United States 

Department of 

Agriculture 

Forest Service 

Pacific 

Northwest 

Region 

Olympic National Forest 

Final Environmental 

Impact Statement 

And Record of Decision 

Beyond Prevention: 

Site-Specific Invasive Plant 

Treatment Project 

March 17, 2008 

Clallam, Grays Harbor, Jefferson, and 

Mason Counties in the State of Washington 
 

 

 

 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its 

programs and activities on the basis of race, color, national origin, gender, religion, 

age, disability, political beliefs, sexual orientation, or marital or family status. (Not all 

prohibited bases apply to all programs.) Persons with disabilities who require 

alternative means for communication of program information (Braille, large print, 

audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice 

and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil 

Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, 

Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an 

equal opportunity provider and employer. 
ROD - 1

Record of Decision 

Introduction 

I have decided to treat invasive plants on the Olympic National Forest (Forest) within the state of 

Washington. I am approving integrated manual, mechanical, herbicide, and restoration treatments on 

3,800 acres of known infestations, as well as on future detections within and outside mapped treatment 

areas. The treatments will be done according to Project Design Features that limit the extent and method 

of treatment appropriate to site conditions. The project will be implemented over the next five to ten 

years or longer, depending on treatment effectiveness and funding. Treatment objectives and 

prescription vary depending on the values at risk from invasive species; the biology of particular 

invasive plant species, the proximity to water and other sensitive resources, and the size of the 

infestation (these factors may change over time). 

My decision is based on the analysis contained in the 2008 Final Environmental Impact Statement 

(FEIS), along with public comments, interagency consultation, and government to government 

discussions with Indian tribes. The FEIS incorporates the best available science related to invasive plant 

management on National Forest system lands and is tiered to the Pacific Northwest Invasive Plant 

Program Final Environmental Impact Statement (R6 2005 FEIS).1

The invasive plant treatments will be implemented in conjunction with on-going invasive plant 

management efforts, including prevention practices such as cleaning heavy equipment, using weed-free 

straw and mulch, using pelletized or certified weed free feed, roads management, and restoration of 

disturbed areas. 

Purpose and Need 

With this project, the Forest Service is responding to the need for timely containment, control, and/or 

eradication of invasive plants that are currently known and those discovered in the future. High priority 

target invasive species include herb Robert, knapweed, hawkweed, knotweed, Canada thistle, and reed 

canarygrass. These sites are predominantly located in disturbed areas: along road systems, in timber 

sale units (e.g., Matwat Timber Sale), at the Lake Quinault summer residences, in administrative sites 

(e.g., Dennie Ahl seed orchard, Snider Work Center, Quinault Ranger Station), in high public use areas 

(parking areas, viewpoints), in managed areas such as plantations, and in areas utilized for recreation 

such as campgrounds, dispersed recreation, etc. (Quinault Loop Trail, OHV Slab camp quarry, Seal 

Rock Campground, etc,). 

Places where ecosystem functioning and native plant communities are of high value are also affected; 

these include meadow systems (Mint Meadow, Schmidt Knob, Skokomish Savannah Restoration Site, 

Matheny Prairie); sphagnum bogs (e.g., Cranberry Bog); Research Natural Areas (e.g., Wet Weather 

Creek and Quinault); and/or wilderness areas (Buckhorn, Colonel Bob, The Brothers, Mt. Skokomish 

and Wonder Mountain Wilderness). Plant community functioning has been disrupted and native 

vegetation has been replaced by invasive plants in some areas. Without treatment, these weed sites will 

further displace native plant communities, and continue to spread. Invasive plants have been estimated 

 

1

 The R6 2005 FEIS contains detailed analysis for invasive plant management throughout the region. In October 2005, the R6 

Regional Forester signed a Record of Decision (R6 2005 ROD) which added standards for invasive plant management to the 

Olympic National Forest Plan, intended to effectively manage invasive plants while minimizing adverse effects of treatment. 
The purpose of this project is to control invasive plants in a cost-effective manner that complies with the 

R6 2005 ROD and other management direction. Without effective treatment, invasive plants would 

continue to spread within these and other special areas on and adjacent to the National Forest. Invasive 

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

Thus, the Forest Service needs the flexibility to adapt to changing conditions, and rapidly respond to 

invasive plant threats that may be currently 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 Selected Alternative 

I have selected Alternative B (the Proposed Action) described in the Beyond Prevention: Site-specific 

Invasive Plant Project FEIS, including all portions described in Chapter 2, including the Common 

Control Measures, Implementation Planning Process, and Project Design Features (PDFs)and Buffers. 

Alternative B allows for a wide range of invasive plant treatment options on Olympic National Forest 

system lands. Treatments will be done according to PDFs. The PDFs limit the herbicide formulation 

and application method that may be used in sensitive areas (e.g. along streams, near roadside ditches 

with higher risk to deliver herbicides into streams, and near botanical species of local interest). 

Alternative B incorporates all practicable measures to minimize environmental harm while effectively 

treating invasive plants. Components of the decision are summarized below. 

Table 1. Components of the Selected Alternative 

 Component Selected Alternative B 

(Proposed Action) 

Estimated Acres of Current 

Inventory Approved For Treatment 

3,830 

Floating and Submerged Aquatic 

Invasive Plants 

None have been identified. Treatment of floating or submerged aquatic 

invasive plants is outside the scope of this project. 

Terrestrial, Riparian and Emergent 

Aquatic Invasive Plants 

Invasive plants have been detected mainly along roads, trails, and 

other disturbed and/or publicly traveled areas. High priority target 

species have been detected within streambanks, gravel bars and 

wetlands. All of these situations may be treated using a variety of 

tools, including herbicide, with limitations on the application method 

and herbicide formulation allowed. 

Proportion of Current Inventory 

Where Broadcast Application of 

Herbicide Is Approved 

34% 

Proportion of Current Inventory 

Where Broadcast Application of 

Herbicide Is NOT Approved 

66% 

Treatment of Currently Unknown 

Infestations 

New infestations will be treated according to PDFs. New infestations 

found in the future may be prioritized over existing infestations. New 

infestations requiring treatments outside the scope of this project will 

not be authorized under this decision. 

Restoration Plan Passive restoration is estimated to be effective on about one-third of 

the treatment sites. Mulching, competitive seeding and planting will be 

part of the prescription on approximately two-thirds of the treatment 

sites. 

ROD - 2
 Component Selected Alternative B 

(Proposed Action) 

Herbicide Use Herbicides will be used in accordance with label instructions and 

advisories, except where more restrictive measures are required. 

Herbicide applications will only treat the minimum area necessary to 

meet site objectives. Herbicide formulations will be limited to those 

containing one or more of the following 10 active ingredients: 

chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, metsulfuron 

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

Herbicide application methods include wicking, wiping, injection, 

spot, and broadcast, as permitted by the product label and PDFs. The 

use of triclopyr is limited to spot and hand/selective methods. 

Herbicide carriers (solvents) are limited to water and/or specifically 

labeled vegetable oil. 

Herbicide Application Rates Lowest effective label rates will be used for each given situation. In no 

case will broadcast applications of herbicide or surfactant exceed 

typical label rates. 

Surfactants POEA surfactants, urea ammonium nitrate or ammonium sulfate will 

not be used in applications within 150 feet of surface water, wetlands 

or on roadside treatment areas having high potential to deliver 

herbicide to streams. 

Gas-Powered Equipment Fueling of gas-powered equipment with gas tanks larger than 5 gallons 

will not occur within 150 feet of surface waters. Fueling of gaspowered equipment with gas tanks smaller than 5 gallons will not 

occur within 25 feet of any surface waters. 

Wetlands Where possible, treatments will be done when soils are dry. If 

herbicide treatment is necessary for emergent target plants when soils 

are wet, use aquatic labeled herbicides. Favor hand/selective treatment 

methods where effective and practical. 

Lakes and Ponds No more than half the perimeter or 50 percent of the vegetative cover 

or 10 contiguous acres around a lake or pond will be treated with 

herbicides in any 30-day period. 

Aquatic Influence Zones Herbicide use near streams will follow buffers that limit the rate and 

method of application. The buffers were developed considering the 

toxicity and environmental behavior of the ten different herbicides 

approved in the R6 2005 ROD. The buffers are intended to allow for 

the maximum flexibility in herbicide use to treat all known situations 

in the project area, while minimizing risk of herbicide delivery to 

streams and adverse effects to water quality, fish, and the aquatic 

ecosystem. Annually, treatments within the aquatic influence zone 

(above bankfull) will not exceed 10 acres along any 1.5 mile of stream 

reach within a 6th field subwatershed. 

Emergent Invasive Plants Invasive plants growing in stream margins, wetlands, and gravel bars 

may be treated using aquatic labeled herbicides and spot or selective 

methods. Treatments below bankfull will not exceed 6 acres total 

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

ROD - 3
 Component Selected Alternative B 

(Proposed Action) 

Roadside Treatment Areas No broadcast of any herbicide and no use of picloram and/or triclopyr 

BEE (Garlon 4) along roads that are identified as having higher risk of 

herbicide delivery to streams. Aquatic labeled herbicides will be 

required within roadside ditches. Aquatic labeled herbicides or 

herbicides associated with lower risk to aquatic organisms will be 

applied using spot or hand/selective methods within 15 feet of the edge 

of a wet roadside ditch. Aquatic labeled herbicides will be required 

for treatments of target vegetation emerging out of the wet roadside 

ditch. 

Herbicide Handling and 

Transportation Safety 

An Herbicide Transportation and Handling Safety/Spill Response Plan 

is required. 

Wells and Springs All wells and springs used for domestic water supplies will be 

protected with a 100 foot no herbicide buffer for wells and a 200 foot 

no herbicide buffer for springs. 

Consultation With Tribes American Indian tribes will be notified annually as treatments are 

scheduled so that tribal members may provide input and/or be notified 

prior to gathering cultural plants. Individual cultural plants identified 

by tribes will be buffered as above for botanical species of local 

interest. 

Botanical Species of Local Interest Botanical species of local interest will be protected by barriers or 

herbicide use buffers (see FEIS Chapter 2.5.8) 

Monitoring 

This project involves extensive pre- and post- treatment record keeping, monitoring and reporting. 

Details are in FEIS Chapter 2.7. A project work plan will be documented for herbicide use and 

herbicide use will be reported to meet Forest Service requirements at FSH 2109.14. Appendix E of the 

DEIS includes typical forms for herbicide use reporting. 

Post-treatment reviews will occur to determine whether treatments were effective, whether or not 

passive/active restoration is occurring as expected, and whether PDFs were appropriately applied. Nontarget vegetation (e.g., botanical species of local interest) will be evaluated on sample sites before and 

immediately after treatment, and two to three months later. Contract administration and other existing 

mechanisms will be used to correct deficiencies. 

Post-treatment monitoring will also be used to detect whether PDFs were appropriately applied, and 

whether non-target vegetation impacts are within tolerable levels. Re-treatment and active restoration 

prescriptions will be developed based on post-treatment results. 

Candidates for monitoring under the Regional Framework (R6 2005 ROD) will be submitted for higher 

risk situations such as emergent vegetation treatment or broadcast spray of aquatic labeled imazapyr 

and/or glyphosate within 100 feet of streams. Additional monitoring may be included as part of the 

Olympic National Forest Annual Monitoring Plan or other ongoing programs such as state water quality 

monitoring. 

ROD - 4
Public Involvement 

This project has been in development for several years. The project was first listed in the Olympic 

National Forest Schedule of Proposed Actions in 2004. A Notice of Intent (NOI) to prepare an EIS 

requesting public input was published in the Federal Register on February 23, 2004. The NOI proposed 

a project with a geographic scope covering the current project area (Olympic National Forest) along 

with the Columbia River Gorge National Scenic Area, the Gifford Pinchot and Mount Hood National 

Forests. Individuals, organizations, agencies, businesses, and local and tribal governments were 

contacted by letter and solicited for comments on the proposal. County weed coordinators and staff 

provided technical input on project design. News releases in the local area offered face to face 

meetings but none were requested by any member of the public. 

A Draft EIS was published in 2006, followed by a 45-day comment period. All substantive comments 

are shown in Appendix H of the FEIS, along with individual responses. Two of the commenters were 

federal agencies (U.S. Environmental Protection Agency (EPA) and National Marine Fisheries Service 

(NMFS). 

In general, the comments all supported effective invasive plant management. However, most of the 

commenters expressed concern about the use of herbicides within riparian reserves and near fish habitat. 

Two other commenters specifically mentioned a preference for Alternative C, which does not allow 

herbicide use in riparian reserves or along roads with high potential to deliver herbicides to water 

bodies. 

The Forest Service addressed the public and interagency comments with additional analysis in the FEIS 

and modifications to the Proposed Action. My staff and I have worked closely with FWS and NMFS to 

develop PDFs to minimize effects on fish and other aquatic organisms and flesh out analysis methods. 

Standards in the R6 2005 ROD require me to design invasive plant treatments to minimize adverse 

effects to fish and other aquatic organisms; along with other wildlife species; water quality; non-target 

vegetation; and human health. The PDFs, Buffers and Implementation Planning Process outlined in the 

FEIS are sufficient to follow these standards. 

The FEIS notes that herbicides could contact streams on the National Forest despite the PDFs and 

buffers. While the amount predicted is small and the probability is low, I recognize that some members 

of the public would have preferred I eliminate all risk of herbicide contact with streams. As the 

following sections explain, herbicide treatment within riparian areas is necessary to effectively treat high 

priority species, including (but not limited to) knotweed, reed canarygrass, and purple loosestrife. The 

adverse effects of the invasive species themselves far outweigh the low risk associated with herbicide 

use according to the PDFs and buffers adopted in this project. 

Reasons for this Decision 

I have selected Alternative B because it best meets the purpose and need for action while adequately 

minimizing adverse effects to people and the environment. It is the most effective and economically 

efficient of all the alternatives in reducing acreage of invasive plants compared to the current inventory. 

Alternative B includes a strategy to meet the Forest Plan objective of reduced herbicide use over time 

(see FEIS Chapter 3.1). 

Factors influencing my decision included: 

ROD - 5
(1) Effectiveness of treatments in reducing acreage of invasive plants compared to the current 

inventory 

(2) Potential adverse effects to human health and the environment; and 

(3) Monetary costs and financial efficiency, as indicated by the economic efficiency analysis 

displayed in Chapter 3.7 of the FEIS. 

Alternative B will reduce acreage of invasive plants compared to the current inventory. It minimizes 

adverse effects to human health and the environment through cautious project design criteria and 

herbicide use buffers. It restricts broadcasting on the two-thirds of the project area within riparian 

reserves and along roads with high potential for herbicide delivery to streams. Broadcasting is allowed 

where needed on a portion of the area, therefore decreasing costs by approving this cost-effective 

method along some roadsides in upland areas. Alternative B is the most likely alternative to control 

invasive plants that are degrading special areas on the Olympic National Forest 

Alternative B responds to public concerns expressed during two scoping periods (2004 and 2005) and 

the DEIS comment period (2006). It follows terms and conditions set forth in a Biological Opinion for 

this project issued by the US Fish and Wildlife Service and National Marine Fisheries Service in 2007. 

Alternatives Considered 

Three alternatives to the proposed action were considered in the FEIS; No Action (Alternative A), 

Alternative C and Alternative D. Alternative A would have implemented treatments according to 

existing plans; no new invasive plant treatments would be approved. Alternative A would not have 

approved effective, timely treatments of newly discovered infestations. Also, alternative A would not 

have included a plan for restoring native plant communities. 

Alternative C was developed to resolve most concerns related to herbicide use by eliminating herbicide 

application on about two-thirds of the National Forest system lands. Under Alternative C, only very 

limited herbicide use would have been permitted within riparian reserves and near roadside ditches. 

Alternative C also would have eliminated all broadcast applications throughout the project area. 

Alternative C would have minimized herbicide impacts, but would have increased treatment costs and 

decreased treatment effectiveness. Alternative D was developed to reduce treatment cost and increase 

effectiveness by allowing more options than the Proposed Action. Alternative D would have allowed 

herbicide broadcasting across dry streams and along roads with high potential to deliver herbicide to 

streams. 

Why Alternative A Was Not Selected 

Alternative A was not selected because it was the least effective of the alternatives. Without effective 

treatment, invasive plants would have continued to spread within and adjacent to the National Forest. 

The cost, difficulty, and potential adverse effects of controlling invasive plants would have continued to 

increase. 

Alternative A would have allowed limited use of 3 herbicides, as compared to 10 in Alternative B. The 

limited number of herbicides has comparatively less effectiveness and may result in herbicide resistance 

(R6 2005 FEIS Chapter 4.2). There would have been no explicit strategies to reduce herbicide reliance 

over time, restore native plant communities, or achieve long-term control. Alternative A would have 

been less cost-effective. It would not have resulted in restored native plant communities because of the 

absence of a restoration plan. 

ROD - 6
Why Alternative C Was Not Selected 

Alternative C was not selected because it would have not have been as effective or timely in controlling 

invasive plants. It would have reduced potential impacts related to herbicide use, but at too great an 

expense. It would have incorporated more measures to minimize or eliminate risk of environmental 

harm from herbicides as compared to the selected alternative; however, it would have done so at the 

expense of project effectiveness and cost. The FEIS estimates that treatment cost per acre would have 

increased by an average of approximately 43 percent under Alternative C as compared to Alternative B. 

Why Alternative D Was Not Selected 

Alternative D would have been nominally more cost-effective than Alternative B; however the greater 

flexibility in treatment method would have increased risk of herbicide delivery to streams and other 

water bodies. More treatment areas would likely be accomplished with an equal budget, because the 

estimated costs would be $30 less per acre than Alternative B. However, risks to water quality and the 

aquatic ecosystem would have been too great. Without mitigation, Alternative D would not have 

followed the Aquatic Conservation Strategy in the Northwest Forest Plan (see FEIS Chapter 3.4). 

Alternative Comparison – Decision Factors 

Effectiveness of Treatments in Reducing Acreage of Invasive Plants Compared to the Current Inventory 

(see FEIS Chapter 3.2 for detailed analysis) 

Treatment effectiveness increases with the number of treatment options available across the largest area. 

Alternative A provides three herbicide options on 2 percent of the project area. In contrast, Alternative 

B (and D) allow for ten herbicide options on the entire project area. Alternative C allows for ten 

herbicide options on approximately 30 percent of the project area. Alternatives B and D include the 

greatest number of options on the greatest possible acreage, thus increasing potential effectiveness. 

The limited herbicide options under Alternative A were estimated to reduce invasive plants at a given 

treatment site by 50 percent per year. Alternatives B and D are more effective (due to greater number of 

treatment options). At any given treatment site, infested acreage would be reduced by 80 percent per 

year. Alternative C would be equally effective as B on 30% of the project acreage; the remaining area 

would have effectiveness similar to Alternative A. 

 Potential for Adverse Effects on Human Health and the Environment (FEIS Chapters 3.2 – 3.8) 

Alternative A does not pose substantial impacts on human health and the environment from herbicide 

treatment; however its lack of treatment effectiveness means that invasive plants would continue to 

threaten native plant communities and habitats on the Olympic National Forest. Small scale impacts 

from currently approved treatments (not considered significant or of high public concern) would 

continue to be possible. 

Alternative B increases risk to human health and the environment from herbicide use compared to 

Alternative A. However, the layers of caution added to herbicide use (see FEIS Chapter 3.1); project 

design features and buffers (FEIS Chapter 3.5); following guidance in the Forest Plan; using well trained 

applicators; and following required safety practices for herbicide transportation and handling would 

serve to minimize these risks. 

Peer-reviewed risk assessments using the best available scientific methods and analysis show no harmful 

exposure scenarios to people or drinking water are associated with the type of herbicide use proposed in 

ROD - 7
Alternative B. Conflicts between treatments and gathering areas would be minimized through 

newspaper or individual notification, fliers, and posting signs. No exposure exceeding thresholds of 

concern for people are plausible. 

No populations of botanical species of local interest will be adversely impacted (FEIS Chapter 3.2). 

Protection buffers and physical barriers will be required for sensitive and other rare or uncommon 

botanical species. The project design criteria minimize drift; however individual common non-target 

plants may be exposed to herbicides and in some cases, individual non-target plants may die. 

Wildlife species may also be inadvertently exposed to herbicides; however potential impacts will be 

minimized by restricting treatment during certain times of the year (e.g. owl nesting season) and 

avoiding use of certain herbicide ingredients and additives in special habitats. 

Similarly, Alternative C would have minimized adverse impacts on human health and eliminate risk to 

the aquatic environment from herbicide treatment by avoiding herbicide use within riparian reserves and 

along roads with high potential to deliver herbicide to streams, amounting to no herbicide use on 70 

percent of the project area. This restriction would have reduced the effectiveness of Alternative C, and 

unless budgets were unlimited; invasive plants would likely continue to degrade riparian and other 

habitats. Even with unlimited budgets, the restrictions on herbicide use would make eradication of some 

key target species improbable. 

In addition, risks to the aquatic environment from disturbance, erosion and sediment would continue to 

occur from non-herbicide treatments. 

Alternative D incurs the greatest risk to water quality and fish because it does not include certain buffers 

for intermittent streams or roadside ditches. The lack of these buffers would pose unacceptable risk to 

the aquatic environment and would not follow terms and conditions established by the National Marine 

Fisheries Service and US Fish and Wildlife Service, which apply to certain watersheds. 

Monetary Costs and Financial Efficiency, as Indicated By the Economic Efficiency Analysis (FEIS Chapter 

3.7) 

Alternative A is estimated to cost approximately $664,000 under the most ambitious conceivable 

treatment scenario over a five year period. On a per acre basis, Alternative A would cost about $994 per 

acre. No site restoration would be included at that price. 

The most ambitious treatment scenario under Alternative B is estimated to cost about $2.2 million over a 

five year period, including site restoration. Alternative C is estimated to be far more expensive, with its 

most conceivable treatment scenario costing $3.5 million over five years to implement (including 

restoration). It is associated with the most expensive per acre treatment costs at $1025 per acre (almost 

double the per acre cost of Alternative B). Alternative D is slightly less expensive than Alternative B, 

due to fewer operational restrictions ($540 per acre). 

I have selected Alternative B because it is relatively cost-effective and minimizes risk to the 

environment. Given sufficient funding, it would reduce the acreage of invasive plants compared to the 

2004 inventory. 

Table 2 displays a comparative analysis for the alternatives in terms of the public issues. 

ROD - 8
ROD - 9

Table 2. Analysis of alternatives in terms of public issues 

Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative 

C 

1 – Human Health and Worker Safety 

1a Exposure to Herbicides 

No significant impact Alternative B will not expose 

people to harmful levels of 

herbicide ingredients. 

Same as Alternative 

B 

Sa

1b – Drinking Water No significant impact Drinking water will not be 

adversely affected. 

Same as Alternative 

B 

Sa

2 - Treatment Strategy and Effectiveness 

2a Herbicides Available 

for Use 

3 

10 

All herbicides are available, 

subject to PDFs and buffers 

(see FEIS Chapter 2.5.8) 

Same as Alternative 

B Sa

2a Proportion of Infested 

Acres that May be Treated 

Using Herbicide 

2 % - herbicides may 

be used on a few of 

the sites in the 2004 

inventory 

100% - herbicides may be 

used in all sites, subject to 

PDFs and buffers 

(see FEIS Chapter 2.5.8) 

30% - herbicides 

may be used on less 

than one-third of 

the Forest 

Sa

wi

2a Acres of Invasives in 

2012 (assuming unlimited 

funding beginning in 2008) 

3,503 acres estimated 

to need treatment 

after 5 consecutive 

years, about the same 

as today 

Estimated at 51 acres, 

minimal acreage would need 

to be treated after 2012 and 

potential for new infestations 

greatly reduced. 

Estimated at 459 

acres, substantially 

more than 

Alternative B but 

less than current 

inventory 

Sa

2b Long Term Strategy, 

Reduce Reliance on 

Herbicides Over Time 

Long term strategy is 

not directly addressed 

in NEPA document 

Active and passive 

restoration would be part of 

every prescription. Each year 

of treatment, as target 

population size is reduced 

non-herbicide methods will 

likely become more practical 

and effective. 

Same as Alternative 

B. 

Sa
Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative 

C 

2c Treatment Priority Treatment priorities 

are not directly 

addressed in NEPA 

document 

Each treatment area has been 

given a priority, as shown in 

Chapter 2.5 

Fewer treatment 

areas likely treated 

with equal budget. 

M

Issue Group 3 – Social and Economic 

3a – Total Cost for the 

Most Ambitious Program 

over 5 years 

$664,000 $2,183,000 $3,496,000 

3a – Average Annual Cost 

for the Most Ambitious 

Program over 5 years 

$149,000 $490,000 $785,000 

3a – Average Cost Per 

Treated Acre over a 5 year 

period 

$988 $570 $1025 

3b – Jobs Associated with 

Treatments (per 6 month 

year) 

8 18 54 

3c – Effects on Scenic, 

Recreation and 

Wilderness Values 

No significant impact Containing, controlling 

and/or eradicating invasive 

plants will indirectly 

improve scenic, recreation 

and wilderness values. 

Project Design Features limit 

potential short term adverse 

impacts. 

Less effectiveness 

in Riparian Reserve 

may result in 

increased risk to 

scenic, recreation 

and wilderness 

values in the long 

run. 

Sa

ROD - 10
Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative 

C 

3d – Special Forest 

Products and Gatherers 

No significant impact Conflicts between treatments 

and gathering areas will be 

minimized. Inadvertent 

exposures will be minimized 

through newspaper or 

individual notification, fliers, 

and posting signs. No 

exposure exceeding 

thresholds of concern for 

people are plausible. 

Same as Alternative 

B. 

Sa

3e – Effects on Tribes, 

Civil Rights, 

Environmental Justice 

No significant impact No disproportionate effects 

on any group of people, 

ongoing government-togovernment consultation 

with tribes. 

Same as Alternative 

B. 

Sa

Issue Group 4 – NonTarget Plants And Wildlife 

4a – Estimated Proportion 

of Project with Potential 

Broadcast Application 

0% - No broadcasting 

included 

34% - risks are greatest with 

broadcasting, however 

buffers and PDFs are 

expected to protect Botanical 

Species of Local Interest 

0% - Least risk of 

all the action 

alternatives 

br

b

e

B

4b – Terrestrial Wildlife

No significant impact Not likely to adversely affect 

wildlife species of local 

concern, including mollusks 

and salamanders. PDFs (see 

FEIS Chapter 2.5.8; PDF 

Group J) are specific to 

habitats of interest on the 

Forest. 

Same as Alternative 

B 

Sa

ROD - 11
Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative 

C 

Issue Group 5 – Effects on Soils, Water and Aquatic Organisms 

5a – Effects on Soils 

No significant impact Project Design Features 

avoid herbicide 

concentrations of concern in 

soils; limitations on 

herbicide selection 

depending on site-specific 

soil conditions See FEIS 

Chapter 2.5.8, PDF group H. 

Same as Alternative 

B, less use of 

herbicide. 

Sa

br

Issue Group 5 – Effects on Soils, Water and Aquatic Organisms 

5b – Character of 

Herbicide Use Within 

Aquatic Influence Zones 

Restricted to hand 

applications of 

aquatic glyphosate 

approved under 

current EA. 

Risks from herbicide use 

within Aquatic Influence 

Zones and along roads 

having high risk of herbicide 

delivery are avoided or 

minimized through PDFs and 

buffers (see FEIS Chapter 

2.5.8). 

Same as Alternative 

A. 

w

i

a

w

n

5b – Estimated Acres 

Herbicide Use Within 

Aquatic Influence Zones Fewer than 30 acres Approximately 620 acres Same as Alternative A. Sa

5b – Estimated Proportion 

of Project with Potential 

Broadcast Application 0% - Very Low risk of herbicide delivery 

to surface waters 

34%, risks are greatest with 

broadcasting, however 

buffers and PDFs are 

expected to minimize 

herbicide delivery to surface 

waters 

Same as Alternative 

A. 

84

w

ROD - 12
Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative 

C 

5b – Estimated acreage 

where herbicide treatment 

may occur on roadside 

treatment sites with high 

potential to deliver 

herbicides 

Fewer than 40 acres. 

Low risk of herbicide 

delivery through the 

ditch network. 

1,420 acres, PDFs (see 

Chapter 2.5) limit herbicide 

use on within higher risk 

roadside treatment sites and 

in or near roadside ditches. 

Low risk of herbicide 

delivery through the ditch 

network. 

0 – herbicide use on 

these roadsides is 

completely 

avoided. No risk of 

herbicide delivery 

through the ditch 

network. 

Sa

5b – Estimated proportion 

of project where broadcast 

of herbicide may occur on 

roadside treatment areas 

with high potential to 

deliver herbicides 

0 – No broadcasting 

included. 

0 – Broadcasting would not 

be allowed on specific 

roadsides (see Appendix D) 

0 – No broadcasting 

included. 

37

b

h

w

5c - Potential for fish to be 

exposed to harmful 

concentrations of 

herbicide 

Very Low, limited 

herbicide treatment 

near fish habitat, 

existing treatments 

are not likely to 

adversely affect 

aquatic species of 

local interest 

Low, treatment of emergent 

vegetation near fish habitat 

carries some risk of herbicide 

contacting water, 

concentrations expected to 

be below a threshold of 

concern. 

Very Low, limited 

herbicide treatment 

near fish habitat, 

emphasis on nonherbicide 

treatments may 

increase sediment 

to fish habitat at 

some sites. 

w

co

tha

ROD - 13
ROD - 14

Environmentally Preferred Alternative 

I find that Alternative B is the environmentally preferred alternative in accordance with Council on 

Environmental Quality (CEQ) regulations (40 CFR Part 1505.2 (b)). The relatively greater costeffectiveness in restoring native plant communities associated with Alternative B outweighs this low 

level of risk. Alternative A and C are not environmentally preferred because both are too restrictive to 

effectively control invasive plants that currently threaten environmental quality. By prohibiting 

herbicide use on 85% and 70% of the project area respectively, Alternatives A and C are more costly 

and less likely to be effective than Alternative B. Alternative D is not environmentally preferred because 

it carries greater risk of herbicide delivery to streams. 

The selected alternative incorporates practicable measures to minimize harm to the environment. 

Additional restrictions on herbicide use such as included in Alternative C would have reduced our 

ability to effectively treat invasive plants, as discussed in Chapter 3.2 of the FEIS. 

Findings Required by Other Laws and Regulations 

My decision is consistent with all other current laws, regulations and policies guiding invasive plant 

programs and other management activities on National Forest System lands including, but is not limited 

to: National Forest Management Act; the Olympic National Forest Plan; the Clean Water Act and Safe 

Drinking Water Act; the Wilderness Act; the National Historic Preservation Act; and Executive Orders 

11988, 11990 and 12898. 

Specific findings and rationales required by law follow. 

National Forest Management Act and Forest Plan 

The project complies with the Olympic National Forest Plan (see Chapter 1 of the FEIS for discussion). 

The project is consistent with the Aquatic Conservation Strategy (ACS), Invasive Plant Treatment 

Standards, and other applicable guidance in the Olympic National Forest Plan (see FEIS Chapter 1 for 

more information on ACS and applicable Forest Plan standards). 

Consistency with Forest Service Policies and Plans 

The proposed project is consistent with all Forest Service policies and existing plans. No conflicts with 

existing plans have been noted. A recent lawsuit Washington Toxics Coalition et al. v EPA, regarding 

the lack of Endangered Species Act consultation on use of certain herbicides, was resolved by requiring 

certain buffers near streams. Herbicide use on federal land was exempt from the buffer zone 

requirement because such use already “implements safeguards routinely required” by the regulatory 

agencies. 

The conclusions and findings in this analysis are supported by the best scientific information available. 

The FEIS (and the broader scale R6 2005 FEIS to which it is tiered) identifies methods used, discusses 

responsible opposing views, and discloses incomplete or unavailable information, scientific uncertainty, 

and risk (See 40 CFR, 1502.9 (b), 1502.22, 1502.24). 
Invasive plant treatments are no longer subject to the requirements of the 1989 Mediated Agreement that 

affected removal of unwanted vegetation in Region Six. The R6 2005 ROD vacated the mediated 

agreement; replacing it with management direction for invasive plant prevention, treatment, restoration 

and monitoring. In April 2007, Northwest Coalition for Alternatives to Pesticides, the lead signer in the 

1989 Mediated Agreement, agreed it was willing to dissolve the Mediated Agreement for purposes of 

controlling invasive plants in Region 6. The Portland Audubon Society (July 2, 2007) and the Oregon 

Environmental Council (October 15, 2007) have also agreed in writing to dissolve the Mediated 

Agreement for invasive plant control." 

Clean Water Act and Safe Drinking Water Act 

The Selected Alternative will meet and conform to the Clean Water Act as amended in 1982 and Safe 

Drinking Water Act as amended in 1996 (FEIS, Chapter 3, Section 3.9). The Clean Water Act requires 

States to set water quality standards to support the beneficial uses of water. The Act also requires States 

to identify the status of all waters and prioritize water bodies whose water quality is limited or impaired. 

This project will meet and conform to these Acts; although the project may result in some herbicide 

entering surface or ground waters, the amount would be below a threshold of concern for beneficial uses 

because of the restrictions on certain herbicides near streams, PDC and the nature of the type of 

infestations treated. 

The National Historic Preservation Act 

 The USDA, Forest Service, Advisory Council on Historic Preservation and the Washington State 

Historic Preservation Office (SHPO) (Office of Archaeology and Historic Preservation), have a 

programmatic agreement addressing the management of cultural resources on national forests in the 

state of Washington (Agreement Number 97-06-59-10). There are several actions that were determined 

to have little or no potential to affect historic properties. Examples of these actions include fence 

construction, planting on disturbed areas, aerial seeding, pre-commercial thinning, encroachment 

thinning using hand methods to lop branches and cut small trees, and reforestation planting by hand. 

While invasive plant treatments within the scope of this EIS are not specifically itemized in the 

Programmatic Agreement between the Forest Service and the Washington SHPO, the techniques, 

methods and effects are generally similar. Forest Service staff has coordinated with the Washington 

SHPO and affected Tribes to classify all actions within the scope of this EIS as having no effect on 

heritage resources. 

One exception is weed wrenching of Scotch broom proposed within undisturbed, unsurveyed areas of 

the National Forest. Such treatments could occur under all action alternatives. 

While most Scotch broom infestations occur in disturbed areas (roadsides), some infestations are in less 

disturbed areas. Weed wrenching of larger-sized Scotch broom has the potential to disturb heritage 

resources in undisturbed sites. To mitigate for this possible effect, weed wrenching sites would be 

evaluated by a heritage resource specialist prior to and/or during treatment to eliminate disturbance to 

heritage resources. PDFs would adequately protect cultural resources where new detections are 

identified for similar treatments. 

ROD - 15
The Wilderness Act 

The Selected Alternative includes two treatment areas currently mapped within congressionally 

designated wilderness areas and trailheads near wilderness boundaries. No mechanical equipment or 

mechanized transportation will be used in the wilderness. Handheld backpack pumps may be used to 

spot treat some invasive plants on wilderness trails. Minimum impact treatment methods will be 

selected as per PDF D2 (see full list of PDFs in FEIS 2.5.8). 

Executive Orders 11988 and 11990: Flood Plains and Wetlands 

Proposed invasive plant treatments within riparian areas are discussed in FEIS Chapter 3.4 and 3.5. The 

project is intended to restore native plant communities and habitats within riparian and upland areas. No 

adverse effects are anticipated to occur to wetlands and floodplains from treatment in the Selected 

Alternative B. 

Executive Order 12898: Environmental Justice 

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

Low Income Populations, directs Federal agencies to address effects accruing in a disproportionate way 

to minority and low income populations. FEIS, Chapter 3.6 and 3.8, discusses the potential impacts of 

this project on these groups. With the implementation of any action alternative, there is the potential for 

some impact to Hispanic, Asian and American Indian communities. Harvesters of non-timber forest 

products tend to come from Asian, Hispanic and American Indian communities. These groups may be 

disproportionately exposed to herbicide treatments in areas available for picking their products (see 

FEIS Chapters 3.6 and 3.8). 

The potential for harmful exposure of herbicide to any person is eliminated by PDC that require public 

notification including posting treatment areas and limitations on herbicide and surfactant selection, 

application rate, and application method. Inadvertent exposures will occur rarely and will not adversely 

affect anyone’s livelihood or health. 

Secretary of Agriculture Memorandum of 1827: Prime Farmland, Rangeland, 

Forestland and Parkland 

No prime farmlands, rangelands, forestlands or parklands are within the project area, thus there will be 

no direct, indirect or cumulative effects on these lands. 

Endangered Species Act 

Consultation with the Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS, 

also referred to as NOAA Fisheries) has been completed for this project. The Forest Service worked 

with these agencies from project inception throughout the planning process. The FWS concurred with 

the Forest Service that the Proposed Action was not likely to adversely affect any terrestrial wildlife 

species listed under the Endangered Species Act (or proposed for listing). The FWS and NMFS 

concurred with the Forest Service that a portion of the project may adversely affect listed fish species 

and/or their habitat. 

ROD - 16
The Biological Assessment was sent to FWS and NMFS in January 2007, covering proposed actions that 

were considered both “not likely” and “likely” to adversely affect aquatic species listed or proposed for 

listing under the Endangered Species Act. Each agency (FWS and NMFS) prepared its own documents 

in response to the BA, including letters of concurrence on the portions of the project they considered 

“not likely” to adversely affect the species (FWS April 2007 and NMFS May 2007) and Biological 

Opinions (BO’s) for portions of the project they considered “likely” to affect such species (FWS 

September 2007 and NMFS October 2007). The BO’s concluded that the project is not likely to 

jeopardize the continued existence of bull trout, Puget Sound Chinook, Hood Canal summer-run chum, 

or Puget Sound steelhead, or result in the adverse modification or destruction of designated critical 

habitat. 

FWS and NMFS have authorized incidental take on the known sites as well as the EDRR approach for 

future detections. “Reasonable and Prudent Measures” necessary to minimize the taking of federally 

listed fish are documented in the BO’s. The Forest Service will follow the measures during 

implementation of the project. The BA, letters of concurrence and BO’s are available hard copy on 

request or via the Forest Service website: http://www.fs.fed.us/r6/olympic. 

FEIS Chapter 3.4 and 3.5 detail the effects on terrestrial and aquatic animal species of local interest, 

including federally listed species. The biologists analyzing this project have noted that without effective 

treatment, invasive plants are likely to adversely affect habitats on which federally listed fish and 

wildlife species depend. 

Magnuson-Stevens Fishery Conservation and Management Act 

The National Marine Fisheries Service (NMFS) also completed an essential fish habitat (EFH) 

consultation, prepared in accordance with section 305(b)(2) of the Magnuson-Stevens Fishery 

Conservation and Management Act (MSA) (16 U.S.C. 1801, et seq.), and implementing regulations at 

50 CFR 600. 

NMFS October 2007 BO determined that the action may have adverse effects on EFH for Chinook 

salmon, coho salmon, and pink salmon as follows: 

1. Short-term degradation of water quality (chemical) from in-water, ditch and riparian herbicide 

treatments. 

2. Short-term reduction in salmon food sources as a result of herbicide treatments to control 

invasive plant species. 

NMFS (ibid.) also stated that “conservation measures included as part of the proposed action to address 

the endangered species act are adequate to avoid, minimize, or otherwise offset potential adverse effects 

on the EFH of Pacific salmon.” The Forest Service will follow these recommendations during 

implementation of this project. 

. 

ROD - 17
Implementation 

Implementation Date 

If no appeals are filed within the 45-day time period, implementation of the decision may occur on, but 

not before, 5 business days from the close of the appeal filing period. When appeals are filed, 

implementation may occur on, but not before, the 15th business day following the date of the last appeal 

disposition. 

Administrative Review or Appeal Opportunities 

This decision is subject to appeal pursuant to Forest Service regulations at 36 CFR 215. Any individual 

or organization who submitted comments during the comment period specified at 36 CFR.6 may appeal. 

