

2646-410, 2646-435, 2646-284, 2640, 2635, 2600-343, 2600-503 (closed)

TES species of concern: steelhead, bull trout, Helodium blandowii

Comments:

A large portion of the Journey Through Time Scenic Byway (US-26, OR-7) 

traverses this watershed; major grazing allotments in this area are vacant 

or are in non-use

Species Watershed Total

Sites Acres

Canada thistle 163 273

Scotch thistle 2 0 .3

Dalmatian toadflax 95 24

St. Johnswort 36 19

houndstongue 68 153

sulphur cinquefoil 1 0 .1

spotted knapweed 14 10

diffuse knapweed 39 24

whitetop 2 0 .2

TOTAL 420 504

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 69 66 45 14

Scotch thistle 1 0 .1 1 0 .007

Dalmatian toadflax 16 2 9 0 .5

St. Johnswort 14 3 7 1

houndstongue 21 12 12 2 1 30 ft. Helodium blandowii

sulphur cinquefoil 1 0 .1 1 0 .03

spotted knapweed 8 4 3 1

diffuse knapweed 16 6 11 0.9

TOTAL 146 94 89 20 1 – 1
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

316

Camp Creek- Middle Fork John Day River (1707020302)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 119,047

Special land uses: Vinegar Hill-Indian Rock Scenic Area, Dixie Mountain Proposed Research 

Natural Area

Major streams and water bodies:

Middle Fork John Day River, Vinegar Creek, Vincent Creek, Little Boulder 

Creek, Granite Boulder Creek, Ruby Creek, Big Boulder Creek, Lick 

Creek, Camp Creek

Recreation: Camp Creek CG, Middle Fork CG, Middle Fork Day Use Site, Deerhorn 

CG, dispersed campsites

Grazing allotments: Upper Middle Fork, Lower Middle Fork, Long Creek, Slide Creek, Camp 

Creek, Balance Creek

Watershed regional priorities: Focus Watershed within Priority Basin (John Day) of the Whole Watershed 

Restoration Initiative (WWRI)

Major roads and/or infested roads:

County Road-20, 2045, 2050, 2055, 2055-518 (closed), 2055-364 

(closed), 2055-432 (closed), 2010, 2614, 2000-120, 2000-139 (closed), 

2000-612 (closed), 3600, 3650, 3660, 3670, 3675, 4500, 4550, 4555, 

4557, 4559, 4559-283, 4559-284

TES species of concern: steelhead, bull trout, Phacelia minutissima (no known invasive plants 

within 100 ft.)

Comments: None

Species

Watershed Total

Sites Acres

Canada thistle 149 326

Scotch thistle 5 2.0

musk thistle 9 8.0

Dalmatian toadflax 26 10.0

yellow toadflax 5 0.5

St. Johnswort 39 70.0

houndstongue 2 0.6

leafy spurge 1 0.1

sulphur cinquefoil 12 15.0

spotted knapweed 33 14.0

diffuse knapweed 16 11.0

squarrose knapweed 1 0.1

meadow knapweed 1 0.1

yellow star-thistle 2 1.0

perennial 

pepperweed 1 0.1

whitetop 6 16.0

Total 308 475
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

317

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 65 63 42 21

musk thistle 2 0 .1

Dalmatian toadflax 11 1 7 0 .3

yellow toadflax 4 0 .4 1 0 .07

St. Johnswort 16 15 13 4

houndstongue 1 0 .05

sulphur cinquefoil 6 3 3 0 .2

spotted knapweed 17 5 11 1

diffuse knapweed 4 1 3 0 .2

squarrose knapweed 1 0 .07

meadow knapweed 1 0 .1 1 0 .01

yellow star-thistle 1 0 .1

perennial 

pepperweed 1 0 .03

whitetop 1 5 1 2

Total 133 95.0 82 29 0 – 0

Big Creek- Middle Fork John Day River (1707020303)

Ranger District: Blue Mountain RD

County: Grant

Total FS acreage: 45,722

Special land uses: Vinegar Hill-Indian Rock Scenic Area

Major streams and water bodies: Middle Fork John Day River, Deep Creek, Big Creek, Slide Creek, Elk

Creek, Mud Lake

Recreation: Dispersed Campsites

Grazing allotments: Slide Creek, York, Lower Middle Fork, Camp Creek, Bear Creek

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads:

County Road-20, 2000-893, 2000-621, 2000-893, 2000-978 (closed), 

2090, 2090-048, 2090-519, 2090-521 (closed), 3690, 3514, 4500, 4560, 

4560-155 (closed), 4560-570 (closed)

TES species of concern: steelhead, bull trout

Comments: None
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

318

Species

Watershed Total

Sites Acres

Canada thistle 23 28.0

Scotch thistle 3 0.4

Dalmatian toadflax 1 0.2

St. Johnswort 39 22.0

sulphur cinquefoil 15 153.0

spotted knapweed 9 15.0

diffuse knapweed 4 2.0

Total 94 221

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 12 5 9 1

Dalmatian toadflax 1 0 .2 1 0 .01

St. Johnswort 18 7 9 1

sulphur cinquefoil 11 36 10 7

spotted knapweed 3 2 2 0 .3

diffuse knapweed 1 0 .1 1 0 .7

TOTAL 46 50 32 10 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

319

Long Creek (1707020304)

Ranger District: Blue Mountain RD

County: Grant

Total FS acreage: 29,911

Special land uses: Long Creek Municipal Water Supply

Major streams and water bodies: Long Creek

Recreation: dispersed campsites

Grazing allotments: Long Creek, War Canyon, Highway, Fox, Keeney Meadows, Mt. 