Written notice of appeal must be postmarked or received by the Appeal Deciding Officer, Regional 

Forester Linda Goodman, ATTN: Appeals, USDA Forest Service, PO Box 3623, Portland, OR 97208-

3623 within 45 days of the date of publication of notice regarding this decision in The Olympian 

(Olympia, WA). The appeal must state that the document is an appeal pursuant to 36 CFR 215, and at a 

minimum must meet the content requirements of 36 CFR 215.14, and include the name and address of 

the appellant, and must identify the decision by title, subject, date of decision, and name of the 

Responsible Official. The appeal narrative must be sufficient to identify the specific change(s) to the 

decision sought by the appellant or portions of the decision to which the appellant objects, and must 

state how the Responsible Official’s decision fails to consider comments previously provided. If 

applicable, the appeal should state how the appellant believes this decision violates law, regulation, or 

policy. 

Appeals (including attachments) may be filed by regular mail, fax, e-mail, hand delivery, express 

delivery, or messenger service. The publication date of the notice regarding this decision in the 

newspaper of record is the sole means of calculating the appeal filing deadline, and those wishing to 

appeal should not rely on dates or timelines from any other source. E-mail appeals must be submitted to: 

appeals-pacificnorthwest-regional-office@fs.fed.us, and must be in one of the following three formats: 

Microsoft Word, rich text format (rtf) or Adobe Portable Document Format (pdf). FAX appeals must be 

submitted to: 503-808-2255. Appeals may be hand-delivered to the Resource Planning and Monitoring 

Office, 333 SW First Ave., Portland, between 8:00 AM and 4:30 PM Monday-Friday. 

It is the responsibility of all individuals and organizations to ensure their appeals are received in a timely 

manner. For electronically mailed appeals, the sender should normally receive an automated electronic 

acknowledgement from the agency as confirmation of receipt. If the sender does not receive an 

automated acknowledgement of the receipt of the appeal, it is the sender’s responsibility to ensure 

timely receipt by other means. 

ROD - 18
ROD - 19

Contact Person 

Joan Ziegltrum, Forest Ecologist 

1835 Black Lake Blvd. SW, Suite A 

Olympia, WA 98512 

Tel. (360) 956-2320 

 

______________________ _____March 20, 2008_______________ 

 

Dale L. Hom 

Olympic National Forest Supervisor 
ROD - 20
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

Final Environmental Impact Statement 

Site-Specific Invasive Plant Treatment Project 

Clallam, Grays Harbor, Jefferson and Mason Counties, State of Washington 

Lead Agency: USDA Forest Service 

Responsible Official: Dale Hom, Olympic National Forest Supervisor 

For Information Contact: Joan Ziegltrum, Olympic National Forest 

 Invasive Plant Program Manager 

(360) 956-2320 

 

Website http://www.fs.fed.us/r6/olympic 

Abstract

This Final Environmental Impact Statement (FEIS) discloses the effects of treating invasive plants on the 

Olympic 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/projects/four-threats). Invasive plants 

are displacing native plants, destabilizing streams, reducing the quality of fish and wildlife habitat; and 

degrading natural areas. While invasive plant prevention is an integral part of the invasive plant program, the 

focus of this Final Environmental Impact Statement (FEIS) is on the part of the program that has a need for 

action beyond prevention. 

Strong public concern has been expressed regarding Forest Service response (or lack of response) to invasive 

plants. Several organizations and individuals have offered to cooperate with the Forest Service in this 

endeavor. The Forest Service is responding to a crucial need for timely containment, control, and/or 

eradication of invasive plants, including those that are currently known and those discovered in the future. The 

purpose of this project is to treat invasive plants in a cost-effective manner that complies with environmental 

standards. 

Approximately 3,830 acres of infestation have been inventoried, including but not limited to herb Robert, 

knapweeds, hawkweeds, knotweeds, and reed canary grass. This Final Environmental Impact Statement 

includes detailed consideration of four alternatives to address these infestations. 

No Action (also referred to as Alternative A) would implement treatments according to existing plans; no new 

invasive plant treatments would be approved. The Proposed Action (also referred to as Alternative B) would 

apply an initial prescription, along with re-treatment in subsequent years, until the site was restored with 

desirable vegetation. Herbicide treatments would be part of the initial prescription for most sites, but the use of 

herbicides would be expected to decline in subsequent entries as populations became small enough to treat 

manually or mechanically. 

Ongoing inventories would confirm the location of specific invasive plants and effectiveness of past 

treatments. Treatment prescriptions would be strict enough to ensure that adverse effects are minimized, while 

flexible enough to adapt to changing conditions over time. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

Alternative B would allow invasive plant treatments in all land allocations, including wilderness and riparian 

reserves, across the National Forest. Project design features for the Proposed Action restrict certain treatment 

methods depending on the land allocation and other site conditions such as proximity to surface water bodies, 

wildlife habitats, botanical species of local interest, etc. 

Two action alternatives were developed in response to public issues related to herbicide use. Alternative C 

resolves most concerns related to herbicide use by eliminating herbicide application on about two-thirds of the 

National Forest System lands. Under Alternative C, only very limited herbicide use would be permitted within 

riparian reserves and road drainage ditch networks. Alternative C would minimize herbicide impacts, but 

would increase treatment costs and decrease treatment effectiveness. 

Alternative D was developed to increase treatment flexibility by approving broadcast treatments in more 

situations than the Proposed Action. Alternative D reduces the costs of treatments, but under worst-case 

conditions, herbicides could enter streams and other water bodies and harm aquatic organisms. 

The Forest Service Preferred Alternative is the Proposed Action (Alternative B). The Proposed Action has 

been modified in response to public and interagency comments.

Cover photo: Knotweed growing near Lake Quinault, Olympic National Forest. Knotweed is an invasive plant 

often used in landscaping. Once established, knotweed can out-compete native vegetation with serious adverse 

impacts to the environment. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

- i - 

TABLE OF CONTENTS 

Summary................................................................................................................................................................5

Chapter 1. Purpose of and Need for Action...........................................................................................................7

1.1 Introduction .................................................................................................................................................7

1.1.1 Changes between Draft and Final EIS..................................................................................................7

1.2 Project Area.................................................................................................................................................8

1.3 Proposed Action ..........................................................................................................................................8

1.4 Purpose and Need for Action ......................................................................................................................9

1.4.1 Regulatory Basis for Project/Environmental Standards .....................................................................11

1.5 Decision Framework .................................................................................................................................16

1.6 Public Involvement ...................................................................................................................................16

1.6.1 Issue Group 1: Human Health and Worker Safety .............................................................................17

1.6.2 Issue Group 2 – Treatment Strategy and Effectiveness......................................................................18

1.6.3 Issue Group 3 – Social and Economic................................................................................................19

1.6.4 Issue Group 4 – Effects on Non-Target Plants and Wildlife ..............................................................21

1.6.5 Issue Group 5 – Effects on Soils, Water and Aquatic Organisms ......................................................22

1.6.6 Summary of Significant Public Issues and Alternative Comparison Factors .....................................23

1.6.7 Comments to the DEIS .......................................................................................................................25

1.7 Non-Significant Issues ..............................................................................................................................25

1.7.1 Funding and Partnerships for Managing Invasive Plants on Private Land.........................................26

1.7.2 Funding Sources and Commitments...................................................................................................26

1.7.3 Linking the Project to Other Initiatives ..............................................................................................26

Chapter 2. Alternatives, Including the Proposed Action .....................................................................................27

2.1 Introduction ...............................................................................................................................................27

2.2 Alternative Development Process .............................................................................................................27

2.3 Invasive Plant Treatment Methods............................................................................................................28

2.4 No Action ..................................................................................................................................................32

2.5 The Proposed Action.................................................................................................................................33

2.5.1 Changes to the Proposed Action between Draft and Final .................................................................33

2.5.1 Treatment Areas..................................................................................................................................33

2.5.2 Treatment Priority and Strategy..........................................................................................................34

2.5.3 Common Control Measures................................................................................................................35

2.5.4 Treatment Site Restoration .................................................................................................................40

2.5.5 Proposed Herbicides and Additives....................................................................................................41

2.5.6 Early Detection-Rapid Response Approach .......................................................................................41

2.5.7 Implementation Planning Process.......................................................................................................42

2.5.8 Project Design Features and Buffers ..................................................................................................44

2.5.9 Proposed Action Summary Table.......................................................................................................58

2.6 Alternative C - Less Herbicide Use Allowed............................................................................................59

2.6.1 Treatment Areas, Priority and Strategy ..............................................................................................59

2.6.2 Common Control Measures and Treatment Site Restoration .............................................................59

2.6.3 Implementation Planning and Early Detection-Rapid Response Approach .......................................59

2.6.4 Herbicide Selection.............................................................................................................................59

2.6.5 Project Design Features and Buffers ..................................................................................................59

2.6.6 Alternative C Summary Table ............................................................................................................59

2.7 Alternative D – More Broadcast Allowed.................................................................................................60

2.7.1 Treatment Areas, Priority and Strategy ..............................................................................................60

2.7.2 Common Control Measures and Treatment Site Restoration .............................................................60

2.7.3 Implementation Planning and Early Detection-Rapid Response Approach .......................................60

2.7.4 Herbicide Selection.............................................................................................................................60
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

- ii - 

2.7.5 Project Design Features and Buffers ..................................................................................................60

2.7.6 Alternative D Summary Table............................................................................................................60

2.8 Alternatives Considered but Eliminated from Detailed Study ..................................................................61

2.8.1 Preventing, Rather Than Treating Invasive Plants .............................................................................61

2.8.2 No Herbicide Use ...............................................................................................................................62

2.8.3 Follow Herbicide Label Directions – No Additional Design Features...............................................62

2.9 Alternatives Compared..............................................................................................................................62

Chapter 3. Affected Environment and Environmental Consequences.................................................................67

3.1 Introduction ...............................................................................................................................................67

3.1.1 The Project Area.................................................................................................................................67

3.1.2 Treatment Areas..................................................................................................................................67

3.1.3 Invasive Plants and Their Impact on Special Places...........................................................................67

3.1.4 Life of the Project and “Most Ambitious Treatment” Analysis Scenarios.........................................69

3.1.5 Herbicide Risk Assessments and Layers of Caution ..........................................................................73

3.1.6 Basis for Cumulative Effects Analysis ...............................................................................................85

3.2 Botany and Treatment Effectiveness.........................................................................................................88

3.2.1 Affected Environment ........................................................................................................................88

3.2.2 Treatment Effectiveness .....................................................................................................................93

3.2.3 Environmental Consequences of Invasive Plant Treatments on Non-target Plants............................99

3.3 Terrestrial Wildlife..................................................................................................................................105

3.3.1 Introduction ......................................................................................................................................105

3.3.2 Affected Environment ......................................................................................................................106

3.3.3 Environmental Consequences...........................................................................................................112

3.4 Soils and Water .......................................................................................................................................123

3.4.1 Introduction ......................................................................................................................................123

3.4.2 Affected Environment ......................................................................................................................124

3.4.3 Environmental Consequences...........................................................................................................134

3.5 Aquatic Organisms and Habitat ..............................................................................................................158

3.5.1 Affected Environment ......................................................................................................................159

3.5.2 Environmental Consequences...........................................................................................................168

3.6 Effects of Herbicide Use on Workers and The Public ............................................................................190

3.6.1 Introduction ......................................................................................................................................190

3.6.2 Affected Environment ......................................................................................................................190

3.6.3 Environmental Consequences...........................................................................................................191

3.7 Project Costs, Financial Efficiency and Jobs ..........................................................................................195

3.7.1 Introduction ......................................................................................................................................195

3.7.2 Treatment Costs by Method..............................................................................................................196

3.7.4 Total and Average Project Costs ......................................................................................................197

3.7.3 Jobs by Alternative ...........................................................................................................................198

3.8 Additional Environmental Effects...........................................................................................................199

3.8.1 Heritage (Cultural) Resources ..........................................................................................................199

3.8.2 Tribal and Treaty Rights...................................................................................................................200

3.8.3 Environmental Justice and Civil Rights............................................................................................200

3.8.4 Recreation and Scenery ....................................................................................................................201

3.8.5 Congressionally Designated Areas: Wilderness and Wild and Scenic Rivers..................................201

3.8.6 Energy Requirements and Conservation Potential ...........................................................................202

3.8.7 Irreversible or Irretrievable Use of Resources..................................................................................202

3.8.8 Effects on Long-term Productivity ...................................................................................................202

3.8.9 Consistency with Forest Service Policies and Plans.........................................................................202

3.8.10 Conflicts with Other Plans..............................................................................................................203

3.8.11 Adverse Effects That Cannot Be Avoided......................................................................................203

CHAPTER 4. List of Preparers, Consultation and Coordination with Others (Tribes, Agencies)...................205
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

- iii - 

4.1 List of Preparers ......................................................................................................................................205

4.2 Consultation with Regulatory Agencies..................................................................................................206

4.3 Consultation with Tribal Governments ...................................................................................................206

4.4 Consultation with Counties and Municipal Water Boards ......................................................................206

4.5 Consultation with Others.........................................................................................................................206

CHAPTER 5. REFERENCES, INDEX, ACRONYMS AND GLOSSARY ...................................................209

5.1 References ...............................................................................................................................................209

5.2 Index........................................................................................................................................................226

5.3 Acronyms ................................................................................................................................................226

5.4 Glossary...................................................................................................................................................228

APPENDICES 

A - Treatment Area Data Tables and Maps (Published in Total) 

B - Common Control Measures (not republished in FEIS, available on cd, online or by request) 

C - Species of Local Interest (Published in Total) 

D - List of Roadside Treatment Areas with High Potential for Herbicide Delivery to Water (not republished in hard copy 

FEIS, available on cd, online or by request) 

E - Implementation Monitoring and Pesticide Use Forms (not republished in hard copy FEIS, available on cd, online or by 

request) 

F – Restoration Guidelines (not republished in FEIS, available on cd, online or by request) 

G – Prevention Guidelines (not republished in FEIS, available on cd, online or by request) 

H – Public and Interagency Comments and Forest Service Responses (Published in Total) 

LIST OF TABLES

Table 1-Goals and Objectives from the R6 2005 ROD .......................................................................................12

Table 2-Standards from the R6 2005 ROD and How the Project Complies with these Standards .....................14

Table 3-Additional Olympic National Forest Plan Standards and How the Project Complies with These 

Standards .....................................................................................................................................................16

Table 4-Significant Issues, How Issues are Addressed, and Factors for Alternative Comparison......................23

Table 5-Biological Controls Currently Distributed on the Olympic Peninsula that Comply with Standard 14..31

Table 6-Alternative A - Acres by Treatment Combination .................................................................................32

Table 7-Infested Acres by Treatment Area Description......................................................................................33

Table 8-Treatment Priority and Strategy .............................................................................................................34

Table 9-Acres by Treatment Strategy..................................................................................................................35

Table 10-Common Control Measures by Target Species....................................................................................36

Table 11-Typical Herbicide Application Rates ...................................................................................................41

Table 12-Project Design Features........................................................................................................................45

Table 13-Herbicide Use Buffers – Perennial and Wet Intermittent Streams - Proposed Action (Alternative B)55

Table 14-Herbicide Use Buffers, Dry Streams....................................................................................................56

Table 15-Herbicide Use Buffers – Wetlands/High Water Table/Lake/Pond - Proposed Action (Alternative B)56

Table 16-Protection Buffers for Botanical Species of Local Interest ..................................................................58

Table 17-Acres by Treatment Combination - Proposed Action (Alternative B) .................................................58

Table 18-Total Acres by Treatment Combination – Alternative C .....................................................................59

Table 19-Total Acres by Treatment Combination – Alternative D .....................................................................60

Table 20-Alternative Components Compared .....................................................................................................62

Table 21-Alternative Comparison Relative to Issues ..........................................................................................63

Table 22-Estimated Target Species Acres by Treatment Area Description ........................................................68

Table 23-Most Ambitious Annual Treatment Scenario – Alternative A.............................................................71

Table 24-Most Ambitious Annual Treatment Scenario – Alternative B .............................................................71
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

- iv - 

Table 25-Most Ambitious Annual Treatment Scenario - Alternative C..............................................................72

Table 26-Most Ambitious Annual Treatment Scenario - Alternative Comparison.............................................72

Table 27-Herbicide Risk Assessments ................................................................................................................73

Table 28-Products Meeting Standard 18 That Are Approved by WSDA For Use Near Surface Waters............78

Table 29-Herbicides Ingredients, Properties, General Uses and Design Features for Herbicides.......................81

Table 30-Baseline and Scales for Botany, Wildlife, Soils, Water Quality, Aquatic Organisms and Human 

Health...........................................................................................................................................................87

Table 31-Target Species in Wetter Habitats........................................................................................................90

Table 32-Botanical Species of Local Interest, Olympic National Forest ............................................................91

Table 33-Estimated Invasive Plant Acres, No Action 2007-2012.......................................................................95

Table 34-Summary of Effectiveness Indicators, No Action................................................................................96

Table 35-Estimated Invasive Plant Acres, Alternatives B and D, 2007-2012.....................................................97

Table 36-Summary of Effectiveness Indicators, Alternatives B and D...............................................................97

Table 37-Estimated Acres of Invasive Plants, Alternative C, 2007-2012 ...........................................................98

Table 38-Summary of Effectiveness Indicators, Alternative C...........................................................................98

Table 39-Comparison of Alternatives, Effectiveness Indicators .........................................................................98

Table 40-Effects to Non-target Vegetation from No Action .............................................................................101

Table 41-Effects on Botanical SOLI from Treatments in Alternatives B and D...............................................103

Table 42-Alternative C Botanical SOLI at Risk from Treatment......................................................................104

Table 43-Summary of Effects on Botanical SOLI.............................................................................................105

Table 44-Federally Listed Species on Olympic National Forest.......................................................................107

Table 45-Regional Forester Sensitive Terrestrial Wildlife Species...................................................................107

Table 46-Terrestrial Wildlife Management Indicator Species...........................................................................109

Table 47-Primary Excavator Species.................................................................................................................109

Table 48-Effects Determinations on Federally Listed Species (All Action Alternatives).................................116

Table 49-Impact Determinations for Sensitive Wildlife Species ......................................................................119
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

5

Final Environmental Impact Statement 

Olympic National Forest 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

Summary 

Land managers for the Olympic National Forest propose to treat invasive plants via a combination of manual, 

mechanical, and herbicide methods and site restoration (seeding/mulching/planting). 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/projects/four-threats). Invasive plants are displacing native plants and degrading 

natural areas, potentially destabilizing streams and reducing the quality of fish and wildlife habitat. Our 

integrated invasive plant management program includes a) herbicide and non-herbicide treatment of existing 

infestations, b) early detection and rapid response to new infestations, c) restoration of treated sites, d) 

reducing the rate of spread of invasives through adopting prevention practices, and e) interagency and public 

education and coordination. The focus of this Final Environmental Impact Statement (FEIS) is on the part of 

our program related to treatment and restoration of invasive plant sites. 

New invasive plant management direction has recently been approved by the Pacific Northwest (R6) 

Regional Forester, allowing for a wider range of herbicide options and specific treatment and restoration 

standards (USDA 2005b, the Pacific Northwest Invasive Plant Program Record of Decision, referred to 

herein as the R6 2005 ROD). 

The purpose of this project is to control invasive plants in a cost-effective manner that complies with the new 

management direction. Proposed treatment methods include a limited amount of herbicide broadcast along 

roadsides, and spot and selective herbicide applications that target individual invasive plants in combination 

with manual, mechanical and restoration treatments. 

With this project, the Forest Service is responding to a need for timely containment, control, and/or 

eradication of invasive plants, including those that are currently known and those discovered in the future. 

Approximately 3,830 acres are currently estimated to need treatment, including but not limited to herb 

Robert, knapweeds, hawkweeds, knotweeds, and reed canary grass. Under the Proposed Action (also 

referred to as Alternative B), infested areas would be treated with an initial prescription and retreated in 

subsequent years until the site was restored with desirable vegetation. Herbicide treatments would be part of 

the initial prescription for most sites; however, use of herbicides would be expected to decline in subsequent 

entries. Ongoing inventories would confirm the location of specific invasive plants and effectiveness of past 

treatments. Treatment prescriptions would be strict enough to ensure that adverse effects are minimized, 

while flexible enough to adapt to changing conditions over time. 

This FEIS has been prepared to consider the site-specific environmental consequences of treating invasive 

plants over the next 5 to 15 years (until invasive plant objectives are met or until changed conditions or new 

information warrants the need for a new decision). This EIS is tiered to a broader scale analysis (the Pacific 

Northwest Region Invasive Plant Program Final Environmental Impact Statement, USDA 2005a, hereby 

referred to as the R6 2005 FEIS). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

6

The R6 2005 FEIS culminated in a Record of Decision (USDA 2005b, hereby referred to as the R6 2005 

ROD), which added management direction relative to invasive plants to the Olympic National Forest Plan. 

The management direction applied to the broader Forest invasive plant program, establishing goals, 

objectives and standards for public education and coordination, prevention of the spread of invasive plants 

during land uses and activities, reducing reliance on herbicides over time, and treatment and restoration. 

This project level EIS is focused on issues related to treatment and minimizing the adverse effects of 

treatment. In total, four alternatives are considered, including No Action (also referred to as Alternative A), 

the Proposed Action (also referred to as Alternative B), and two action alternatives (Alternatives C and D). 

Under No Action (Alternative A), no new treatments would be implemented, beyond those previously 

approved. The Proposed Action (Alternative B) is the Preferred Alternative. Under Alternative B, known 

infestations of invasive plants could conceivably be controlled within five years (assuming an unlimited 

funding level which is at least five times greater than current projections). Control would take longer (30 

years) given a more likely and sustainable funding level, with lower priority areas unlikely to be treated. 

Alternative B minimizes environmental and human health risks through adherence to Project Design Features 

that abate herbicide and site-specific hazards. 

Two action alternatives were developed in response to public issues related to herbicide use (Alternatives C 

and D). Alternative C resolves most concerns related to herbicide use by eliminating herbicide application 

on about two-thirds of the National Forest System lands. Alternative D was developed to increase treatment 

flexibility and reduce costs. 

Under Alternative C, very limited herbicide use1

 would be permitted within Riparian Reserves. No herbicides 

would be used within roadside treatment areas with high potential to deliver herbicides. Alternative C would 

minimize herbicide impacts by virtually eliminating herbicide delivery mechanisms to surface water bodies, 

but would increase treatment costs and decrease treatment effectiveness. 

Alternative D was developed to increase treatment flexibility by approving broadcast treatments in more 

situations than the Proposed Action. Alternative D reduces the costs of treatments, but under worst-case 

conditions, herbicides could enter streams and other water bodies and harm aquatic organisms. 

The Proposed Action (Alternative B) is the Preferred Alternative. Although Alternative B assumes more risk 

to non-target organisms, water quality, wildlife and fish from herbicide use than Alternative C, the increased 

risks are small compared to the benefits. Alternative B is predicted to cost about five percent more to 

implement than Alternative D, but otherwise is similarly effective. This cost savings is small, especially 

compared to the additional risk associated with broadcast treatments near intermittent streams and ditches 

that would be allowed in Alternative D. 

Chapter 1 of this project level EIS describes the purpose and need for action, the decision to be made, a brief 

outline of the proposed action, the public involvement process, and key public issues. Chapter 2 describes 

and compares the four alternatives considered in detail. Chapter 3 provides the analytical basis for the 

alternative comparison in Chapter 2. Substantive changes made to the Proposed Action and analysis between 

the Draft and Final EIS are identified throughout the documents. 

The Draft EIS contained several appendices that did not changes between the Draft and Final EIS and are not 

reproduced in the printed copy of the FEIS (Appendix B, D, E, F and G). These are on the cd version of the 

FEIS and are available on the project website (find link at http://www.fs.fed.us/r6/olympic). 

 

1

 Existing agreements allow for the use of aquatic-labeled glyphosate within streams to treat knotweed. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

7

Chapter 1. Purpose of and Need for Action 

1.1 Introduction 

Land managers for the Olympic National Forest propose to treat invasive plants over the next five to fifteen 

years via a combination of manual, mechanical, and herbicide methods and site restoration. This 

Environmental Impact Statement (EIS) has been prepared to consider the site-specific environmental 

consequences of taking this action. The main body of the EIS is organized into four chapters: 

• Chapter 1. Purpose and Need for Action: The 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 agency’s 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 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 situation and the resources that are at risk from invasive plants on the Olympic National 

Forest. It also details the environmental effects of implementing the Proposed Action and other 

alternatives. 

• 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. 

This FEIS summarizes specialist input and analysis completed for botany, hydrology, fisheries, soils, 

wildlife, and heritage resources, as well as for cost effectiveness and effects to human health. The analysis 

files contain records of interagency and public correspondence, including documents related to Section 7 

Endangered Species Act Consultation with National Marine Fisheries Service (NMFS or NOAA Fisheries) 

and the United States Fish and Wildlife Service (USFWS or FWS). 

This FEIS is tiered to the broader scale Pacific Northwest Region Invasive Plant Program Final 

Environmental Impact Statement (USDA 2005a, referred to herein as the R6 2005 FEIS). Agencies are 

encouraged to tier their environmental impact statements to eliminate repetitive discussions of the same 

issues and to focus on the actual issues ripe for decision at each level of environmental review (36 CFR 

1508.28). As required, this “subsequent statement” summarizes issues discussed in the broader statement 

(R6 2005 FEIS) and concentrates on site-specific issues. The R6 2005 FEIS incorporated the best available 

scientific information from herbicide risk assessments and other reliable scientific sources. 

The R6 2005 FEIS culminated in a Record of Decision (R6 2005 ROD) that amended the Olympic National 

Forest Plan by adding management direction relative to preventing and treating invasive plants. This project 

is intended to comply with the new management direction. Despite our best efforts at prevention (see 

Appendix G), invasive plants currently grow, and without treatment will continue to spread. 

1.1.1 Changes between Draft and Final EIS 

The Proposed Action was modified and analysis was added in response to public and interagency comments 

since the release of the Draft EIS (see Appendix H for DEIS Comments and Responses). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

8

Modifications to the Proposed Action are described in Chapter 2. Additional analysis is identified in each 

section of Chapter 3. Appendix H also summarizes the changes made in response to public and interagency 

comment. 

1.2 Project Area 

The project area is the entire Olympic National Forest (see vicinity map). The Forest comprises 632,300 

acres of the Olympic Peninsula, the northwestern-most portion of land in the Continental United States. 

1.3 Proposed Action 

Under the Proposed Action, site-specific treatments prescriptions would be implemented over the next three 

to fifteen years, based on Common Control Measures (see Table 10 and Appendix B) and Project Design 

Features (see Table 12). A variety of target species would be treated including but not limited to knapweed, 

knotweed, hawkweed, and reed canarygrass. 

Prescriptions would vary depending on the values at risk from invasive species; the biology of particular 

invasive plant species, the proximity to water and other sensitive resources, and the size of the infestation 

(these factors may change over time). 

The Proposed Action would be implemented over several years as funding allows, until treatments were no 

longer 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, without necessitating further analysis; for 

instance, treated infestations would be reduced in size, untreated infestations would continue to spread and/or 

new invasive plants could become established within the project area. The effects analysis considers a range 

of treatments applied to a range of site conditions to accommodate the uncertainty associated with the project 

implementation schedule. Treatment prescriptions would be strict enough to ensure that adverse effects are 

minimized, while flexible enough to adapt to changing conditions. 

The Proposed Action would allow for treatment of infestations that are not currently inventoried, even those 

found outside mapped treatment areas (see Appendix A). An Implementation Planning process would be 

applied to new infestations to ensure that treatments are within the scope of the analysis and eventual 

decision. Project Design Features were developed to minimize the potential for adverse effects no matter 

how many acres may be selected for treatment in a given season. 

Infested areas would be treated with an initial prescription, and retreated in subsequent years, depending on 

the results, until control objectives were met. Many variables could affect invasive plant treatments, 

including treatment effectiveness, timing, weather, soil type, conditions on neighboring non-federal lands, 

and available funding and personnel. 

The Proposed Action would allow invasive plant treatments in all land allocations, including wilderness and 

riparian reserves, across the National Forest. Project design features for the Proposed Action restrict certain 

treatment methods depending on the land allocation and other site conditions such as proximity to surface 

water bodies, wildlife habitats, botanical species of local interest, etc. 

Herbicide treatments are part of the initial prescription for most sites; however, use of herbicides would be 

expected to decline in subsequent entries (see section 3.1.4) 

A decision to implement the Proposed Action (or action alternative) would replace the management direction 

provided in the Environmental Assessment for the Integrated Weed Management Program, Olympic National 

Forest (USDA Forest Service, 1998). 

For a full description of the Proposed Action (also referred to as Alternative B), see Chapter 2. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

9

1.4 Purpose and Need for Action 

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/projects/four-threats). Invasive plants are adversely 

impacting approximately 3,830 acres, scattered across the Olympic National Forest. Invasive plants are 

displacing native plants, destabilizing streams, reducing the quality of fish and wildlife habitat; and 

degrading natural areas on the Olympic National Forest. Strong public concern has been expressed regarding 

Forest Service response (or lack of response) to invasive plants. Several organizations and individuals have 

offered to cooperate with the Forest Service in this endeavor. The Forest Service is responding to the crucial 

need for timely containment, control, and/or eradication of invasive plants, including those that are currently 

known and those discovered in the future. The purpose of this project is to treat invasive plants in a costeffective manner that complies with environmental standards. 

The R6 2005 ROD added the following Desired Future Condition Statement to the Olympic 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 Olympic] 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. 

Habitat for native plant communities has been degraded in or near special places such as the Colonel Bob, 

Mount Skohomish and Buckhorn Wilderness Areas; Matheny Pond, Matheny Prairie, Bill’s Bog, and 

Cranberry Bog Botanical Areas; Quinault and Wet Weather Creek Research Natural Areas, Quinault and 

Crescent Lakes; and a host of trails, campgrounds, and other popular recreation areas. These areas require 

action to restore native plant communities. 

Without treatment, invasive plants will continue to spread within these and other special areas on and 

adjacent to the National Forest. Invasive plants on National Forest System lands also have the potential to 

spread to neighboring lands including the Olympic National Park, Native American tribal lands, state and 

private properties. Chapter 3 details site-specific values at risk from invasive plants, and describes places 

where invasive plants are most likely to spread to neighboring lands. Invasive plants are currently 

spreading at a rate of 8 to 12 percent annually (R6 2005 FEIS). 
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Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

11

Not all invasive plants are equally threatening to environmental and social values; priority for treatment and 

treatment strategy2

 varies depending on the biology of the invasive species, size of the infestation, and the 

values at risk from the infestation now and in the future. 

Treatment intensity and restoration requirements are highly variable. As a result, the need for action is 

multi-faceted and more complex than simply “killing weeds.” 

The R6 2005 ROD provided an updated approach to invasive plant management, including standards for 

preventing invasive plants and using new herbicides. While invasive plant prevention is an integral part of 

the invasive plant program, the focus of this FEIS is on the part of the program that has a need for action 

beyond prevention. The R6 2005 FEIS found that prevention practices alone will not result in reaching 

invasive plant program goals and objectives (see table 1). The proposed treatment/restoration prescriptions 

include a combination of herbicide and non-herbicide methods; however, key public issues are primarily 

related to the use of herbicides. 

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

Thus, the Forest Service needs the flexibility to adapt to changing conditions, and rapidly respond to invasive 

plant threats that may be currently 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 is when treated, the more likely the treatment will be effective. 

Timely treatments are also important to help meet the Forest Plan objective of reduced herbicide use over 

time. 

1.4.1 Regulatory Basis for Project/Environmental Standards 

Several broad federal policies require the control of invasive plants. Executive Order 13112 (1999) directs 

federal agencies to reduce the spread of invasive plants. The Forest Service Pesticide Use Handbook (FSH 

2109.14) provides agency guidance on planning, implementation, and reporting of projects that include 

herbicide (see Appendix E for more information). 

The R6 2005 ROD added invasive plant management direction (displayed in tables 1 and 2) to the existing 

direction for the Olympic National Forest Plan (displayed in table 3). Land uses and activities, including 

invasive plant treatments, would be designed to comply with the R6 2005 ROD standards. Standards for 

preventing invasive plants are in Appendix G. 

 

2

 Definitions of these treatment strategies are adapted from the 2005 R6 FEIS. Two additional objectives (tolerate and 

suppress) are also discussed in the 2005 R6 FEIS. Invasive plants with these objectives would not be treated using the 

methods described in this EIS. 

Eradicate: Totally eliminate an invasive plant species from a site. This strategy generally applies to the hardest to 

control invasive species and highest-valued sites over about 11 percent of the infested acreage. 

Control: Reduce the acreage of the infestation over time. This strategy applies to about 39 percent of the project area. 

Contain: No increase in acreage infested. This objective applies to about 50 percent of the infested acreage. 

Priority is further discussed in Chapter 2. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

12

Table 1-Goals and Objectives from the R6 2005 ROD 

Invasive Plants Treatment Goals and Objectives from the R6 2005 ROD 

Goal 1 - Protect ecosystems from the impacts of invasive plants through an integrated approach that emphasizes 

prevention, early detection, and early treatment. All employees and users of the National Forest recognize that 

they play an important role in preventing and detecting invasive plants. 

Objective 1.1 Implement appropriate invasive plant prevention practices to help reduce the introduction, 

establishment and spread of invasive plants associated with management actions and land 

use activities. 

Objective 1.2 Educate the workforce and the public to help identify, report, and prevent invasive plants. 

Objective 1.3 Detect new infestations of invasive plants promptly by creating and maintaining complete, 

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

susceptible areas not infested with invasive plants. 

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

combination of available tools including manual, cultural, mechanical, herbicides, biological 

control. 

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

infestations where control is not practical, conduct follow up inspection of treated sites to 

prevent reestablishment. 

Goal 2 - Minimize the creation of conditions that favor invasive plant introduction, establishment and spread during 

land management actions and land use activities. Continually review and adjust land management practices to 

help reduce the creation of conditions that favor invasive plant communities. 

Objective 2.1 Reduce soil disturbance while achieving project objectives through timber harvest, fuel 

treatments, and other activities that potentially produce large amounts of bare ground. 

Objective 2.2 Retain native vegetation consistent with site capability and integrated resource 

management objectives to suppress invasive plants and prevent their establishment and 

growth. 

Objective 2.3 Reduce the introduction, establishment and spread of invasive plants during fire 

suppression and fire rehabilitation activities by minimizing the conditions that promote 

invasive plant germination and establishment. 

Objective 2.4 Incorporate invasive plant prevention as an important consideration in all recreational land 

use and access decisions. Use Forest-level Access and Travel Management planning to 

manage both on-highway and off-highway travel and travel routes to reduce the 

introduction, establishment and spread of invasive plants. 

Objective 2.5 Place greater emphasis on managing previously “unmanaged recreation” (OHVs, dispersed 

recreation, etc.) to help reduce creation of soil conditions that favor invasive plants, and 

reduce transport of invasive plant seeds and propagules. 

Goal 3 - Protect the health of people who work, visit, or live in or near National Forests, while effectively treating 

invasive plants. Identify, avoid, or mitigate potential human health effects from invasive plants and treatments. 

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

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

Goal 4 – Implement invasive plant treatment strategies that protect sensitive ecosystem components, and 

maintain biological diversity and function within ecosystems. Reduce loss or degradation of native habitat from 

invasive plants while minimizing adverse effects from treatment projects. 

Objective 4.1 Maintain water quality while implementing invasive plant treatments. 

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

applied herbicides. Where herbicide treatment of invasive plants is necessary within the 

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

consistent with riparian management direction, contained in Pacfish, Infish, and the Aquatic 

Conservation Strategies of the Northwest Forest Plan. 

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

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

and maintain species viability. 

Goal 5 – Expand collaborative efforts between the Forest Service, our partners, and the public to share learning 

experiences regarding the prevention and control of invasive plants, and the protection and restoration of native 

plant communities. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

13

Invasive Plants Treatment Goals and Objectives from the R6 2005 ROD 

Objective 5.1 Use an adaptive management approach to invasive plant management that emphasizes 

monitoring, learning, and adjusting management techniques. Evaluate treatment 

effectiveness and adjust future treatment actions based on the results of these evaluations.

Objective 5.2 Collaborate with tribal, other federal, state, local and private land managers to increase 

availability and use of appropriate native plants for all land ownerships. 

Objective 5.3 Work effectively with neighbors in all aspects of invasive plant management: share 

information and resources, support cooperative weed management, and work together to 

reduce the inappropriate use of invasive plants (landscaping, erosion control, etc.). 

In addition, Standards 11 through 23 from the R6 2005 ROD apply to invasive plant treatment and 

restoration (see table 2). Standards 1 through 10 apply to invasive plant prevention. These standards and 

additional information about prevention on the Olympic National Forest are displayed in Appendix G. All 

alternatives assume prevention practices will be implemented as directed. 

The R6 2005 ROD standards require that prevention practices be considered in land management activities 

and decisions. Ongoing programs such as roads, trail, vegetation, habitat and/or timber management can 

influence invasive plant spread. Prevention of invasive plants is managed in the context of each program’s or 

project’s objectives and opportunities. This project EIS focuses on issues and alternatives related to 

treatment and is tiered to the R6 2005 FEIS programmatic analysis of prevention. 

Table 3 shows additional standards from the 1990 Olympic National Forest Plan (as amended by the 1994 

Northwest Forest Plan3

) that apply to municipal watersheds, and Riparian Reserves (a land allocation, 

including Olympic National Forest System lands, within an area reaching upslope approximately 1 to 2 times 

the average height of a tree on either side of a creek or water body). 

Part of compliance with the Northwest Forest Plan relates to considering watershed analysis 

recommendations in project planning. Nineteen watershed assessments have been prepared on the Olympic 

National Forest since 1994. Of these, 13 discuss invasive plants/noxious weeds. Invasive species were also 

identified as a threat to native plant ecosystems in six Late-Successional Reserve (LSR) Assessments. The 

watershed assessments and LSR Assessments provide evidence of the presence of invasive plants, their 

adverse impact, and the need for treatment. 4

Treatments may also be proposed within wilderness areas. Any treatment within wilderness would be aimed 

at preserving or protecting wilderness character. Mechanized equipment would not be used. 

 

3

 The Northwest Forest Plan is formally referred to as the Record of Decision for Amendments to Forest Service and 

Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl (USDA/USDI 1994). 

4

 Watershed assessment and LSR Assessment references and excerpts pertaining to invasive plant management are 

available in the project files. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

14

Table 2-Standards from the R6 2005 ROD and How the Project Complies with these Standards 

Standard # Forest Plan Standard How Project Complies with Standard 

11 Prioritize infestations of invasive plants for 

treatment at the landscape, watershed or larger 

multiple forest/multiple owner scale. 

Treatment priorities are described in Chapter 2 

and depicted on the treatment area maps in 

Appendix A. 

12 Develop a long-term site strategy for 

restoring/revegetating invasive plant sites prior to 

treatment. 

Treatment strategies and restoration plans are 

described in Chapter 2. Appendix B includes 

common control measures for invasive target 

species and Appendix F outlines the restoration 

approach. 

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, 

non-invasive 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 non-native invasive plant 

species be used for revegetation. 

Revegetation (seeding and planting) would 

occur as needed to replace invasive plants with 

native plant communities. Non-native, nonpersistent species may be used infrequently as 

an interim measure to control erosion or prevent 

target species from returning on treated sites. 

Appendix F outlines the restoration approach 

including use of native plant materials. 

14 Use only USDA Animal and Plant Health 

Inspection Service (APHIS) and State-approved 

biological control agents. Agents demonstrated to 

have direct negative impacts on non-target 

organisms would not be released. 

APHIS and Washington state approved 

Biological Agents currently released within or 

near Olympic National Forest are listed in 

Chapter 2. Agents found to have negative 

impacts may not be distributed on the Olympic 

National Forest; this list will be updated annually 

and discussed with adjacent landowners. 

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 are listed in Chapter 2. 

Policies/compliance monitoring and reporting 

forms related to herbicide use are further 

discussed in Appendix E. 

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 Forest Plan or 

project level through appropriate risk analysis and 

NEPA/ESA procedures. 

See Chapter 2 for details about Project Design 

Features (PDFs), which add layers of caution 

and minimize or eliminate adverse effects 

related to use of herbicides and adjuvants. 