Vernon/John Day

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: County Road-18, County Road-35, 3945, 3946

TES species of concern: Steelhead

Comments: None

Species

Watershed Total

Sites Acres

Canada thistle 33 11

Dalmatian toadflax 2 0 .2

St. Johnswort 5 0 .7

leafy spurge 2 0 .2

sulphur cinquefoil 4 4

spotted knapweed 7 1

diffuse knapweed 5 0 .5

Russian knapweed 1 0 .1

Total 59 18

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 6 0 .4 1 0 .04

St. Johnswort 1 0 .007

sulphur cinquefoil 1 0 .09 1 0 .0003

diffuse knapweed 2 0 .1 1 0 .04

Russian knapweed 1 0 .07

Total 11 1 3 0 .08 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

320

Upper John Day Sub-basin – Main Stem Portion (17070201)

Reynolds Creek-John Day River (1707020105)

Grub Creek-John Day River (1707020106)

Canyon Creek (1707020107)

Beech Creek (1707020108)

Laycock Creek-John Day River (1707020109)

Fields Creek-John Day River (1707020110)

Figure A- 5. Upper John Day Sub-basin – Main Stem Portion (17070201)
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

321

Reynolds Creek-John Day River (1707020105)

Ranger district: Prairie City RD, Blue Mountain RD

County: Grant

Total FS acreage: 54,573

Special land uses: Strawberry Mountain Wilderness

Major streams and water bodies: John Day River, Reynolds Creek, Deardorf Creek, Roberts Creek, Rail 

Creek, Call Creek

Recreation: Trout Farm CG, Crescent CG, Sunshine Flat TH, Deardorf TH, Reynold 

Creek TH, dispersed campsites

Grazing allotments: Reynolds Creek, Deardorff, Hot Springs, Rail Creek, Dixie

Watershed regional priorities: Within Whole Watershed Restoration Initiative (WWRI) Priority Basin 

(John Day)

Major roads and/or infested roads: US-26, County Road-62, 2600-306, 2600-272 (closed), 2600-390 (closed), 

2600-392 (closed), 1300, 1344, 2635, 2635-629

TES species of concern: Steelhead, Bull Trout

Comments: None

Species Watershed Total

Sites Acres

Canada thistle 16 2

Dalmatian toadflax 114 34

yellow toadflax 1 0 .1

St. Johnswort 14 2

houndstongue 4 10

spotted knapweed 5 0 .6

diffuse knapweed 49 7

meadow knapweed 1 0 .2

TOTAL 204 56

Invasive Species Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0 .05

Dalmatian toadflax 28 3 17 0 .6

St. Johnswort 7 0 .6 4 0 .1

houndstongue 1 0 .5 1 0 .1

spotted knapweed 1 0 .1 1 0 .06

diffuse knapweed 10 0 .7 5 0 .1

meadow knapweed 1 0 .2 1 0 .1

Total 49 5 29 1 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

322

Grub Creek-John Day River (1707020106)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 50,089

Special land uses:

Strawberry Mountain Wilderness, Strawberry Mountain Proposed 

Research Natural Area, Baldy Mountain Proposed Research Natural Area, 

Dixie Mountain Proposed Research Natural Area

Major streams and water bodies: Strawberry Creek, Indian Creek, Pine Creek, Dixie Creek, Bear Creek, 

Grub Creek, Strawberry Lake, Slide Lake, Little Slide Lake

Recreation:

Strawberry Campground, Slide Creek, CG, McNaughton Spring CG, Slide 

Horse Camp, Slide Creek TH, Onion Creek TH, Strawberry Basin TH, 

Indian Creek TH, dispersed campsites

Grazing allotments: Dixie, Roundtop, Indian Creek

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: County Road-18, 3670, 5401, 6001

TES species of concern: steelhead, bull trout, Thelypodium eucosmum (no know invasive plants 

within 100 ft.), Luina serpentina (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 3 0.3

Dalmatian toadflax 9 1

St. Johnswort 2 0.2

spotted knapweed 3 0.4

diffuse knapweed 1 0.1

TOTAL 18 2

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0.006

Dalmatian toadflax 1 0.2 1 0.1

spotted knapweed 3 0.3 1 0.07

TOTAL 5 0.5 2 0.2 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

323

Canyon Creek (1707020107)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 59,583

Special land uses: Strawberry Mountain Wilderness, Canyon Creek Research Natural Area

Major streams and water bodies: Canyon Creek, West Fork Canyon Creek, Middle Fork Canyon Creek, 

Canyon Meadows Reservoir

Recreation: Wickiup CG, Canyon Meadows CG, dispersed campsites

Grazing allotments: Seneca, Dark Canyon, Williams Pasture, Joaquin, Fawn Spring

Watershed regional priorities:

Within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: US-395, County Road-65, 1500, 6510, 3920, 1516, 1520, 1530

TES species of concern: steelhead, Thelypodium eucosmum (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 2 0.2

Scotch thistle 6 0.6

Dalmatian toadflax 22 3

St. Johnswort 1 0.1

houndstongue 1 0.1

leafy spurge 1 0.3

sulphur cinquefoil 6 0.7

spotted knapweed 6 0.6

diffuse knapweed 14 4

Russian knapweed 3 0.3

squarrose knapweed 1 0.1

whitetop 3 0.3

TOTAL 66 10

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0 .2 1 0 .06

Scotch thistle 2 0 .2 1 0 .1

Dalmatian toadflax 11 0 .04 4 0 .2

houndstongue 1 0 .04

sulphur cinquefoil 2 0 .2

spotted knapweed 2 0 .2 1 0 .04

diffuse knapweed 5 2 2 0 .4

Russian knapweed 1 0 .1 1 0 .01

squarrose knapweed 1 0 .1 1 0 .08

whitetop 1 0 .02

TOTAL 28 4 11 1 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

324

Beech Creek (1707020108)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 40,568

Special land uses: none

Major streams and water bodies: Beech Creek, Clear Creek, Lake Creek, Tinker Creek, Magone Lake

Recreation: Magone Lake Recreation Area, Beech Creek CG, Raddue Forest Camp, 

dispersed campsites

Grazing allotments: Fox, Mt. Vernon/John Day, Beech Creek, McCullough, Herberger, 

Roundtop

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: US-395, County Road-32, 3600, 3618, 3620, 3940, 3900-131

TES species of concern: steelhead

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 17 12

Scotch thistle 5 0.7

Dalmatian toadflax 13 2

St. Johnswort 11 2

sulphur cinquefoil 6 9

spotted knapweed 26 27

diffuse knapweed 8 10

Russian knapweed 2 0.2

TOTAL 88 63

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 7 0 .6 3 0 .1

Scotch thistle 4 0 .3 1 0 .05

Dalmatian toadflax 9 1 5 0 .3

St. Johnswort 3 0 .6 1 0 .1

sulphur cinquefoil 3 3 3 0 .4

spotted knapweed 15 8 12 2

diffuse knapweed 6 8 6 3

Russian knapweed 2 0 .2 1 0 .01

TOTAL 49 21 32 6 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

325

Laycock Creek-John Day River (1707020109)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 30,473

Special land uses: none

Major streams and water bodies: Riley Creek, Laycock Creek, Birch Creek

Recreation: dispersed campsites

Grazing allotments: Deadhorse, Hanscomb, Seneca, McClellan, Field Peak

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 4900, 2190

TES species of concern: steelhead, Thelypodium eucosmum (no know invasive plants within 100 

ft.), Luina serpentina (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 3 0.3

Dalmatian toadflax 6 0.8

yellow toadflax 1 0.1

St. Johnswort 1 0.1

spotted knapweed 4 0.6

diffuse knapweed 2 0.2

whitetop 3 0.5

TOTAL 20 3

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0 .2 1 0 .06

Dalmatian toadflax 2 0 .2 1 0 .07

spotted knapweed 1 0 .05

diffuse knapweed 1 0 .1 1 0 .08

whitetop 2 0 .3 1 0 .06

TOTAL 8 1 4 0 .3 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

326

Fields Creek-John Day River (1707020110)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 25,296

Special land uses: Cedar Grove Botanical Special Interest Area

Major streams and water bodies: Fields Creek, Belshaw Creek

Recreation: Billy Fields CG, Cedar Grove TH, dispersed campsites

Grazing allotments: Fields Peak, Aldrich

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 2100, 2140, 3955, 3955-486, 3955-417

TES species of concern: steelhead, Luina serpentina

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 5 3

Dalmatian toadflax 12 1

yellow toadflax 1 0.1

St. Johnswort 8 1

sulphur cinquefoil 5 0.5

spotted knapweed 7 0.7

diffuse knapweed 6 0.6

TOTAL 44 7

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2 1 0.08

Dalmatian toadflax 7 0.5 2 0.1 1 57 ft. Luina serpentina

yellow toadflax 1 0.02

St. Johnswort 2 0.2 2 0.07

sulphur cinquefoil 2 0.1

spotted knapweed 5 0.4 2 0.01 1 51 ft. Luina serpentina

diffuse knapweed 2 0.1

TOTAL 21 2 7 0.4 2 – 1
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

327

Upper John Day Sub-basin – South Fork Portion (17070201)

Upper South Fork John Day River (1707020101)

Middle South Fork John Day River (1707020102)

Murderers Creek (1707020103)

Figure A- 6. Upper John Day Sub-basin - South Fork Portion (17070201)
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

328

Upper South Fork John Day River (1707020101)

Ranger district: Blue Mountain RD, Emigrant Creek RD

County: Grant, Harney

Total FS acreage: 63,396

Special land uses: none

Major streams and water bodies: South Fork John Day River, Bear Creek, Lonesome Creek, Lewis Creek, 

Spoon Creek

Recreation: dispersed campsites

Grazing allotments: Izee, Lonesome, Smoky, Lewis Creek, Snowshoe, Rosebud

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: County Road-63, 4700, 3160, 3150, 4785, 6370

TES species of concern: Calochortus longibarbatus var. peckii (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 33 21