The herbicide formulations listed in this 

document are approved for use according to the 

PDFs. 

Table 28 lists the herbicide formulations that 

currently meet Standards 16 and 18, based on 

analysis by Bakke (2003a and 2003b) and 

SERA (various, see Chapter 3.1.5) and 

disclosures herein. 

Since the release of the DEIS, the herbicide 

formulation Habitat (the aquatic formulation for 

Imazapyr) has become approved for use. 

Policies/compliance monitoring and reporting 

forms related to herbicide use are further 

discussed in Appendix E. 

17 The 2005 ROD does not include any Standard 17 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

15

Standard # Forest Plan Standard How Project Complies with Standard 

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

inert ingredients reviewed in Forest Service hazard 

and risk assessment documents. 

R6 has provided a list of adjuvants that meet this 

standard. In addition, the project follows State of 

Washington regulations for adjuvant use near 

surface waters. 

19 To minimize or eliminate direct or indirect negative 

effects to non-target plants, terrestrial animals, 

water quality and aquatic biota (including 

amphibians) from the application of herbicide, use 

site-specific soil characteristics, proximity to 

surface water and local water table depth to 

determine herbicide formulation, size of buffers 

needed, if any, and application method and timing. 

Consider herbicides registered for aquatic use 

where herbicide is likely to be delivered to surface 

waters. 

Chapter 3 discusses how risks from herbicide 

use are abated by Project Design Features 

including buffers and restrictions on herbicide 

use and method of application in Aquatic 

Influence Zones and roadside treatment areas 

that have high potential to deliver herbicide to 

streams and other water bodies. . 

20 Design invasive plant treatments to minimize or 

eliminate adverse effects to species and critical 

habitats proposed and/or listed under the 

Endangered Species Act. This may involve 

surveying for listed or proposed plants prior to 

implementing actions within unsurveyed habitat if 

the action has a reasonable potential to adversely 

affect the plant species. Use site-specific 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 abated by 

Project Design Features. 

21 Provide a minimum buffer of 300 feet for aerial 

application of herbicides near developed 

campgrounds, recreation residences and private 

land (unless otherwise authorized by adjacent 

private landowners). 

No aerial application is proposed. 

22 Prohibit aerial application of herbicides within 

legally designated municipal watersheds. 

No aerial application is proposed. Coordination 

with water users would occur in accordance with 

Municipal Watershed Plans (more information in 

Chapter 3). 

23 Prior to implementation of herbicide treatment 

projects, National Forest staff will ensure timely 

public notification. Treatment areas will be posted 

to inform the public and forest workers of herbicide 

application dates and herbicides used. If 

requested, individuals may be notified in advance 

of spray dates. 

Chapter 2 lists Project Design Features, 

including public notification requirements. 

Policies/compliance monitoring and reporting 

forms related to herbicide use are further 

discussed in Appendix E. 

*ATSDR, 2004. Guidance Manual for the Assessment of Joint Toxic Action of Chemical Mixtures. U.S. Department Health and Human 

Services, Public Health Service, Agency for Toxic Substances and Disease Registry. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

16

Table 3-Additional Olympic National Forest Plan Standards and How the Project Complies with These 

Standards 

Forest Plan Standard How Project Complies with Standard 

Apply silvicultural practices for 

Riparian Reserves to control 

stocking, reestablish and manage 

stands, and acquire desired 

vegetation characteristics needed 

to attain Aquatic Conservation 

Strategy objectives. 

Invasive species are degrading native plant communities and habitats. Invasive 

plants retard or prevent recovery of native plant communities, which may reduce 

structural diversity of plant communities in riparian areas. Vegetation 

management is necessary within Riparian Reserves to restore native plant 

communities that have been affected by invasive plants. The adverse impacts 

of invasive plants are discussed under “Affected Environment” in each resource 

section of Chapter 3. 

Herbicides, insecticides, and other 

toxicants, and other chemicals 

shall be applied [within Riparian 

Reserves] only in a manner that 

avoids impacts that retard or 

prevent attainment of Aquatic 

Conservation Strategy objectives. 

Compliance with Aquatic Conservation Strategy objectives is discussed in 

Chapter 3.4. As currently designed, Alternative D would not be consistent with 

the Aquatic Conservation Strategy because of its higher potential to deliver 

herbicide to streams and other water bodies. If Alternative D were to be 

selected, additional mitigation would be required to ensure that herbicide use 

near dry streams and along higher risk roads was done in a manner consistent 

with the Aquatic Conservation Strategy, or a project-specific Forest Plan 

amendment would be required. 

Herbicides and pesticides should 

not be used in municipal 

watersheds. Chemicals should be 

used as a last resort, and only 

where analysis demonstrates water 

quality will not be adversely 

affected. 

Herbicide use is proposed in municipal watersheds as a part of this project to 

meet the purpose and need for action. Drinking water would be protected (see 

buffers and design features in Chapter 2.5, especially PDF B3 and H12). 

Treatments would be done in accordance with individual municipal watershed 

agreements. Chapter 3.4 summarizes the potential effects of invasive plant 

treatments proposed within municipal watersheds. 

1.5 Decision Framework 

The Forest Supervisor for the Olympic National Forest is the Responsible Official for this EIS. The Forest 

Supervisor will review the environmental consequences to decide whether to implement the Proposed Action 

(Alternative B), another action alternative, or continue to implement the No Action alternative (Alternative 

A). 

Factors influencing the decision include: 

1. Effectiveness in reaching control objectives for invasive plants, as indicated by the acreage of 

invasive plants estimated for the year 2012 (under the most ambitious conceivable treatment 

scenario as defined in Chapter 3.1). 

2. Potential adverse effects to human health and the environment, as indicated by the effects 

analysis throughout Chapter 3, and 

3. Monetary costs and financial efficiency, as indicated by the economic efficiency analysis 

displayed in Chapter 3.7. 

1.6 Public Involvement 

This FEIS has been developed over many years. It was first listed in the Olympic National Forest Schedule 

of Proposed Actions in January 2004 and a Notice of Intent (NOI) to prepare an EIS requesting public input 

was published in the Federal Register on February 23, 2004. The NOI proposed a project with a geographic 

scope covering the Olympic National Forest, along with two other National Forests in western Washington 

and Oregon and the Columbia River Gorge National Scenic Area. Individuals, organizations, agencies, 

businesses, and local and Tribal governments were contacted by letter and solicited for comments on the 

proposal. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

17

Approximately 150 comments were received. One concern was the large geographical scope of the project. 

Another concern was that the programmatic R6 FEIS was not complete so management direction pertinent to 

the project was in flux. 

The Forest Service decided to prepare an EIS specific to the Olympic National Forest, and to reinitiate 

scoping in August 2005, following the public release of the R6 2005 FEIS. A new NOI was published on 

August 25, 2005, and a letter describing an updated proposal was widely circulated. The public was advised 

that the 2004 comments would still be considered, along with any new comments. Approximately 15 

comments were received during the second scoping period. 

The following section (1.6.1) summarizes the significant issues identified through the scoping process and 

discusses how they are addressed in the EIS analysis. The issues are grouped into broad resource categories. 

Issue Group 1 relates to human health, Issue Group 2 relates to the effectiveness of treatments, Issue Group 3 

relates to social and economic issues, Issue Group 4 relates to effects on non-target terrestrial plant and 

animal species, and Issue Group 5 relates to soils, water quality and aquatic organisms. Table 4 displays how 

each significant issue is addressed and the factors for alternative comparison. 

The project file includes scoping comments received during both scoping periods, copies of the 2004 and 

2005 NOIs, scoping outreach letters and legal notices. 

The topics listed here do not reflect issues that were raised with this proposal, but are required disclosures for 

EIS documents. These are addressed in Chapter 3. 

• Congressionally Designated Areas 

• Prime Farm and Forest Lands 

• Cultural Resources 

• Relationship Between Short-term Uses and Long-term Productivity 

• Conflicts with Other Policies, Plans, Jurisdictions 

• Irretrievable and Irreversible Commitment of Resources 

1.6.1 Issue Group 1: Human Health and Worker Safety 

Issue Components: 

1a: Exposure to Herbicides 

1b: Drinking Water 

1c: Worker Safety 

1a: Exposure to Herbicides 

Issue Statement: People, including neighbors, visitors, and herbicide applicators, may become exposed to 

herbicides from invasive plant treatments and experience adverse health effects. 

This issue has been resolved by the Standards in the R6 2005 ROD. Chapter 4.5 and Appendix Q of the R6 

2005 FEIS provided detailed descriptions of the hazards associated with the herbicides proposed for use. 

The herbicides available for use (Standard 16) were selected because they pose comparatively low risks to 

people. Standard 15 requires that all projects be implemented by certified applicators who have been training 

in herbicide safety. Standard 23 requires public notification prior to using herbicides. 

The Project Design Features in all alternatives further reduce risk by practices such as limiting herbicide 

application rates, favoring formulations with the lowest possible risks, and temporarily closing areas such as 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

18

campgrounds or special forest product gathering areas to ensure no inadvertent contact between people and 

herbicides occurs. All alternatives would be implemented to follow pesticide use policies of the US Forest 

Service (see FSH 2109.14, Appendix E) intended to reduce risk to human health. 

1b: Drinking Water 

Issue Statement: Herbicides may contaminate drinking water through direct contact (a spill into a drinking 

water source), or indirectly through leaching, percolation, or run off. 

This issue has been resolved by compliance with the Standards in the R6 2005 ROD and other management 

direction (Clean Water Act, Olympic National Forest Plan). The herbicide risk assessments and analysis in 

the R6 2005 FEIS, especially Appendix Q, demonstrate that there is very low risk of drinking water 

contamination or health impacts from the herbicides and types of applications proposed for use. Project 

Design Features for all alternatives ensure that herbicide mixing would occur away from streams and water 

sources. 

No herbicides would be applied near wells and or springs (PDF H12). Safe transportation and handling of 

herbicides, and spill containment, would be documented in a pre-project plan (PDF G). Chapter 3.4 

discusses why herbicide would not be delivered to drinking water in concentrations of concern. Chapter 3.6 

discusses the human health effects analysis. 

1c: Worker Injuries 

Issue Statement: Workers may be injured (sprains, strains, cuts and falls) during invasive plant treatments. 

This issue is addressed by adherence to OSHA guidelines in all alternatives. Some people perceive that risks 

to workers are greatest from herbicide treatments due to potential chemical exposure (see Issue 1a). Others 

perceive that non-herbicide treatments are more likely to result in physical injuries since these methods tend 

to be more labor-intensive. Injuries associated with non-herbicide work are not considered unusual and are 

mitigated through accepted field safety practices. Therefore, this issue will not be tracked through the 

analysis. 

1.6.2 Issue Group 2 – Treatment Strategy and Effectiveness 

Issue Components: 

2a: Effectiveness of Treatment Methods 

2b: Long-term Strategy 

2c: Treatment Priority 

2d: Adaptive Management/Early Detection-Rapid Response 

2a – Effectiveness of Treatment Methods 

Issue Statement: Restrictions on herbicide use tend to reduce treatment effectiveness and increase cost. 

Many invasive plants do not respond effectively to manual and mechanical treatments without herbicide. 

The Proposed Action and Alternative D allow for the use of herbicides in most invasive plant situations. 

With unlimited funding, existing infestations would largely be controlled by 2012. 5

 

5

 The most ambitious treatment scenarios for each alternative are described in Chapter 3.1 and used as the basis for 

comparison of effects. This scenario is unlikely to occur because it would require at least a five-fold increase in 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

19

Alternative C, however, would rely on manual and mechanical methods on a greater proportion of the 

infested acreage, which decreases the likelihood that control objectives may be met, especially for sites 

having a control objective of eradicate. If control objectives are not met, adverse effects of invasives would 

continue. 

This is a key issue tracked throughout this document. The alternatives are compared by: 

• The number of herbicide formulations available for use 

• The proportion of infested acres that may be treated using herbicide 

• Acres of invasives predicted for the year 2012 

2b – Long-term Strategy, Reduce Reliance on Herbicides Over Time 

Issue Statement: Treated sites need to be restored to hasten recovery of native vegetation and reduce 

reliance on herbicides over time. 

Treatment prescriptions in all alternatives include site restoration (passive revegetation, mulching, seeding, 

and planting). Manual and mechanical follow-up treatments would be favored, especially when populations 

are small enough to control without herbicides. 

Restoration is described in Chapter 2 and Appendix F. Restoration prescriptions do not vary significantly 

between action alternatives. Multi-year treatment scenarios demonstrating declining reliance on herbicides 

are displayed in Chapter 3.1. 

2c – Treatment Priority 

Issue Statement: Treatments must be prioritized so that available funding can be utilized as efficiently as 

possible. 

This issue is addressed through adherence to invasive plant treatment standards in the Olympic National 

Forest Plan as amended by the R6 2005 ROD. The standards require that invasive plant treatments sites be 

prioritized. Treatment priorities are described in Chapter 2.5. Treatment priorities do not vary between 

alternatives; however, given limited budgets, alternatives that cost more per acre to implement are less likely 

to treat all high priority sites. 

2d – Adaptive Management/Early Detection-Rapid Response 

Issue Statement: The Forest Service needs the ability to respond rapidly to new infestations and improve 

effectiveness through adaptive management. 

This issue is addressed through inclusion of an adaptive management plan and early detection-rapid response 

strategy in all action alternatives. The adaptive management plan and early detection-rapid response strategy 

is described in Chapter 2 and does not vary significantly between alternatives. 

1.6.3 Issue Group 3 – Social and Economic 

Issue Components: 

3a: Treatment Costs and Financial Efficiency 

3b: More Jobs Associated with Manual Treatments 

3c: Effects on Scenic, Recreation, and Wilderness Values 

 

expected funding, however it provides a basis for analysis and highlights differences in effectiveness between the 

alternatives. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

20

3d: Effects on Special Forest Products 

3e: Effects on American Indian Tribes and Treaty Rights, Civil Rights and Environmental 

Justice 

3a – Treatment Costs and Financial Efficiency 

Issue Statement: Treatment costs vary depending on method. Non-herbicide methods tend to be more 

expensive than herbicide methods. Spot and hand herbicide application methods tend to be more expensive 

that broadcast herbicide methods. 

This issue is addressed through the development of Alternative D, which emphasizes use of broadcast 

herbicide methods. In contrast, the Proposed Action restricts broadcast herbicide application methods in 

many situations and Alternative C does not allow any broadcast treatment. Alternative C also relies on nonherbicide methods on about 70 percent of currently infested acreage, which increases treatment costs. 

This is a key issue tracked throughout this document. The alternatives are compared by: 

• Total cost for the most ambitious conceivable project over a 5 year period 

• Average annual cost for the most ambitious conceivable project over a 5 year period 

• Average cost per acre of treatment over a 5 year period 

3b – More Jobs Associated with Manual Treatments 

Issue Statement: Manual treatments tend to be more labor-intensive and employ more workers than 

herbicide treatment methods. 

This issue is addressed through the development of Alternative C, which has the greatest relative proportion 

of manual treatments compared to the other action alternatives. 

This is a key issue tracked throughout this document. The alternatives are compared by: 

• The estimated number of jobs provided by the most ambitious treatment scenario 

3c – Effects of Invasive Plant Treatment on Scenic, Recreation and Wilderness 

Values 

Issue Statement: Invasive plant treatments may be visible along road corridors and in recreation and 

wilderness areas. 

This issue is addressed through adherence to invasive plant treatment management direction in the Olympic 

National Forest Plan as amended by the R6 2005 ROD. Over the long term, controlling invasive plants 

would improve scenic, recreation and wilderness values. Potential effects on these values are described in 

Chapter 3. 

3d – Effects of Herbicide on Special Forest Products and Gatherers 

Issue Statement: Herbicide treatments may leave residues on special forest products making them unsafe 

for consumption or unsuitable for collection. 

This issue is addressed through adherence to invasive plant treatment management direction in the Olympic 

National Forest Plan as amended by the R6 2005 ROD. These standards require public education and a 

public notification strategy if herbicides are used. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

21

The Project Design Features described in Chapter 2 ensure that conflicts between treatments and special 

forest products and gathering areas are minimized. Potential effects on special forest products and gatherers 

are described in Chapter 3. 

3e – Effects on American Indian Tribes and Treaty Rights, Civil Rights and 

Environmental Justice 

Issue Statement: Invasive plant treatments may harm culturally important plants or have disproportionate 

effects on cultures that rely on subsistence or special forest product gathering. Asian, Hispanic, and Native 

American communities may be impacted by invasive plant treatments. 

Executive Order 12898 (1994) requires federal agencies to identify and address adverse effects to human 

health and the environment that may disproportionately impact minority and low-income people. Also, the 

Executive Order directs agencies to consider patterns of subsistence hunting and fishing when an agency 

action may affect fish and wildlife. 

This issue is addressed in all alternatives through Project Design Features described in Chapter 2. These 

include ongoing consultation with American Indian Tribes, outreach with subsistence and special forest 

product gathering communities, and public notification of herbicide treatments through the newspaper, onsite 

posting, and use of flyers. 

1.6.4 Issue Group 4 – Effects on Non-Target Plants and Wildlife 

Issue Components: 

4a: Effects on Non-Target Botanical Species of Local Interest 

4b: Effects of Herbicides on Terrestrial Wildlife Species of Local Interest 

4a – Effects of Herbicide on Non-Target Botanical Species of Local Interest 

Issue Statement: Herbicides may harm native plants due to drift (especially from broadcast treatments), 

runoff, and/or leaching. The potential for adverse effects to non-target species are dependent on the type of 

herbicide used and the application method chosen. Non-target vascular plants, lichens, bryophytes, and fungi 

in close proximity to invasive plants, especially species of local interest, are at particular risk because they 

are rarer or more susceptible to pollutants, including biological pollutants such as invasive plants. 

This issue is addressed through adherence to invasive plant treatment standards in the Olympic National 

Forest Plan as amended by the R6 2005 ROD. The R6 2005 FEIS provided detailed assessments of the risks 

to non-target vegetation from herbicide. Chapter 2 describes the Project Design Features intended to avoid 

potential harm and Chapter 3.2 discusses the potential for adverse effects to non-target botanical species. 

Effects on non-vascular plants are especially uncertain when broadcast herbicide application methods are 

used. This uncertainty cannot be fully mitigated. Thus, the alternatives are compared by: 

• Estimated Proportion of Project With Potential Broadcast Application 

4b – Effects of Herbicide on Terrestrial Wildlife Species of Local Interest 

Issue Statement: Invasive plant treatments may disturb wildlife or trample wildlife habitat. Wildlife may 

contact herbicides or ingest invasive plants treated with herbicide and become sick or die. 

This issue is generally addressed through adherence to invasive plant treatment standards in the Olympic 

National Forest Plan as amended by the R6 2005 ROD. Chapter 2 describes the Project Design Features 

intended to avoid potential harm to wildlife and Chapter 3 explains why the potential for adverse effects to 

wildlife is minimized in all alternatives. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

22

However, herbicide effects on specific wildlife species of local concern may be uncertain because studies are 

limited. This issue is of specific interest to FWS in regards to species listed or proposed for listing under the 

federal Endangered Species Act (ESA). 

Consultation with FWS was documented through the Forest Service Biological Assessment (BA). In a letter 

dated May 18, 2007, the FWS concurred with the FS effect determinations for bald eagle, marbled murrelet, 

and northern spotted owl (FWS BO 2007)6 Bald eagle has since been taken off the Endangered Species list. 

It is still considered a Regional Forester’s Sensitive Wildlife Species on the Olympic National Forest. 

1.6.5 Issue Group 5 – Effects on Soils, Water and Aquatic Organisms 

Issue Components: 

5a: Potential Adverse Effects of Invasive Plant Treatment on Soils 

5b: Potential for Herbicide Delivery to Streams, Lakes, Rivers, Floodplains and Wetlands 

5c: Potential for Herbicides to Result in Adverse Effects to Aquatic Ecosystems 

5a – Potential Adverse Effects of Invasive Plant Treatment on Soils 

Issue Statement: Invasive plants provide ground cover that may be disturbed by treatments. Herbicide use 

may harm soil organisms or soil biology. This issue is addressed through adherence to invasive plant 

treatment standards in the Olympic National Forest Plan as amended by the R6 2005 ROD. Chapter 2 

describes the Project Design Features intended to avoid potential harm and Chapter 3 explains why the 

potential for adverse effects to soils are minimized in all alternatives. 

5b – Potential for Herbicide Delivery to Streams, Lakes, Rivers, Floodplains and 

Wetlands 

Issue Statement: Herbicides used near or along streams, lakes, rivers, floodplains and wetlands may enter 

surface or ground waters through drift, runoff, leaching or direct contact. Roads with high potential to 

deliver herbicides can function as conduits for herbicide delivery to these water bodies. 

This issue is primarily addressed through adherence to invasive plant treatment standards in the Olympic 

National Forest Plan as amended by the R6 2005 ROD. Chapter 2 describes the Project Design Features 

intended to minimize the chance that herbicide concentrations of concern would enter streams. Broadcast 

treatments have the greatest potential for off site movement of herbicides; spot and hand treatments result in 

far less risk of herbicide delivery to water bodies. Thus, Project Design Features and buffers are proposed to 

limit broadcast within the Aquatic Influence Zone (an area defined as half the distance of a Riparian 

Reserve). Fish bearing streams have an Aquatic Influence Zone of approximately 150 feet (50 meters) each 

side of a stream – half the 300 foot Riparian Reserve for such a stream). 

The alternatives are compared by: 

• Character of herbicide use within Aquatic Influence Zones 

• Estimated acres of herbicide use within Aquatic Influence Zones 

• Estimated acreage of herbicide treatment on roadside treatment areas with high potential to deliver 

herbicides 

 

6

 The Forest Service submitted a single Biological Assessment covering aquatic and terrestrial federally listed species in 

January 2007. FWS and NMFS responded with letters of concurrence on the portions of the project with a 

determination of “May Affect, Not Likely to Adversely Affect” (FWS, April 2007 and NMFS, May 2007) and 

Biological Opinions on the portions of the project with the determination of “May Affect, Likely to Adversely Affect” 

(FWS, Sept. 2007) and NMFS, October 2007) covering various portions of project. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

23

• Estimated proportion of project where broadcast treatment may occur on roadside treatment areas 

with high potential to deliver herbicides 

5c – Potential for Adverse Effects to Aquatic Organisms from Herbicide 

Issue Statement: Herbicides that enter water bodies may harm aquatic organisms, including fish species of 

local interest. 

This issue is addressed by limiting the herbicide formulation and application rate, timing, and method so that 

the risk of adverse effects is minimized or eliminated. The alternatives vary as to the treatments allowed in 

Aquatic Influence Zones and along roadsides with high potential to deliver herbicides to streams. These 

differences influence the level of risk that herbicides will enter water bodies. The alternatives are compared 

by: 

• Potential for aquatic organisms to be exposed to harmful concentrations of herbicide 

The invasive plant treatment BA was developed by an interagency consultation team (referred to as the Level 

1 Team) including staff from the FS, NMFS), and the FWS. The Level 1 Team worked together periodically 

over the past two years to review and develop project design criteria that incorporate the best management 

practices to minimize adverse effects to aquatic resources. The BA describes and evaluates the effects of 

manual, mechanical and chemical invasive plant treatment methods (FWS 2007 BO, page 1.) 

1.6.6 Summary of Significant Public Issues and Alternative Comparison Factors

Table 4 summarizes how the issues are addressed and factors used to compare the effects of the alternatives. 

Table 4-Significant Issues, How Issues are Addressed, and Factors for Alternative Comparison 

Issue Group Issue Component How Issue is Addressed Factors for Alternative 

Comparison 

1 – Human Health 

and Worker Safety 

1a – Exposure to 

Herbicides 

 Exposure scenarios that may harm 

workers and/or the public are avoided in all 

alternatives. 

No substantial difference 

between action alternatives 

1 – Human Health 

and Worker Safety 

1b – Drinking Water No plausible scenarios for public harm due 

to drinking water contamination are 

associated with any alternative. 

No substantial difference 

between action alternatives 

1 – Human Health 

and Worker Safety 

1c – Worker Safety Adherence to OSHA guidelines. No substantial difference 

between action alternatives; 

not tracked further in this 

document. 

2 – Treatment 

Strategy and 

Effectiveness 

2a – Range of 

Treatment Methods 

Approved 

Analysis of differences in treatment 

effectiveness based on restrictions to 

herbicide use. 

· The number of herbicides 

available for use 

· Percent of infested land base 

where herbicide may be used 

2 – Treatment 

Strategy and 

Effectiveness 

2b – Long-term Strategy, 

Reduce Reliance on 

Herbicides Over Time 

 Treatment prescriptions in all alternatives 

include site restoration (passive 

revegetation, mulching, seeding, and 

planting). Manual and mechanical follow 

up treatments would be favored, especially 

when populations are small enough to 

control without herbicides. 

No substantial difference 

between action alternatives. 

Restoration strategy is in 

Appendix F and Chapter 2.5; 

declining reliance on herbicide 

over time is addressed in 

Chapter 3.1. 

2 – Treatment 

Strategy and 

Effectiveness 

2c – Treatment Priority Invasive plant treatment areas are 

prioritized. 

No substantial difference 

between action alternatives; 

see Chapter 2.5 for how 

priorities were set. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

24

Issue Group Issue Component How Issue is Addressed Factors for Alternative 

Comparison 

2 – Treatment 

Strategy and 

Effectiveness 

2d – Adaptive 

Management/Early 

Detection-Rapid 

Response 

An adaptive management plan and early 

detection-rapid response strategy is part of 

all action alternatives. 

No substantial difference 

between action alternatives, 

see discussions in Chapter 

2.5. 

Issue Group 3 – 

Social and Economic 

3a – Treatment Costs 

and Financial Efficiency 

Analysis of the total and annual estimated 

costs of treatment and financial efficiency. 

·Total estimated project cost 

over a 5-year period. 

·Annual estimated project cost 

over a 5-year period 

·Average cost of a treatment 

acre over a 5-year period 

Issue Group 3 – 

Social and Economic 

3b – More Jobs 

Associated with Manual 

Treatments 

Analysis of the estimated number of worker 

days needed for the project. 

· The estimated number of 

jobs provided by the most 

ambitious treatment scenario 

Issue Group 3 – 

Social and Economic 

3c – Scenic, Recreation, 

and Wilderness Values 

This issue is addressed in all alternatives 

through the Project Design Features 

described in Chapter 2, including 

coordination and notification requirements. 

No substantial difference 

between action alternatives, 

see Project Design Features in 

Chapter 2.5. 

Issue Group 3 – 

Social and Economic 

3d– Effects on Special 

Forest Products 

 This issue is addressed in all alternatives 

through public education, notification and 

outreach to special forest product 

gatherers. Project Design Features 

described in Chapter 2 include coordination 

and notification requirements. 

No substantial difference 

between action alternatives; 

no exposure scenarios are 

associated with people 

harvesting or eating special 

forest products near sprayed 

areas. 

Issue Group 3 – 

Social and Economic 

3e – Effects on 

American Indian Tribes 

and Treaty Rights, Civil 

Rights and 

Environmental Justice 

This issue is addressed through 

consultation with tribes, outreach to 

subsistence gatherers, and extensive 

public notification. 

No substantial difference 

between action alternatives, 

no disproportionate effects on 

any minority group; see 

Chapter 3.6. 

Issue Group 4 –NonTarget Plants And 

Wildlife 

4a – Adverse Effects of 

Herbicide Treatment on 

Botanical Species Of 

Local Interest 

This issue is addressed through 

development of Project Design Features 

intended to avoid potential adverse effects 

to non-target plants. 

·Acres of Broadcast Allowed 

·Number of Plant Species of 

Local Interest Potentially 

Affected by Broadcast 

Herbicide Application Methods

Issue Group 4 – NonTarget Plants And 

Wildlife 

4b – Potential Adverse 

Effects Of Invasive Plant 

Treatment On Terrestrial 

Wildlife, Species Of 

Local Interest 

This issue is addressed through 

development of Project Design Features 

intended to minimize potential adverse 

effects to terrestrial wildlife, including 

salamanders and mollusks. 

No substantial difference 

between action alternatives; 

none of the alternatives are 

likely to adversely affect or 

impact any wildlife species of 

local interest. 

Issue Group 5 – 

Effects on Soils, 

Water and Aquatic 

Organisms 

5a – Potential Adverse 

Effects of Invasive Plant 

Treatment on Soils 

This issue is addressed through Project 

Design Features intended to avoid 

potential harm to soils. 

No substantial difference 

between action alternatives; 

none of the alternatives would 

harm soil productivity. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

25

Issue Group Issue Component How Issue is Addressed Factors for Alternative 

Comparison 

Issue Group 5 – 

Effects on Soils, 

Water and Aquatic 

Organisms 

5b – Potential for 

Herbicide Delivery to 

Streams, Lakes, Rivers, 

Floodplains and 

Wetlands 

This issue is addressed through Project 

Design Features intended to minimize 

herbicide delivery to water. 

· Character of herbicide use 

within Aquatic Influence Zones

·Estimated acres of herbicide 

use within Aquatic Influence 

Zones 

· Estimated acreage where 

herbicide treatment may occur 

on roadside treatment areas 

with high potential to deliver 

herbicides 

· Estimated proportion of 

project where broadcast of 

herbicide may occur on 

roadside treatment areas with 

high potential to deliver 

herbicides 

Issue Group 5 – 

Effects on Soils, 

Water and Aquatic 

Organisms 

5c – Potential for 

Adverse Effects on 

Aquatic Organisms from 

Herbicide 

This issue is addressed through Project 

Design Features intended to avoid 

herbicide delivery to water and minimize or 

eliminate risk of concentrations above a 

threshold of concern to fish and aquatic 

ecosystems. Treatment situations likely to 

result in herbicide concentrations of 

concern to fish are avoided in all 

alternatives except D: analysis for 

Alternative D indicates that herbicide 

concentrations of concern to aquatic 

organisms are possible under worst-case 

conditions. 

• Potential for aquatic 

organisms to be exposed to 

harmful concentrations of 

herbicide 

1.6.7 Comments to the DEIS 

The public was invited to comment on the Draft Environmental Impact Statement between June 16 and July 

31, 2006. Appendix H displays the content of the public and agency comments and specific Forest Service 

responses, along with copies of all letters received from government agencies. 

Nearly all of the comments focused on effects to water quality and fish from the use of herbicides within 

riparian reserves and near fish habitat. Two of the commenters asserted a preference for Alternative C, which 

does not allow herbicide use in riparian reserves or along roads with high potential to deliver herbicides to 

water bodies. 

The Proposed Action was modified (see Chapter 2.5), and additional information has been provided 

throughout the EIS in response to these comments. The FS has worked closely with NMFS to address their 

comments through the Endangered Species Act Consultation process. 

1.7 Non-Significant Issues 

The Council of Environmental Quality requires the USDA Forest Service to identify and eliminate from 

detailed study the issues that are not significant (40 CFR 1501.7). Issues are eliminated from further analysis 

when the issue is outside the scope of the EIS; is already decided by law, regulation, Forest Plan, or other 

higher level decision; is not clearly relevant to the decision to be made; or is conjectural and not supported by 

credible scientific or factual evidence. 

The Forest Supervisor for the Olympic National Forest determined that the following public issues would be 

eliminated from further analysis: 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

26

1.7.1 Funding and Partnerships for Managing Invasive Plants on Private Land 

Some people expressed that invasive plant treatments on private lands should be funded or technical 

assistance provided for private landowners, and that management of noxious weeds can also be improved on 

both public and private lands by the formation and participation in weed management areas. This issue is 

outside the scope of this analysis and is therefore not significant to the project analysis. 

The Forest Service supports establishing weed management areas in partnership with others. All alternatives 

would be consistent with such partnerships and the likelihood of success would certainly be increased. 

However, establishment of weed management areas may be accomplished without consideration in an EIS. 

Technical assistance for projects off National Forest is available and is not subject to consideration in an EIS. 

National Environmental Policy Act (NEPA) documentation may be required when federal funding is used for 

work on other ownerships. No specific proposals for work off-National Forest System lands were brought 

forward during initial project development and scoping, thus, none could be evaluated as a connected action. 

However, similar work on adjacent lands has occurred in the past and will likely continue to occur. 

1.7.2 Funding Sources and Commitments 

Several commenters mentioned that project effectiveness is directly related to funding. Funding secured for 

the past several years is not adequate to fully implement any action alternative. While this is an important 

issue relevant to the ability of the Forest Service to meet the purpose and need, it is outside the scope of this 

EIS because it cannot be resolved through the NEPA process. 

Funding is dependent on many unpredictable factors and some sources may become available once a NEPA 

decision has been made. Financial efficiency analysis displays estimated costs of treating all known 

infestations over a five-year period. The average cost of a treatment acre is also disclosed. This information 

can be used to demonstrate funding that would be needed over time to complete the project, however this 

NEPA document cannot guarantee that all planned work would be funded. 

1.7.3 Linking the Project to Other Initiatives 

Some comments suggested linking this invasive plant project EIS to the Fuels Reduction and Healthy Forest 

Initiatives or other initiatives to provide a more strategic approach to controlling invasive plants rather than a 

stand alone document. 

One role of the Olympic National Forest Supervisor is to consider the scope of Proposed Actions in the 

context of other actions that may be connected. In the case of invasive plant management, several 

approaches may be valid; for instance, invasive plant treatments could be addressed through project planning 

at a watershed scale that integrates invasive plant treatments with other vegetation management proposals. 

In the past, invasive plant treatments have been connected with projects intended to improve forest health or 

reduce fuels. 

In this case, the Forest Supervisor decided to consider invasive plant management Forest-wide to allow for 

timely treatment wherever the need arises, and however funding may be secured. In some cases, treatments 

may be linked with other projects, and future NEPA documents will likely tier to analysis herein so that 

integrated resource management can be achieved in the best way possible. However, no matter what other 

actions occur in the project area, the current invasive plant inventory demonstrates the ongoing need for 

treatment. 

Thus, actions other than invasive plant management are not connected to this proposal, so linking this EIS to 

forest health or fuels reduction projects is outside the scope of this EIS and not a significant issue for the 

analysis. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

27

Chapter 2. Alternatives, Including the Proposed Action 

2.1 Introduction 

Chapter 2 describes and compares alternatives considered for invasive plant treatment on the Olympic 

National Forest in the state of Washington. Chapter 2 focuses on the resource trade-offs associated with 

differences between the alternatives. 

The descriptions of the alternatives in Chapter 2 are derived from a detailed project database founded on 

invasive plant inventories and refined using anecdotal information. The project area was divided into 

treatment areas that were classified by the type of site (e.g., roads, administrative sites, meadows) and 

prioritized considering the threat posed by existing invasive species and the potential for effective treatment. 

Treatment methods (herbicide and non-herbicide) and strategies were identified based on the location, extent 

and biology of the existing invasive plant species. Treatment priorities, methods and strategies are tiered to 

the R6 2005 FEIS. A primary focus of the site-specific analysis is development of Project Design Features so 

that invasive plant treatments comply with the recently adopted treatment and restoration standards. 

2.2 Alternative Development Process 

In 2004, all known invasive plant sites (field surveys were completed on main vectors) were mapped and 

entered into an inventory data base. Infested sites were aggregated into treatment areas, and control 

measures, strategies, objectives and priorities were determined. The treatment areas were then classified by 

the type of site (e.g., roads, administrative sites, meadows) and prioritized considering the threat posed by 

existing invasive species and the potential for effective treatment. Treatment methods (herbicide and nonherbicide) and strategies were identified based on the location, extent and biology of the existing invasive 

plant species. The treatment priorities, methods and strategies in the Proposed Action were developed based 

on the R6 2005 FEIS. In 2004 and 2005, the public was asked to provide scoping input on the Proposed 

Action. Public issues were identified (see Chapter 1), and Project Design Features (see Chapter 2.5) were 

developed so that invasive plant treatments using herbicide would comply with the recently adopted 

treatment and restoration standards and resolve public issues to the extent possible. 

Alternative C was developed to further resolve public concerns about herbicide use. Alternative C would 

eliminate most adverse effects from herbicide by 1) eliminating broadcast applications, which account for 

most of the concern/uncertainty related to herbicide use and 2) eliminating use of herbicide within Riparian 

Reserves and along roadsides that cross or follow streams. Eliminating such herbicide use resolves nearly all 

public issues related to adverse effects of herbicide. 

Alternative D was developed to allow more flexibility in broadcasting herbicide on certain road systems. 

This alternative highlights trade offs between economic effectiveness and risk to water quality and aquatic 

organisms. 

Other alternatives were considered but were eliminated from detailed study. These are discussed in Chapter 

2.8. 

The DEIS was circulated for public comment May 2006. Throughout the next year and a half, the Forest 

Service worked with NMFS and FWS to respond to concerns about herbicide use and its effects on fish and 

fish habitat. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

28

2.3 Invasive Plant Treatment Methods 

All of the alternatives (including No Action) employ a variety of invasive plant treatment methods.7 This 

section offers a brief description of the different methods proposed for manual/mechanical and herbicide 

treatments in all alternatives, including No Action. These descriptions are based on Tu, et. al. 2001, edited 

for local conditions and knowledge. 

Manual and Mechanical Methods for Treatment and Restoration 

Manual techniques include hand pulling, clipping, or digging out invasive plants with non-motorized hand 

tools. Mechanical methods involve chain saws, mowers, or other mechanized equipment. These techniques 

tend to minimize damage to desirable plants and animals, but they are generally labor and time intensive. 

Treatments must typically be administered several times a year over several years to prevent the weed from 

re-establishing. Manual and mechanical techniques are generally favored to treat small infestations and/or in 

situations where a large pool of volunteer labor is available. They are often used in combination with other 

techniques. 

Weed Pulling - Pulling or uprooting plants can be effective against some shrubs, tree saplings, and 

herbaceous weeds. Annuals and tap-rooted plants are particularly susceptible to control by hand-pulling. 

Weed wrenches and other tools are surprisingly powerful and can enable a person to control large 

saplings and shrubs that are too big to be pulled by hand. 

Weed pulling is not as effective against many perennial weeds with deep underground stems and roots 

that are often left behind to re-sprout. 

The advantages of pulling include its small ecological impact, minimal damage to neighboring plants, 

and low (or no) cost for equipment or supplies. Pulling is extremely labor intensive, however, and is 

effective only for relatively small areas, even when abundant volunteer labor is available. Hand pulling 

is easy to plan and implement, and is often the best way to control small infestations, such as when a 

weed is first detected in an area. Hand pulling may be a good alternative in sites where herbicides or 

other methods cannot be used. 

The key to effective hand pulling is to remove as much of the root as possible while minimizing soil 

disturbance. For many species, any root fragments left behind have the potential to re-sprout, and 

pulling is not effective on plants with deep and/or easily broken roots. 

Most weed-pulling tools are designed to grip the weed stem and provide the leverage necessary to pull its 

roots out. Tools vary in their size, weight, and the size of the weed they can extract. The Root Talon is 

inexpensive and lightweight, but may not be as durable or effective as the all-steel Weed Wrench, which 

is available in a variety of sizes. Both tools can be cumbersome and difficult to carry to remote sites. 

Both work best on firm ground as opposed to soft, sandy, or muddy substrates. 

Clip – “Clip” means to cut or remove seed heads and/or fruiting bodies to prevent germination. This 

method is labor intensive but effective for small and spotty infestations. 

Clip and Pull – “Clip and pull” means cutting a portion of the invasive plant stem and pulling it from its 

substrate, generally the bole of a tree. This method is labor intensive, but can be effective for larger 

infestations. 

 

7

 The alternatives vary as to the total and relative amount of treatment approved and some alternatives do not approve 

some treatment options listed. Appendix A displays proposed treatment methods based on the current inventory. These 

are subject to change given local conditions at the time of implementation. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

29

Mowing, Cutting, Brush Hog, Raking, Trimming, Weed-eating - Mowing and cutting can reduce seed 

production and restrict weed growth, especially in annuals cut before they flower and set seed. Some 

species however, re-sprout vigorously when cut, replacing one or a few stems with many that can quickly 

flower and set seed. These treatments are used as primary treatments to remove aboveground biomass in 

combination with herbicide treatments to prevent resprouting, or as follow up treatments to treat target 

plants missed by initial herbicide use. 

Stabbing - Some plants can be killed by severing or injuring (stabbing) the carbohydrate storage 

structure at the base of the plant. Depending on the species, this structure may be a root corm, storage 

rhizome (tuber), or taproot. These organs are generally located at the base of the stem and under the soil. 

Cutting off access to these storage structures can help “starve” or greatly weaken some species. 

Girdling - Girdling is often used to control trees or shrubs that have a single trunk. It involves cutting 

away a strip of bark several centimeters wide all the way around the trunk. The removed strip must be 

cut deep enough into the trunk to remove the vascular cambium, or inner bark, the thin layer of living 

tissue that moves sugars and other carbohydrates between areas of production (leaves), storage (roots), 

and growing points. This inner cambium layer also produces all new wood and bark. 

Active Restoration - Active post-treatment site restoration includes hand or machine mulching 

(machines limited to areas that are on roads), along with competitive seeding, and/or planting with hand 

tools. 

Steaming or Foaming - Pouring boiling hot water onto weeds, or subjecting weeds to hot steam, is a 

method of weed control that has been practiced for some time. A hot foam system for steam-killing 

vegetation is also available. Hot foam may be an effective treatment for annuals, and with repeated 

treatments, may be effective for some perennials. No steaming or foaming sites are currently prescribed 

in any treatment area. Effects are not likely to be substantially different than those disclosed for other 

treatment methods; however site-specific analysis would be conducted if this equipment is later 

prescribed. 

Herbicide Application Methods 

The environmental impacts of three types of herbicide application methods are evaluated in this EIS: 

Broadcast (includes but not limited to boom spray) – Broadcast treatments would be used to treat 

denser (approximately 70 percent or greater) patches of target vegetation. A boom, a long horizontal 

tube with multiple spray heads, may be mounted or attached to a tractor, all terrain vehicle (ATV) or 

other vehicle. The boom is then carried above the weeds while spraying herbicide, allowing large areas 

to be treated rapidly with each sweep of the boom. 

Offsite movement due to vaporization or drift and possible treatment of non-target plants can be of 

concern when using this method. Two alternatives (No Action and Alternative C) do not approve any 

broadcast treatment. 

Not all broadcast methods include a boom; boom-less nozzles are currently in use that can reduce the 

risk of non-target effects. Backpack pumps and sprayers may also be used as a broadcast tool if directed 

at a broad area rather than individual plants. 

Spot spray - Herbicide is sprayed directly onto small patches or individual target plants; non-target 

plants are avoided. These applicators range from motorized rigs with spray hoses to backpack sprayers, 

to hand-pumped spray or squirt bottles, all of which can target very small plants or parts of plants. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

30

Drift is far less of a concern because the applicator ensures that spray is directed immediately toward the 

target plant. 

Hand/Selective – Hand/selective methods treat individual target plants, reducing the potential for 

herbicide to impact soil or non-target organisms. Hand/selective methods include wicking and wiping; 

foliar application; basal bark treatment; frill, hack, and squirt, stem injection, and/or cut-stump methods. 

Wicking, Wiping, and other stem and leaf application - Involves using a sponge, spray bottle, paint 

brush, cloth and/or a wick on a long handle to wipe herbicide onto foliage and stems. Use of a wick 

eliminates the possibility of spray drift.

Basal Bark - This method applies a 6 to 12 inch band of herbicide around the circumference of the 

trunk of the target plant, approximately one foot above ground. The width of the sprayed band 

depends on the size of the plant and the species’ susceptibility to the herbicide. The herbicide can be 

applied with a backpack sprayer, hand-held bottle, or a wick. 

Frill, Hack and Squirt - The frill method, also called the “hack and squirt” treatment, is often used 

to treat woody species with large, thick trunks. The tree is cut using a sharp knife, saw, or ax, or 

drilled with a power drill or other device. Herbicide is then immediately applied to the cut with a 

backpack sprayer, squirt bottle, syringe, or similar equipment. Because the herbicide is placed 

directly onto the thin layer of growing tissue in the trunk (the cambium), an ester formulation is not 

required. 

Stem Injection - Herbicides can be injected into herbaceous stems using a hand held injection system 

with an attached needle. Herbicide pellets can also be injected into the trunk of a tree using a 

specialized tool. Higher concentrations of active ingredients are often needed for effective stem 

injection, for instance, the maximum label rate of aquatic labeled glyphosate was used to effectively 

kill knotweed by stem injection (Lucero presentation, May 2005). 

Cut-stump - This method is often used on woody species that normally re-sprout after being cut. Cut 

down the tree or shrub, and immediately spray or squirt herbicide on the exposed cambium (living 

inner bark) of the stump. The herbicide must be applied to the entire inner bark (cambium) within 

minutes after the trunk is cut. The outer bark and heartwood do not need to be treated since these 

tissues are not alive, although they support and protect the tree’s living tissues. The cut stump 

treatment allows for a great deal of control over the site of herbicide application, and therefore, has a 

low probability of affecting non-target species or contaminating the environment. It also requires 

only a small amount of herbicide to be effective. 

The following methods are not included in the Proposed Action: 

• Aerial Herbicide Application 

• Herbicides other than the ten analyzed in this document 

• Prescribed Burning 

• Plowing/Tilling/Disking/Digging With Heavy Equipment 

• Grazing 

• Flooding/Drowning 

• Steaming and Foaming (see above) 

Biological Controls 

Table 5 displays the biological control (biocontrol) agents currently released by Clallam, Grays Harbor, 

Jefferson, and Mason counties on the Olympic Peninsula to treat invasive plants. Releases and redistribution 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

31

of these biological agents would be expected to occur regardless of alternative selected for this project, 

including No Action (Alternative A). Canadian Thistle Defoliating Beetle (Cassida rubiginosa) has been 

reported as distributed within adjacent counties. This biocontrol species has not been approved by the Animal 

and Plant Health Inspection Service (APHIS) and therefore may not be redistributed on the National Forest 

as per Standard 14. 

Table 5-Biological Controls Currently Distributed on the Olympic Peninsula that Comply with 

Standard 14 

Target Species Biocontrol Agents 

Purple Loosestrife Purple Loosestrife Beetle (Galerucella calmariensis), Golden Loosestrife Beetle 

(Galerucella pusilla), Big Purple Loosestrife Weevil (Hylobius transversovittatus) and 

Little Purple Loosestrife Weevil (Nanophyes marmoratus) 

Tansy Ragwort Ragwort Flea Beetle (Longitarsus jacobaea) 

Scotch Broom Scotch Broom Seed Beetle (Bruchidius villosus), Scotch Broom Seed Weevil (Apion 

fuscirostre), or Scotch Broom Twig Miner (Leucoptera spartifoliella) 

Knapweed Seed Head Beetle (Larinus obtusus) 

Canadian Thistle Canadian Thistle Gall Fly (Urophora cardui) 

St. John’s Wort Klamath Weed Beetle (Chrysolina quadrigemina) 

Meadow Knapweed, 

Spotted Knapweed 

Seed Head Gall Fly (Urophora quadrifasciata), Banded Gall Fly (Urophora affinis), 

Knapweed Root Moth (Agapeta zoegana) and Knapweed Root Weevil (Cyphocleonus 

achates) 

Biological control agents undergo a rigorous testing procedure prior to initial release. Agents are tested for 

their effectiveness in controlling the target organism and for their host specificity. Testing includes potential 

effects on economic crops, rare plants, and similar species found in North America. An agent can be released 

only after it has been determined that it is unlikely that the agent will feed or cause injury to any native or 

agronomic species. It generally takes between ten and fifteen years for an agent to be cleared for release. 

The analyses for effects of such tools have already been completed under documents (including NEPA 

decisions) developed by APHIS for approval of entry of such organisms. 

The APHIS analysis assumed that biological agents would spread throughout North America, to wherever the 

target species exists. Like the invasive plants that are targeted, biological agents do not recognize property 

boundaries. Biological agents are expected to spread onto National Forest System lands regardless of any 

action the Forest Service may take, including redistribution (agents moved from one location to another). 

Similar to prevention, biological agents alone do not eradicate, control or contain invasive plants. However, 

both prevention and use of biological agents are part of the integrated management program and contribute to 

the goal of slowing the spread of invasive plants. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

32

2.4 No Action 

The No Action Alternative is also known as Alternative A 

Alternative A Description

Total Acres to Be Treated: 672 

Total Acres Estimated Herbicide Treatment: 86 

Estimated Proportion of Herbicide Treatment Acres - Broadcast: 0% 

Estimated Proportion of Herbicide Treatment Acres - Spot/Hand: 100% 

Under Alternative A, the No Action alternative, invasive plant treatments would be implemented according to 

existing NEPA decisions, including the Integrated Weed Management Program Environmental Assessment

(EA - 1998)/Decision Notice (DN - 1999) and APHIS approved biological controls released on the Olympic 

Peninsula. In addition, prevention practices would be integrated into all future projects to slow the spread of 

invasive plants throughout the National Forest. 

The existing NEPA decisions allow for an integrated weed management strategy emphasizing prevention and 

control of invasive plants scattered across the Forest. The 1998 EA/1999Decision Notice approved manual, 

mechanical and herbicide treatments on 75 sites totaling approximately 672 acres. 

Spot or hand herbicide treatments were prescribed on 86 acres, singly or in combination with manual or 

mechanical treatments. No broadcast treatments were approved. Available herbicides included glyphosate, 

dicamba and picloram, with aquatic glyphosate to be used in the vicinity of surface water. 

The remaining 586 acres were proposed for manual and mechanical treatment. The 1999 EA included all 

inventoried invasive plant sites at that time. 

No early detection/rapid response mechanism for new sites or adaptive management approaches for new 

methods were considered in the EA. 

The No Action alternative would leave more than 80 percent of the currently infested acreage untreated. 

Table 6-Alternative A - Acres by Treatment Combination 

Total Acres Herbicide Only Herbicide combined with Manual 

and/or Mechanical Treatment 

Manual and 

Mechanical Only

Acres by treatment 

combination 

672 0 86 586 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

33

2.5 The Proposed Action 

2.5.1 Changes to the Proposed Action between Draft and Final 

In response to public and interagency comments, PDFs and buffers have been adjusted in the Proposed 

Action. 

The Proposed Action is also known as Alternative B. 

Alternative B Description

Estimated Acres to Be Treated: 3,830 

Total Acres Estimated Herbicide Treatment: 3,687 

Estimated Proportion of Herbicide Treatment Acres - Broadcast: 34% 

Estimated Proportion of Herbicide Treatment Acres - Spot/Hand: 66% 

The Proposed Action (Alternative B) was developed to respond to the need for action by approving a range 

of treatment options to eradicate, contain, control and/or suppress the spread of invasive plants. The 

Proposed Action would allow treatment of the 672 acres included under No Action using new tools and 

approaches. It would also approve treatment on approximately 3,200 additional infested acres detected in the 

November 2004 inventory. 

The Proposed Action would approve treatments based on common control measures (see table 10). Any of 

ten herbicides would be used according to Project Design Features and buffers listed in section 2.5.8. 

About 85 percent of the infested acres are in roadside treatment areas. Broadcast application would be the 

most cost-effective method where the target plant density exceeds 70 percent cover, or where the distribution 

of target plants is continuous along the road. Project Design Features would eliminate the option of 

broadcasting on about 60 percent of the roadside treatment acreage. 

2.5.1 Treatment Areas 

Treatment areas are geographic assemblages of inventoried and anecdotal invasive plant sites that have been 

prioritized and prescribed for treatment. There are 99 treatment areas mapped; the majority of the 

infestations are along roadsides and other disturbed areas. Appendix A provides data tables corresponding to 

maps depicting the treatment areas. 

Table 7-Infested Acres by Treatment Area Description 

Treatment Area 

Description 

Estimated 

Infested Acres 

Roadside 3,270

Administrative Sites, Campgrounds, Summer Homes 130

Meadows, Wetlands and Floodplains 80

Trails 135

Forest 215

Total 3,830
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

34

2.5.2 Treatment Priority and Strategy 

Each treatment area was also assigned an overall priority. The urgency, necessity, and intensity of treatment 

vary depending on priority, as shown in table 8. In general, higher priority treatments would be favored, and 

are most likely to be accomplished. Given current funding levels, lower priority treatments may not be 

accomplished, or may only be accomplished in connection with higher priority areas. Priorities on the 

Olympic National Forest are partially driven by the unique conditions here. Some invasive species that may 

be tolerated elsewhere may be targeted here, given the high value placed on natural habitats in wilderness 

areas, Research Natural Areas, Botanical Areas, tribal lands and the National Park. 

Table 8-Treatment Priority and Strategy 

Priority Associated Treatment Strategy Local Situations Acres 

Highest All treatments in areas with potential for 

significant ecological impact 

New infestations of aggressive species 

when small 

Botanical areas, Research Natural 

Areas, infestations in riparian areas and 

under a forest canopy. 

620 

Second Eradication of aggressive species 

Treatment in areas of high public use 

and infestation potential (e.g. parking 

lots, campgrounds, trailheads, horse 

camps, gravel pits) 

Roadside treatment areas with access 

to Olympic National Park. 

Treatment of Herb Robert, knotweeds, 

knapweeds, hawkweeds, butter and 

eggs, purple loosestrife. 

Meadows and administrative sites. 

620 

Third Containment/control of existing large 

infestations of aggressive species with 

focus on boundaries of infestation. 

Roadsides with access to areas of 

concern, 

1,290 

Fourth Containment/control of remaining 

infestations. 

Other roadsides. 1,300 

Target species within each treatment area were assigned a treatment strategy. These strategies vary 

depending on the potential negative impacts of a given invasive species and the value or sensitivity of the 

treatment site (or adjacent lands) and are related to priority shown above. Treatment strategies considered for 

the Proposed Action include:8

• Eradicate: Totally eliminate an invasive plant species from a site. This objective generally applies 

to the hardest to control invasive species (Canada thistle, bull thistle, knapweed and knotweed) and 

highest-valued sites (e.g. wilderness and botanical areas). 

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

This objective applies to target species such as Scotch broom, English ivy and tansy. 

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

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

St. John’s wort. 

 

8

 Two other possible strategies exist: suppress and tolerate. Actions needed to meet these strategies are not the focus of 

this EIS. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

35

Table 9 displays the number of acres proposed for each treatment strategy. Half of the proposed treatment 

acreage has a strategy of contain, which means that the outer perimeter of the treatment sites are likely to be 

treated, rather than the whole area.9

 Treatment cost estimates and assumptions vary by strategy (more 

information in Chapter 3.7). 

 Table 9-Acres by Treatment Strategy10

Total Eradicate Control Contain 

Acres 3,830 420 1,475 1,930 

Percent of Total 100% 11% 39% 50% 

2.5.3 Common Control Measures 

Table 10 summarizes the common control measures, including for herbicides, used to treat target invasive 

species known on the Olympic National Forest. Site-specific prescriptions would be refined for specific 

sites. Control measures may be updated through the life of the project as integrated control methods are 

refined and made more effective. Site-specific prescriptions would follow the Implementation Planning 

Process (2.5.7) and comply with Project Design Features and buffers (2.5.7). 

New invasive plant sites (including new target species that do not appear in Table 10) found during the life of 

the project would be treated with similar control measures. Acreage is shown for target species where 

inventories indicate more than one acre of coverage. Some of the target species listed were not detected in 

the current inventory, but have the potential to be found on the Olympic National Forest. 

Appendix B provides additional information about the control measures, including restoration emphasis 

items and manual disposal considerations. The full text of Appendix B is incorporated into the Proposed 

Action, however some control measures listed in table 10 or Appendix B may not be available in some 

locations due to the PDFs or because they are outside the scope of those analyzed in this EIS. 

Implementation of the Common Control Measures would not “focus on the eradication of an invader but 

instead attempts to understand what makes it spread and focuses on reducing that spread through a 

combination of prevention, early detection/rapid response, treatment and restoration options. The main goal 

is to find the most effective methods with the least risk” (Appendix B-3). 

 

9

 Acreage estimates include the entire infested area, and therefore overestimate the acreage that would actually be 

treated. 

10 The reason these acreages do not add up to the proportions shown above is that the treatment strategy is identified for 

each individual infestation, while priority is associated with the entire treatment area. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

36

Table 10-Common Control Measures by Target Species 

Target Species – 

Common Names, 

Scientific Names 

and Growth Habit

Acres from 

current 

inventory 

Common Control Measures Documented 

Effective 

Herbicides 

Spotted knapweed (CEBI) 

Centaurea biebersteinii 

Diffuse knapweed (CEDI) 

Centaurea diffusa 

Meadow knapweed 

(CEDE) 

Centaurea debeauxii

Brownray knapweed 

(CEJA) 

Centaurea jacea 

Biennial or Perennial 

7 Manual treatments could be used for follow- up to herbicide. 

Hand pull or dig small populations or when regular volunteers 

are available. Multiple entries per year are required. 

Mowing is possible, but timing is critical. 

These treatments may take up to ten years due to long term 

seed viability. 

Clopyralid 

Picloram 

Glyphosate 

Japanese knotweed 

(POCU) 

Polygonum cuspidatum 

Giant knotweed (POSA) 

Polygonum sachalinense

Perennial 

11 Herbicide treatment most effective. Use stem injection or 

foliar spray. If chemicals are used, manual treatments could 

be used for follow- up. Revegetate with desirable species if 

surrounding cover is primarily non-native. 

Glyphosate, 

Triclopyr 

Imazapyr 

 

Hawkweeds (HIPR, HIAU, 

HIVU) 

Hieracium pratense, 

Hieracium aurantiacum, 

Hieracium vulgatum 

Perennial

<1 Herbicide treatment is most effective. Some manual removal 

or covering with a plastic tarp possible for small infestations. 

If chemicals are used, manual treatments could be used for 

follow- up. 

Clopyralid 

Picloram 

Glyphosate 

Butter 'n' eggs (LIVU2) 

Linaria vulgaris

Perennial 

<1 Hand pull or dig small populations or when regular volunteers 

are available. Cutting stems in spring or early summer will 

eliminate plant reproduction, but not the infestation. These 

treatments may take up to ten years due to long-term seed 

viability. 

Metsulfuron 

methyl 

Imazapic (in fall 

only) 

Glyphosate 

Tansy ragwort (SEJA) 

Senecio jacobaea

Common tansy (TAVU) 

Tanacetum vulgare 

Biennial or perennial 

536 Hand-pulling is effective if done in moist soils, as a follow up 

to herbicide treatments are used to achieve initial control 

objectives. 

Metsulfuron 

methyl 

Picloram 

Clopyralid 

Glyphosate 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

37

Target Species – 

Common Names, 

Scientific Names 

and Growth Habit

Acres from 

current 

inventory 

Common Control Measures Documented 

Effective 

Herbicides 

Scotch broom (CYSC4) 

Cytisus scoparius 

Perennial 

203 Hand pulling, cutting, weed wrenching or digging up of small 

populations or when regular volunteers are available or as a 

follow up to chemical use. Hand-pulling or weed wrenching is 

most effective in moist soils. Cutting will require multiple visits 

in one year. These treatments may take up to ten years due to 

long-term seed viability. 

Triclopyr 

Clopyralid 

Picloram 

Glyphosate 

English ivy (HEHE) 

Hedera helix 

Perennial 

93 Manually remove infestations by removing vines first, than 

digging root mats from the soil. Vines must be cut at both the 

shoulder and ankle height, then stripped away from the tree. 

Work away from the tree pulling out the entire root mat for at 

least six feet. Apply herbicide in combination with string 

trimming. 

Triclopyr 

Glyphosate 

Reed canarygrass 

(PHAR3) 

Phalaris arundinaceae

Perennial 

156 Use a combination of herbicides and manual, mechanical, or 

cultural treatments. Manual treatments or mowing are only 

practical for small stands when multiple entries per year can 

be made. The entire population must be removed 2 to 3 times 

per year for at least five years. Covering populations with 

black plastic may be effective if shoots are not allowed to grow 

beyond tarps. This technique could take over two years to be 

effective. 

Sulfometuron 

methyl 

Glyphosate 

Cheatgrass (BRTE) 

Bromus tectorum 

Annual

3 Hand-pulling is minimally effective and may take up to five 

years due to long-term seed viability. Repeated mowing 

(every three weeks) may help contain this species, especially 

as a follow up to herbicide use. 

Imazapic 

Sethoxydim 

Sulfometuron 

methyl/ 

imazapyr (in fall 

only) 

Glyphosate 

Canada thistle (CIAR4) 

Cirsium arvense 

 

Perennial 

308 Herbicide treatment is most effective. The only manual 

technique would be hand cutting of flower heads, which 

suppresses seed production. Mowing may be effective in rare 

cases if done monthly (this intensity would damage native 

species). Covering with a plastic tarp may also work for small 

infestations. 

Clopyralid 

Picloram 

Chlorsulfuron 

Glyphosate (best 

in fall) 

Herb Robert (GERO) 

Geranium robertianum

Annual, Biennial or 

Perennial 

10 Hand-pulling is most effective if the entire plant is pulled. 

Herbicides may also be used on larger infestations. 

Steaming/foaming may be an effective treatment. 

Glyphosate 

English holly (ILAQ80) 

Ilex aquifolium

Perennial 

<1 Use herbicides in combination with manual and mechanical 

techniques that remove lower and rooted branches. 

Glyphosate 

Purple loosestrife 

(LYSA2) 

Lythrum salicaria 

Perennial 

<1 Herbicide treatment is most effective Hand removal of small 

populations or isolated stems is possible, but only if entire 

rootstock is removed. Hand cut flower heads to suppress 

seed production. 

Glyphosate 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

38

Target Species – 

Common Names, 

Scientific Names 

and Growth Habit

Acres from 

current 

inventory 

Common Control Measures Documented 

Effective 

Herbicides 

Himalayan blackberry 

(RUDI2) 

Rubus discolor 

Cutleaf blackberry 

(RULA) 

Rubus laciniatus 

Perennial (canes die off 

annually) 

86 Use a combination of herbicides and manual and/or 

mechanical treatments. Usually mechanical removal of large 

biomass in the summer (using a mower, or brush hog), 

followed by manual removal of re-sprouting canes and roots, 

then herbicide treatment of new growth in the fall/winter is 

most effective. The massive root crown must be fully dug out 

at some point if using only manual/mechanical techniques. 

Triclopyr 

Glyphosate 

Bull thistle (CIVU) 

Cirsium vulgare 

 

Biennial 

600 Use manual, mechanical or chemical control or a combination. 

Any manual method that severs the root below the soil surface 

will kill these plants. Effective control requires cutting at the 

onset of blooming. Treatment before plants are fully bolted 

results in re-growth. Repeated visits at weekly intervals over 

the 4 to 7 week blooming period provide most effective 

control. 

Clopyralid 

Picloram 

Glyphosate 

St. John’s wort (HYPE) 

Hypericum perforatum 

 

Perennial 

341 Hand removal of small populations or isolated stems is 

possible, but repeated treatments will be necessary as lateral 

roots give rise to new plants. These treatments may take up 

to ten years due to long-term seed viability. 

Metsulfuron 

methyl 

Picloram 

Glyphosate (not 

found as 

effective in the 

literature) 

Oxeye Daisy (LEVU) 

Leucanthemum vulgare

Perennial 

505 Hand removal is possible, but only if entire rootstock is 

removed. Hand removal must be repeated for several years. 

Mowing is effective if repeated throughout the long growing 

season. 

Clopyralid 

Picloram 

Glyphosate (not 

found as 

effective in the 

literature) 

Queen Anne’s Lace 

(DACA6) 

Daucus carota

Biennial 

2 Small populations could be handpulled, but typically it is 

mowed along roadsides. A combination of mowing, then 

applying herbicide in late fall has been effective. 

Metsulfuron 

methyl 

Chlorsulfuron 

Glyphosate (not 

found as 

effective in the 

literature) 

Narrow leaved plantain 

(PLLA) 

Plantago lanceolata 

 

Perennial 

246 Can be handpulled or dug. 

Repeated treatments will be necessary. 

 If chemicals are used, manual treatments could be used for 

follow-up. Out-competing through revegetation is the most 

effective treatment. 

Clopyralid 

Glyphosate 

Creeping buttercup 

(RARE3) 

Ranunculus repens 

Perennial

6 Hand digging is effective. If chemicals are used, manual 

treatments could be used for follow- up. 

Glyphosate 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

39

Target Species – 

Common Names, 

Scientific Names 

and Growth Habit

Acres from 

current 

inventory 

Common Control Measures Documented 

Effective 

Herbicides 

Yellow nutsedge (CYES) 

Cyperus esculentus 

 

Perennial 

15 Hand digging is effective if done before root tubers form. If 

chemicals are used, manual treatments could be used for 

follow-up. Out-competing through revegetation is the most 

effective means. 

Glyphosate 

Everlasting Peavine 

(LALA4) 

Lathyrus latifolius 

Perennial 

<1 Herbicide treatment most effective. Hand control possible with 

repeated effort or combined herbicide/hand treatment. Hand 

removal must be repeated for several years. 

Triclopyr 

Glyphosate 

Clopyralid 

Picloram/imazap

yr (sites without 

grass cover) 

Hairy cat’s ear (HYRA3) 

Hypochaeris radicata 

 

Perennial 

345 Herbicide treatment most effective. Hand removal is possible, 

and must be repeated for several years. If chemicals are 

used, manual treatments could be used for follow-up. 

Clopyralid, 

Picloram 

Glyphosate 

Big trefoil (LOPE80) 

Lotus pedunculatus 

 

Perennial 

263 Herbicide treatment most effective. If chemicals are used, 

manual treatments could be used for follow-up. 

Clopyralid or 

Picloram 

Triclopyr or 

Imazapyr (sites 

without grass 

cover) 

Glyphosate 

English laurel (PRLA5) 

Prunus laurocerasus 

Perennial

<1 Hand pulling, cutting, girdling, weed wrenching or digging up 

of small plants is effective, especially when volunteers are 

available. Hand-pulling or weed wrenching is most effective 

when plants are small in moist soils. Herbicides cut and paint, 

stem injection, spot spray) may be used in combination with 

mechanical cutting or manual girdling. Annual re-treatment 

may be needed for several years to eradicate sprouts. 

Triclopyr 

Glyphosate 

Dandelion (TAOF) 

Taraxacum officinale 

Perennial 

<1 Manual treatment for isolated individuals or small infestations 

using an appropriate digging tool designed to penetrate deep 

into the ground to remove the entire tap root. Do not hand pull 

as root fragments left behind will re-sprout. Covering plants 

with a tarp is an effective control method for seedlings. 

Mechanical treatment by mowing is not recommended as it 

can be beneficial to dandelions by reducing crowding/shading 

from surrounding vegetation. 

Herbicide treatment by spot spraying is effective. 

Glyphosate 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

40

2.5.4 Treatment Site Restoration 

Treatment site restoration is a component common to all action alternatives. Treatment site restoration may 

include mulching, seeding, and/or active revegetation, or may be passive in situations where desirable 

vegetation can naturally replace target invasive species removed. Treatment site restoration is part of the 

prescription developed during implementation planning. Restoration prescriptions would be influenced by 

site-scale conditions and broader land management objectives (for more information on restoration 

prescription process, see Appendix F, Excerpts from the 2003 Draft Guidelines for Revegetation of Invasive 

Weed Sites and Other Disturbed Areas on National Forests and Grasslands in the Pacific Northwest).

The analysis assumption is that passive restoration will be successful on about 35 percent of the treatment 

sites, with 65 percent needing some kind of mulching, seeding, and/or infrequent planting. This proportion is 

based on the range of situations evident surrounding the inventoried invasive plant populations known across 

the Olympic National Forest. For instance, meadows and forested areas are most likely to respond favorably 

to passive restoration, while roadsides and other highly disturbed areas may require mulching and/or 

seeding/planting with desirable vegetation. 

The intent is to re-establish competitive local, native vegetation post-treatment in areas of bare ground. In 

some cases, preferred non-natives may be utilized as temporary ground cover for erosion control and as 

noxious weed competitors, until native species can become established at the site. 

Local native species are always preferred, but use of other desirable species such as non-native species that 

do not persist could be used as an interim step. A combination of native and desirable non-natives could be 

an initial mix for revegetation. A fast growing desirable non-native 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 may 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 would 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. Planting of 

native shrubs may also occur in cases where rapid revegetation is desired; for example, native shrubs may be 

planted adjacent to summer homes around Lake Quinault to replace the non-native English laurel dominant 

there. 

Appendix F is excerpted from an unpublished document (2003) Draft Guidelines for Revegetation of 

Invasive Weed Sites and Other Disturbed Areas on National Forests and Grasslands in the Pacific 

Northwest. This document provides further information on methods and guidelines for revegetation of 

invasive weed sites and disturbed areas. Steps are outlined for assessing existing and potential site 

conditions, and for developing long-term revegetation strategies that are 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. 

Appendix F was published in total in the Draft EIS and is available on the project website (find link at 

http://www.fs.fed.us/r6/olympic). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

41

2.5.5 Proposed Herbicides and Additives 

Table 11 displays typical application rates for herbicides proposed for use in the Proposed Action. The 

effective rate varies depending on many factors (application method, herbicide characteristics, target species, 

site conditions). The lowest effective rate would be used. Greater concentrations (rates) would be used 

infrequently and only where necessary to be effective. Lucero (personal communication, 2005) reported that 

stem injection with the highest application rates of glyphosate were required to effectively treat knotweed. In 

no case would herbicide concentrations be greater than maximum label rate and broadcast and spot 

applications within aquatic influence zones would never exceed typical rates (see PDFs below). 

Table 11-Typical Herbicide Application Rates 

Herbicide Typical Application Rate 

Lbs. a.i./acre 

Chlorsulfuron 0.056

Clopyralid 0.35

Glyphosate 2

Imazapic 0.13

Imazapyr 0.45

Metsulfuron Methyl 0.03

Picloram 0.35

Sethoxydim 0.3

Sulfometuron Methyl 0.045

Triclopyr 1.0

Herbicide Adjuvants (Additives) including Surfactants and Dyes 

Several types of surfactants or additives have been reviewed in hazard and risk assessments and thus would 

meet Standard 18 of the R6 2005 ROD. Surfactants and other additives are used to help herbicides adhere to 

target plants and reduce drift (Bakke 2003). Dyes may be added during implementation to mark treated areas 

(ibid). Cationic, non-ionic, and silicon based surfactants; vegetable and crop oils; kerosene; and colorfast 

purple and hi-light blue dyes are discussed in Bakke’s 2003 hazard assessment. Only those adjuvants that are 

approved by the Washington State Department of Agriculture (WSDA) and Department of Ecology 

(WSDOE) would be permitted within or immediately adjacent to streams. More information about 

herbicides and adjuvants is in Chapter 3.1. 

2.5.6 Early Detection-Rapid Response Approach 

The Early Detection/Rapid Response process allows for treatment “within the scope of the EIS” to occur on 

new, unknown, and unpredicted infestations found over the next five to fifteen years using treatment methods 

that are similar to those described in the EIS. The analysis for the Proposed Action considered treatment of 

3,830 acres estimated as the current inventory. However, invasive plants are likely to spread to additional 

acreage beyond the current inventory within and outside mapped treatment areas. In addition, unknown 

infestations may currently exist. 

Under the Early Detection/Rapid Response approach, new or previously undiscovered infestations would be 

treated using the range of methods described in this EIS, according to the Project Design Features listed later 

in this section. The Common Control Measures shown in Table 10 would be the starting point for a 

treatment prescription under the EDRR approach. 

This approach is needed because 1) the precise locations 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 

would not allow for rapid response; infestations may grow and spread into new areas during the time it 

usually takes to prepare NEPA documentation. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

42

The intent of the Early Detection/Rapid Response approach is to treat new infestations when they are small 

so that the likelihood of adverse treatment effects is minimized. 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 Early Detection/Rapid Response approach included in the Proposed Action allows the Forest Service to 

treat anywhere on the Forest that the need exists, based on, but not limited to the current inventory and 

anticipated rates of spread. The Implementation Planning process detailed in the following section is 

intended to ensure that effects are within the scope of those disclosed in this EIS; new situations that may 

have different effects would be subject to further NEPA analysis. 

2.5.7 Implementation Planning Process 

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

implemented. The methodology follows Integrated Weed Management (IWM) principles (R6 2005 FEIS, 3-

3) and satisfies pesticide use planning requirements at FSH 2109.14. It applies to currently known and new 

sites within or outside mapped treatment areas. 

Characterize invasive plant infestations to be treated 

• Map and describe target species, density, extent, treatment strategy and priority. 

• Add or refine target species information to database. 

• Validate affected environment at the treatment site and ensure no extraordinary site conditions exist 

that were not considered in EIS.11

Develop site-specific prescriptions 

• Use Integrated Weed Management principles to identify possible effective treatment 

methods.12 Considerations include the biology of the target species and surrounding environment. 

Determine whether effective methods are within the scope of those analyzed in the EIS. 13 

Prescribe herbicides as needed based on the biology of the target species and size of the infestations 

(for instance, manual treatment alone cannot effectively eradicate rhizomatous species). 

• Broadcast application of herbicide would be considered for situations warranted by the density 

(approximately 70-80 percent cover) and/or the distribution (e.g. continuous target populations along 

a road) of invasive plants, unless limited by PDFs. Broadcast application would not occur on any 

road segments identified as having high potential to deliver herbicide to streams. 

• Apply appropriate PDFs and buffers based on: 

o Range of effective treatments available, including herbicide (or mixture) and method of 

application14

o The size of the infestation, its treatment history and response to past treatment 

 

11 Conditions throughout current treatment areas are assessed in Chapter 3 (more information in Appendix A). 

Treatment areas include all areas where spread could be predicted to occur, based on current infestations and possible 

vectors or spread. Treatment areas include established populations; new infestations could occur outside treatment 

areas. Early detection-rapid response is intended to allow for treatment of new infestations outside treatment areas. 

New treatment areas found during future inventories need to be evaluated for extraordinary site conditions that may 

trigger additional NEPA requirements. 

12 Table 10 displays a summary of current control measures for various target species. These methods are intended to 

be refined through monitoring and adaptive management 

13 If preferred methods have effects that are outside the scope of those analyzed in the EIS, additional NEPA would be 

required. 

14 A tank mixtures analysis, as described in Appendix B, would be conducted and Standard 16 criteria met if tank 

mixtures are prescribed. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

43

o Proximity to species of local interest or their habitats15

o Proximity to streams, lakes, wetlands 

o Whether the treatment site is along a road associated with high risk of herbicide delivery to 

surface water 

o Soil conditions 

o Municipal watersheds and/or domestic water intakes 

o Places people gather (recreation areas, special forest product and special use areas). 

o Additional considerations, such as weather conditions, can be found in the PDF section. 

Specialists will review and apply appropriate PDFs for the final site-specific prescription. 

For example, a fish biologist would review the annual program of work to ensure that 

appropriate buffer widths are included where fish species of local interest are present. 

• Review compliance criteria for Forest Plan and other environmental standards that apply to a given 

treatment site. 

• If treatments would not be effective once PDFs are applied, further NEPA would be required to 

authorize the effective treatment. 

• Review manual Scotch broom treatments to ensure no effect on heritage resources. 

• Complete Form FS-2100-2 (see Appendix E), 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. 

• Confirm that surfactants proposed meet Standard 18. 

• Confirm whether active restoration is likely to be needed (see Appendix F). Plan for acquiring seed, 

plant or mulch materials. 

• Determine need for pre-project surveys for species of local interest and/or their habitats. 

• Coordinate with adjacent landowners, water users, agencies, and partners. 

• Document the elements of the public notification plan. 

• Follow NMFS and FWS Reasonable and Prudent Measures and Terms and Conditions. 

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; the equipment, 

materials and supplies needed; the herbicide application method and rate; field crew organization; 

lines of responsibility; and a description of 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. Include the 

appropriate PDFs, buffers, and approved surfactants in contracts and agreements. 

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

database, via the Forest Service Activity Tracking System (FACTS).16 

• WSDA is the responsible agency for pesticide management. WSDA also holds the Non-Point 

Discharge permit for use of herbicides to control aquatic and/or emergent noxious weeds in 

Washington State. 

• Implement the public notification plan and document accomplishments.

 

15 The list of particular species of local interest would be defined during Implementation Planning. New listed or 

sensitive species may be added during the life of the project. Appropriate surveys and mitigation measures would be 

applied according to protocols current at the time of Implementation Planning. 

16 See Appendix E for forms. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

44

Post-treatment Monitoring and Adaptive Management 

• Post-treatment reviews would occur to determine whether treatments were effective, whether or not 

passive/active restoration is occurring as expected, and whether PDFs were appropriately applied. 

Non-target vegetation (e.g., botanical species of local interest) would be evaluated on sample sites 

before and after treatment, and two to three months later. 

• Contract administration and other existing mechanisms would be used to correct deficiencies. 

• Treatment accomplishments would be reported via the FACTS database. Herbicide use would be 

reported as required by the FSH 2109.14. 

• Post-treatment monitoring would also be used to detect whether PDFs were appropriately applied, 

and whether non-target vegetation impacts are within tolerable levels. 

o Re-treatment and active restoration prescriptions would be developed based on posttreatment results. Changes in herbicide or non-herbicide methods, all within the scope of the 

FEIS, would occur based on results. 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. 

o Treatment buffers would be expanded if damage were found outside 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 buffers for water bodies. Buffers may be adjusted for certain 

herbicides/application methods and not others, depending on results. 

• Candidates for monitoring under the Regional Framework (R6 2005 ROD) would be submitted for 

higher risk situations such as emergent vegetation treatment or broadcast spray of aquatic labeled 

imazapyr and/or glyphosate within 100 feet of streams. Few higher risk situations currently exist. 

• Additional monitoring may be included as part of the Olympic National Forest Annual Monitoring 

Plan or other ongoing programs such as state water quality monitoring. 

2.5.8 Project Design Features and Buffers 

The following Project Design Features (PDFs) are intended to reduce the potential impacts of invasive plant 

treatment and provide sideboards for early detection/rapid response and adaptive management.17 The PDFs 

are based on site-specific resource conditions within the treatment areas, including (but not limited to) the 

current invasive plant inventory, the presence of special interest species and their habitats, potential for 

herbicide delivery to water, and the social environment. Implementation of the PDFs ensures that treatments 

would have effects within the scope of those disclosed in Chapter 3. All distances in the PDF and buffer 

tables are horizontal distances.18 

For emphasis, some design features include herbicide label guidance and Forest Plan standards, however, not 

all Forest Plan standards or label directions are repeated here. Forest Plan standards and label directions 

would be followed, regardless of whether they are listed in the PDF table. Project Design Features were 

developed to minimize potential for significant adverse effects to such a degree that even though precise 

treatment locations may be uncertain, the character of the impacts can be predicted, and pose low risk to 

people and/or the environment. The Project Design Features avoid or minimize the potential for adverse 

effects. 

 

17 In this EIS, the terms project design feature and project Design Features are synonymous. 

18 This is a change from the DEIS, which assumed “slope” rather than “horizontal” or map distances. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

45

The following steps were taken to generate the PDFs and buffers: 

1. The November 2004 invasive plant inventory and database was developed to provide sitespecific basis for the Proposed Action. Infested sites were aggregated into treatment areas. See 

Appendix A data tables that correspond to maps depicting each treatment area. 

2. The range of site conditions encountered throughout the treatment areas were considered and 

analyzed the effects of applying a range of treatment prescriptions to these situations. 

PDFs are summarized in table 12. Tables 13 – 16 show the herbicide use and protection buffers that would 

apply to streams and other water bodies, and botanical species of local interest. 

The Project Design Features and buffers were updated in response to public comment and interagency 

consultation. Differences made in these tables between the Draft and Final EIS are noted in the tables. A 

specific risk assessment for the aquatic formulation of imazapyr (Habitat) has been completed and integrated 

into the FEIS effects analysis. 

The FWS and NMFS BOs specify reasonable and prudent measures to minimize the likelihood of incidental 

take, along with non-discretionary terms and conditions to implement the reasonable and prudent measures. 