Dalmatian toadflax 4 0.4

St. Johnswort 1 0.1

Russian knapweed 1 0.1

whitetop 6 25

TOTAL 45 47

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 20 14 13 10

Dalmatian toadflax 2 0 .2 1 0 .08

St. Johnswort 1 0 .1 1 0 .08

Russian knapweed 1 0 .1

whitetop 3 2 1 0 .2

TOTAL 27 18 16 11 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

329

Middle South Fork John Day River (1707020102)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 34,966

Special land uses: Murderer’s Creek Wild Horse Territory

Major streams and water bodies: Deer Creek, Buck Creek, Corral Creek, Vester Creek

Recreation: dispersed campsites

Grazing allotments: Murderer’s Creek, Frenchy, Rosebud, Poison

Watershed regional priorities: within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 2400, 2400-338, 6370, 6370-407

TES species of concern: steelhead

Comments: none

Species Watershed Total

Sites Acres

musk thistle 2 0.2

Dalmatian toadflax 1 0.1

St. Johnswort 1 0.2

houndstongue 2 99

sulphur cinquefoil 1 0.8

spotted knapweed 3 0.6

diffuse knapweed 2 5

Russian knapweed 1 0.1

whitetop 20 6

TOTAL 33 112

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

musk thistle 1 0 .1 1 0 .1

houndstongue 2 23 2 1

sulphur cinquefoil 1 0 .02

spotted knapweed 1 0 .3 1 0 .2

whitetop 11 4 10 2

TOTAL 16 28 14 3 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

330

Murderers Creek (1707020103)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 65,101

Special land uses: Shaketable Research Natural Area, Murderer’s Creek Wild Horse Territory

Major streams and water bodies: Murderer’s Creek, Tex Creek, South Fork Murderer’s Creek, Thorn Creek

Recreation: Murderer’s Creek GS, Deer Creek GS, dispersed campsites

Grazing allotments: Murderer’s Creek, Fields Peak, Aldrich

Watershed regional priorities: Priority Terrestrial Restoration and Conservation Watershed (TRACS), 

within Whole Watershed Restoration Initiative (WWRI) Priority Basin (John 

Day)

Major roads and/or infested roads: 2100, 2160, 2150, 2170, 2180, 2490, 2480

TES species of concern: steelhead, Luina serpentina (no know invasive plants within 100 ft.), 

Phacelia minutissima (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 1 8

Dalmatian toadflax 6 0.6

St. Johnswort 5 1

sulphur cinquefoil 3 0.3

spotted knapweed 5 0.5

diffuse knapweed 3 0.4

Russian knapweed 2 0.2

yellow star-thistle 1 0.1

perennial pepperweed 1 0.1

whitetop 2 0.2

TOTAL 29 11

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Dalmatian toadflax 3 0 .2 2 0 .05

St. Johnswort 3 0 .2

spotted knapweed 2 0 .2 2 0 .02

diffuse knapweed 2 0 .3 2 0 .1

Russian knapweed 2 0 .1

yellow star-thistle 1 0 .07

perennial pepperweed 1 0 .03

whitetop 1 0 .1 1 0 .03

TOTAL 15 1 7 0 .2 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

331

Upper Malheur Sub-basin – North Fork Portion (17050116)

Upper North Fork Malheur River (1705011611)

Little Malheur River (1705011612)

Figure A- 7. Upper Malheur Sub-basin – North Fork Portion (17050116)
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

332

Upper North Fork Malheur River (1705011611)

Ranger district: Prairie City RD

County: Grant, Baker

Total FS acreage: 96,732

Special land uses: Monument Rock Wilderness, North Fork Malheur Wild and Scenic River, 

Dugout Research Natural Area

Major streams and water bodies: North Fork Malheur River, Crane Creek, Little Crane Creek, Bear Creek, 

Elk Creek, Flat Creek, Swamp Creek, Spring Creek, Cow Creek, Sheep 

Creek

Recreation: Short Creek CG, Elk Creek CG, Little Crane CG, North Fork Malheur CG, 

Crane Crossing CG, Crane Prairie CG, North Fork TH, Crane Creek TH, 

Sheep Creek TH, Elf Flat TH, dispersed campsites

Grazing allotments: Spring Creek, Ott, Flag Prairie, Crane Prairie, North Fork

Watershed regional priorities: Priority Terrestrial Restoration and Conservation Watershed (TRACS)

Major roads and/or infested roads: 1300, 1400, 1600, 1370, 1675,1665, 1663

TES species of concern: bull trout

Comments: Significant groundwater dependent ecosystems throughout watershed

Species Watershed Total

Sites Acres

Canada thistle 70 47

Scotch thistle 2 1

Dalmatian toadflax 6 0.8

St. Johnswort 1 0.2

houndstongue 17 21

spotted knapweed 2 0.3

diffuse knapweed 10 5

whitetop 4 1

TOTAL 112 76

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 10 4 7 1

Scotch thistle 1 0 .09

Dalmatian toadflax 1 0 .01

houndstongue 7 2 5 0 .5

spotted knapweed 1 0 .04

diffuse knapweed 1 0 .2 1 0 .06

whitetop 2 0 .2 1 0 .01

TOTAL 23 7 14 2 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

333

Little Malheur River (1705011612)