These measures do not substantively change the Proposed Action. See 2007 BOs and the ROD for more 

information 

Table 12-Project Design Features 

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

A - Pre-Project Planning 

A1 Prior to treatment, confirm species/habitats of local 

interest, watershed and aquatic resources of concern 

(e.g. hydric soils, streams, lakes, roadside treatment 

areas with higher potential to deliver herbicide, 

municipal watersheds, domestic water sources), and 

places where people gather. 

Ensure project is 

implemented 

appropriately. 

This approach follows 

several previous NEPA 

documents. 

Pre-project planning also 

discussed in the previous 

section. 

B - Coordination with Other Landowners/Agencies 

B1 Work with owners and managers of neighboring 

lands to respond to invasive plants that straddle 

multiple ownerships. Coordinate treatments within 

150 feet of Forest boundaries, including lands over 

which the Forest has right-of-way easements, with 

adjacent landowners. 

To ensure that 

neighbors are fully 

informed about nearby 

herbicide use and to 

increase the 

effectiveness of 

treatments on multiple 

ownerships. 

The distance of 150 feet 

was selected because it 

approximates the Aquatic 

Influence Zone for fish 

bearing streams. 

B2 Coordinate herbicide use within 1000 feet of known 

water intakes with the water user or manager. 

To ensure that 

neighbors are fully 

informed about nearby 

herbicide use. 

The distance of 1000 feet 

was selected to respond 

to public concern. 

Herbicide use as 

proposed for this project 

would not contaminate 

drinking water supplies. 

B3 Coordinate herbicide use with Municipal Water 

boards. Herbicide use or application method may be 

excluded or limited in some areas. 

To ensure that 

neighbors are fully 

informed about nearby 

herbicide use and 

standards for municipal 

watersheds are met. 

1990 Olympic National 

Forest Plan and existing 

municipal agreements. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

46

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

C - To Prevent the Spread of Invasive Plants During Treatment Activities 

C1 Where practical, clean vehicles and equipment 

(including personal protective clothing) prior to 

leaving treated areas or entering new areas. 

To prevent the spread 

of invasive plants 

during treatment 

activities 

Common measure 

D - Wilderness Areas 

D1 No motorized equipment would be used in 

wilderness areas. 

To maintain wilderness 

character and meet 

environmental 

standards. 

Wilderness Act, 1990 

Olympic National Forest 

Plan 

D2 Choose minimum impact treatment methods. To maintain wilderness 

values (e.g. solitude, 

unimpeded natural 

processes) and comply 

with environmental laws 

and policies. 

Wilderness Act, 

1990 Olympic National 

Forest Plan 

E - There are no Design Features under “E”. These were mainly intended to protect aquatic habitats and were 

therefore moved to “H.” 

F - Herbicide Applications 

F1a Herbicides would be used in accordance with label 

instructions and advisories, except where more 

restrictive measures are required as described 

herein. Herbicide applications would only treat the 

minimum area necessary to meet site objectives. 

Herbicide formulations would be limited to those 

containing one or more of the following 10 active 

ingredients: chlorsulfuron, clopyralid, glyphosate, 

imazapic, imazapyr, metsulfuron methyl, picloram, 

sethoxydim, sulfometuron methyl, and triclopyr. 

To limit potential 

adverse effects on 

people and the 

environment. 

Standard 16, 2005 R6 

ROD; Pesticide Use 

Handbook 2109.14 

F1b F1a and 1b were split out for reader’s ease. 

Herbicide application methods include wicking, 

wiping, injection, spot, and broadcast, as permitted 

by the product label and these Project Design 

Features. The use of triclopyr is limited to spot and 

hand/selective methods. 

Herbicide carriers (solvents) are limited to water 

and/or specifically labeled vegetable oil. 

To limit potential 

adverse effects on 

people and the 

environment. 

Standard 16, 2005 R6 

ROD; Pesticide Use 

Handbook 2109.14 

F2 Herbicide use would comply with standards in the 

Pacific Northwest Regional Invasive Plant Program – 

Preventing and Managing Invasive Plants FEIS 

(2005), including standards on herbicide selection, 

restrictions on broadcast use of some herbicides, 

tank mixing, licensed applicators, and use of 

adjuvants, surfactants and other additives. 

To limit potential 

adverse effects on 

people and the 

environment. 

R6 2005 ROD Treatment 

Standards 

F3 POEA surfactants, urea ammonium nitrate or 

ammonium sulfate would not be used in applications 

within 150 feet of surface water, wetlands or on 

roadside treatment areas having high potential to 

deliver herbicide. 

NPE surfactants do not pose similar risks to aquatic 

organisms and was therefore removed from this 

PDF. 

To protect aquatic 

organisms. 

The distance of 150 feet 

was selected because it is 

wider than the largest 

buffer and approximates 

the Aquatic Influence 

Zone for fish bearing 

streams. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

47

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

F4 The lowest effective application rates would be used 

for each given situation. NPE surfactant would not be 

broadcast at a rate exceeding 0.5 active ingredient 

per acre. Other classes of surfactants besides NPE 

would be favored wherever they are expected to be 

effective. 

In no case would imazapyr be applied at a rate 

exceeding 0.70 lbs. a.i./ac. (pounds of active 

ingredient per acre). 

To eliminate possible 

herbicide or surfactant 

exposures of concern to 

human health, and/or 

wildlife. 

SERA Risks 

Assessments, Appendix 

Q of the R6 2005 FEIS 

F5 Herbicide applications would occur when wind 

velocity is between two and eight miles per hour. 

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. 

F6 To minimize herbicide application drift during 

broadcast operations, use low nozzle pressure; apply 

as a coarse spray, and use nozzles designed for 

herbicide application that do not produce a fine 

droplet spray, e.g., nozzle diameter to produce a 

median droplet diameter of 500-800 microns. 

To 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 3.2 for 

details). 

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: 

9 Address spill prevention and containment. 

9 Estimate and limit the daily quantity of herbicides 

to be transported to treatment sites. 

9 Require that impervious material be placed 

beneath mixing areas in such a manner as to 

contain small spills associated with 

mixing/refilling. 

9 Require a spill cleanup kit be readily available for 

herbicide transportation, storage and application 

(minimum FOSS Spill Tote Universal or 

equivalent). 

9 Outline reporting procedures, including reporting 

spills to the appropriate regulatory agency. 

9 Ensure applicators are trained in safe handling 

and transportation procedures and spill cleanup. 

9 Require that equipment used in herbicide storage, 

transportation and handling are maintained in a 

leak proof condition. 

9 Address transportation routes so that traffic, 

domestic water sources, and blind curves are 

avoided to the extent possible. 

9 Specify conditions under which guide vehicles 

would be required. 

9 Specify mixing and loading locations away from 

water bodies so that accidental spills do not 

contaminate surface waters. 

9 Require that spray tanks be mixed or washed 

further than 150 feet of surface water. 

9 Ensure safe disposal of herbicide containers. 

9 Identify sites that may only be reached by water 

travel and limit the amount of herbicide that may 

be transported by watercraft.

To reduce likelihood of 

spills and contain any 

spills. 

FSH 2109.14, 

Bonneville Power 

Administration Biological 

Assessment, 

Buckhead Knotweed 

Project, Willamette NF 

Biological Assessment 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

48

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

H - Soils, Water and Aquatic Ecosystems 

H1 Herbicide use buffers have been established for 

perennial and wet intermittent steams; dry streams; 

and lakes and wetlands. These buffers are depicted 

in the tables below. Buffers vary by herbicide 

ingredient and application method. 

Tank mixtures would apply the largest buffer as 

indicated for any of the herbicides in the mixture. 

To reduce likelihood 

that herbicides would 

enter surface waters in 

concentrations of 

concern. 

Comply with R6 2005 

ROD Standards 19 and 

20. 

Buffers are based on label 

advisories, and SERA risk 

assessments. Buffer 

distances are based on 

the Berg’s 2004 study of 

broadcast drift and run off 

to streams, along with 

Washington State Dept. of 

Agriculture’s DOA’s 2003-

2005 monitoring results. 

Source updated since 

DEIS. 

H2 The following treatment methods are shown in order 

of preference (if effective and practical), within 

roadside treatment areas having high risk of 

herbicide delivery and, in wetlands, near aquatic 

influence areas, especially adjacent to fish bearing 

streams; Species of Local Interest or their critical 

habitat: 

 (1) Manual methods (e.g, hand pulling). 

 (2) Application of clopyralid, imazapic, and 

metsulfuron methyl, aquatic glyphosate, aquatic 

triclopyr, aquatic imazapyr. 

 (3) Application of chlorsulfuron, imazapyr, 

sulfometuron methyl. 

 (4) Application of glyphosate, triclopyr, picloram, and 

sethoxydim 

To protect aquatic 

organisms by favoring 

lower risk methods 

where effective. Lower 

risk herbicides are 

preferred where 

effective. Nonherbicide, manual 

methods have the least 

potential for impact, 

therefore they would be 

preferred. 

Herbicides were classed 

into low, moderate and 

higher risk to aquatic 

organisms based on 

SERA Risk Assessments. 

H3 No use of picloram or Triclopyr BEE, and no 

broadcast of any herbicide on roadside treatment 

areas that have a high risk of herbicide delivery to 

surface waters (see Appendix D for a map and list of 

these roads). 

To ensure herbicide is 

not delivered to streams 

in concentrations that 

exceed levels of 

concern. 

Not broadcasting far 

reduces potential for 

exposure because spot 

and selective method 

substantially reduce 

potential for off site 

impacts, drift, and other 

herbicide delivery 

mechanisms to water 

(runoff, leaching), 

No use of picloram and 

triclopyr BEE eliminates 

potential for these 

herbicides through the 

road ditch network. 

SERA Risk Assessments, 

R6 2005 FEIS Fisheries 

Biological Assessment 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

49

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

H4 Aquatic labeled herbicides or herbicides associated 

with lower risk to aquatic organisms would be applied 

using spot or hand/selective methods within 15 feet 

of the edge of a wet roadside ditch. For treatments of 

target vegetation emerging out of the wet roadside 

ditch only aquatic labeled herbicides would be used. 

To ensure herbicide is 

not delivered to streams 

in concentrations that 

exceed levels of 

concern. 

Not broadcasting far 

reduces potential for 

exposure because spot 

and selective method 

substantially reduce 

potential for off site 

impacts, drift, and other 

herbicide delivery 

mechanisms to water 

(runoff, leaching), 

A restriction on 

herbicide selection 

avoids potential for 

herbicides to reach a 

threshold of concern. 

SERA Risk Assessments 

R6 2005 FEIS and 

Fisheries Biological 

Assessment 

BPA Columbia River 

Biological Opinion 

H5 Vehicles (including all terrain vehicles) used to 

access or implement invasive plant projects would 

remain on roadways, trails, parking areas or other 

previously disturbed areas to prevent damage to 

riparian vegetation and soil, and potential 

degradation of water quality and aquatic habitat. 

To protect riparian and 

aquatic habitats. 

BPA Columbia River 

Biological Opinion 

H6 Avoid use of clopyralid on high-porosity soils (coarser 

than loamy sand). 

To avoid 

leaching/ground water 

contamination. 

Typical label advisory. 

H7 Avoid use of chlorsulfuron on soils with high clay 

content (finer than loam). 

To avoid excessive 

herbicide runoff. 

Typical label advisory. 

H8 Avoid use of picloram on shallow or coarse soils 

(coarser than loam.) 

No more than one application of picloram would be 

made within a two-year period, except to treat areas 

missed during initial application. 

To reduce the potential 

for picloram to enter 

surface and/or ground 

water and/or 

accumulate in the soil. 

Picloram has the 

highest potential to 

impact organisms in soil 

and water, and tends to 

be more persistent than 

the other herbicides. 

SERA Risk Assessment. 

Based on quantitative 

estimate of risk from 

worst-case scenario and 

uncertainty. 

H9 Avoid use of sulfometuron methyl on shallow or 

coarse soils (coarser than loam.) 

No more than one application of sulfometuron methyl 

would be made within a one-year period, except to 

treat areas missed during initial application. 

To reduce the potential 

for sulfometuron methyl 

accumulation in the soil. 

Sulfometuron methyl 

has some potential to 

impact soil and water 

organisms and is 

second most persistent. 

SERA Risk Assessments. 

Based on quantitative 

estimate of risk from 

worst-case scenario and 

uncertainty. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

50

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

H10 Lakes and Ponds –- No more than half the perimeter 

or 50 percent of the vegetative cover or 10 

contiguous acres around a lake or pond would be 

treated with herbicides in any 30-day period. 

To reduce exposure to 

herbicides by providing 

some untreated areas 

for some organisms to 

use. Abates risks 

associated with worstcase scenarios and 

uncertainty regarding 

effects to reptiles and 

amphibians. 

SERA Risk Assessments. 

H11 Wetland vegetation would be treated when soils are 

driest. If herbicide treatment is necessary for 

emergent target plants when soils are wet, use 

aquatic labeled herbicides. Favor hand/selective 

treatment methods where effective and practical. 

To reduce exposure to 

herbicides by providing 

some untreated areas 

for some organisms to 

use. Abates risks 

associated with worstcase models for 

treatment of emergent 

vegetation. 

SERA Risk Assessments.

H12 All wells and springs used for domestic water 

supplies would be protected with a 100 foot buffer for 

wells and a 200 foot buffer for springs. Follow label 

guidance relative to water contamination. 

This is a new PDF that responds to public concern 

for drinking water quality. 

The PDF related to “foaming” was removed because 

this method is currently not associated with 

treatments in Appendix A 

Safe drinking water. Label advisories and state 

drinking water regulations 

(Washington State WAC 

246-290-315). 

H13 With the exception of hand/select methods, 

herbicides would be applied at typical (or lower) rates

within Aquatic Influence Zones. 

This is a new PDF to limit the application rate for spot 

and broadcast treatments in response to interagency 

comments. 

To ensure herbicide 

exposures are below 

thresholds of concern 

for aquatic ecosystems. 

SERA Risk Assessments, 

Biological Assessment 

H14 Treatments above bankfull, within the aquatic 

influence zone, would not exceed 10 acres along any 

1.5 mile of stream reach within a 6th field 

subwatershed in any given year. 

In addition, treatments below bankfull would not 

exceed 6 acres total within a 6th field sub-watershed 

in any given year. 

This is a new PDF to limit the application rate for spot 

and broadcast treatments in response to interagency 

comments. 

Limits the extent of 

treatment within the 

Aquatic Influence Zone 

so that adverse effects 

are within the scope of 

analysis. 

Analysis based on SERA 

risk assessment 

worksheets and emergent 

vegetation analysis 

completed for the 

Cranberry Bog and Middle 

Hoh River. Ten acres is 

based on GLEAM model 

factors. 

H15 PDF H15 was in the DEIS but is omitted in the FEIS. The FS, FWS and NMFS are working together to 

address the need for rainfall delay specifications as a part of implementation planning. 

H16 Plan and schedule project activities to avoid 

disturbance of spawning fish or damage to redds. 

This is a new PDF in response to interagency 

comments. 

Minimize adverse 

impacts within 

waterbodies. 

Memorandum of 

Understanding between 

WDFW and USDA Forest 

Service, January 2005 

H17 Limit the numbers of people on any one site at any 

one time while treating areas within 150 feet of 

creeks. 

This was previously PDF E2. 

To minimize trampling 

and protect riparian and 

aquatic habitats. 

The distance of 150 feet 

was selected because it 

approximates the Aquatic 

Influence Zone for fish 

bearing streams. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

51

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

H18 Fueling of gas-powered equipment with gas tanks 

larger than 5 gallons would not occur within 150 feet 

of surface waters. 

Fueling of gas-powered equipment with gas tanks 

smaller than 5 gallons would not occur within 25 feet 

of any surface waters. 

This was previously PDF E3. 

To protect riparian and 

aquatic habitats. 

The distance of 150 feet 

was selected because it 

approximates the Aquatic 

Influence Zone for fish 

bearing streams. Filling 

of smaller tanks has 

inherently less risk. 

I - Vascular and Non-Vascular Plant and Fungi Species of Local Interest 

I1 Adaptive management would be used to refine 

buffers to adequately protect perennial fungi, 

vascular and non-vascular plant Species of Local 

Interest (SOLI) and other non-target plants. Such 

species are on Regional Forester Sensitive Plant lists 

and Survey and Manage Species lists. 

This PDF has been reworded for clarity. 

To prevent any 

repeated effects to 

SOLI populations, 

thereby mitigating any 

long-term effects. 

Broadcast buffer sizes are 

based on Marrs, R.H., 

1989, based on tests on 

vascular plants. 

Spot and hand/selective 

buffer distances are also 

based on reports from 

Cathy Lucero, Clallam 

County Noxious Weed 

Coordinator and other 

experienced herbicide 

applicators. 

I2 Perennial fungi, vascular and non-vascular plant 

SOLI within 100 feet of planned broadcast would be 

covered by protective barrier, or broadcast 

application would be avoided in these areas (spot or 

hand herbicide treatment, or non-herbicide methods 

may be used). 

To ensure SOLI are 

protected and surveys 

are conducted when 

appropriate. 

Forest Service Manual 

2670 

Survey and Manage 

Species Direction. 

I3 Perennial fungi, vascular and non-vascular plant 

SOLI within 10 feet of planned spot applications 

would be covered by protective barrier, or spot 

application would be avoided in these areas (hand 

herbicide treatment, or non-herbicide methods may 

be used). 

Under saturated or wet soil conditions present at the 

time of treatment, only hand application of herbicide 

is permitted within 10 feet of SOLI. 

To ensure SOLI are 

protected and surveys 

are conducted when 

appropriate. 

Forest Service Manual 

2670 

Survey and Manage 

Species Direction 

I4 Prior to treatment, botanical surveys would occur as 

necessary to identify vascular and non-vascular plant 

and perennial fungi SOLI if unsurveyed suitable 

habitat is within 100 feet of planned broadcast 

treatments, 10 feet of planned spot treatments, 

and/or 5 feet of planned hand herbicide treatments 

(increased to 10 feet in saturated/wet soils). 

To ensure SOLI are 

protected and surveys 

are conducted when 

appropriate. 

Forest Service Manual 

2670 

Survey and Manage 

Species Direction 

I5 Use special care when applying sulfonylurea 

herbicides due to their potency and potential to harm 

non-target vegetation. Do no use chlorsulfuron, 

metsulfuron methyl or sulfometuron methyl on dry, 

ashy, or light, sandy soils. 

This PDF was added to highlight the potential for 

these herbicides to harm non-target vegetation 

through dust or drift. 

To protect non-target 

vegetation. 

Label advisories. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

52

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

J - Wildlife Species of Local Interest 

Many of the Wildlife PDFs have been amended or supplemented as a part of Endangered Species Act 

Consultation with Fish and Wildlife Service. 

J1-Bald Eagle 

J1a Treatment of areas within 0.25 mile, or 0.50 mile lineof-sight, of bald eagle nests would be timed to occur 

outside the nesting 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). This seasonal restriction may be 

waived if a biologist determines by appropriate 

surveys that nest sites are not active that year. 

To minimize 

disturbance to nesting 

bald eagles and protect 

eggs and nestlings 

Bald Eagle Management 

Guidelines for OR-WA 

(Anonymous); U.S. Fish 

and Wildlife Service 2003, 

p. 9 

J1b Noise-producing activity above ambient levels would 

not occur between October 31 and March 31 within 

0.25 mile, or 0.50 mile line-of-sight, of known winter 

roosts and concentrated foraging areas. Disturbance 

to daytime winter foraging areas would be avoided. 

To minimize 

disturbance and reduce 

energy demands during 

stressful winter season 

Bald Eagle Management 

Guidelines for OR-WA 

(Anonymous); Olympic 

National Forest 

Programmatic BO (U.S. 

Fish and Wildlife Service 

2003, p. 9) 

J2 - Spotted Owl 

J2 Chainsaw use within 65 yards, and mower or heavy 

equipment use within 35 yards, of any nest site, 

activity center, or un-surveyed suitable habitat will be 

timed to occur outside the early nesting season of 

March 1 to July 15, unless treatment activity is within 

ambient levels of noise and human presence (as 

determined by a local specialist). There is no 

seasonal restriction on the use of roadside broadcast 

sprayers. 

To minimize 

disturbance to nesting 

spotted owls and 

protect eggs and 

nestlings 

Olympic National Forest 

Programmatic BO (U.S. 

Fish and Wildlife Service 

2003) 

J3 - Marbled Murrelet 

J3a Chainsaw or motorized tool use within 45 yards, and 

mower or heavy equipment use within 35 yards of 

any known occupied site or un-surveyed suitable 

habitat would will be timed to occur outside April 1 to 

August 5, unless treatment activity is within ambient 

levels of noise and human presence (as determined 

by a local specialist). There is no seasonal restriction 

on the use of roadside broadcast sprayers. 

To minimize 

disturbance to nesting 

marbled murrelets and 

protect eggs and 

nestlings 

Olympic National Forest 

Programmatic BO (U.S. 

Fish and Wildlife Service 

2003) 

J3b After August 5 and before April 1, activities 

generating noise above 92 dB may occur within the 

disturbance distances listed above, but must still be 

conducted between 2 hours after sunrise and 2 hours 

before sunset. 

To minimize 

disturbance to marbled 

murrelets returning to 

nest tree during the late 

breeding season. 

Olympic National Forest 

Programmatic BO (U.S. 

Fish and Wildlife Service 

2003) 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

53

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

J4 - Peregrine Falcon 

J4a All invasive plant treatments would be seasonally 

prohibited within 0.5 miles of peregrine nest sites 

(primary nest zone). 

Invasive plant treatments involving motorized 

equipment and/or vehicles would be seasonally 

prohibited within 1.5 miles of known nest sites 

(secondary nest zones). This may include activities 

such as mulching, chainsaws, vehicles (with or 

without boom spray equipment) or other 

mechanically based invasive plant treatment. 

Non-mechanized or low disturbance invasive plant 

activities (such as spot spray, hand pull, etc.) may 

occur within the secondary nest zone, but would be 

coordinated with the wildlife biologist on a case-bycase basis to determine potential disturbance to 

nesting falcons and identify mitigating measures, if 

necessary. 

To reduce disturbance 

to nesting falcons and 

protect eggs and 

nestlings. Agitated 

parents can damage 

the eggs with thin shells 

resulting in failed 

reproduction for that 

nest. 

Pagel, J. (2006) 

Peregrine falcon nest site 

data, 1983-2006. 

J4b Seasonal restrictions would be waived within primary 

and secondary nest zones if the site is unoccupied or 

if nesting efforts fail and monitoring indicates no 

further nesting behavior. 

To reduce disturbance 

to nesting falcons and 

protect eggs and 

nestlings. Agitated 

parents can damage 

the eggs with thin shells 

resulting in failed 

reproduction for that 

nest. 

Pagel, J. (2006) 

Peregrine falcon nest site 

data, 1983-2006. 

J4c Seasonal restrictions would apply during the periods 

listed below based on the following elevations: 

Low elevation sites (1000-2000 ft) 

01 Jan - 01 July 

Medium elevation sites (2001 - 4000 ft) 

15 Jan - 31 July 

Upper elevation sites (4001+ ft) 

01 Feb - 15 Aug 

Seasonal restrictions would be extended if 

monitoring indicates late season nesting, 

asynchronous hatching leading to late fledging, or 

recycle behavior which indicates that late nesting and 

fledging would occur. 

To reduce disturbance 

to nesting falcons and 

protect eggs and 

nestlings. Agitated 

parents can damage 

the eggs with thin shells 

resulting in failed 

reproduction for that 

nest. 

Pagel, J. (2006) 

Peregrine falcon nest site 

data, 1983-2006. 

J4d Protection of nest sites would be provided until at 

least two weeks after all young have fledged. 

To protect falcon nest 

sites and fledglings. 

Pagel, J. (2006) 

Peregrine falcon nest site 

data, 1983-2006. 

J4e Clopyralid would not be used within 1.5 miles of 

peregrine nest more than once per year. Picloram 

would not be used more than once every two years 

(see PDF H8). 

To reduce exposure to 

hexachlorobenzene. 

This chemical has been 

detected in peregrine 

falcon eggs. 

Pagel, J. (2006) 

Peregrine falcon nest site 

data, 1983-2006. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

54

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

J5 - Van Dyke’s, Cope’s Giant, and Olympic Torrent Salamanders 

J5a Avoid broadcast spraying of herbicide in talus or 

rocky outcrops, springs, seeps or stream margins. 

Utilize aquatic design features for suitable habitat in 

riparian areas, streams, and rivers. 

To reduce likelihood of 

exposure to herbicides 

or additives from 

contaminated soil or 

water. 

Herbicide characteristics 

and risk to amphibians in 

SERA risk assessments, 

and local biologist 

judgment. 

J6 - Sensitive Mollusk Habitat, Burrington’s and Warty jumping slugs 

J6a In known sites or high potential suitable habitat 

outside of roadside treatment locations, avoid 

manual, mechanical, or herbicide treatments when 

soil moisture is high (generally late fall to late spring).

To reduce likelihood of 

trampling and herbicide 

exposure. 

Herbicide characteristics 

in SERA risk 

assessments, and 

professional opinion of 

local taxa expert. 

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. 

Areas of potential conflict would be prominently 

marked on the ground or otherwise posted. 

Postings would indicate the date of treatments, the 

herbicide used, and when the areas are expected to 

be clear of herbicide residue. 

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/or posting signs. 

Forest Service and other websites may also be used 

for public notification. 

To ensure that no 

inadvertent public 

contact with herbicide 

occurs. 

R6 2005 ROD Standard 

23. 

L - Special Forest Products 

L1 Triclopyr would not be applied to foliage in areas of 

known special forest products or other wild foods 

collection. 

To eliminate any 

scenario where people 

might be exposed to 

harmful doses of 

triclopyr. 

SERA Risk Assessments, 

Appendix Q of the R6 

2005 FEIS 

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 

SERA Risk Assessments, 

Appendix Q of the R6 

2005 FEIS 

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 

SERA Risk Assessments, 

Appendix Q of the R6 

2005 FEIS 

L4 Special forest product gatherers would be notified 

about herbicide treatment areas when applying for 

their permits. Flyers indicating treatment areas may 

be included with the permits, in multi-lingual formats 

if necessary. 

To ensure that no 

inadvertent public 

contact with herbicide 

occurs. 

R6 2005 ROD Standard 

23 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

55

PDF 

Reference 

Design Feature Purpose of PDF Source of PDF 

M - Archeology and American Indian Rights 

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. Individual cultural plants identified by 

tribes would be buffered as above for botanical 

species of local interest. 

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 Olympic 

National Forest 

M2 The Forest Archaeologist will annually assess 

proposed treatment areas where minor ground 

disturbing actions such as weed wrenching and 

grubbing with a shovel in areas that are outside 

landslides, flood deposits, previously surveyed areas, 

skid trails, landings, road shoulders, cuts and fills, 

are proposed. 

The Forest Archaeologist will have an opportunity to 

review project locations to determine if any cultural 

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 no 

potential to affect cultural resources. 

This PDF was added since the DEIS to ensure 

cultural resources are adequately protected. 

To avoid conflicts 

impacts to cultural 

resources. 

Common practice. 

Herbicide Use Buffers 

Herbicide use buffers in tables 13-15 act as a safety zone to keep herbicides from reaching levels of concern 

in surface waters. Broadcast methods are restricted near streams and wetlands. Aquatic labeled herbicides 

are available for use on emergent vegetation, through dry intermittent streams, and in ditches or other areas 

of likely delivery to surface water bodies. 

Table 13-Herbicide Use Buffers – Perennial and Wet Intermittent Streams - Proposed Action 

(Alternative B) 

Perennial and Wet Intermittent 

Stream Buffers 

Herbicide 

Broadcast (feet) Spot (feet) Hand/ 

Select (feet) 

Chlorsulfuron 100 50 Bankfull 

Clopyralid 100 15 Bankfull 

Glyphosate 100 50 50 

Glyphosate (Aquatic Formula) 50 No buffer** No buffer 

Imazapic 100 15 Bankfull 

Imazapyr 100 50 Bankfull 

Imazapyr (Aquatic Formula) 50 No buffer No buffer 

Metsulfuron Methyl 100 15 Bankfull 

Picloram 100 50 50 

Sethoxydim 100 50 50 

Sulfometuron Methyl 100 50 Bankfull 

Triclopyr-BEE None Allowed 150 150 

Triclopyr-TEA (Aquatic Formula) None Allowed 15 No buffer 

*Changed from waters’ edge to no buffer to allow for effective treatment of some target populations in stream islands using spot 

methods. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

56

**No buffer means that treatment may occur anywhere across the stream channel where target vegetation exists including backwater 

channels, braided streams, floodplains, etc even when water is present. 

Table 14-Herbicide Use Buffers, Dry Streams 

Buffers For Streams That Are 

Dry At The Time Of Treatment 

Herbicide 

Broadcast (feet) Spot (feet) Hand/ 

Select (feet) 

Chlorsulfuron 50 15 Bankfull 

Clopyralid 50 Bankfull No buffer 

Glyphosate 100 50 50 

Glyphosate (Aquatic Formulation) 50* No buffer No buffer 

Imazapic 50* Bankfull No buffer 

Imazapyr 50 15 Bankfull 

Imazapyr (Aquatic Formulation) 50* No buffer No buffer 

Metsulfuron Methyl 50* Bankfull No buffer 

Picloram 100 50 50 

Sethoxydim 100 50 50 

Sulfometuron Methyl 50 15 Bankfull 

Triclopyr-BEE None Allowed 150 150 

Triclopyr-TEA (Aquatic Formula) None Allowed 15 No buffer 

*The broadcast buffer increased to 50 feet to respond to public and interagency comments (see Appendix H). 

Table 15-Herbicide Use Buffers – Wetlands/High Water Table/Lake/Pond - Proposed Action 

(Alternative B) 

Wetlands, High Water Table Areas, 

Lakes and Ponds 

Herbicide 

Broadcast (feet) Spot (feet) Hand/ 

Select (feet) 

Chlorsulfuron 100 50 Water’s Edge 

Clopyralid 100 15 Water’s Edge 

Glyphosate 100 50 50 

Glyphosate (Aquatic Formula) 50** No buffer No buffer 

Imazapic 100 15 Water’s Edge 

Imazapyr (Aquatic Formula) 50** No buffer No buffer 

Imazapyr 100 50 Water’s Edge 

Metsulfuron Methyl 100 15 Water’s Edge 

Picloram 100 50 50 

Sethoxydim 100 50 50 

Sulfometuron Methyl 100 50 Water’s Edge 

Triclopyr-BEE None Allowed 150* 150 

Triclopyr-TEA (Aquatic Formula) None Allowed 15 No buffer 

*This buffer was increased from 50 to 150 feet to ensure non-aquatic triclopyr is avoided throughout all Aquatic Influence Zones. 

** If wetland, pond or lake is dry, there is no buffer. 

Figure 1 illustrates how the Aquatic Influence Zone restricts application methods and herbicides to only those 

approved for use in aquatic areas. “Aquatic Influence Zone” is not equal to the “buffer widths” listed in the 

tables above. The Aquatic Influence Zone is defined by the innermost half of the Riparian Reserve, as 

defined by the Northwest Forest Plan. For instance, a 300 foot Riparian Reserve would have an Aquatic 

Influence Zone of 150 feet. Establishing buffer widths reduces the potential for herbicides to come in 

contact with water via drift, leaching, and runoff at or near concentrations of concern. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

57

Roadside Ditches 

The illustration above in Figure 1 exemplifies a cross-section of either a stream or a roadside ditch that has a 

high potential for herbicide delivery. Roadside ditches can also act as extensions of the stream network when 

there is enough flow and depth in a ditch to deliver sediment. The analysis in this BA uses sediment delivery 

as a surrogate for potential herbicide delivery in roadside ditches. To reduce the potential for herbicides to 

come in contact with water via runoff at or near concentrations of concern, the following restrictions would 

apply to roadside treatments: 

• No broadcasting of any herbicide on roads identified as a high potential for herbicide delivery (PDF 

H3) 

• No use of picloram or Triclopyr BEE on roads identified as a high potential for herbicide delivery 

(PDF H3) 

• Where there is standing water in a roadside ditch located outside the established buffers of a stream, 

apply a 15 foot buffer around the standing water and use only low risk herbicides within 15 feet of 

the edge of a wet roadside ditch. For treatments of target vegetation emerging out of the wet 

roadside ditch only aquatic labeled herbicides would be used (PDF H4). 

• Apply appropriate buffer widths to road sections that cross streams (refer to buffer tables above) 

Figure 1-Schematic Showing Herbicide Use Buffers 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

58

Table 16 displays the protection buffers specific to botanical species of local interest. These buffers are in 

addition to herbicide use buffers within Aquatic Influence Zones. Hence, if a botanical species of local 

interest is found at or near the edge of a stream buffer, then the stream buffer size may be enlarged to 

incorporate protection buffers established for botanical species of local interest. 

Table 16-Protection Buffers for Botanical Species of Local Interest 

Distance from Species of Interest 

Further than 100 ft. 100 ft to 10 ft. Closer than 10 ft. 

Application 

Method 

Allowed 

All methods according to 

PDFs. 

Botanical SOLI would be 

shielded with a protective 

barrier during broadcast 

herbicide application. 

No additional limitations for 

spot and hand/selective 

treatments 

1. Broadcast application is not 

permitted. 

2. If soils are saturated or wet at time of 

application, spot application is not 

permitted. Elsewhere, botanical SOLI 

would be shielded with a protective 

barrier during spot treatments. Hand 

application of herbicide and/or nonherbicide treatment permitted without 

protective shielding. 

Design features for treatments closer than 5 feet from botanical SOLI were combined with design features 

for treatments 5 – 10 feet from botanical SOLI since the release of the DEIS. This change was made to 

simplify implementation. 

2.5.9 Proposed Action Summary Table 

Table 17 displays proposed treatment combinations based on the information gathered for existing 

infestations. 

Table 17-Acres by Treatment Combination - Proposed Action (Alternative B) 

Total Acres Herbicide Only Herbicide combined with Manual 

and/or Mechanical Treatment 

Non-Herbicide Only 

3,830 16 3,671 143 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

59

2.6 Alternative C - Less Herbicide Use Allowed 

Alternative Description

Total Acres to Be Treated: 3,410 

Total Acres Estimated Herbicide Treatment: 1,035 

Estimated Proportion of Herbicide Treatment Acres - Broadcast: 0% 

Estimated Proportion of Herbicide Treatment Acres - Spot/Hand: 100% 

Alternative C is the Proposed Action, modified to further minimize (or eliminate) risks to soils, water and 

non-target organisms from the use of herbicides. 

2.6.1 Treatment Areas, Priority and Strategy 

Alternative C would approve treatment within the same treatment areas as the Proposed Action. However, 

Alternative C was modeled to treat 3,410 acres, omitting the 420 acres associated with a treatment strategy of 

“eradicate” in the Proposed Action. Fewer acres would be treated because treatments would tend to be less 

economically efficient and because eradication of invasive plant species would likely be impractical given 

the limitation on herbicide use inherent in this alternative. 

2.6.2 Common Control Measures and Treatment Site Restoration 

Alternative C would draw upon the same common control measures and treatment site restoration approach 

as the Proposed Action. Target species most effectively treated with herbicides would either not be treated or 

more time and money would be spent controlling or containing such species. 

2.6.3 Implementation Planning and Early Detection-Rapid Response Approach 

Alternative C would draw upon the same implementation planning and early detection-rapid response 

approach as the Proposed Action. 

2.6.4 Herbicide Selection 

Alternative C would allow for much less herbicide use overall (herbicides would not be used on more than 

two-thirds of the project area); however the slate of herbicides available would be the same as the Proposed 

Action. 

2.6.5 Project Design Features and Buffers 

All of the Project Design Features in the Proposed Action would be adopted except PDFs H1, H2, H3, H10, 

H 11, H 13, and H 14. Herbicides would generally not be used within Riparian Reserves19 or within roadside 

treatment areas having high risk of herbicide delivery to streams under Alternative C. Broadcast treatments 

would not be approved anywhere on the National Forest (0% of the project area as compared to 34% for 

Alternative B).2.6.6 Alternative C Summary Table 

Table 18-Total Acres by Treatment Combination – Alternative C 

Total Acres Herbicide Only Herbicide combined with Manual and/or 

Mechanical Treatment 

Non- Herbicide Only

3,410 0 1,035 2,375 

 

19 High priority species such as knotweed would continue to be treated as a part of ongoing prescriptions developed in 

partnership with other landowners and agencies. Such treatments would be very limited in extent (fewer than 10 acres).. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

60

2.7 Alternative D – More Broadcast Allowed 

Alternative Description

• Total Acres to Be Treated: 3,830 

• Total Acres Estimated Herbicide Treatment: 3,687 

• Estimated Proportion of Herbicide Treatment Acres - Broadcast: 84% 

• Estimated Proportion of Herbicide Treatment Acres - Spot/Hand: 16% 

Alternative D is similar to the Proposed Action except that more broadcasting would be allowed to increase 

the cost-effectiveness of treatments near dry streams and along roadside ditches. 

2.7.1 Treatment Areas, Priority and Strategy 

Alternative D would approve treatment within the same treatment areas as the Proposed Action. The 

priorities and strategies would also be the same as the Proposed Action. 

2.7.2 Common Control Measures and Treatment Site Restoration 

Alternative D would draw upon the same common control measures and treatment site restoration approach 

as the Proposed Action. 

2.7.3 Implementation Planning and Early Detection-Rapid Response Approach 

Alternative D would draw upon the same implementation planning and early detection-rapid response 

approach as the Proposed Action. 

2.7.4 Herbicide Selection 

Alternative D would allow for the same slate of herbicides as the Proposed Action. 

2.7.5 Project Design Features and Buffers 

All of the Project Design Features listed for Alternative B would be adopted, except for H3 (H3 restricts 

broadcasting of any herbicide, and any use of certain herbicides, on roads identified as having high risk of 

herbicide delivery to streams). In addition, buffers would not be implemented for dry streams (label 

restrictions would continue to apply). Under Alternative D, broadcast would be approved on a larger portion 

of the project area (84 percent as compared to 34 percent for the Proposed Action and 0 percent in 

Alternative C). 

2.7.6 Alternative D Summary Table 

Table 19-Total Acres by Treatment Combination – Alternative D 

Total Acres Herbicide Only Herbicide combined with Manual and/or 

Mechanical Treatment 

Non-Herbicide Only 

3,830 16 3,671 143 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

61

2.8 Alternatives Considered but Eliminated from Detailed Study 

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

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

detail (40 CFR 1502.14). Scoping input received in response to the Proposed Action provided suggestions for 

alternative methods for achieving the purpose and need. Some of these alternatives may have been outside 

the scope of this EIS, not meet the Purpose and Need for Action, not reasonably feasible or not viable, 

duplicative of the alternatives considered in detail, or were determined to cause unnecessary environmental 

harm. Therefore, the following alternatives were considered, but dismissed from detailed consideration for 

the reasons summarized in sections 2.8.1-2.8.3. 

2.8.1 Preventing, Rather Than Treating Invasive Plants 

Some comments expressed that the best approach for addressing invasive plant infestations is to eliminate 

disturbance caused by logging, grazing, road building, and vehicular traffic. These comments suggested that 

logging and other ground-disturbing projects should be suspended until a comprehensive EIS is completed 

that fully addresses the existing problem and ‘root causes’ of invasive plants. A similar issue was raised in 

the R6 2005 FEIS but dismissed from detailed study in the R6 2005 FEIS because “suspending multiple-use 

activities [would be] inconsistent with current laws governing the management of National Forest System 

lands” (R6 2005 FEIS page 2-33). 

Prevention is an important component of invasive plant management addressed throughout the R6 2005 FEIS 

and ROD, additional national and regional manual direction and policy statements, and the USDA-Forest 

Service Guide to Noxious Weed Prevention. The R6 2005 ROD added a standard to all Forest Plans 

requiring that all land use projects, assessments and plans address prevention of invasive plant introduction, 

establishment and spread (Appendix 1). The Regional Forester intended the prevention standards to reduce 

rates of spread of invasive plants, while still maintaining the ability of the Forest Service to provide for 

existing uses and management activities on National Forest System lands (ROD page 9). 

Invasive plant prevention practices will occur regardless of alternative selected for invasive plant treatment 

in this FEIS, including No Action. Washing equipment before entering the National Forest, scheduling 

activities to avoid moving between infested and uninfested areas, prompt revegetation of disturbed areas with 

native plants, managing off road vehicle use, and avoiding ground disturbance in certain areas are examples 

of current, ongoing invasive plant prevention practices. 

Prevention is an important component of the integrated program, but without treatment, invasive plants will 

continue to spread. Recent work by Mehta et al 2007 found that early detection and rapid response increased 

managers' chances to successfully restore invasive plant sites and increases the effectiveness of prevention 

practices. 

These invasive plant prevention practices are not connected actions to the proposed treatments. The focus of 

this FEIS is on the project level issues, alternatives, and effects related to invasive plant treatment and 

restoration of treated sites. NEPA regulations encourage such narrowing so that EIS’s may be focused on 

issues that are ripe for decision: 

“Agencies are encouraged to tier their environmental impact statements to eliminate repetitive 

discussions of the same issues and to focus on the actual issues ripe for decision at each level of 

environmental review (§1508.28). Whenever a broad environmental impact statement has been prepared 

(such as a program or policy statement) and a subsequent statement or environmental assessment is then 

prepared on an action included within the entire program or policy (such as a site specific action) the 

subsequent statement or environmental assessment need only summarize the issues discussed in the 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

62

broader statement and incorporate discussions from the broader statement by reference and shall 

concentrate on the issues specific to the subsequent action” (40 CFR 1502.20). 

In this case, the project analysis tiers to the broader scale R6 2005 FEIS regarding the issue of suspending 

land uses in order to prevent the spread of invasive plants. 

2.8.2 No Herbicide Use 

Additional public comments suggested that herbicide use should be severely minimized or eliminated 

altogether. The No Action alternative serves this function by allowing fewer than 100 acres of herbicide use 

(less than 2 percent of the current infested acres), which is very similar to a “no-herbicide” alternative. 

Alternative C was also developed to address public concerns about herbicide use by severely limiting 

herbicide use over about two-thirds of the Forest. 

Both No Action and Alternative C rely mostly on manual and mechanical treatments. The impacts and 

effectiveness of such treatments are discussed in Chapter 3. If No Action were selected, future manual and 

mechanical treatments that have not already been approved would likely be categorically excluded from 

NEPA documentation. 

2.8.3 Follow Herbicide Label Directions – No Additional Design Features 

Public comments expressed a concern that Project Design Features proposed by the Forest Service are overly 

cautious and costly. All action alternatives must comply with new Forest Plan and other relevant invasive 

plant management direction. An alternative that only follows label directions may meet some, but not all of 

this management direction. In particular, all action alternatives must prescribe design features to minimize 

and/or eliminate adverse effects on non-target organisms. Chapter 3 describes how adverse effects may be 

avoided through application of design features. Alternative D is intended to allow the maximum flexibility 

in treatment options while still complying with management direction and standards. 

2.9 Alternatives Compared 

Table 20 displays similarities and differences between the alternatives. The alternatives mainly differ by how 

and where herbicides may be used. All of the alternatives (including No Action) include some herbicide use 

and allow for approved releases of biological controls. All of the action alternatives would allow for 

treatment of future detections of invasive plants and restoration of treated sites. 

 Table 20-Alternative Components Compared 

Alternative Component Alternative 

A B C D 

Total Treatment Acres 672 3,830 3,410 3,830 

Estimated Percentage of Current Infestation Treated 18% 100% 89% 100% 

Acres of Proposed Herbicide Use 86 3,687 1,035 3,687 

Estimated Proportion of Project Area Where Broadcast is 

Approved 

0 34% 0 84% 

Estimated Proportion of Project Area Herbicide Treatment 

Where Broadcast is not Approved 

100% 66% 100% 16% 

Includes approved existing biological releases Yes Yes Yes Yes 

Includes Treatment of Future Detections No Yes Yes Yes 

Includes Restoration Plan No Yes Yes Yes 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

63

Table 21 displays how each alternative addresses public issues described in Chapter 1. 

Table 21-Alternative Comparison Relative to Issues 

Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative C Alternative D 

1 – Human Health and Worker 

Safety 

1a Exposure to Herbicides 

No significant impact 

. 

No plausible harm from 

herbicide exposure to workers 

or public. 

Same as 

Alternative B 

Same as 

Alternative B 

1b – Drinking Water No significant impact 

. 

Drinking water would not be 

adversely affected. 

Same as 

Alternative B 

Same as 

Alternative B 

2 - Treatment Strategy and 

Effectiveness 

2a Herbicides Available for 

Use 

3 10 10 10 

2a Proportion of Infested 

Acres that May be Treated 

Using Herbicide 

2 % 100% 30% 100% 

2a Acres of Invasives in 2012 

(assuming unlimited funding) 

3,503 51 459 51 

2b Long Term Strategy, 

Reduce Reliance on 

Herbicides Over Time 

Long term strategy is 

not directly 

addressed in NEPA 

document 

Active and passive restoration 

would be part of every 

prescription. Each year of 

treatment, as target population 

size is reduced non-herbicide 

methods would likely become 

more practical and effective. 

Same as 

Alternative B. 

Same as 

Alternative B 

2c Treatment Priority Treatment priorities 

are not directly 

addressed in NEPA 

document 

Each treatment area has been 

given a priority, as shown in 

Chapter 2.5 

Fewer treatment 

areas likely treated 

with equal budget. 

 More treatment 

areas likely 

treated with 

equal budget. 

Issue Group 3 – Social and 

Economic 

3a – Total Cost for the Most 

Ambitious Program over 5 

years 

$664,000 $2,183,000 $3,496,000 $2,070,000 

Issue Group 3 – Social and 

Economic 

3a – Average Annual Cost for 

the Most Ambitious Program 

over 5 years 

$149,000 $490,000 $785,000 $465,000 

Issue Group 3 – Social and 

Economic 

3a – Average Cost Per Acre 

over a 5 year period 

$988 $570 $1025 $540 

Issue Group 3 – Social and 

Economic 

3b – Jobs Associated with 

Treatments (per 6 month year) 

8 18 54 13 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

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Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative C Alternative D 

3c – Effects on Scenic, 

Recreation and Wilderness 

Values 

No significant impact 

. 

Containing, controlling and/or 

eradicating invasive plants 

would indirectly improve 

scenic, recreation and 

wilderness values. Project 

Design Features limit potential 

short term adverse impacts. 

 Less effectiveness 

in Riparian 

Reserve may result 

in increased risk to 

scenic, recreation 

and wilderness 

values in the long 

run. 

Same as 

Alternative B. 

3d – Special Forest Products 

and Gatherers 

No significant impact 

. 

Conflicts between treatments 

and gathering areas would be 

minimized. Inadvertent 

exposures would be minimized 

through newspaper or 

individual notification, fliers, 

and posting signs. No 

exposure exceeding 

thresholds of concern for 

people are plausible. 

Same as 

Alternative B. 

Same as 

Alternative B. 

3e – Effects on Tribes, Civil 

Rights, Environmental Justice 

No significant impact 

. 

No disproportionate effects on 

any group of people, ongoing 

government-to-government 

consultation with tribes. 

Same as 

Alternative B. 

 Same as 

Alternative B. 

Issue Group 4 – Non-Target 

Plants And Wildlife 

4a – Estimated Proportion of 

Project Where Broadcast 

Application is Approved 

0% 34% 0% 84% 

·Number of Plant Species of 

Local Interest Potentially 

Affected by Broadcast 

Herbicide Application Methods 

0 0 0 0 

Issue Group 4 – Non-Target 

Plants And Wildlife 

4a – Potential Impact to 

botanical species of interest 

No significant impact No adverse effects on 

botanical species of local 

concern. 

Same as 

Alternative B 

Same as 

Alternative B 

Issue Group 4 – Non-Target 

Plants And Wildlife 

4b – Terrestrial Wildlife 

No significant impact 

. 

Not likely to adverse affect or 

impact wildlife species of local 

concern, including mollusks 

and salamanders. 

Same as 

Alternative B 

Same as 

Alternative B 

Issue Group 5 – Effects on 

Soils, Water and Aquatic 

Organisms 

5a – Effects on Soils 

No significant impact 

. 

Project Design Features avoid 

herbicide concentrations of 

concern in soils; limitations on 

herbicide selection depending 

on site-specific soil conditions. 

Same as 

Alternative B, less 

use of herbicide. 

Same as 

Alternative B, 

more potential 

broadcast of 

herbicide. 

Issue Group 5 – Effects on 

Soils, Water and Aquatic 

Organisms 

5b – Character of Herbicide 

Use Within Aquatic Influence 

Zones 

Restricted to hand 

applications of 

aquatic glyphosate 

approved under 

current EA. 

Risks from herbicide use 

within Aquatic Influence Zones 

and along roads having high 

risk of herbicide delivery are 

avoided or minimized through 

PDFs and buffers (see 

Chapter 2.5). 

Same as 

Alternative A. 

Fewer 

restrictions 

would apply to 

dry intermittent 

streams and 

roads with high 

risk of herbicide 

delivery to 

surface waters 

through ditch 

networks (see 

Chapter 2.7). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

65

Issue No Action 

(Alternative A) 

Proposed Action 

(Alternative B) 

Alternative C Alternative D 

5b – Estimated Acres 

Herbicide Use Within Aquatic 

Influence Zones 

Fewer than 30 acres Approximately 620 acres Same as 

Alternative A. 

Same as 

Alternative B. 

5b – Estimated Proportion of 

Project Where Broadcast 

Application is Approved 

0% 34% 0% 84% 

5b – Estimated acreage where 

herbicide treatment may occur 

on roadside treatment areas 

with high potential to deliver 

herbicides 

Fewer than 40 acres 1,420 0 1,420 

5b – Estimated proportion of 

project where broadcast of 

herbicide may occur on 

roadside treatment areas with 

high potential to deliver 

herbicides 

0 0 0 37% 

5c - Potential for fish to be 

exposed to harmful 

concentrations of herbicide 

Very Low Low Very Low Moderate to high
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

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Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

67

Chapter 3. Affected Environment and Environmental 

Consequences 

3.1 Introduction 

3.1.1 The Project Area 

The Olympic National Forest is comprised of 63 6th-field watersheds (a list of watersheds is displayed in the 

soil and water section later in this chapter) that cover over 1.8 million acres. Approximately one-third of the 

acreage within these watersheds lies on National Forest system lands. The Forest surrounds the Olympic 

National Park, and many of these watersheds originate there. 

The Forest has a comparatively large number of streams and high rainfall. Approximately one-third of the 

project area lies within streamside Riparian Reserves (a land allocation from the Northwest Forest Plan – 

USDA/USDI 1994a). 

3.1.2 Treatment Areas 

Invasive plant sites have been inventoried and grouped into 99 treatment areas (see Appendix A). Of these, 

16 treatment areas are in special land allocations: two treatment areas are within the Buckhorn Wilderness 

and 14 treatment areas are in designated botanical and/or Research Natural Areas (reference Forest Plan). 

Each treatment area contains a variety of site conditions that are more or less susceptible to the effects of 

invasive plants and/or their treatment. 

Approximately 2,180 miles of roads cross the Forest. About 84 percent (3,270 acres) of the infestations are 

found within roadside treatment areas. Roadside type treatment areas include disturbed skid trails and 

landings within adjacent managed timber stands. Approximately 43 percent of the roadside treatment acres 

(1,420 acres) are estimated to occur along roads identified as high potential for herbicide delivery (Appendix 

D shows roadside treatment areas in relation to fish bearing streams). 

3.1.3 Invasive Plants and Their Impact on Special Places 

Approximately 30 invasive plants are inventoried on the Olympic National Forest. Infestations range in size 

from less than 1 to more than 200 acres within any single treatment area. Table 22 shows how treatment 

areas are classified. 

Most invasive plants are predominantly located in disturbed areas: along road systems, in timber sale units 

(e.g., Matwat Timber Sale), at the Lake Quinault summer residences, in administrative sites (e.g., Dennie Ahl 

seed orchard, Snider Work Center, Hood Canal Ranger Station), in managed timber stands, and in areas 

utilized for recreation such as campgrounds, dispersed recreation, etc. (Quinault Loop Trail, Slab camp 

quarry, Seal Rock Campground, etc,). While most of the infestations are in disturbed areas (many invasive 

species do not grow well under a forest canopy), invasive species such as herb Robert, ivy and English holly 

can thrive in forested settings. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

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Table 22-Estimated Target Species Acres by Treatment Area Description 

Treatment Area 

Description 

Estimated 

Target Species Acres 

Roadside 3,270

Administrative Sites, Campgrounds, Summer Homes 130

Meadows, Wetlands and Floodplains 80

Trails 135

Conifer Forest 215

Total Acres 3,830

Roads are conduits for the spread of invasive plants, providing for their transport and dispersal (e.g., seeds 

and vegetative reproductive parts attached to vehicles) and providing disturbed ground for easy colonization 

and establishment. Olympic National Forest System roads also serve to introduce invasive species onto the 

Olympic National Park, where native plant communities and ecological integrity are highly valued. 

Roads serve to introduce and establish invasives in areas where they were previously unknown. For 

example, gorse has been found (and is being treated) on Quinault Indian Nation Lands on Highway 101. 

These control measures are especially important because gorse has not yet spread to Olympic National Forest 

System lands. 

Timber harvest, road building, and other ground-disturbing activities occur on National Forest System lands 

and contribute to the spread of invasive plants, as the habitat conditions that facilitate colonization are 

created. Recreation activities (e.g. pack stock) can spread invasives along trail systems. 

In addition, invasive plants are spread through the movement of water in creeks and across wetlands. Floods 

move invasive plant seed and materials into adjacent riparian areas. 

Intentional and accidental introductions have occurred for centuries, but major introductions have occurred 

most rapidly over the past century. Introductions of invasive plants for forage (i.e. contaminated livestock 

feed), ornamental landscaping, road and dune stabilization, and erosion control have occurred throughout 

National Forest and adjacent lands in the Pacific Northwest. Most invasive plants have been introduced for 

horticultural use by nurseries, botanical gardens, and individuals (ibid.). 

Commercial landscape nurseries in Washington sell, or once sold, exotic species for domestic landscaping 

that later were found to be invasive (e.g. butterfly bush, pampas grass, purple loosestrife, English ivy). These 

have been shown to spread to federal lands (ibid.). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

69

On the Olympic National Forest, invasive plants have displaced native vegetation and disrupted the 

functioning of plant communities in many important areas, including (but not limited to): 

• Meadow systems: Mint Meadow, Schmidt Knob, Savannah Restoration Site, Matheny Prairie; 

• Buckhorn, Colonel Bob, Mt. Skokomish and the Brothers Wilderness Areas; 

• Research Natural Areas: Wet Weather Creek, and Quinault Research Natural Area; 

• Botanical Areas: Three Peaks, Matheny Ponds, Bill’s Bog, North Fork Matheny Ponds, Matheny 

Ridge Alaska Yellow Cedar, Cranberry (sphagnum) Bog, Buckhorn, Three O’Clock Ridge, South 

Fork Calawah, Matheny Prairie, and Tyler Peak Botanical Area. 

Without treatment, invasive plants will further displace native plant communities, and spread to new areas. 

In recent years, acres of invasives have increased at an average rate of 8 to12 percent each year; prevention 

practices were estimated to reduce that number by half (R6 2005 FEIS Chapter 4.2, page 4-24). Early 

detection of populations of invasive species is critical before they spread and become larger. As populations 

increase in number and size, they become more difficult and costly to control. 

Appendix A-Treatment Area Information displays the invasive plant species that have been detected on the 

Olympic National Forest. The treatment acreage estimates in Appendix A have accounted for expected 

spread of invasive plants between the time of inventory and the first year of anticipated treatment under this 

EIS (2008). 

3.1.4 Life of the Project and “Most Ambitious Treatment” Analysis Scenarios 

This project 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, without necessitating further analysis: treated 

infestations will be reduced in size, untreated infestations will continue 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. The effects analysis considers a range of treatments applied to a range of site conditions to 

accommodate the uncertainty associated with the project implementation schedule. 

Many variables affect invasive plant treatment prescriptions, including: land management objectives and 

standards related to a particular site; treatment area priority and treatment strategy (see Chapter 2 for more 

discussion about treatment areas, priorities and strategy); and landscape scale goals. The relative proportion 

and timing of integrated treatments including herbicides and other methods; the effectiveness of invasive 

plant management on neighboring lands; and available funding also affect the treatment that would be 

implemented. 

Tables 23, 24 and 25 display the most ambitious annual treatment scenarios by alternative that form the basis 

for the analysis of economic efficiency, cost-effectiveness and environmental consequences and alternative 

comparisons. They are not intended to be binding treatment prescriptions.

Actual annual treatments will adapt to information gathered through inventory and monitoring and make the 

most of available funding. Newly discovered infestations could be prioritized over existing sites. 

The most ambitious treatment scenario assumes a life of approximately 5 years. It would require a five to 

tenfold increase in funding compared to previous years (see the financial analysis later in Chapter 3.7). This 

funding level is not likely to be available; however, the most ambitious treatment scenario provides a 

consistent assumption for analysis purposes. The assumption of full funding allows the greatest and most 

intense impacts possible to be evaluated; however, both the positive and negative impacts of the project are 

likely to be less than predicted for the most ambitious conceivable treatment. However, analysis of the most 

ambitious conceivable treatment scenario clearly highlights the differences between the costs, effectiveness, 

and adverse effects from different treatment approaches. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

70

The scenarios show how reliance on herbicides would be decreased over time. Non-herbicide methods are 

expected to become more effective over time, as populations have been substantially reduced. While not 

depicted in the charts, manual and mechanical treatments may occur instead, before or during herbicide 

treatment according to the Common Control Measures (see Chapter 2.5 and Appendix B) adapted to site 

conditions and experience. 

These scenarios also assume that restoration is implemented as planned in the action alternatives. About 65 

percent of the treated acres are assumed to require active restoration activity (mulching, seeding, planting) to 

reach desired conditions. Some restoration activities may actually be implemented before or during 

herbicide or non-herbicide treatments. 

These scenarios are intended to portray the pattern of treatment. It illustrates concepts about restoration as 

part of the overall prescription, and demonstrates how reliance on herbicide methods would be decreased 

through the life of the project. The scenarios also emphasize that follow up is an absolute necessity to meet 

containment, control and/or eradication strategies. 

These scenarios are not sensitive to the role of treatment priority and/or strategy (see Chapter 2.5 for more 

information on these variables, treatment strategy is factored into the Economic Analysis displayed in 

Chapter 3.7). The scenarios show all acreage treated in Year 1. In reality, the highest priority areas would 

most likely be treated first; lower priority infestations would continue to spread, increasing acreage where 

treatment may be needed. 

No Action (Alternative A) Most Ambitious Treatment Scenario 

As described in Chapter 2, No Action includes treatments that would occur under existing NEPA decisions. 

An EA completed in 1998 allowed for 672 acres of manual and mechanical treatment, of which 86 acres also 

included use of herbicides. 

Between the years 2000-2001, approximately 2 acres of treatment with herbicide occurred per year, along 

with about 34 acres of manual/mechanical treatment.20 The majority of the treatments involved repeated 

hand pulling of small roadside infestations of high priority species, such as spotted and meadow knapweed. 

Treatments were generally effective. However, some of the manual treatments used for species like scotch 

broom and tansy ragwort needed repeat treatments annually, and were not very cost effective. 

In the year 2002, the budget increased four-fold, to approximately $80,000, due to Forest Service Title II 

funding to counties for cooperative efforts on invasive plant management of the National Forest and adjacent 

lands. From the years 2002 through 2005, the four counties on the Olympic Peninsula participated in 

invasive plant treatments on National Forest system land averaging about 130 acres/year of manual 

treatment. In 2005, the Forest accomplished herbicide treatments for two Japanese knotweed infestations (2 

acres) according to the 1998 EA. 

For the purposes of analysis, No Action assumes that all 672 acres are treated in year 1 (86 acres with 

spot/hand herbicide applications followed by manual and mechanical treatment plus 586 acres of manual and 

mechanical treatment). Each year, 25 percent fewer acres are assumed to need re-treatment based on the 

relative estimated effectiveness of each year’s work. No specific restoration plan was included, thus no 

applicable estimate could be made for acres restored. The assumptions built into No Action for the most 

ambitious treatment scenario would require a two-fold increase in funding (compared to current estimates), 

thus actual effectiveness may be less than predicted. 

 

20 Low acreages overall resulted from small budgets in these years (about $20,000 per year) and concerns about the 

adequacy of NEPA documents supporting herbicide use. Budgets have increased and are expected to continue to grow 

once this EIS is completed and action is approved. No Action is assumed to have a low effectiveness ranking due to its 

limited use of herbicide (see Botany and Treatment Effectiveness section below). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

71

Table 23-Most Ambitious Annual Treatment Scenario – Alternative A 

Treatment Scenario Year 1 Year 2 Year 3 Year 4 Year 5 

Total Acres Treated 672 504 378 284 213

Acres Treated with Herbicide 86 65 49 37 28

Acres Treatment With Non-Herbicide 586 439 329 247 185

Acres Active Restoration (mulch, seed, 

plant) 

NA NA NA NA NA

Alternative B Most Ambitious Treatment Scenario 

Under Alternatives B all 3,830 estimated infested acres would be treated in Year 1, which would be assumed 

to reduce infestation size by 80 percent (see Botany and Effectiveness section later in this Chapter). Each 

year, 80 percent fewer acres would need to be re-treated, until Year 5, when desired conditions for all known 

infestations would be assumed to be achieved. Alternative B has an effectiveness ranking of 80 percent 

because it allows a relatively wide range of treatment options available at a given site. 

For the purposes of analysis, under Alternative B, the project would be concluded within 5 years assuming 

the most ambitious treatment scenario. In reality, some infestations may still need to be treated after five 

years if there is a persistent seed bank. As invasive plant populations get significantly smaller, non-herbicide 

methods would become more cost-effective. Thus, the proportion of non-herbicide compared to herbicide 

methods would increase over time. The most ambitious treatment scenario would require a five-fold

increase in funding over a five-year period. 

Table 24-Most Ambitious Annual Treatment Scenario – Alternative B 

Treatment Scenario Year 1 Year 2 Year 3 Year 4 Year 5 

Total Acres Treated 3,830 765 148 29 0

Acres Treated with Herbicide 3,687 544 62 0 0

Acres Treated With Non-Herbicide 143 221 86 29 0

Percentage of treatments that are nonherbicide 4% 29% 58% 100% NA

Acres Restored Passive or Active (mulch, 

seed, plant) 

 0 958 958 958 958 

Alternative C Most Ambitious Treatment Scenario 

Under Alternative C, sites having a treatment strategy of “eradicate” would not be treated.21 This would 

leave about 3,410 acres to be treated in year 1. The analysis assumes that treatments using herbicides would 

reduce infestation size by 80 percent annually, similar to Alternatives B and D. Treatments in areas having 

an herbicide use restriction would reduce infestation size by 25 percent annually, similar to Alternative A. 

 

21 This assumption was included to emphasize how eradication of aggressive target species may require herbicides to 

accomplish, and the restrictions on herbicide use inherent to Alternative C would not allow the Forest Service to fully 

accomplish this strategy. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

72

Table 25-Most Ambitious Annual Treatment Scenario - Alternative C 

Treatment Scenario Year 1 Year 2 Year 3 Year 4 Year 5 

Total Acres Treated 3,410 1979 1133 657 381

Acres Treated with Herbicide 1,035 600 333 193 112

Acres Treated With Non-Herbicide 2,375 1379 800 464 269

Percentage of treatments that are nonherbicide 70% 70% 70% 70% 70%

Acres Restored Passive or Active (mulch, 

seed, plant) 

 0 853 853 853 853

Alternative D Most Ambitious Treatment Scenario 

The most ambitious treatment scenario associated with Alternative D is exactly the same as the scenario for 

Alternative B. The differences between these alternatives do not affect the most ambitious scenario or 

balance between herbicide and non-herbicide treatments through the 5 years that were modeled. 

Most Ambitious Treatment Scenario Alternative Comparison 

Table 26 displays the acreage that would be treated using herbicide, manual and mechanical methods each 

year under the most ambitious conceivable program. These scenarios would result in the greatest predicted 

level of treatment effectiveness and the maximum potential for adverse effects of treatment. 

The most ambitious conceivable treatment scenario assumes treatment begins in 2007.22 Due to delays in 

completing Endangered Species Act Consultation for federally listed aquatic species, the project would not 

begin until 2008. Throughout this FEIS, when addressing the life of the project, please add one year to the 

estimates to account for the delay. 

Table 26-Most Ambitious Annual Treatment Scenario - Alternative Comparison 

Treatment Acres 

(Most Ambitious Conceivable Treatment Scenario) 

Year 

Alternative A Alternatives B and D Alternative C 

2007 672 3,830 3,410

2008 504 765 765 

2009 378 148 148 

2010 284 29 29 

2011 213 0 0 

Relationship of Analysis Scenarios to Early Detection-Rapid Response 

All action alternatives include the ability for Forest Service land managers to approve treatments on currently 

unknown invasive plant sites assuming Project Design Features would be followed. The premise of early 

detection-rapid response analysis approach is that treatments of new infestations according to methods and 

design features defined in this project-level EIS will have similar effects to treatments of existing sites. 

Assuming the most ambitious conceivable treatment scenario under each alternative, early detection/rapid 

response would be expected to be a very small part of the program, because so much of the current inventory 

would be treated in year 1. 

 

22 This analysis assumed implementation would begin in 2007. Due to delays associated with consultation under the 

Endangered Species Act, implementation is now scheduled to begin in 2008. All dates associated with the life of the 

project would be advanced by one year. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

73

If the most ambitious treatment scenarios were not implemented, over time, early detection-rapid response 

would tend to become a larger part of the program. The acreage treated in any one year would not likely 

exceed the most ambitious treatment scenario analyzed because the most ambitious scenario is already five to 

ten times the current budget, which makes a more ambitious program extremely unlikely. 

Even if the acreage treated in one year were to exceed the most ambitious treatment scenario, the effects 

analysis would still be valid, because the Project Design Features (PDFs) and Implementation Planning 

process described in Chapter 2 ensure that the plausible adverse effects of treating currently unknown 

infestations would be within the scope of those disclosed here. Section 3.1.5 provides further reasoning 

about how PDFs minimize or eliminate herbicide exposure scenarios of concern to people and the 

environment. 

3.1.5 Herbicide Risk Assessments and Layers of Caution 

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. Formal 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. 

They considered worst-case scenarios including accidental exposures and application at maximum label 

rates. The risk assessments meet the requirements of the Pesticide Use Handbook, FSH 2109.14 Chapter 20. 

The R6 2005 FEIS added a margin of safety to the SERA Risk Assessments by making the thresholds of 

concern substantially lower than normally used for such assessments (see R6 2005 FEIS Appendix P for 

details). Although the risk assessments have limitations (see R6 2005 FEIS pages 3-95 through 3-97), they 

represent the best science available. Table 27 displays the risk assessments that may be accessed via the 

Pacific Northwest Region website at http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/HerbicidesAnalyzed-InvPlant-EIS.htm. 

The herbicides on the list are those listed in Standard 16 that was approved in the R6 2005 ROD. They were 

selected because they are the lowest risk herbicides that are effective against the full range of target species 

known within Region 6 (ROD page 23). 

Table 27-Herbicide Risk Assessments 

Herbicide Date Final Risk Assessment Reference 

Chlorsulfuron November 21, 2004 SERA TR 04-43-18-01c 

Clopyralid December 5, 2004 SERA TR 04 43-17-03c 

Glyphosate March 1, 2003 SERA TR 02-43-09-04a 

Imazapic December 23, 2004 SERA TR 04-43-17-04b 

Imazapyr December 18, 2004 SERA TR 04-43-17-05b 

Metsulfuron methyl December 9, 2004 SERA TR 03-43-17-01b 

Picloram June 30, 2003 SERA TR 03-43-16-01b 

Sethoxydim October 31, 2001 SERA TR 01-43-01-01c 

Sulfometuron methyl December 14, 2004 SERA TR 03-43-17-02c 

Triclopyr March 15, 2003 SERA TR 02-43-13-03b 

NPE Surfactant May 2003 USDA Forest Service, R-5 (Bakke 2003) 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

74

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). However, EPA has not classified any of the 

inerts as toxic. Some of the inerts are approved food additives (for instance, glacial acetic acid, 

monoethanolamine and isopropyl alcohol).

Additives, Impurities and Inert Ingredients 

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. Adjuvants are compounds added to the formulation to improve its performance. 

Adjuvants 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, for example. 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 (see Chapter 3.1 for more information on the risk assessment process and 

terminology). 

Of the adjuvants approved for us on National Forests in Washington, two carry the Danger signal word 

(EntryTM II and LI-700®), due to the potential effects to the eyes (severely irritating or corrosive). None of 

these adjuvants carry the poison symbol. 

All of the adjuvants discussed here are no more than slightly toxic when ingested, inhaled, or absorbed 

through the skin (Acute Toxicity Categories III or IV) and none of these adjuvants contain ingredients found 

on U.S. EPA’s inerts list I or II (known to be hazardous). The primary known hazard to these surfactants is 

skin and eye irritation. Health risks are minimized by following industrial hygiene practices. 

At certain rates, NPE and POEA surfactants have been shown to have adverse effects on human health and 

aquatic ecosystem elements. Therefore, use of POEA surfactants is not proposed where delivery to water is 

possible, and rates of NPE are restricted, especially in areas of special forest products. 

Available information for inerts contained in the proposed herbicides is as follows: 

Chlorsulfuron – The identity of inerts used in chlorsulfuron are confidential, but SERA reviewed them for 

preparation of the risk assessment (SERA, 2003 Chlorsulfuron). EPA has not classified any of the inerts as 

toxic. These inert ingredients do not affect the assessment of risk. 

Clopyralid – Identified inerts include monoethanolamine and isopropyl alcohol, both approved food 

additives. These inert ingredients do not impact the assessment of risk 

Glyphosate – There are at least 35 glyphosate formulations that are registered for forestry applications 

(SERA, 2003 Glyphosate) with a variety of inert ingredients. SERA obtained clearance to access 

confidential business information (i.e. the identity of proprietary ingredients) and used this information in the 

preparation of the risk assessment. Surfactants (discussed below) were the only additives identified that 

impact risk (SERA, 2003 Glyphosate). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

75

Imazapic - The identity of inerts used in imazapic formulations are confidential, but SERA reviewed them 

for preparation of the risk assessment (SERA, 2003 Imazapic). None of the inerts are classified by EPA as 

toxic. 

Imazapyr – The NCAP website (http://www.pesticide.org/FOIA/picloram.html) identifies only glacial acetic 

acid as an inert ingredient. Isopropanolamine is also present, and it is classified as a List 3 inert. 

Metsulfuron methyl - The identity of inerts used in metulfuron methyl formulations are confidential, but 

SERA reviewed them for preparation of the risk assessment (SERA, 2003 Metsulfuron methyl). None of the 

inerts are classified by EPA as toxic. 

Picloram - Tordon K and Tordon 22K contain the following inerts: potassium hydroxide, ethoxylated cetyl 

ether, alkyl phenol glycol ether, and emulsified silicone oil (NCAP website; 

http://www.pesticide.org/FOIA/picloram.html). Potassium hydroxide is an approved food additive. The 

other compounds are all on EPA’s List 4B, inerts of minimal concern. They may also contain the surfactant 

polyglycol 26-2, which is on EPA’s List 3: Inerts of Unknown Toxicity, discussed in the following section. 

The toxicity data on the formulations encompasses toxic risk from the inerts. Inerts in picloram formulations 

do not appear to pose a unique toxic risk (SERA, 2003 Picloram). 

Sethoxydim - The formulation Poast contains 74 percent petroleum solvent that includes naphthalene. The 

EPA has placed this naphthalene on List 2 (“agents that are potentially toxic and a high priority for testing”). 

Petroleum solvents and naphthalene depress the central nervous system and cause other signs of 

neurotoxicity (SERA, 2001). 

Poast has also been reported to cause skin and eye irritation. There is no information suggesting that the 

petroleum solvent has a substantial impact on the toxicity of sethoxydim to experimental animals, with the 

important and notable exception of aquatic animals (SERA, 2001). Poast is much more toxic to aquatic 

species than sethoxydim. 

Sulfometuron methyl - The identity of inerts used in Oust are confidential, but SERA reviewed them for 

preparation of the risk assessment (SERA, 2003 Imazapic). None of the inerts are classified by EPA as toxic. 

Based on comparison of the toxicities of the active ingredient and the formulation, there is no reason to 

suspect that Oust contains other ingredients that substantially affect the potential risk to the environment. 

Triclopyr - Formulations contain ethanol (Garlon 3A) or kerosene (Garlon 4), which are known to be 

neurotoxic. However, the toxicity of these compounds is less than that of triclopyr, so the amount of ethanol 

and kerosene in these formulations is not toxicologically significant (SERA, 2003 Triclopyr). The amount of 

inert ingredients in the formulations is generally not known, so exposure and dose estimates cannot be 

calculated. 

Surfactants 

The following types of surfactants have been reviewed in risk assessments and may be used to help 

herbicides adhere to target plants (Bakke 2003). Trade name examples are also provided. Surfactants help 

reduce drift and abate risk of off site movement of herbicides. 

The effects of using these ingredients, along with other inerts and metabolites, have been disclosed in the R6 

2005 FEIS (Chapters 4.4, 4.5, 4.7 along with Appendices P and Q; and the Biological Assessment prepared 

for ESA consultation). 

Limitations are proposed for use of some surfactants associated with potential adverse effects on human 

health, wildlife and aquatic ecosystem elements (see discussions in Chapter 3). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

76

Ethoxylated fatty amines (Cationic)

EntryTM II (Monsanto Company) 

POEA (Polyethoxylated Tallow Amine - Roundup® (non-aquatic glyphosate) has 15% POEA. The 

POEA is associated with adverse effects on aquatic ecosystems. These risks are abated by project design 

features. 

Alkylphenol and Alcohol ethoxylate-based surfactants (non-ionic) 

R-11® Spreader Activator (Wilbur-Ellis Company) 

Activator 90 (Loveland Industries) 

X-77® (Loveland Industries) 

Latron AG-98TM (N) (Dow AgroSciences LLC) 

Cide-kick®, Cide-kick® IITM (Brewer International) 

These surfactants usually include an alcohol as a solvent (isopropanol (X-77®, AG-98TM), butanol (R11®, AG-98TM (N)), glycol (AG-98TM (N), Activator 90)), a silicone defoamer (polydimethylsiloxane) 

and water. 

 

Activator N.F. (Loveland Industries) 

Nonylphenol Polyethoxylate (NPE) is a common non-ionic surfactant associated with some risks to 

human health and the environment. These risks are abated by project design features. 

Silicone-Based Surfactants

Also known as organosilicones, these are increasing in popularity because of their superior spreading ability. 

This class contains a polysiloxane chain. Some of these are a blend of non-ionic surfactants (NIS) and 

silicone while others are entirely silicone. The combination of NIS and a silicone surfactant can increase 

absorption into a plant so that the time between application and rainfall can be shortened. 

Sylgard® 309 (Wilbur-Ellis Company) –silicones 

Freeway® (Loveland Industries) –silicone blend 

Dyne-Amic® (Helena Chemical Company) - silicone blend 

Silwet L-77® (Loveland and Helena) - silicones 

Blends normally include an alcohol ethoxylate, a defoamer, and propylene glycol. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

77

Oils

Surfactants that are primarily oil-based have been gaining in popularity especially for the control of grassy 

weeds. Oil additives function to increase herbicide absorption through plant tissues and increase spray 

retention. They are especially useful in applications of herbicides to woody brush or tree stems to allow for 

penetration through the bark. Oil adjuvants are made up of either petroleum, vegetable, or methylated 

vegetable or seed oils plus an emulsifier for dispersion in water. 

Vegetable Oils – The methylated seed oils are formed from common seed oils, such as canola, soybean, or 

cotton. They act to increase penetration of the herbicide. These are comparable in performance to crop oil 

concentrates. In addition, silicone-seed oil blends are also available that take advantage of the spreading 

ability of the silicones and the penetrating characteristics of the seed oils. 

The U.S. Food and Drug Administration (FDA) consider methyl and ethyl esters of fatty acids produced from 

edible fats and oils to be food grade additives (CFR 172.225). Because of the lack of exact ingredient 

statements on these surfactants, it is not always clear whether the oils that are used in them meet the U.S. 

FDA standard. 

MSO® Concentrate Methylated Seed Oil (Loveland Industries) 

Hasten® (Wilbur-Ellis Company) 

The surfactant in PathfinderTM II (a triclopyr formulation) 

Improved JLB Oil Plus (Brewer International) 

Cide-Kick and Cide-Kick II (Brewer International) 

Blends of vegetable oils and silicone-based surfactants

Syl-tacTM (Wilbur-Ellis Company) 

PhaseTM (Loveland Industries) 

Crop Oils and Crop Oil Concentrates 

These are normally derivatives of paraffin-based petroleum oil. Crop oils are generally 95-98 percent oil 

with 1-2 percent surfactant/emulsifier. Crop oils also promote the penetration of a pesticide spray. 

Traditional crop oils are more commonly used in insect and disease control than with herbicides. Crop oil 

concentrates are a blend of crop oils (80-85 percent) and a nonionic surfactant (15-20 percent). The purpose 

of the nonionic surfactant in this mixture is to emulsify the oil in the spray solution and lower the surface 

tension of the overall spray solution. Kerosene is found in the triclopyr formulation Garlon IV. This 

formulation would not be broadcast nor used within 150 feet of surface water bodies or wetlands. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

78

Adjuvants Approved For Riparian Areas 

Adjuvants that are approved for used in the immediate Aquatic Influence Zone in Washington State (see table 

28 below) meet the following criteria: 

• The product must fulfill all requirements for registration of a food/feed use spray adjuvant in 

Washington 

• The spray adjuvant must be either slightly toxic or practically non-toxic to freshwater fish (such as 

rainbow trout, coho salmon or other cold water species) 

• The spray adjuvant must be moderately toxic, slightly toxic or practically non-toxic to aquatic 

invertebrates (such as Daphnia spp.) 

• The spray adjuvant formulation must contain less than 10% alkylphenol ethoxylates (including 

phosphate esters) 

Table 28-Products Meeting Standard 18 That Are Approved by WSDA For Use Near Surface Waters 

Product Name Registrant Principal Functioning Agent Risk/Hazard 

Assessment 

Agri-Dex Helena Chemical 

Company 

Petroleum Oil, polyoxyethylene sorbitant fatty 

acid ester, sorbitant fatty acid ester 

SERA 1997, Bakke 

2003 

Competitor Wilbur-Ellis Company Modified vegetable (seed) oil, polyethylene 

glycol fatty acid ester, polyoxyethylene sorbitant 

fatty acid ester 

SERA 1997, Bakke 

2003 

InterLock Agriliance Modified vegetable (seed) oil, polyoxyethylene 

sorbitant fatty acid ester, vegetable (seed) oil 

SERA 1997, Bakke 

2003 

LI 700 Loveland 

Industries/Loveland 

Products 

Phosphatidylcholine, propanoic (propionic) acid, 

alkylphenol ethoxylate 

SERA 1997, Bakke 

2003 

Liberate Loveland 

Industries/Loveland 

Products 

Phosphatidylcholine, alcohol ethoxylate, 

modified vegetable (seed) oil 

SERA 1997, Bakke 

2003 

Herbicide Toxicology Terminology 

The following terminology is used throughout this chapter to describe relative toxicity of herbicides 

proposed for use in the alternatives. 

Exposure Scenario: The mechanism by which an organism (person, animal, fish) may be exposed to 

herbicides active ingredients or additives. The application rate and method influences the amount of 

herbicide to which an organism may be exposed. 

Threshold of Concern: A level of exposure below which there is a low potential for adverse effects to an 

organism. Effects on wildlife and other organisms are considered insignificant and discountable when 

herbicide exposure is below the threshold of concern. 