Ranger district: Prairie City RD

County: Grant, Baker, Malheur

Total FS acreage: 31,525

Special land uses: Monument Rock Wilderness

Major streams and water bodies: Little Malheur River, Camp Creek, Squaw Creek

Recreation: Elk Flat Spring CG, Little Malheur TH, Horse Creek TH, Table Rock TH, 

dispersed campsites

Grazing allotments: Spring Creek, North Fork, Flag Prairie

Watershed regional priorities: none

Major roads and/or infested roads: 1600, 1672, 1370

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 26 7

Scotch thistle 4 0.7

musk thistle 2 3

St. Johnswort 2 0.4

houndstongue 36 9

spotted knapweed 1 1

diffuse knapweed 1 0.2

whitetop 6 2

TOTAL 78 23

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 6 0.6 1 0.1

Scotch thistle 1 0.2 1 0.06

musk thistle 1 2 1 0.6

St. Johnswort 1 0.2 1 0.1

houndstongue 11 2 5 0.2

spotted knapweed 1 0.09

TOTAL 21 5 9 1 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

334

Upper Malheur Sub-basin – Main Stem Portion (17050116)

Headwaters Malheur River (1705011601)

Wolf Creek (1705011602)

Pine Creek (1705011603) Otis Creek (1705011606)

Griffin Creek-Upper Malheur River (1705011605)

Figure A- 8. Upper Malheur Sub-basin – Main Stem Portion (17050116)
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

335

Headwaters Malheur River (1705011601)

Ranger district: Prairie City RD, Emigrant Creek RD

County: Grant, Harney

Total FS acreage: 111,947

Special land uses: Strawberry Mountain Wilderness, Malheur Wild and Scenic River, Fergy 

Spruce Grove Proposed Botanical Special Interest Area

Major streams and water bodies: Malheur River, McCoy Creek, Summit Creek, Big Creek, Lake Creek, 

Crooked Creek, Bosenberg Creek, Mud Lake, Little Mud Lake, High Lake

Recreation: Big Creek CG, Murray CG, Lake Creek Organizational Camp, Malheur 

Ford CG, Huddleston SnoPark, Hog Flat TH, Malheur Ford TH, Lake 

Creek TH, Meadow Fork TH, Big Creek/Snowshoe TH, Skyline TH, 

Huddleston TH, Starvation TH, dispersed campsites

Grazing allotments: Summit Prairie, Lake Creek, Logan Valley, McCoy Creek, Dollar Basin, 

Star Glade, Bluebucket, Central Malheur, Antelope

Watershed regional priorities: none

Major roads and/or infested roads: County Road-62, 1600, 1640, 1648, 1649, 1651, 1647, 1643, 1630, 1560, 

1400, 1450

TES species of concern: bull trout

Comments: Significant groundwater dependent ecosystems in Logan Valley

Species Watershed Total

Sites Acres

Canada thistle 71 26

Scotch thistle 1 0.1

bull thistle 1 0.1

Dalmatian toadflax 9 3

yellow toadflax 2 0.4

St. Johnswort 5 0.5

houndstongue 3 3

sulphur cinquefoil 2 5

spotted knapweed 9 4

diffuse knapweed 9 1

perennial pepperweed 1 0.6

whitetop 2 0.2

TOTAL 115 44

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 14 2 7 0.6

Dalmatian toadflax 1 0.3 1 0.1

yellow toadflax 1 0.2 1 0.1

St. Johnswort 1 0.1 1 0.006

sulphur cinquefoil 1 2 1 0.6

spotted knapweed 3 1 2 0.4

diffuse knapweed 1 0.02

whitetop 1 0.1 1 0.02

TOTAL 23 6 14 2 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

336

Wolf Creek (1705011602)

Ranger district: Emigrant Creek RD

County: Grant, Harney

Total FS acreage: 70,865

Special land uses: none

Major streams and water bodies: Wolf Creek, Calamity Creek

Recreation: Rock Springs CG, dispersed campsites

Grazing allotments: Antelope, Wolf Mountain, West Malheur, Van, Calamity, Muddy

Watershed regional priorities: none

Major roads and/or infested roads: 1500, 1700, 1630, 1710, 1712, 1705, 1705-378, 1780, 1550-804

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 93 25

Dalmatian toadflax 12 4

houndstongue 3 0.2

diffuse knapweed 2 0.1

Russian knapweed 5 0.4

perennial pepperweed 1 0.1

whitetop 18 9

TOTAL 134 39

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 43 8 30 3

Dalmatian toadflax 6 1 5 0.3

Russian knapweed 3 0.2 1 0.001

perennial pepperweed 1 0.009

whitetop 8 5 6 1

TOTAL 61 14 42 4 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

337

Pine Creek (1705011603)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 32,021

Special land uses: none

Major streams and water bodies: Pine Creek

Recreation: dispersed campsites

Grazing allotments: Calamity, Alkali, Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: 2800, 2850, 2855, 2800-189, 2850-262, 2850-951 (closed), 2850-265 

(closed), 2800-336 (closed)

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 68 67

Scotch thistle 1 0.1

Dalmatian toadflax 26 11

spotted knapweed 1 0.1

whitetop 6 0.6

TOTAL 102 79

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 19 30 9 10

Dalmatian toadflax 4 0.7 2 0.1

TOTAL 23 31 11 10 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

338

Griffin Creek-Upper Malheur River (1705011605)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 7,343