Hazard Quotient (HQ): A "toxicity threshold" was established for each herbicide (and NPE) to indicate the 

point below which adverse effects would not be expected for a variety of organisms (e.g. people, wildlife, 

fish). The predicted level of exposure from herbicide use is compared to the toxicity threshold and expressed 

in terms of a "hazard quotient (HQ)". The HQ is the result (quotient) of the exposure estimate divided by the 

toxicity threshold. Toxicity thresholds are based on extrapolated laboratory results and accepted scientific 

protocols. In Region 6, the toxicity thresholds were lowered to account for risk to federally listed species, 

following protocol used by EPA (EPA 2004, p. 46). An HQ less than or equal to 1 indicates an extremely low 

level of risk. An HQ above 1 does not necessarily indicate a level where adverse effects are likely, however, 

the probability of harmful effects increases with HQ. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

79

Layers of Caution Integrated Into Herbicide Use 

Figure 2 displays the layers of caution that are integrated into herbicide use in the Pacific Northwest Region 

(Region Six). First, label requirements, federal and state laws, and the EPA approval process provide an 

initial level of caution regarding chemical use. Next, the SERA Risk Assessments disclosed hazards 

associated with worst-case herbicide conditions (maximum exposure allowed by the label). 

The R6 2005 FEIS included an additional margin of safety by reducing the level of herbicide exposure 

considered to be of concern to fish and wildlife (see Appendix P – Summary of Herbicide Effects to Wildlife 

for further explanation). Herbicides such as 2,4-D and Dicamba were not approved for use in the R6 2005 

ROD (page 23) and restrictions on application method for many herbicides were included in Standard 16 

(ibid.). 

At the project scale, additional layers of caution would be integrated into herbicide use in both action 

alternatives: 

1. Treatment methods would be limited to those necessary to eradicate, control or contain invasive 

plants on the Olympic National Forest; no aerial treatment is proposed and broadcast application 

would be limited to certain areas or prohibited altogether. 

2. Project Design Features (PDFs) under the Proposed Action and Alternative C23 would ensure 

proposed herbicide exposures do not exceed thresholds of concern for people and botanical, 

wildlife, and aquatic Species of Local Interest (see Effects Thresholds in table 29 below). This is 

true for known infestations as well as those found in the future, because the PDFs serve to limit 

the rate, type and method of herbicide application sufficiently to eliminate exposure scenarios 

that would cause concern, based on the site conditions at the time of treatment. Further analysis 

would be required if a new infestation would not be treated effectively according to the PDFs 

(for instance, the herbicides available for use near streams were not effective for a new 

infestation). 

3. The implementation planning and monitoring processes described in Chapter 2 ensure that 

effective treatments are completed according to PDFs and undesired effects are indeed 

minimized. 

Table 29 displays the relative properties, risks and uses of each herbicide and indicates some of the PDFs that 

address toxicological concerns by limiting application rate and herbicide exposure. Herbicide properties and 

risks adapted from R6 2005 FEIS (pg. 3-91), 

 

23 Alternative D incurs some risk of exceeding thresholds of concern. . 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

80

Figure 2-Region Six Layers of Caution in Herbicide Use 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

81

Table 29-Herbicides Ingredients, Properties, General Uses and Design Features for Herbicides 

Active Ingredient 

Selected Herbicide 

Brand Names and 

Mode of Action 

Properties General Uses/ 

Known to be 

Effective on: 

Risks Design Features to Minimize or 

Eliminate Risks 

Chlorsulfuron 

(Telar, Glean, 

Corsair) 

SulfonylureaInterferes with 

enzyme acetolactate 

synthase with rapid 

cessation of cell 

division and plant 

growth in shoots and 

roots. 

Glean -Selective 

pre-emergent or 

early post-emergent 

Telar – Selective 

pre- and postemergent. 

Both are for many 

annual, biennial and 

perennial broadleaf 

species. 

Safe for most 

perennial grasses, 

conifers. Some soil 

residue. 

Use at very low 

rates on annual, 

biennial and 

perennial species;

especially 

Dalmatian 

toadflax and 

houndstongue. 

Moderate risk to 

aquatic organisms.

H-7 Avoid use of chlorsulfuron on 

soils with high clay content (finer than 

loam). 

I-5 Use special care around nontarget vegetation. Do not use on dry, 

ashy, or light, sandy soils 

 H-2 Application of chlorsulfuron is the 

second to last choice within roadside 

treatment areas having high risk of 

herbicide delivery and, in wetlands, 

near aquatic influence areas, 

especially adjacent to fish bearing 

streams. 

H-4 No use within 15 feet of wet 

roadside ditches. 

Clopyralid 

(Transline) 

Synthetic auxin -

Mimics natural plant 

hormones. 

A highly 

translocated, 

selective herbicide 

active primarily 

through foliage of 

broadleaf species. 

Little effect on 

grasses. 

Particularly 

effective on 

Asteraceae, 

Fabaceae, 

Polygonaceae, 

Solanaceae. 

Some species 

include 

knapweeds, 

yellow starthistle, 

Canada thistle, 

hawkweeds. 

Provides control 

of new germinants 

for one to two 

growing seasons.

Contains 

hexachlorobenzene 

(persistent 

carcinogen) in 

amounts below a 

threshold of 

concern this 

substance is 

ubiquitous in the 

environment. 

Highly mobile, but 

does not degrade 

in water. Lower 

risk to aquatic 

organisms. 

H-6 Avoid use of clopyralid on soils 

with high clay content (finer than 

loam). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

82

Active Ingredient 

Selected Herbicide 

Brand Names and 

Mode of Action 

Properties General Uses/ 

Known to be 

Effective on: 

Risks Design Features to Minimize or 

Eliminate Risks 

Glyphosate 

(35 formulations, 

including RoundUp, 

Rodeo, Accord XRT, 

Aquamaster, etc.) 

Inhibits three amino 

acids and protein 

synthesis. 

A broad spectrum, 

non-selective 

translocated 

herbicide with no 

apparent soil 

activity. 

Adheres to soil 

which lessens or 

retards leaching or 

uptake by nontargets. 

Low volume 

applications are 

most effective. 

Trans-locates to 

roots and 

rhizomes of 

perennials. While 

considered nonselective, 

susceptibility 

varies depending 

on species. Main 

control for purple 

loosestrife, herb 

Robert, English 

ivy and reed 

canary grass. 

Aquatic labeled 

formulations can 

be used near 

water. 

Non-selective. 

Greater risk to 

aquatic organisms.

Aquatic labeled glyphosate may be 

used within the bankfull channel 

Aquatic Influence Zones, which poses 

inherent risk of delivery to water. 

Along with buffers that restrict method 

of application, design features 

intended to keep herbicide from 

entering water in concentrations 

above a threshold of concern include: 

H-10 Lakes and Ponds –- No more 

than half the perimeter or 50 percent 

of the vegetative cover or 10 

contiguous acres around a lake or 

pond would be treated with herbicides 

in any 30-day period. 

H-11. Wetland vegetation would be 

treated when soils are driest. If 

herbicide treatment is necessary for 

emergent target plants when soils are 

wet, use aquatic labeled herbicides. 

Favor hand/selective treatment 

methods where effective and 

practical. 

H-13 With the exception of 

hand/selective treatment methods, 

herbicide application within the 

Aquatic Influence Zone would not 

exceed typical label rates. 

H-14 Treatments above bankfull and 

within the aquatic influence zone 

(riparian area), would not exceed 10 

acres along any 1.5 mile of stream 

reach within a 6th field subwatershed 

in any given year. In addition, 

treatments below bankfull would not 

exceed 6 acres total on an annual 

basis per 6th field sub-watershed. 

Imazapic 

(Plateau) 

Inhibits the plant 

enzyme acetolactate, 

which prevents 

protein synthesis. 

Used for the control 

of some broadleaf 

plants and some 

grasses. 

Use at low rates 

can control leafy 

spurge, 

cheatgrass, 

medusa head rye, 

toadflaxes and 

houndstongue 

More potential to 

kill non-target 

vegetation. 

Lower risk to 

aquatic organisms.

Follow label advisories and apply 

botanical buffers. No selected PDFs 

for aquatic organisms. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

83

Active Ingredient 

Selected Herbicide 

Brand Names and 

Mode of Action 

Properties General Uses/ 

Known to be 

Effective on: 

Risks Design Features to Minimize or 

Eliminate Risks 

Imazapyr 

(Arsenal, Arsenal 

AC, Chopper, 

Stalker, Habitat) 

Inhibits the plant 

enzyme acetolactate, 

which prevents 

protein synthesis. 

Broad spectrum, 

non-selective preand post-emergent 

for annual and 

perennial grasses 

and broadleaved 

species. 

Most effective as 

a post-emergent. 

Has been used on 

cheatgrass, 

whitetop, 

perennial 

pepperweed, 

dyers woad, 

tamarisk, woody 

species, and 

spartina. Aquatic 

labeled 

formulations can 

be used near 

water. 

More potential to 

kill non-target 

vegetation. 

Moderate risk to 

aquatic organisms.

Human health 

hazard associated 

with higher label 

rates. 

More mobile. 

F-4 Do not exceed a rate of 0.70 lb 

active ingredient (a.i.)/acre with 

broadcast and spot applications. 

Aquatic labeled imazapyr may be 

used within Aquatic Influence Zones, 

which poses inherent risk of delivery 

to water. Along with buffers that 

restrict method of application, PDFs 

intended to keep herbicide from 

entering water in concentrations 

above a threshold of concern include: 

H-10 Lakes and Ponds –- No more 

than half the perimeter or 50 percent 

of the vegetative cover or 10 

contiguous acres around a lake or 

pond would be treated with herbicides 

in any 30-day period. 

H-11. Wetland vegetation would be 

treated when soils are driest. If 

herbicide treatment is necessary for 

emergent target plants when soils are 

wet, use aquatic labeled herbicides. 

Favor hand/selective treatment 

methods where effective and 

practical. 

H-13 With the exception of 

hand/selective treatment methods,, 

herbicide application within the 

Aquatic Influence Zone would not 

exceed typical label rates. 

H-14 Treatments above bankfull and 

within the aquatic influence zone 

(riparian area), would not exceed 10 

acres along any 1.5 mile of stream 

reach within a 6th field subwatershed 

in any given year. In addition, 

treatments below bankfull would not 

exceed 6 acres total on an annual 

basis per 6th field sub-watershed. 

Metsulfuron methyl 

(Escort XP) 

Sulfonylurea - 

Inhibits acetolactate 

synthesis, protein 

synthesis inhibitor, 

and blocks formation 

of amino acids. 

Used for the control 

of many broadleaf 

and woody species. 

Most susceptible 

crop species in the 

lily family (i.e. 

onions). 

Safest sulfonylurea 

around non-target 

grasses. 

Use at low rates 

to control such 

species as 

houndstongue, 

sulfur cinquefoil 

perennial 

pepperweed 

plant. 

More potential to 

kill non-target 

vegetation. 

Lower risk to 

aquatic organisms. 

I-5 Use special care around nontarget vegetation. Do not use on dry, 

ashy, or light, sandy soils 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

84

Active Ingredient 

Selected Herbicide 

Brand Names and 

Mode of Action 

Properties General Uses/ 

Known to be 

Effective on: 

Risks Design Features to Minimize or 

Eliminate Risks 

Picloram 

(Tordon K, Tordon 

22K) 

Restricted Use 

Herbicide 

Synthetic auxin - 

Mimics natural plant 

hormones. 

Selective, systemic 

for many annual 

and perennial 

broadleaf herbs and 

woody plants. 

Use at low rates 

to control such 

species as 

knapweeds, 

Canada thistle, 

yellow starthistle, 

houndstongue, 

toadflaxes, sulfur 

cinquefoil, and 

hawkweeds. 

Provides control 

of new germinants 

for two to three 

growing seasons.

Most mobile, but 

persistent in soil. 

Contains 

hexachlorobenzene 

(persistent 

carcinogen) in 

amounts below a 

threshold of 

concern this 

substance is 

ubiquitous in the 

environment. 

More potential to 

kill non-target 

vegetation. 

Greater risk to 

aquatic organisms.

Human health 

hazard associated 

with higher label 

rates. 

H-8 Avoid use of picloram on shallow 

or coarse soils (coarser than loam.) 

No more than one application of 

picloram would be made within a twoyear period, except to treat areas 

missed during initial application. 

H-3 No use of picloram... on roadside 

treatment areas that have a high risk 

of herbicide delivery. 

H-4 No use within 15 feet of wet 

roadside ditches. 

Sethoxydim 

(Poast, Poast Plus) 

Inhibits acetyl coenzyme, a key step 

for synthesis of fatty 

acids. 

A selective, postemergent grass 

herbicide. 

Would control 

many annual and 

perennial grasses 

such as 

cheatgrass. 

Greatest risk to 

aquatic organisms.

H-2 Application of sethoxydim is the 

last choice within roadside treatment 

areas having high risk of herbicide 

delivery and, in wetlands, near 

aquatic influence areas, especially 

adjacent to fish bearing streams: 

H-4 No use within 15 feet of wet 

roadside ditches. 

Sulfometuron methyl 

(Oust, Oust XP) 

Sulfonylurea -Inhibits 

acetolactase 

synthase; a key step 

in branch chain 

amino acid 

synthesis. 

Broad spectrum 

pre- and postemergent herbicide 

for both broadleaf 

species and 

grasses. 

Used at low rates 

as a pre-emergent 

along roadsides. 

Known to be 

effective on reed 

canary grass, 

cheatgrass, and 

medusahead. 

Persistent in soil. 

Toxic to soil 

organisms. 

More potential to 

kill non-target 

vegetation. 

Moderate risk to 

aquatic organisms.

Human health 

hazard associated 

with higher label 

rates. 

H-9 Avoid use on shallow or coarse 

soils (coarser than loam.) No more 

than one application within a one-year 

period, except to treat areas missed 

during initial application. 

I-5 Use special care around nontarget vegetation. Do no use on dry, 

ashy, or light, sandy soils. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

85

Active Ingredient 

Selected Herbicide 

Brand Names and 

Mode of Action 

Properties General Uses/ 

Known to be 

Effective on: 

Risks Design Features to Minimize or 

Eliminate Risks 

Triclopyr 

(Garlon 3A, Garlon 

4, Forestry Garlon 4, 

Pathfinder II, 

Remedy, Remedy 

RTU, Redeem R&P) 

Synthetic auxin - 

Mimics natural plant 

hormones. 

A growth regulating 

selective, systemic 

herbicide for control 

of woody and 

broadleaf perennial 

invasive plants. 

Little or no impact 

on grasses. 

Effective for many 

woody species 

such as scotch 

broom and 

blackberry. Also 

effective on 

English ivy, 

Japanese 

knotweed. Amine 

formulation may 

be used near 

water 

Greatest risk to 

aquatic organisms.

Exposure may 

exceed thresholds 

of concern for 

workers and the 

public. 

F-2 Comply with R6 2005 ROD 

requiring spot and hand/selective 

treatments only. 

L-1 Triclopyr would not be applied to 

foliage in areas of known special 

forest products or other wild foods 

collection. 

H-3 No use of ...Triclopyr BEE, ... on 

roadside treatment areas that have a 

high risk of herbicide delivery 

Aquatic labeled triclopyr may be used 

up to 15 feet from surface waters. 

Additional PDFs intended to keep 

herbicide from entering water in 

concentrations above a threshold of 

concern include: 

H-10 Lakes and Ponds –- No more 

than half the perimeter or 50 percent 

of the vegetative cover or 10 

contiguous acres around a lake or 

pond would be treated with herbicides 

in any 30-day period. 

H-11. Wetland vegetation would be 

treated when soils are driest. If 

herbicide treatment is necessary for 

emergent target plants when soils are 

wet, use aquatic labeled herbicides. 

Favor hand/selective treatment 

methods where effective and 

practical. 

H-13 With the exception of 

hand/selective treatment methods,, 

herbicide application within the 

Aquatic Influence Zone would not 

exceed typical label rates. 

H-14 Treatments above bankfull and 

within the aquatic influence zone 

(riparian area), would not exceed 10 

acres along any 1.5 mile of stream 

reach within a 6th field subwatershed 

in any given year. In addition, 

treatments below bankfull would not 

exceed 6 acres total on an annual 

basis per 6th field sub-watershed 

3.1.6 Basis for Cumulative Effects Analysis 

As defined by 40 CFR 1508.7 and 1508.8, and FSH 1909.15 Section 15.1, A cumulative effect is the effect on the 

environment that results from the incremental effect of the action when added to the effects of other past, present, 

and reasonably foreseeable future actions, regardless of what agency or person undertakes the other actions and 

regardless of land ownership on which the other actions occur. An individual action when considered alone may 

not have a significant effect, but when its effects are considered in sum with the effects of other past, present, and 

reasonably foreseeable future actions, the effects may be significant. 

The Olympic National Forest surrounds the Olympic National Park and shares some watersheds with the park, 

along with tribal and other lands. The Forest Service manages about one-third of the lands within 6th -field 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

86

watersheds containing National Forest (a list of watersheds is displayed in the soil and water section later in this 

chapter). Actions on neighboring lands can contribute to the containment of invasive plants on National Forests 

(and visa versa). 

The following roads within National Forest treatment areas provide access to/from adjacent non-Forest lands and 

are likely vectors of invasive plant spread between different ownerships: 2180, 22, 2294, 2340, 2464, 2610, 

2902, 2918, 2920, 2922, 2923, 30, 3006, 3006400, and 3116. 

The National Forest portions of these roads are proposed for treatment in the action alternatives. Treatment 

effectiveness would be increased if adjacent lands were also treated. 

Invasive plants are managed on private and public lands throughout the analysis area. Treatments on and off 

National Forest system lands would be coordinated using existing mechanisms such as Weed Management Areas 

and interagency coordination with the counties and the US Park Service, and government-to-government 

consultation with American Indian tribes. 

Cumulative effects analysis throughout this chapter considers whether there are significant additive, synergistic 

or offsetting effects of other past, present, and foreseeable future actions in combination with the proposed 

project. Herbicides are widely used for agricultural and industrial forest management, landscaping, and invasive 

plant management. Herbicide use occurs on Quinault tribal lands, the Olympic National Park, state and county 

lands, private forestry lands, rangeland, utility corridors, and road rights of way. 

No central source exists for compiling invasive plant management information off National Forests within 

Washington. There is no requirement for landowners or counties to report invasive plant treatment information, 

thus an accurate accounting of the cumulative acreage of invasive plant treatment for all land ownerships is 

unavailable. The National Park Service reported treating fewer than 100 acres of invasive plants with herbicide 

over the past several years (Acker, personal communication, 2006). 

Although many herbicides are registered by the U.S. Environmental Protection Agency for use in agriculture, 

most are not used in forestry. Forestry uses account for less than one percent of the total herbicides or pesticides 

used in the United States of America (Norris et al. 1991). 

The potential for adverse effects of the use of the proposed herbicides is fairly small (see table 29). While 

workers, the public, wildlife and/or fish may be exposed to herbicides within and outside the Olympic National 

Forest, multiple exposures do not necessarily equate to cumulative adverse effects. The herbicides proposed for 

use are water-soluble, are rapidly eliminated from humans and do not concentrate in fatty tissues and do not 

significantly bioaccumulate (R6 2005 FEIS). This is true whether an organism is exposed to one or several of the 

chemicals proposed for use. 

 Table 30 displays the baseline, spatial and temporal scales considered for cumulative adverse effects for each 

resource area. The EIS considers the effects of each alternative when combined with past, ongoing or future 

proposed actions. These actions may occur on or off National Forest lands. Cumulative adverse effects can occur 

if one or more activities occur close enough in time and space for impacts to be combined. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

87

Table 30-Baseline and Scales for Botany, Wildlife, Soils, Water Quality, Aquatic Organisms and Human 

Health 

Resource Baseline (existing 

condition) 

Spatial Scale Temporal Scale 

Botany Current extent of botanical 

species of local interest is the 

baseline for effects 

comparison. 

No known threats to botanical 

SOLI from past and ongoing 

herbicide use in the analysis 

area. 

Treatment effects are localized. All 

methods pose some risk of harming nontarget botanical species. Mistakes can 

be made with all tools. Herbicide may 

drift or run off up to 15 – 100 feet from 

treatment site depending on application 

method. 

Impacts to non-target vegetation 

would occur at the time of treatment. 

Localized residual effects to 

vegetation are possible with longerlived herbicides such as picloram 

and clopyralid. 

Wildlife Current extent of habitats for 

wildlife species of local 

interest is the baseline for 

effects comparison. 

No known threats to wildlife 

SOLI from past and ongoing 

herbicide use in the analysis 

area. 

Treatment effects are localized. 

Herbicide may drift or run off up to 15 – 

100 feet from treatment site depending 

on application method. Extent of 

treatment extremely low compared to 

extent of available habitats. 

Chronic exposure to low levels of 

herbicide is possible over the life of 

the project. The herbicides 

proposed for use are metabolized 

and excreted faster than they can 

accumulate in the bodies of animals. 

Soils Current soil inventory is the 

baseline. No adverse effects 

on soils from past and 

ongoing herbicide use in the 

analysis area. 

Treatment effects are localized. 

Herbicide may drift or run off up to 15 – 

100 feet from treatment site depending 

on application method. 

Herbicides vary as to persistence in 

soils. Picloram, clopyralid and 

sulfometuron methyl are residually 

active in soil. 

Water Quality Baseline for comparison is 

current water quality. No 

streams within analysis area 

listed for chemical 

contamination. 

Cumulative effects are considered at the 

6th field watershed scale. Treatments of 

emergent and riparian target and 

treatments along roads that have high 

potential to deliver herbicide to surface 

water bodies are areas where cumulative 

deliveries to streams are possible. 

Herbicides may be persistent in 

water for months after treatment 

however quantities are far below 

amounts that would cause harm. 

Aquatic 

Organisms 

Baseline for comparison is 

current extent of fish species 

of local interest. No known 

threats to aquatic SOLI from 

past and ongoing herbicide 

use in the analysis area. 

Acute exposure is considered at the sitescale. Acute exposure is evaluated 

along a stream approximately 1.5 miles 

long. Acute exposure in a discrete 

contiguous wetland is also evaluated at 

the treatment area scale. 

Potential acute effects are evaluated 

over the course of 24 hours. After 

that, there is no potential for 

concentrations to exceed a level of 

concern. The herbicides proposed 

for use are metabolized and 

excreted faster than they can 

accumulate in the bodies of aquatic 

animals. 

Human Health Baseline for comparison is 

the current situation. No 

known threats to human 

health from past and ongoing 

herbicide use in the analysis 

area, however most humans 

are subject to some 

background level of chemical 

exposures. 

Direct and indirect effects of treatment 

limited to 15 – 100 feet from treatment 

site. 

People may be exposed to herbicide 

in a chronic manner (e.g. 

applicators) or through multiple 

exposure mechanisms (breath, skin, 

ingestion of contaminated meat, 

mushrooms or fruit). The herbicides 

proposed for use are metabolized 

and excreted faster than they can 

accumulate in human bodies. 

The Project Design Features (PDFs) displayed in Chapter 2 for the Proposed Action constrain the rate and 

method of herbicide use to such a degree that the likelihood of adverse effects occurring is low. Adverse effects 

from acute, multiple or chronic exposures are unlikely. Chronic exposures do not exceed thresholds of concern 

because the herbicides are excreted from organisms so rapidly that they do not accumulate over time. 

The PDFs limit the mechanisms by which workers, the public, non-target plants, wildlife and fish may be 

exposed to herbicides. The PDFs were developed considering the risks and properties of the herbicides proposed 

for use. Herbicide selection and/or method are restricted depending on the toxicity, mobility, and persistence of 

each chemical applied to a range of site conditions. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

88

The PDFs sufficiently minimize risks to compensate for inherent uncertainty about the impacts of herbicide use 

on neighboring lands. In watersheds where the majority of acreage is administered by the Forest Service, the 

likelihood of cumulative effects is low because less than one percent of the total watershed acreage would be 

treated. As the portion of National Forest system lands decreases, the plausible contribution of Forest Service to 

the overall chemical load within the watershed also decreases. Either way, herbicide use within the scope of this 

EIS has little potential for cumulative effects, whether in the context of proposed treatment at any one site or total 

chemical exposure in any 6th-field watershed. 

Early detection-rapid response is part of all action alternatives, and considered in the direct, indirect and 

cumulative effects analysis. 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 

Project Design Features do so much to minimize or eliminate the potential for adverse effects, whether all 

acreage was treated in a single year, or whether less acreage was treated in a single year and treatments occurred 

over a longer period of time. Effects of treatments under early detection-rapid response would be sufficiently 

minimized by the PDFs regardless of when the treatments occurred. If effective treatments of new infestations 

required methods outside the scope of the project, or if PDFs could not be applied without a significant loss of 

effectiveness, further analysis would be necessary prior to treatment. 

Table 29 provides a link between the herbicides properties and risk and specific design features intended to 

minimize adverse effects. Glyphosate, imazapyr and triclopyr have more associated design features because 

aquatic formulations of these herbicides may be used near water bodies. 

3.2 Botany and Treatment Effectiveness 

This section focuses on the relative likelihood that the treatment methods approved in each alternative would be 

effective in reducing threats to non-target vegetation from invasive plants (Issue Group 2). This section also 

discloses the risks to non-target vegetation, especially Botanical Species of Local Interest, from the treatment of 

invasive plants (Issue Group 4). 

In general, the threats from invasive plants to non-target vegetation are greater than the threats from treatment. 

As treatment effectiveness increases, the threats to native vegetation decrease. Broadcast herbicide treatments 

can be the most cost-effective of the methods considered in this EIS, and while this method poses the greatest 

risk to non-target vegetation, Project Design Features would mitigate the risks. Adequate measures are in place 

to mitigate the risk of broadcast treatments occurring in proximity to Botanical Species of Local Interest; 

monitoring is recommended to manage uncertainty related to the potential effect of herbicide drift on certain nonvascular plants. 

3.2.1 Affected Environment 

Invasive plants have been detected on 3,830 acres of the Olympic National Forest. These sites are predominantly 

located in disturbed areas: along road systems, in timber sale units (e.g., Matwat Timber Sale), at the Lake 

Quinault summer residences, in administrative sites (e.g., Dennie Ahl seed orchard, Snider Work Center, 

Quinault Ranger Station), in high public use areas (parking areas, viewpoints), in managed areas such as 

plantations, and in areas utilized for recreation such as campgrounds, dispersed recreation, etc. (Quinault Loop 

Trail, OHV Slab camp quarry, Seal Rock Campground, etc,). 

Places where ecosystem functioning and native plant communities are of high value are also affected; these 

include meadow systems (e.g., Mint Meadow, Mount Schmidt Knob, Skokomish Savannah Restoration Site, 

Matheny Prairie); sphagnum bogs (e.g., Cranberry Bog); Research Natural Areas (e.g., Wet Weather Creek and 

Quinault); and/or wilderness areas (Buckhorn, Colonel Bob, the Brothers Wilderness). Plant community 

functioning has been disrupted and native vegetation has been replaced by invasive plants in some areas. 

Without treatment, these weed sites will further displace native plant communities, and continue to spread. 

Invasive plants have been estimated to spread at a rate of 8 to12 percent each year. Prevention practices may 

reduce that number by half (2005 R6 FEIS Chapter 4.2, page 4-24). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

89

Roads are conduits for the spread of invasive plants, providing for their transport and dispersal (e.g., seeds and 

vegetative reproductive parts attached to vehicles) and providing disturbed ground for easy colonization and 

establishment. Olympic National Forest System roads also serve to introduce invasive species onto the Olympic 

National Park, where native plant communities and ecological integrity are highly valued, as well as to the 

Quinault Indian Nation land, where they are aggressively treating Japanese knotweed and gorse to protect 

riparian areas. 

Roads serve to introduce and establish invasives in areas where they were previously unknown. For example, 

currently gorse is unknown on the Olympic National Forest, although it is a species on their watch list. Gorse is 

moving in from the Quinault Indian Nation on Highway 101, which goes to Olympic National Forest system 

lands. This EIS would allow for treatment of these sites. 

Timber harvest, livestock grazing, road building, and other ground-disturbing activities occur on National Forest 

System lands, and contribute to the spread of invasive plants as the habitat conditions that facilitate colonization 

are created. Early detection of populations of invasive species is critical before they become larger and spread. 

As population size increases, difficulty and cost of treatment also increase, to the point where eradication may be 

impossible. 

The Olympic National Forest lies within approximately 632,300 acres in the northwest corner of Washington, 

and surrounds the Olympic National Park. The vegetation of the Olympic Peninsula is strongly influenced by a 

maritime climate, as it is surrounded by saltwater on three sides: the Pacific Ocean on the west, the Strait of Juan 

de Fuca on the north, and the Hood Canal on the east. It has distinct eastside and westside ecology, due to the 

Olympic Mountains in the center. 

The southern part of the westside is known for its high rainfall and temperate rainforest, with Sitka spruce, 

western red cedar, western hemlock, and Douglas-fir. The northern section of the eastside is the driest part of the 

forest, with a small area of climax Douglas-fir, given the rain shadow effect from the mountains. Glacial and 

climactic history influenced the evolution of the Olympic flora. As the alpine and continental glaciers advanced, 

the Peninsula was isolated from other areas. Glacial refugia existed in localized areas where plant species and 

plant communities survived, resulting in pockets of distinct plant communities. Table 31 displays target species 

that may be associated with wetter habitats.24 

 

24 Most of these species have been detected along roadsides and other disturbed areas that may be outside of mapped 

Riparian Reserves. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

90

Table 31-Target Species in Wetter Habitats 

Target Species Potential Wet Habitat 

Knotweed Adjacent to and standing in water (streams, rivers, ponds etc.) and along moist roadside 

ditches. 

Hawkweeds Moist meadows. 

Tansies On streambanks. 

Scotch Broom Adjacent to and in meadows, streams, and riparian margins. 

English Ivy Can grow over rocks and adjacent to water, but not in water. 

Reed Canarygrass Wetland emergent species, likes to be flooded – in wet ground, streams, marshes, canals, 

irrigation ditches, etc. 

Canada and Bull Thistle In meadows and along creeks, streams, and in aspen stands adjacent to creeks. 

Herb Robert Adjacent to water, creek, streambanks. 

Purple Loosestrife Streambanks, canals, ditches, and in shallow ponds. 

Blackberry Often a monoculture along streams and rivers, etc. 

Oxeye Daisy Adjacent to and in meadows, and stream, and river edges. 

Yellow Nutsedge Moist or wet areas. 

Invasive Plants and Native Plant Species of Local Interest 

Botanical Species of Local Interest (SOLI) within 100 feet of treatment areas are displayed in table 32.25 

Botanical SOLI include: 

• Regional Forester Sensitive or Proposed Sensitive Species (Forest Service Manual 2670); and 

• Survey and Manage Mitigation Measure Species.26 

No botanical species listed under the Endangered Species Act grow within 100 feet of any treatment area. 

Invasive plants currently or may someday threaten 20 different botanical SOLI at 90 sites (3 species of fungi, 9 

species of lichens and bryophytes, and 8 vascular plant species). Three botanical SOLI at 13 sites are seriously 

threatened by encroachment of invasive plants. 

 

25 Databases and records from the Olympic National Forest, Washington State Natural Heritage Program, Oregon Natural 

Heritage Program, and ISMS (Interagency Species Management System) database were used to overlay SOLI with the 

invasive plant inventory. Local botanists/ecologists Joan Ziegltrum, Deborah McConnell, and Pat Grover assisted in 

determining proximity of target species to SOLI. All of the botanical SOLI within 100 feet of treatment areas are Regional 

Forester Sensitive Species except E. quinaultense, which is proposed to be added to the sensitive list. 26“Survey and Manage” is a mitigation measure in the Northwest Forest Plan adopted as part of the Olympic National Forest 

Plan. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

91

Table 32-Botanical Species of Local Interest, Olympic National Forest 

Botanical Species Type of Species/ 

Habitat 

Number of SOLI sites 

near invasive plant 

treatment areas 

Level of Threat from Invasive 

Plants 

Lichens and Bryophytes 

Diplophyllum plicatum 

Survey and Manage Species 

Liverwort 1 (of 11 populations 

recorded in the Pacific 

Northwest, ISMS 

database) 

No direct threats from invasives 

have been observed; future (within 

ten years) threats include loss 

of/competition for habitat. 

Hypogymnia duplicata 

Survey and Manage Species 

Lichen, epiphytic on mountain 

hemlock, western hemlock, 

Pacific silver fir, Douglas-fir 

and subalpine fir in oldgrowth forests 

11 (of 153 populations 

recorded in the Pacific 

Northwest, ISMS 

database ) 

No direct threats from invasives 

have been observed; future threats 

include loss of/competition for 

habitat if fewer host trees are 

recruited. 

Iwatsukiella leucotricha 

Sensitive and Survey and 

Manage Species 

Moss; wet areas along the 

coastal region, on bark of 

conifers and alders on ridges 

with fog penetration 

5 (of 11 populations 

recorded In Washington) 

No direct threats from invasives 

have been observed; future threats 

include loss of/competition for 

habitat, especially if fewer host trees 

(silver fir) are recruited. 

Nephroma bellum 

Sensitive and Survey and 

Manage Species 

Lichen; in moist forest with 

strong coastal influence; often 

on riparian hardwoods 

2 (of 22 populations 

recorded in Washington) 

No direct threats from invasives 

have been observed; future threats 

include loss of/competition for 

habitat if fewer host trees are 

recruited. 

Platismatia lacunosa 

Sensitive and Survey and 

Manage Species 

Lichen; on boles and 

branches of hardwoods and 

conifers and alders in moist 

riparian forests and cool 

upland sites 

7 (of 18 populations 

recorded in Washington) 

No direct threats from invasives 

have been observed; future threats 

include loss of/competition for 

habitat if fewer host trees are 

recruited. 

Pseudocyphellaria rainierensis

Sensitive and Survey and 

Manage Species 

Epiphytic lichen; moist old 

growth forest 

4 (of 56 populations 

recorded in Washington) 

No direct threats from invasives 

have been observed; future threats 

include loss of/competition for 

habitat if fewer host trees are 

recruited. 

Racomitrium aquaticum 

Survey and Manage Species 

Moss, forms mats on shaded, 

moist rocks and cliffs along 

shady streams or in forests, 

often in splash zones, but 

never in aquatic habitat 

3 (of 23 populations 

recorded in the Pacific 

Northwest, ISMS 

database ) 

No direct threats from invasives 

have been observed; future (within 

ten years) threats include loss 

of/competition for habitat. 

Schistostega pennata 

Sensitive and Survey and 

Manage Species 

Moss; in dark places: 

upturned rootwads, rock 

crevices, adjacent to standing 

water 

3 (of 50 populations 

recorded in Washington) 

No direct threats have been 

observed, and future threats are not 

expected. This species has a highly 

selective habitat, one whose niche 

would not easily be occupied by 

invasive species. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

92

Botanical Species Type of Species/ 

Habitat 

Number of SOLI sites 

near invasive plant 

treatment areas 

Level of Threat from Invasive 

Plants 

Tetraphis geniculata 

Sensitive and Survey and 

Manage Species 

Moss; old growth downed 

stumps and large logs in 

moist areas 

20 (of 40 populations 

recorded in Washington) 

No direct threats have been 

observed, and future threats are not 

expected. This species has a highly 

selective habitat, one whose niche 

would not easily be occupied by 

invasive species. 

Fungi 

Albatrellus avellaneus 

Survey and Manage Species 

Terrestrial, mycorrhizal 

polypore restricted to Sitka 

Spruce 

3 (of 6 populations 

recorded in the Pacific 

Northwest, ISMS 

database ) 

No direct threats from invasives 

have been observed; future (within 

ten years) threats include loss 

of/competition for habitat. 

Bondarzewia mesenterica 

Survey and Manage Species 

A terrestrial, parasitic 

polypore found solitary or in 

clumps, associated with 

conifers 

2 (of 20 populations 

recorded in the Pacific 

Northwest 

No direct threats from invasives 

have been observed; future (within 

ten years) threats include loss 

of/competition for habitat. 

Ramaria lorithamnus 

Survey and Manage Species 

Terrestrial, mycorrhizal 

fungus associated with late 

successional Douglas fir and 

western Hemlock forests in 

the Pacific Northwest 

1 (of 1 population 

recorded in the Pacific 

Northwest 

No direct threats from invasives 

have been observed; future (within 

ten years) threats include loss 

of/competition for habitat. 

Vascular Plants 

Carex anthoxanthea 

Sensitive Species 

Sedge; Grassy, boggy places 1 (of 1 site recorded in 

Washington State) 

Reed canary grass grows in the 

vicinity. Within five years, reed 

canary grass may be directly 

competing with this Carex 

population. 

Carex obtusata 

Sensitive Species 

Sedge; Dry, open ridges, 

scree meadows, talus slopes, 

often in late snowmelt 

pockets from 5800’ to 6800’ 

3 (of approximately 10 

sites recorded in 

Washington) 

Invasive plant surveys are not 

complete at these locations. It is 

unlikely Canada thistle and common 

dandelion are competing with Carex 

obtusata, as rocky, scree ridgeline is 

not conducive habitat for these 

invasives. 

Carex pauciflora 

Sensitive Species 

Sedge; Sphagnum bogs to 

3000’ 

1 (of approximately 20 

recorded sites in 

Washington) 

No direct threat to Carex pauciflora, 

but within 5 years Canada thistle or 

herb Robert may out-compete the 

Carex for space and resources. 

Erythronium quinaultense 

Proposed Sensitive Species 

Herbaceous; In openings and 

rock ledges in coniferous 

forests at an elevation of 

1640 to 2953 ft. (500 to 900 

m). Populations have been 

found from 960-2600 ft. 

9 (of 12 populations 

recorded on the Olympic 

peninsula, on the 

Olympic National Forest)

There are 8 sites where invasives 

are impacting Erythronium 

quinaultense habitat, competing for 

space and resources. 
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Botanical Species Type of Species/ 

Habitat 

Number of SOLI sites 

near invasive plant 

treatment areas 

Level of Threat from Invasive 

Plants 

Galium kamtschaticum 

Sensitive and Survey and 

Manage Species 

Herbaceous; Northerly 

aspects from 1930’ to 2900’, 

in the silver fir or mountain 

hemlock plant associations, in 

wet canopy gaps. 

2 (8 sites on the Olympic 

peninsula all of which are 

on the Olympic National 

Forest) 

No direct threats from invasives. 

Within 5 years, there is potential for 

competition for space and resources 

between invasives and Galium 

kamtschaticum. 

Parnassia palustris var. 

neogaea 

Sensitive Species 

Herbaceous; Wet meadows, 

wet rock faces, seeps and 

along streams and pond 

edges 

5 (19 sites recorded on 

the Olympic National 

Forest) 

At 4 sites, invasives are impacting 

Parnassia palustris var. neogaea 

habitat. Currently, there are no 

direct impacts to individuals, but 

within five years there is potential. 

Pellaea breweri 

Sensitive Species 

Fern; Rocky crevices, rock 

outcrops, ledges and talus 

slopes 

1 (of 10 sites recorded in 

Washington) 

Surveys are not complete. It is 

unlikely invasive species are 

competing with Pellaea breweri, as 

rocky, scree ridgeline is not 

conducive habitat for invasives in 

this treatment area. 

Synthyris pinnatifida var. 

lanuginosa 

Sensitive Species 

Herbaceous; On scree and 

talus slopes and other rocky 

areas in the alpine zone 

6 (of less than 20 sites 

known from the Olympic 

Peninsula) 

There is 1 site where invasives are 

impacting Synthyris pinnatifida var. 

lanuginosa habitat. Within five 

years, there is potential impact to 

individuals. 

3.2.2 Treatment Effectiveness 

Treatment effectiveness increases with the number of treatment options available and percentage of the infested 

land base that may be treated using herbicides. All alternatives, including No Action, approve a wide range of 

non-herbicide methods, including biological, manual and mechanical treatments. The variation between 

alternatives is mostly related to the use of herbicides. For the purposes of this analysis, all herbicide application 

methods (broadcast, hand, spot) are considered equally effective.27 Funding constraints and conditions on 

neighboring lands may also influence treatment effectiveness; these variables are constant across alternatives. 