Special land uses: none

Major streams and water bodies: Muddy Creek

Recreation: dispersed campsites

Grazing allotments: Muddy, Alkali, Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: 1705, 2850, 2850-135

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 11 3

Dalmatian toadflax 1 0.1

diffuse knapweed 1 0.1

whitetop 7 0.7

TOTAL 20 4

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 3 2 2 0.5

whitetop 2 0.2 1 0.1

TOTAL 5 2 3 0.6 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

339

Otis Creek (1705011606)

Ranger district: Prairie City RD

County: Grant, Harney

Total FS acreage: 20,025

Special land uses: none

Major streams and water bodies: Cottonwood Creek

Recreation: dispersed campsites

Grazing allotments: Ott, Spring Creek

Watershed regional priorities: none

Major roads and/or infested roads: 1400, 1420, 1663

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 120 14

Scotch thistle 16 3

houndstongue 1 0.1

perennial pepperweed 1 0.1

whitetop 1 1

TOTAL 139 18

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 11 0.7 3 0.1

Scotch thistle 3 1 2 0.6

perennial pepperweed 1 0.1 1 0.03

TOTAL 15 2 6 0.07 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

340

Silvies River Sub-basin (17120002) 

Headwaters Silvies River (1712000201)

Bear Creek (1712000202)

Upper Silvies River (1712000203)

Middle Silvies River (1712000204)

Emigrant Creek (1712000205)

Sage Hen Creek (1712000206)

Figure A- 9. Silvies River Sub-basin – 17120002
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

341

Headwaters Silvies River (1712000201)

Ranger district: Blue Mountain RD

County: Grant

Total FS acreage: 61,343

Special land uses: none

Major streams and water bodies: Silvies River, Scotty Creek, Wickiup Creek

Recreation: Starr Ridge CG, dispersed campsites

Grazing allotments: Scotty Creek, Jack Creek, Snowshoe, Flagtail, Deadhorse, Hanscomb, 

Seneca, County Road, Windy Point, Hunter Cabin, Pearson

Watershed regional priorities: Priority Terrestrial Restoration and Conservation Watershed (TRACS)

Major roads and/or infested roads: US-395, County Road-63, 2400, 3100, 2100, 4900, 2195, 2400-011, 2400-

017, 2400-022, 3780-274, 3780-070 (closed)

TES species of concern: Botrychium crenulatum, Carex idahoa (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 19 3

Scotch thistle 11 14

Dalmatian toadflax 32 4

yellow toadflax 11 2

St. Johnswort 2 0.2

houndstongue 10 29

sulphur cinquefoil 1 0.1

spotted knapweed 6 2

diffuse knapweed 6 0.6

Russian knapweed 1 0.1

perennial pepperweed 1 0.1

whitetop 4 0.6

TOTAL 104 56

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 9 1 6 0.3 1 54 ft. Botrychium crenulatum

Scotch thistle 2 8 1 2

Dalmatian toadflax 8 0.6 3 0.2

yellow toadflax 5 0.6 1 0.0005

houndstongue 4 9 4 2

spotted knapweed 1 0.1

perennial pepperweed 1 0.1 1 0.02

whitetop 3 0.4 2 0.02

TOTAL 33 20 18 4 1 – 1
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

342

Bear Creek (1712000202)

Ranger district: Blue Mountain RD, Emigrant Creek RD

County: Grant

Total FS acreage: 52,344

Special land uses: Strawberry Mountain Wilderness

Major streams and water bodies: Bear Creek, Antelope Creek

Recreation: Parish Cabin CG, dispersed campsites

Grazing allotments: Dark Canyon, Antelope, Wolf Mountain, Bridge Creek, Hunter Cabin

Watershed regional priorities: none

Major roads and/or infested roads: 1600, 1500, 1601,1619, 1710

TES species of concern: Carex idahoa (no know invasive plants within 100 ft.), Thelypodium 

eucosmum (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 5 0.5

Scotch thistle 1 0.1

Dalmatian toadflax 20 3

yellow toadflax 1 0.1

St. Johnswort 3 0.4

sulphur cinquefoil 2 0.2

spotted knapweed 5 0.5

diffuse knapweed 4 0.4

whitetop 1 0.1

TOTAL 42 5

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0.09

Dalmatian toadflax 9 0.3 4 0.2

St. Johnswort 3 0.1 1 0.002

sulphur cinquefoil 1 0.02 1 0.04

diffuse knapweed 2 0.2 1 0.08

TOTAL 16 0.7 7 0.3
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

343

Upper Silvies River (1712000203)

Ranger district: Emigrant Creek RD, Blue Mountain RD

County: Grant, Harney

Total FS acreage: 80,687

Special land uses: none

Major streams and water bodies: Silvies River, Bridge Creek, Camp Creek, Crooked Creek, Trout Creek

Recreation: Joaquin Miller CG, dispersed campsites

Grazing allotments: Scotty Creek, Camp Creek, Koehler, Antelope, Bridge Creek, Silvies, 

Crooked Creek, House Creek, Calamity, Big Sagehen, Alkali, Devine, Pine 

Creek

Watershed regional priorities: none

Major roads and/or infested roads: US-395, 3700, 2800, 2700, 3935, 2800-021, 3700-843, 3700-115, 3700-

841, 3700-855, 3765-932, 3765-868, 3765-912

TES species of concern: Astragalus tegetarioides, Carex idahoa

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 69 28

Dalmatian toadflax 42 7

houndstongue 15 15

sulphur cinquefoil 1 0.1

spotted knapweed 3 0.3

diffuse knapweed 5 1

Russian knapweed 1 0.1

whitetop 5 0.5

TOTAL 141 52

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 30 11 21 2 1 0 ft. Carex idahoa

Dalmatian toadflax 20 2 4 0.4 3 0 ft. Astragalus tegetarioides

houndstongue 5 6 2 0.7 1 0 ft. Carex idahoa

sulphur cinquefoil 1 0.1 1 0.01

diffuse knapweed 1 0.3 3 0.1

Russian knapweed 3 0.03

whitetop 1 0.1

TOTAL 62 20 31 3 5 – 2
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

344

Middle Silvies River (1712000204)

Ranger district: Emigrant Creek RD

County: Harney, Grant

Total FS acreage: 61,529

Special land uses: none

Major streams and water bodies: Silvies River, Myrtle Creek, Sage Hen Creek

Recreation: West Myrtle TH, dispersed campsites

Grazing allotments: Myrtle, Scatfield, Big Sagehen, West Myrtle, Scotty Creek, Crooked Creek, 

Silvies

Watershed regional priorities: none

Major roads and/or infested roads: 3100, 3700, 3765, 3130, 3125, 3120, 3140

TES species of concern: Astragalus tegetarioides, Carex idahoa (no know invasive plants within 

100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 47 12

Dalmatian toadflax 12 2

St. Johnswort 1 0.1

houndstongue 1 0.2

spotted knapweed 5 1

Russian knapweed 9 1

whitetop 21 3

TOTAL 96 19

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 17 3 9 1

Dalmatian toadflax 4 1 4 0.2

spotted knapweed 2 0.02 1 0.006 1 0 ft. Astragalus tegetarioides

Russian knapweed 1 0.07

whitetop 6 0.4 3 0.1 1 79 ft. Astragalus tegetarioides

TOTAL 30 5 17 1 2 – 2
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

345

Emigrant Creek (1712000205)

Ranger district: Emigrant Creek RD

County: Harney, Grant

Total FS acreage: 130,885

Special land uses: Stinger Creek Proposed Research Natural Area

Major streams and water bodies: Emigrant Creek, Hay Creek, Yellowjacket Creek, Sawtooth Creek, Whisky Creek, 

Crowsfoot Creek, Yellowjacket Lake

Recreation: Yellow Jacket CG, Emigrant CG, Falls CG, Pendleton Spring CG, Alder Springs 

CG, Donnelly CG, dispersed campsites

Grazing allotments: Rainbow, West Myrtle, Sawtooth, Blue Creek, Hughet Valley, Snow Mountain, 

Allison, Donnelly, Green Butte

Watershed regional priorities: none

Major roads and/or infested roads: 3700, 4700, 4300, 4100, 3746, 3745, 3740, 4780, 4781, 4770, 4357, 4360, 4356, 

4370, 4341, 4340, 4334, 4335, 4320, 4332, 4140

TES species of concern: Calochortus longibarbatus var. peckii

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 67 27

Dalmatian toadflax 40 7

yellow toadflax 5 6

St. Johnswort 3 0.3

houndstongue 2 3

spotted knapweed 7 0.8

diffuse knapweed 11 1

Russian knapweed 11 0.9

perennial pepperweed 4 0.4

whitetop 9 0.8

TOTAL 159 47

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 28 6 12 0.9

Dalmatian toadflax 15 0.8 3 0.1

yellow toadflax 3 2 3 0.6 3 0 ft. Calochortus longibarbatus var. peckii

spotted knapweed 3 0.2 2 0.08

diffuse knapweed 3 0.2 2 0.1

Russian knapweed 3 0.1 1 0.05

perennial pepperweed 2 0.06

whitetop 4 0.3 2 0.1

TOTAL 61 10 25 2 3 – 1
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

346

Sage Hen Creek (1712000206)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 2,075

Special land uses: none

Major streams and water bodies: none

Recreation: dispersed campsites

Grazing allotments: Donnelly

Watershed regional priorities: none

Major roads and/or infested roads: County Road-127, 4100

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 1 0.1

Dalmatian toadflax 3 0.2

spotted knapweed 1 0.5

TOTAL 5 1

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

None

TOTAL 0 0 0 0 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

347

Silver Creek Sub-basin (17120004)

Claw Creek (1712000401)

Upper Silver Creek (1712000402)

Middle Silver Creek (1712000403)

Figure A- 10. Silver Creek Sub-basin (17120004)
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

348

Claw Creek (1712000401)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 29,620

Special land uses: Dry Mountain Research Natural Area

Major streams and water bodies: Wickiup Creek, Claw Creek

Recreation: dispersed campsites

Grazing allotments: Silver Creek, Donnelly, Green Butte

Watershed regional priorities: none

Major roads and/or infested roads: 4100, 4335, 4130

TES species of concern: Astragalus tegetarioides (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Dalmatian toadflax 2 0.7

houndstongue 1 0.1

TOTAL 3 1

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

None

TOTAL 0 0 0 0 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

349

Upper Silver Creek (1712000402)

Ranger district: Emigrant Creek RD

County: Harney, Crook

Total FS acreage: 96,071

Special land uses: Silver Creek Proposed Research Natural Area

Major streams and water bodies: Silver Creek, Sawmill Creek, Nicoll Creek, Delintment Creek, Delintment 

Lake

Recreation: Buck Springs CG, Tip Top Spring CG, Delintment Lake CG, dispersed 

campsites

Grazing allotments: Allison, Silver Creek, Sawmill, Buck Mountain, Lower Nicoll

Watershed regional priorities: none

Major roads and/or infested roads: 4100, 4500, 4170, 4160, 4175, 4161, 4545, 4535, 4510, 4525

TES species of concern: Astragalus tegetarioides (no know invasive plants within 100 ft.), 

Calochortus longibarbatus var. peckii (no know invasive plants within 100 

ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 4 0.3

Dalmatian toadflax 5 1

houndstongue 1 0.1

spotted knapweed 1 0.2

diffuse knapweed 4 1

whitetop 2 0.1

TOTAL 17 3

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 1 0.04 1 0.0003

Dalmatian toadflax 1 .09

whitetop 1 .04

TOTAL 3 0.2 1 0.0003 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

350

Middle Silver Creek (1712000403)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 28,376

Special land uses: Dry Mountain Research Natural Area

Major streams and water bodies: none

Recreation: Pine Springs Overlook, dispersed campsites

Grazing allotments: Green Butte, Donnelly

Watershed regional priorities: none

Major roads and/or infested roads: 4100, 4107, 4120, 4126

TES species of concern: Astragalus tegetarioides (no know invasive plants within 100 ft.)

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 4 15

Scotch thistle 1 0.1

Dalmatian toadflax 7 4

whitetop 1 0.2

TOTAL 13 19

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2

Scotch thistle 1 0.1

Dalmatian toadflax 1 0.2

TOTAL 4 0.5 0 0 0 – 0
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

351

Harney-Malheur Lakes Sub-basin (17120001)

North Basin (1712000101)

Malheur Slough (1712000102)

Figure A- 11. Harney-Malheur Lakes Sub-basin (17120001)
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

352

North Basin (1712000101)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 32,979

Special land uses: none

Major streams and water bodies: Rattlesnake Creek, Poison Creek

Recreation: Idlewild CG, dispersed campsites

Grazing allotments: Myrtle, Devine, Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: US-395, 2800, 2800-480, 2810, 2810-478, 2810-482 (closed), 2820, 2820-

216, 2820-028, 3935, 3900-958,

TES species of concern: Astragalus tegetarioides

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 80 21

Scotch thistle 2 0.2

Dalmatian toadflax 112 26

houndstongue 4 0.6

spotted knapweed 4 0.8

diffuse knapweed 6 1

Russian knapweed 5 0.4

perennial pepperweed 2 0.9

whitetop 14 15

TOTAL 229 66

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 14 7 9 2

Dalmatian toadflax 30 3 14 0.3 1 0 ft. Astragalus tegetarioides

houndstongue 4 0.5 2 0.07

spotted knapweed 1 0.03 1 0.02

diffuse knapweed 3 0.2 1 0.02

Russian knapweed 2 0.2 1 0.03

whitetop 6 5 3 0.4

TOTAL 60 16 31 3 1 – 1
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

353

Malheur Slough (1712000102)

Ranger district: Emigrant Creek RD

County: Harney

Total FS acreage: 13,732

Special land uses: none

Major streams and water bodies: Cow Creek

Recreation: Call Meadows SnoPark, dispersed campsites

Grazing allotments: Pine Creek

Watershed regional priorities: none

Major roads and/or infested roads: 2800, 2820, 2810, 2850, 2830, 2815, 2820-499, 2815-700

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 37 22

Dalmatian toadflax 23 6

Russian knapweed 1 0.1

whitetop 5 0.3

TOTAL 66 28

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

Canada thistle 2 0.2 2 0.04

TOTAL 2 0.2 2 0.04 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

354

Deschutes River Basin (170703)

South Fork Beaver Creek (1707030305)

Figure A- 12. Deschutes River Basin (170703), South Fork Beaver Creek (1707030305)
Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement-Appendix A

355

South Fork Beaver Creek (1707030305)

Ranger district: Emigrant Creek RD

County: Harney, Grant

Total FS acreage: 7,428

Special land uses: none

Major streams and water bodies: Freeman Creek

Recreation: dispersed campsites

Grazing allotments: Sawmill, Allison, Little Mowich

Watershed regional priorities: none

Major roads and/or infested roads: 4100

TES species of concern: none

Comments: none

Species Watershed Total

Sites Acres

Canada thistle 1 0.1

TOTAL 1 0.1

Invasive Species

Within 100 ft.

of Stream

Within 25 ft.

of Stream

Within 100 ft.

of TES Plant

Sites Acres Sites Acres Sites Distance TES Species

None

TOTAL 0 0 0 0 0 – 0
Appendix A-Malheur National Forest Site-Specific Invasive Plants Treatment Draft Environmental Impact Statement

356

This page left blank intentionally