Invasive plant spread is not continuous or even across the landscape. Invasive plants can “jump” across far 

distances. For example, a vehicle carrying seeds or propagules, can deposit these “hitchhikers” to another county 

where that invasive might be otherwise unknown. Hikers are likely to deposit invasive plant seeds along the trail 

into dispersed recreation sites within the wilderness. The hazard related to invasion of uninfested areas and high 

value areas like wilderness may be much greater than the hazard related to invasive plant spread elsewhere. 

Several of the infested sites on the Olympic National Forest also threaten plant species of local interest. Another 

indicator of effectiveness is the number of SOLI species that are at risk of extirpation if invasive plants are not 

effectively treated. 

 

27Herbicide application methods may influence cost-effectiveness, for instance, spot and hand treatments tend to cost more 

per acre than broadcast treatments. This is discussed further in the economic analysis in Chapter 3.7. 
Final Environmental Impact Statement 

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Effectiveness of Common Control Measures 

Biological Agents 

Several biological agents have been approved for release on the Olympic National Forest (Jennifer Andreas, email communication, January 2006). The analyses for effects of such tools have already been completed under 

documents developed by Agricultural Plant Health and Insect Service (APHIS) for approval of entry of such 

organisms. 

Biological control is self-perpetuating, selective, energy self-sufficient, economical, and well suited to integration 

in an overall invasive plant management program. Introducing predators, parasites, or pathogens from a plants 

country of origin does not eradicate, but controls any given invasive plant (R6 2005 FEIS, 2-35 to 2-37). 

Biological controls have varied results (Cecile Shohet, personal observations, December 2005). Tansy ragwort 

(Senecio jacobaea), St. John’s wort (Hypericum perforatum), Canada thistle (Circium arvense), and bull thistle 

(Circium vulgare) have been contained using biocontrols in the western United States (Andrea Ruchty, personal 

communication, 2006). 

The time frame for controlling invasives using biocontrols is very long, and would occur regardless of 

alternative. The effects of biological agents are described in Appendix J of the R6 2005 FEIS, which states that 

biological controls: 

“Are unlikely to result in adverse effects to aquatic species (page J-24), 

Have no direct effects on wildlife (page J-19), 

There are few examples of non-target effects (page J-16).” 

Manual and Mechanical Treatments 

Manual and mechanical treatment methods are approved in all alternatives. These treatments are preferred where 

effective (consistent with treatment strategies), particularly where impacts (disturbance, compaction) from use of 

motorized equipment can be minimized. The effectiveness of manual and mechanical treatments increases if 

herbicides are also available for use. However, if herbicide use is not allowed, stand alone manual and 

mechanical treatments are less effective, and may actually increase rather than decrease population numbers. 

For instance, manual and mechanical treatments can increase populations of meadow knapweed, Canada thistle 

and Japanese knotweed as pieces of rhizome/root/stem break off and develop into a plant the following spring. 

Also, in the process of digging/pulling, the disturbance created by the treatment creates the ideal habitat 

conditions for invasive seeds to germinate and flourish. For these species, in order for manual/mechanical to be 

effective, meticulous follow-up is necessary several times in a growing season for at least five years, to prevent 

seeds from being produced and dispersed, and to kill any germinants. In contrast, annuals may be effectively 

pulled out of the ground by hand (manual treatment) because of their one-year life cycle. 

Herbicide Treatments 

Greater numbers of herbicide options tend to result in greater potential effectiveness; lower numbers of options 

tend to result in lower potential effectiveness (R6 2005 FEIS, 4-15 to 4-16, and 4-36). Each invasive species has 

its own physiology, and its own habitat requirements. Herbicide effectiveness varies substantially depending on 

the invasive species, treatment timing, restoration plans, and environmental factors. Chapter 2 includes a chart 

showing the measures considered most effective for the invasive species known on the Olympic National Forest. 

A range of herbicide and non-herbicide options is necessary to effectively treat invasive plants (R6 FEIS 4-15). 

For instance, the herbicide glyphosate does not work effectively for all species of invasives. Glyphosate can be 

used against woody vegetation, but other herbicides such as triclopyr are more effective (Robin Dobson, personal 

communication, November 2006). Glyphosate also has more restrictions for effective use; for instance, 

glyphosate must be applied in the fall after the berries have dropped to effectively treat blackberry, whereas 

triclopyr is effective applied at any time of year (ibid.). 
Final Environmental Impact Statement 

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95

In addition, nationwide a number of invasives have been found to develop a tolerance to glyphosate, and its 

effectiveness has been markedly reduced. Dr. Tim Miller, the Washington State Extension Weed Scientist in Mt. 

Vernon, Washington, reports tolerance to glyphosate in locations close to the Olympic National Forest. 

The percentage of the land-base that would be treated varies between alternatives. The more acres left untreated, 

the greater the likelihood that invasives will spread and compete with native plant communities. Over time, 

infestations that are left untreated will continue to spread. Thus, another indicator of effectiveness is the acreage 

of invasive plant infestations projected five years from now. 

Effectiveness of Alternative A - No Action 

Under Alternative A, the No Action Alternative, some treatments that have been approved under previous NEPA 

decisions would continue. Invasive plant prevention standards were adopted (R6 2005 ROD) that are expected to 

reduce the rate of spread of invasive plants across the Pacific Northwest Region from 8 to 12 percent down to 4 

to 6 percent. In addition, biological releases (see above) have been approved and would continue to be partially 

effective under No Action. 

On the Olympic National Forest, treatments have been approved for 672 acres. Of these, 86 acres are prescribed 

for herbicide use (about 2.2 percent of the 3,830 acres estimated to be currently infested). Herbicide use is 

restricted to spot and/or hand applications of glyphosate, dicamba, and picloram, and in proximity to water, only 

the herbicide glyphosate can be used. The effectiveness of the No Action Alternative is assumed to be 25 

percent, (each year of treatment under Alternative A would reduce population size by 25 percent). This 

percentage is lower than other alternatives because the comparative acreage allowed for herbicide use is low, and 

the herbicide selection is limited. 

Given estimates of target species average rate of spread and the effectiveness predicted for the most ambitious 

treatment scenario analyzed for No Action, net infestation would be reduced by about 327 acres by the year 2012. 

This estimate assumes a $200,000 per year budget and use of the tools currently available under No Action. No 

Action has a low effectiveness because of the limited use of herbicide. Fewer than half the acreage currently 

considered high priority would effectively be treated under the most ambitious conceivable No Action treatment 

scenario. No Action is unlikely to effectively treat invasive plants because so little of the current infestations 

would be treated. 

The rate of invasive plant spread would be reduced via the implementation of prevention practices. The R6 2005 

FEIS estimated that invasive plant spread would be reduced from about 10 percent per year to 5, assuming the 

consistent application of prevention practices. Each year, untreated invasive plants are assumed to spread by this 

rate. 

Invasive plant treatments that occur on parcels neighboring the National Forest System lands would contribute to 

project effectiveness. Invasive plants flow between land ownerships and administrative units. Treatments must 

occur across land ownerships to optimize the effectiveness of this alternative. 

Table 33-Estimated Invasive Plant Acres, No Action 2007-2012

Year Acres Invaded Acres 

Treated 

25% Effectiveness Acres 

Remaining 

5% 

Spread 

2007 3,830 672 168 3,662 3,700

2008 3,700 504 126 3,574 3,612

2009 3,612 378 94.5 3,518 3,554

2010 3,554 284 71 3,483 3,520

2011 3,520 213 53.25 3,467 3,503

2012 3,503 Last Year of Projection
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

96

Table 34-Summary of Effectiveness Indicators, No Action 

Percentage of Invasive Plants 

Treated With Herbicide 

Number of Herbicide 

Options 

Acres of Invasive Plants 

2012 

Alternative A (No 

Action) 2 3 3,503 

Under No Action, the values at risk from invasive plants would continue to be great. Three Species of Local 

Interest would continue to be threatened by invasive plants. Infestations would continue to impact Wilderness 

Area, Botanical Area and Research National Area values. Meadow and riparian habitats would continue to be at 

risk. Roads would continue to act as vectors of invasive plant spread between National Forest and other lands. 

Effectiveness of Alternative B – Proposed Action and Alternative D 

Alternatives B and D respond similarly to this issue, thus they are discussed together in this section. Alternative 

D has the potential to be more cost-effective than the Proposed Action (see Economic Efficiency Analysis) but 

assuming unlimited funding, both alternatives allow a sufficient range of options to be used in most, if not all, 

situations. 

Under both of these alternatives, all currently infested acres would be treated with integrated prescriptions that 

combine manual and mechanical invasive plant control methods with the use of herbicides. Each year of 

treatment is assumed to reduce population size by 80 percent, given the range of tools that would be available. 

The following beneficial effects would be expected from treatment: 

• Invasive plant establishment and spread would be reduced along roads, trails and other disturbed areas. 

• Native plant communities and ecosystem functions would recover in meadows and forested areas. 

• Many invasive populations would never gain a foothold to wilderness, Botanical Special Interest Areas, 

or Research Natural Areas. 

• Recreation and administrative sites would become less of a vector for invasive spread 

• Invasive plants would no longer pose threats to invasive plant species of local concern. 

Assuming current funding estimates, the highest priority invasives (about one-fifth of the current infestations) 

could be fully eradicated or controlled by 2012. The rate of invasive plant spread would be reduced via the 

implementation of prevention practices, however containing or controlling remaining infested sites would take at 

least 30 years, based on the assumption that each year of treatment, about 80 percent of invasive plant infested 

acreage would be controlled if the tools included in these alternatives were available. 
Final Environmental Impact Statement 

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Table 35-Estimated Invasive Plant Acres, Alternatives B and D, 2007-2012 

Year Acres Invaded Acres 

Treated 

80% Effectiveness Acres 

Remaining 

5% 

Spread 

2007 3,830 3,830 3064 766 774

2008 774 765 612 162 164

2009 164 148 118.4 46 46

2010 73 29 23.2 50 50

2011 50 0 0 50 51

2012 51 Last Year of Projection

Table 36-Summary of Effectiveness Indicators, Alternatives B and D 

Percentage of Current Land Base 

Where Herbicides May Be Used 

Number of Herbicide 

Options 

Acres of Invasive Plants 

2012 

Alternatives B 

(Proposed Action) 

and D 

100 10 51 

Effectiveness of Alternative C 

Given an unlimited budget, Alternative C would still not be as effective as Alternatives B and D. It treats fewer 

acres with herbicide, and infestations that are difficult to eradicate would likely not be effectively treated given 

Alternative C’s restrictions on the use of herbicides. Examples of target species that are difficult to control 

without herbicides include Japanese and giant knotweed; purple loosestrife; orange hawkweed; and meadow and 

brownray knapweed. Alternative C would have less potential to effectively treat these species, especially if they 

are growing along road ditches and near streams where herbicides would not be used. 

Alternative C is less effective than other action alternatives because of its limitations on herbicide use; 

Alternative C is assumed to reduce target populations by about 42 percent per year. In contrast, under No Action, 

target populations reduced by 25 percent per year and the other action alternatives are assumed to reduce target 

populations by 80 percent per year. 

Waterways would continue to transport invasives downstream, and invasive dominance would increase along 

lakes, ponds, creeks, etc. Roads would continue to act as corridors, transporting invasive seeds and propagules to 

new locations. Parnassia palustris var. neogaea is a water-loving vascular plant directly threatened by invasive 

species. Habitat loss to Parnassiahas already occurred from invasive plants and continued spread could lead to 

mortality. Thus, since these areas are off limits to herbicide use under Alternative C, these two SOLI species 

would be at continued risk from infestations. 

While currently undetected sites could be treated under Alternative C, these future treatments would be less 

effective because herbicide use restrictions would be applied. Restoration objectives would continue to apply to 

treated sites and would reduce the potential for re-infestation over time. 

As with the other alternatives, the rate of invasive plant spread would be reduced via the implementation of 

prevention practices. Assuming current funding estimates, less than 17 percent of the inventoried sites would be 

controlled by 2012. Containing or controlling remaining infested sites would take longer than 35 years. Full 

eradication of any invasive species would be unlikely. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

98

Invasive plant treatments that occur on parcels neighboring the National Forest system lands contribute to project 

effectiveness. Invasive plants flow between land ownerships and administrative units. Treatments must occur 

across land ownerships to optimize the effectiveness of this alternative. 

Table 37-Estimated Acres of Invasive Plants, Alternative C, 2007-2012 

Year Acres Invaded Acres 

Treated 

42% 

Effectiveness 

Acres Remaining 5% Spread 

2007 3,830 3,410 2728 1,102 1,114

2008 1,114 681 544.8 569 575

2009 575 136 108.8 466 471

2010 471 27 21.6 449 454

2011 454 0 0 454 459

2012 459 Last Year of Projection

Table 38-Summary of Effectiveness Indicators, Alternative C 

Percentage of Current Land Base 

Where Herbicides May Be Used 

Number of Herbicide 

Options 

Acres of Invasive Plants 

2012 

Alternative C 30 10 459 

Alternative Comparison – Effectiveness Indicators 

Table 39-Comparison of Alternatives, Effectiveness Indicators 

Percentage of Current 

Land Base Where 

Herbicides May Be 

Used 

Number of 

Herbicide 

Options 

Annual 

Effectiveness 

(Percent of Population Decreased 

Each Year of Treatment) 

Acres of 

Invasive Plants

2012 

Alternative A (No Action) 2 3 25 3,503 

Alternative B (Proposed 

Action) 

100 10 80 51 

Alternative C 30 10 42 459 

Alternative D 100 10 80 51 
Final Environmental Impact Statement 

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Effectiveness of Early Detection-Rapid Response 

The most ambitious treatment scenario analyzed would effectively treat all known invasive acreage. The 

adoption of an Early Detection-Rapid Response protocol would allow for quick treatment of newly found 

invasive populations, thereby not allowing them to further spread, and reducing impacts on botanical resources in 

the future. Restoration of treated sites would decrease the likelihood for re-infestation. The IDT predicts that if 

all infestations were effectively treated immediately, within approximately 6 years target populations would be 

suppressed, contained, controlled, or eradicated to the extent desired, and treated sites would be restored. Sites 

will likely have to be revisited in a given year to reach the interior of dense invasives such as knotweed, to 

accommodate invasive plant reproductive cycles that occur through the year, or to ensure treatment of individual 

plants that may have been skipped during the initial entry. 

Invasive plant treatments that occur on parcels neighboring the National Forest System lands contribute to 

project effectiveness. Invasive plants flow between land ownerships and administrative units. Treatments must 

occur across land ownerships to optimize the effectiveness of these alternatives. Alternatives B and D allow a 

range of treatment options sufficient to effectively treat invasive plants that may threaten resources off National 

Forest system lands. 

Invasive plant spread would be reduced in all alternatives via the implementation of prevention practices. The 

R6 2005 FEIS estimated that invasive plant spread would be reduced from about 10 percent per year to 5, 

assuming the consistent application of prevention practices. Each year, untreated invasive plants in all 

alternatives are expected to spread at this rate. 

3.2.3 Environmental Consequences of Invasive Plant Treatments on Non-target 

Plants 

Introduction 

All invasive plant treatments are designed to kill or slow the growth of target plants, and some damage to nontarget plant species is likely in all alternatives, despite careful planning and implementation. The effects of nonherbicide methods, including the manual and mechanical methods in the scope of the action alternatives, are 

addressed in Appendix J of the R6 2005 FEIS. While some common vegetation may be impacted by manual and 

mechanical methods, such effects are unlikely to be significant, because an operator would immediately make 

adjustments if adverse effects were to occur. Most of the concern about adverse effects of treatment are related 

to herbicide use, partially because of the potential for drift, leaching or runoff to affect non-target vegetation 

and/or because adverse non-target effects may not be immediately noticeable. 

Herbicides have the potential to shift species composition and reduce diversity of native plant communities, as 

less herbicide-tolerant species are replaced by more herbicide-tolerant species. The type of herbicide and the 

application method may also affect plant pollinators. A reduction or shift in pollinator species could also lead to 

changes in plant species composition or diversity (R6 2005 FEIS Chapter 4.27). For example, the repeated use 

of triclopyr, a broadleaf selective herbicide, might shift the species composition resulting in a reduction of woody 

vegetation and an increase in the herbaceous and grass component. 

Herbicides can move off-site in water, soil, and wind, thereby affecting non-target vegetation. This can result 

from spray drift (broadcast and spot), runoff, leaching, or through groundwater movement. Herbicides can vary 

dramatically in their potential for movement. For example, picloram is highly soluble in water, is mobile under 

both laboratory and field conditions, is resistant to degradation, and has a high potential to leach to groundwater 

in most soils. Glyphosate strongly binds to soil particles, which prevents it from excessive leaching or from 

being taken up from the soil by non-target plants. This herbicide has a low potential for leaching into 

groundwater systems, and degrades quickly (R6 2005 FEIS Chapter 4, 4-29, 4-32). 

Translocation of herbicide between rhizomatous same-species individuals, or from plant-fungi, rootletmycorrhizal interactions can also result in herbicide movement. The result may include mortality, reduced 
Final Environmental Impact Statement 

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100

productivity e.g., physiological, structural, and abnormal growth (R6 2005 FEIS Chapter 4.27). Effects, such as 

mortality, brown spots, and chlorotic coloration, may not be immediate, and may become apparent months later. 

Other non-visible effects e.g., physiologic, may never be noticeable (Marrs, R.H., 1989). 

The risk of adverse effects is dependent on the type of herbicide used and the application method chosen. 

Herbicides have different characteristics, degrees of selectivity, and modes of action. Potency of the herbicide 

and persistence also are a factor, as is duration of the treatment. 

For example, glyphosate is a general, non-selective herbicide, which may kill or damage species from all plant 

families. In contrast, clopyralid has little effect on the mustard family and grasses. Other herbicides are more 

selective and thus have less potential to adversely affect non-target plants. However, glyphosate, which is 

generally non-selective, has no adverse effect on horsetail (non-flowering plant) and some species of algae 

(Cathy Lucero, personal communication, August, 2005). 

Picloram is a persistent herbicide that can remain active for several growing seasons post application. Clopyralid 

mimics auxins, a plant growth hormone and stimulates abnormal growth. Metsulfuron methyl works by 

inhibiting the activity of an enzyme called acetolactate synthase, an enzyme necessary for plant growth. If a nonvascular species does not use the above mechanisms, the herbicide may not have any impact at any distance 

(depending on the surfactant used as well). Table 29 in Chapter 3.1 compares herbicide properties, uses and 

risks. 

The risk to non-target vegetation also varies with the herbicide application method. Spot and hand application 

methods substantially reduce the potential for loss of non-target vegetation because there is little potential for 

drift. Drift is most associated with broadcast treatments and can be mitigated to some extent by the applicator. 

Spray drift is largely a function of droplet particle size. The largest particles, being the heaviest, will fall to the 

ground quickly upon exiting the sprayer. Medium size particles can be carried beyond the sprayer swath (the fan 

shape spray under a nozzle), but virtually all of the particles fall within a short distance of the release point. The 

smallest, and therefore the lightest particles have the potential to travel the farthest. Thus, if the droplet size 

forced out the nozzle can be limited to larger particle sizes, the potential for herbicide to drift beyond the targeted 

vegetation can be controlled. 

Factors affecting droplet size are nozzle type, orifice size and spray angle, as well as spray pressure, and the 

physical properties of the spray mixture. Wind speed restrictions also significantly contribute to a reduction in 

drift (Spray Drift Task Force, 2001). By simply changing the type of nozzle (diameter of pore size) used during 

broadcast treatments, the drift potential of herbicide can be effectively and significantly decreased as the droplet 

size forced out the nozzle is increased in size (Dr. Harold Thistle, personal communication, April 2006). 

The physics of sprayers dictates that there will always be a small percentage of the spray droplets that are small 

enough to be carried in wind currents to varying distances beyond the point of release. Since these smallest 

droplets are a minor proportion of the total spray volume, their toxicological significance beyond the project area 

boundary rapidly declines as they are diluted in increasing volumes of air. Vegetation on the ground, including 

the target invasive species themselves, act as a substantial barrier to herbicide droplet drift as well. 

Marrs, R.H., in the 1989 publication, “Assessment of the Effects of Herbicide Spray Drift on a Range of Plant 

Species of Conservation Interest,” examined the distances drift affected non-target vascular plants using 

broadcast treatment methods similar to those considered in this EIS. Their observations are consistent with driftdeposition models in which the fallout of herbicide droplets has been measured. The maximum safe distance at 

which no lethal effects were found was 20 feet, but for most herbicides the distance was 7 feet. Generally, 

damage symptoms were found at greater distances than lethal effects, but in most cases there was rapid recovery 

by the end of the growing season. No effects were seen to vascular non-target vegetation further than 66 feet 

from the broadcast treatment zone. Little information is available for how drift distances may effect nonvascular non-target vegetation. The distance spray drift will travel can vary substantially based on wind speed, 

topography, temperature, the herbicide applied, and the vegetation present. 
Final Environmental Impact Statement 

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Commercial drift reduction agents are available that are designed to reduce drift beyond the capabilities of the 

determinants previously described. These products create larger and more cohesive droplets that are less apt to 

break into smaller particles as they fall through the air. They reduce the percentage of smaller, lighter particles 

that are the size most apt to drift 

The Common Control Measures (see Chapter 2.5 and Appendix B for details) include information about effective 

herbicides and those to avoid in situations near susceptible non-target vegetation. A100-foot broadcast buffer is 

likely to prevent glyphosate from harming plant species further away (Personal Communications with Dr. Harold 

Thistle, 2005). 

Special Forest Products 

The most popular forest products gathered on the Olympic National Forest are berries, beargrass, salal, 

mushrooms and medicinal plants. Two of these species are target invasive plants (e.g. St. John’s wort, 

Himalayan blackberries). The Olympic National Forest is currently authorized to use herbicide treatments on 86 

acres with no adverse effects on special forest products noted. Non-target special forest products would be 

protected by the Project Design Features in all action alternatives, and increases in herbicide use conceivable in 

all alternatives would not likely result in adverse effects to non-target special forest products. However, forest 

products such as berries that are also invasive species would be killed under the most ambitious treatment 

scenarios. 

Effects from Herbicides to Botanical SOLI by Alternative 

 Direct and Indirect Effects of No Action 

Under No Action, spot and hand herbicide treatment is approved on about 86 acres and manual/mechanical 

treatment on an additional 586 acres. Treatments under the No Action alternative have very low potential to 

adversely impact fungi and vascular and non-vascular plant species of local interest because: 

• The total acreage where herbicide could be used is very low; few treatment acres would occur in any one 

watershed or area of botanical concern. 

• Drift associated with spot application methods is relatively easy to manage and hand application methods 

do not result in any potential drift. 

Under No Action, herbicide use is limited to three herbicides, picloram, dicamba, and glyphosate. This limits the 

range of herbicides available compared to the action alternatives. Picloram poses specific risks to non-target 

vegetation because it can be persistent in the soil for several years, is highly soluble in water, is resistant to 

degradation processes, has a high potential to leach to groundwater in most soils, and is mobile under both 

laboratory and field conditions. Picloram can also move readily to non-target native plants through root 

translocation or runoff (R6 2005 FEIS 4-29). Like picloram, dicamba is a selective herbicide that can affect 

broadleaf and woody species, but in general does not affect grasses (may affect some annual grasses). Runoff 

from dicamba is one of its greatest risks to non-target vegetation, but the effects are highly site specific, and 

therefore difficult to quantify. Vaporized or volatilized dicamba can affect non-target vegetation, but the level of 

effect is not understood, and requires more study (R6 2005 FEIS). 

Table 40-Effects to Non-target Vegetation from No Action 

Alternative Number of Possible Number of SOLI Species at Direct Risk from Treatment 

Broadcast Acres 

Fungi Bryophytes (Moss) Vascular Plants 

No Action 0 0 0 0 
Final Environmental Impact Statement 

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102

Direct and Indirect Effects of Alternatives B (Proposed Action) and D 

Alternatives B and D allow use of several new herbicides (chlorsulfuron, metsulfuron methyl, sulfometuron 

methyl, imazapic, and imazapyr) that are associated with hazards to non-target vegetation (R6 2005 FEIS, 4-27 

to 4-33). The range of herbicides available partially mitigates the risk to non-target vegetation by allowing 

several options; all infestations known within treatment areas may be effectively treated with low risk to nontarget vegetation given careful implementation of Common Control Measures and PDFs. 

Broadcast applications pose the greatest potential for harm to non-target vegetation due to drift. Under the most 

ambitious treatment scenario analyzed, Alternative B is estimated to use broadcast application methods about 34 

percent of the time (1,320 acres); Alternative D is estimated to use broadcast application methods about 86 

percent (3,110 acres) of the time. 

Project Design Features listed in Chapter 2 would adequately protect non-target vegetation, including fungi, 

vascular and non-vascular plant SOLI. Table 16 (Chapter 2.5) displays Protection Widths for Botanical SOLI 

that would apply to all action alternatives. No direct impacts to sensitive species are predicted at this time; 

however, the potential for future conflicts results in a determination that Alternatives B and D May Impact 

Sensitive Plant species. Alternatives B and D would not affect the viability of, and is not likely to lead to, the 

federal listing of any sensitive botanical species. 

Fungi Species of Local Interest 

In general, herbicides are not expected to affect the fruiting bodies of fungi (David Pilz, personal communication, 

Oregon State University, 2005). Fungi can absorb toxic minerals and other toxic compounds, accumulating the 

herbicide. Fungal SOLI are either parasitic or mycorrhizal, both with an extensive underground hyphal network 

that potentially can translocate substances (herbicides) to the fruiting body. The effect of individual herbicides to 

these hyphal networks is largely unknown; therefore, effects to present and future populations of fungi are 

unknown as well. A long term monitoring study would be required to determine effects because population 

variability in fungi is common from year to year. Results of studies of herbicide effects to mycorrhizae are 

varied, running the gamut of effect: stimulation of mycorrhizal growth, no effect, and inhibition (Estok, D. et al, 

1989; Busse, M.D. et. al, 2001). This variability is due to differences in the type of herbicide, the concentration 

utilized, the fungal species, and environmental factors. 

In addition, fungi hyphal networks can extend for long distances, and it is uncertain how to adequately buffer for 

these organisms. Broadcast treatments of herbicide might effect hyphae several hundred feet or more from the 

SOLI site, or not have any effect at all. The duration of the effect is also unclear, and would be variable 

depending on the type and concentration of the herbicide utilized, as well as on environmental factors (microbial 

activity, organic content, soil type, etc.). While the impact herbicides may have on underground hyphal networks 

is uncertain, monitoring of known fungi sites of interest would identify observable impacts. 

Studies have pointed to both beneficial and inhibitory effects due to variation in the type of herbicide, the 

concentration, the species of fungi and environmental factors. However, adverse effect on the three fungal SOLI, 

Albatrellus avellaneus, Bondarzewia mesenterica, and Ramaria lorithamnus, are unlikely as currently there are 

no locations where broadcast treatments would be within 100 feet of the above ground portion (fruiting body) of 

these fungi. Effects to fungi would be difficult to ascertain visually, so while monitoring is recommended to note 

changes in fungi populations after treatment, such monitoring may not be conclusive. 

Lichen and Bryophyte Species of Local Interest 

Bryophyte and lichens are potentially more prone to injury from broadcast drift than other species due to their 

unique physiology. They lack a tissue layer (cuticle) that regulates substances entering cells from the air and 

atmosphere (the cuticle in vascular plants is analogous to human skin). Newmaster et al. (1999) raised concern 

that drift from glyphosate could affect the long-term sustainability of populations of lichens and bryophytes. 

Project Design Features are expected to eliminate impacts to lichens and bryophytes from spot and hand 

application of herbicide. These measures are also expected to eliminate impacts from drift associated with 
Final Environmental Impact Statement 

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103

broadcast application, although there is some uncertainty. Adverse effects (mortality, browning, chlorotic 

coloration, etc.) would likely be visible immediately to several months after treatment. Invisible physiologic 

effects are also possible, including reduced reproductive capacity, where seed-set is reduced or the organism 

becomes infertile. 

The 100-foot buffer Project Design Feature for broadcast treatment is based on a study done under similar 

conditions but for vascular plant species (Marrs et. al., 1989). This buffer incorporates an additional 35 feet to 

mitigate for the uncertainty about effects on non-vascular species. Monitoring and adaptive management (see 

Chapter 2.5) would ensure that buffer widths are appropriate. 

Vascular Plant Species of Local Interest 

Botanical design features were developed to minimize/eliminate effects to vascular plant species from hand, spot, 

and broadcast application of herbicides and are based on scientific literature and resource management 

experience. Proximity between invasives and SOLI species is one factor that determines the potential for effect 

from herbicide application. Translocation may occur between roots of adjacent plants, even with hand 

application of herbicide. 

The robustness or size of the SOLI also plays a role. The likelihood is greater that small, delicate plants may be 

impacted when adjacent invasives are treated. 

Sufficient distance exists between invasive species and botanical SOLI to avoid significant risks, even when 

considering the five rhizomatous botanical SOLI: Carex anthoxanthea, Carex obtusata, Carex pauciflora, 

Galium kamtschaticum, and Pellea breweri. 

Table 41-Effects on Botanical SOLI from Treatments in Alternatives B and D 

Number of SOLI Species at Direct Risk from 

Treatment 

Alternatives Estimated Proportion of 

Project Area Where 

Broadcast Would be 

Allowed 

Fungi Bryophytes (Moss) Vascular Plants

Proposed Action (Alternative B) 34% 0 0 0 

Alternative D 84% 0 0 0 

Direct and Indirect Effects of Alternative C 

Alternative C also allows use of several new herbicides (chlorsulfuron, metsulfuron methyl, sulfometuron 

methyl, imazapic, and imazapyr) that are associated with hazards to non-target vegetation (R6 2005 FEIS, 4-27 

to 4-33). Under Alternative C, there would be no broadcast application of herbicide anywhere on the Olympic 

National Forest so the likelihood of extensive non-target impacts is very low. No direct impacts to sensitive 

species are predicted at this time, however, the potential for future conflicts results in a determination that 

Alternative C May Impact Sensitive Plant species. However, Alternative C would not affect the viability of, and 

is not likely to lead to, the federal listing of any sensitive botanical species. 

Fungi Species of Local Interest 

Alternative C eliminates the broadcast treatment option, therefore eliminating most of the potential for effects to 

fungi. Drift from spot application of herbicide is expected to have no effect to the fungi SOLI, Phaeocollybia 

fallax, because there is sufficient distance to the invasive and drift from spot application is largely controllable by 

the applicator. 
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Lichen and Bryophyte Species of Local Interest 

Alternative C eliminates the broadcast treatment option, therefore eliminating most of the potential for effects to 

fungi. Drift from spot application of herbicide is expected to have no effect to the three fungi SOLI, Albatrellus 

avellaneus, Bondarzewia mesenterica, and Ramaria lorithamnus, because there is sufficient distance to the 

invasive plant and drift from spot application is largely controllable by the applicator. 

Vascular Plant Species of Local Interest 

Botanical PDFs were developed to minimize/eliminate effects to vascular plant species from spot and broadcast 

application of herbicides. Under Alternative C, there would be no broadcast treatments allowable. Proposed 

treatments of the following Olympic National Forest vascular SOLI: Carex anthoxanthea, Carex pauciflora, 

Erythronium quinaultense, Galium kamtschaticum, and Parnassia palustris var. Neogaea, under Alternative C 

would not result in any further direct, or indirect negative effects from treatment to these species, as they are 

mainly found in riparian habitats and would not be treated under Alternative C. 

Carex obtusata, Pellaea breweri, and Synthyris pinnatifida var. lanuginosa are not riparian associated and under 

Alternative C, invasives in proximity to these species could be treated with herbicide. Of the three, none are in 

close proximity to invasives and spot/hand treatment would have no effect.

Table 42-Alternative C Botanical SOLI at Risk from Treatment 

Estimated Proportion of Project Area Number of SOLI at Risk from Treatment 

Where Broadcast Would be Allowed 

Fungi Bryophytes (Moss) Vascular Plants

Alternative C 0 0 0 0 

Biological Evaluation 

The discussions herein and in Appendix C provide the Biological Evaluation that is required by policy for 

Regional Forester’s Sensitive Species and habitats within the project area. None of the sensitive botanical 

species are likely to be directly harmed by the project. The PDFs, buffers and monitoring strategy eliminate the 

likelihood of adverse impacts to species or habitats. No botanical SOLI are near enough to known invasive plant 

sites to be at risk from treatment. 

Under EDRR in all alternatives, an individual SOLI may be damaged or die. Effects on non-vascular plants and 

fungi are particularly uncertain. Therefore, all alternatives are associated with a finding of “May Impact,” for 

sensitive botanical species. 

Pre-project review for potential sensitive non-vascular plants and fungi would occur and any SOLI near a 

treatment site would be buffered or covered by a barrier. The PDFs, buffers and monitoring strategy ensure that 

effects to botanical SOLI would be avoided or minimized. 

Cumulative Effects of Herbicide Use on Non-target Plants and Fungi 

The Affected Environment describes the limited range of some botanical SOLI. While past activities may have 

contributed to the limited extent of botanical SOLI within the analysis area, the pre-disturbance condition is not 

known. Therefore, the baseline for comparison of effects to botanical SOLI is the current inventory. None of the 

alternatives would significantly contribute to population losses of Species of Local Interest compared to the 

current inventory. 
Final Environmental Impact Statement 

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The No Action Alternative does not pose any additional risk to botanical SOLI from treatment above baseline 

conditions. The 1998 EA/DN found that the currently approved treatments under No Action would have no 

significant impact on non-target vegetation. 

While some adverse effects on non-target vegetation are possible from treatments considered in the action 

alternatives, they are unlikely to be significant because the extent and threats posed by treatment are generally 

very small compared to the known range of botanical species, including SOLI. Project Design Features mitigate 

known risks and the monitoring and adaptive management plan would ensure uncertain risks are also mitigated. 

Invasive plant treatments within the range of botanical SOLI may occur on lands outside the National Forest. 

The amount of treatment and/or specific risks from such treatments is unknown. Project Design Features in all 

alternatives minimize or eliminate risks to non-target vegetation. No immediate conflicts between treatments and 

SOLI exist and monitoring and adaptive management would resolve uncertainties over time. 

Summary of Effects of Herbicide Use on Non-target Plants and Fungi 

Table 43 displays the comparison of alternatives in terms of relative risks associated with herbicide use. 

Herbicide use in all alternatives would comply with environmental standards, policies and laws. No loss of 

viability of any botanical SOLI would likely occur. 

Table 43-Summary of Effects on Botanical SOLI 

Alternative Estimated Proportion of Project Area 

Where Broadcast Would be Allowed 

Number Of SOLI At Risk from Invasive Plant 

Treatment (Known Inventory) 

A No Action 0 0 

B Proposed Action 34% 0 

C 0 0 

D 84% 0 

3.3 Terrestrial Wildlife 

3.3.1 Introduction 

The potential effect of invasive plant treatment on wildlife is a primary public issue (Issue Group 4). The 

Olympic National Forest provides diverse habitats, ranging from subalpine forest to wet meadows, and from late 

successional temperate rainforest of Douglas-fir, hemlock and cedar to mixed conifer plantations, for a diverse 

array of wildlife species, including amphibians and reptiles. Olympic National Forest System lands are located 

within the Pacific Flyway, which is a major migratory route for thousands of birds. Many species that are not 

permanent residents on the Forest may be found here during migration. 

Olympic National Forest System lands provide important habitat for three federally listed threatened species and 

two species that are federal candidates, discussed below. No federally listed endangered species occur on the 

Forest. 
Final Environmental Impact Statement 

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Invasive plant species have become established on Olympic National Forest System lands and continue to spread, 

causing a loss of wildlife habitat and posing a risk of injury to wildlife. Methods used to control invasive plants 

have the potential to have adverse effects to individual animals as well as wildlife habitat. The following wildlife 

analysis focuses on potential effects of treatment on terrestrial Species of Local Interest, including Survey and 

Management species; Listed and Proposed Threatened and Endangered Species, Regional Forester Sensitive 

Species and Management Indicator Species (MIS). Effects on MIS species indicate welfare of other species 

using the same habitat (Thomas 1979). Birds of Conservation Concern are also discussed. 

3.3.2 Affected Environment 

Invasive Plants and Wildlife Habitat 

Some wildlife species utilize invasive plants for food or cover. For example, it has been reported that elk, deer 

and rodents eat rosettes and seed heads of spotted knapweed. However, the few uses that an invasive plant may 

provide do not outweigh the adverse impacts to an entire ecosystem (Zavaleta, 2000). More detailed information 

on the effects of invasive plants to wildlife is reported in the R6 2005 FEIS. 

Invasive plants have adversely impacted habitat for native wildlife (Washington Deptartment of Fish and 

Wildlife, 2003). Any species of wildlife that depends upon native understory vegetation for food, shelter, or 

breeding, is or can be adversely affected by invasive plants. In the case of common burdock (Arctium minus),

the prickly burs can trap bats and hummingbirds and cause direct mortality to individuals ((Raloff 1998, National 

Park Service 1999). 

Habitats that become dominated by invasive plants are often not used, or used much less, by native and rare 

wildlife species. 

Washington Department of Fish and Wildlife (2003) identified invasive plants, such as yellow starthistle and 

knapweed, as threats to upland game bird habitat. Species restricted to very specific habitats, for example ponddwelling amphibians, are more susceptible to adverse effects of invasive plants. 

Of the federally listed species that occur on Olympic National Forest System lands, none are known to be 

adversely affected by invasive plants within the project area. Bald eagle mortality in other parts of the U.S. has 

been linked to a toxin produced by a cyanobacterium that grows on the invasive aquatic plant, Hydrilla 

verticillata (Wilde, 2005). 

Some invasive species could adversely affect bald eagle foraging areas by creating dense patches of tall 

vegetation in and around streams or rivers that could hinder access to salmon. This speculation is based on 

observations of some invasive species that grow along rivers and streams in the Region. 

In summary, invasive plants are known or suspected of causing the following effects to wildlife: 

• Embedded seeds in animal body parts (e.g. foxtails), or entrapment (e.g. common burdock) leading to 

injury or death 

• Scratches leading to infection 

• Alteration of habitat structure leading to habitat loss or increased chance of predation 

• Change to effective population through nutritional deficiencies or direct physical mortality 

• Poisoning due to direct or indirect ingestion of toxic compounds found on or in invasive plants 

• Altered food web, perhaps due to altered nutrient cycling 

• Source-sink population demography, with more demographic sinks than sources 

• Lack of proper forage quantity or nutritional value at critical life periods 
Final Environmental Impact Statement 

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Threatened, Endangered, Sensitive, and Management Indicator Species 

Federally Listed Species 

Several species listed as “threatened” under the Endangered Species Act (ESA) of 1973 (as amended) are found 

on Olympic National Forest System lands. In addition, the U.S. Fish and Wildlife Service (FWS) maintains a list 

of “candidate” species. Candidate species are those taxa that the FWS has on file sufficient information on 

biological vulnerability and threats to support issuance of a proposal to list, but issuance of a proposed rule is 

currently precluded by higher priority listing actions (U.S. Fish and Wildlife Service 1996). Listed and candidate 

species of terrestrial wildlife found on Olympic National Forest System lands are included in Table 44. 

Table 44-Federally Listed Species on Olympic National Forest 

Common Name Scientific Name Status Critical Habitat 

Mammals 

Pacific fisher Martes pennanti Candidate None 

Mazama pocket gopher Thomomys mazama melanops Candidate None 

Birds 

Northern spotted owl Strix occidentalis caurina Threatened Designated 

Marbled murrelet Brachyramphus marmoratus Threatened Designated 

The two candidate species found on Olympic National Forest System lands are also included in the Regional 

Forester’s Sensitive Species List and are discussed in the section titled “Forest Service Sensitive Species.” 

Brief general descriptions of the species’ life history, threats, conservation measures, and their occurrence are in 

Appendix C. Detailed species accounts prepared for the Biological Assessment prepared for the R6 2005 FEIS 

are incorporated by reference. 

A Biological Assessment prepared for this project and submitted to the Fish and Wildlife Service (FWS) as part 

of Consultation under the Endangered Species Act is available in the analysis files. The FWS published a Letter 

of Concurrence April 2007, agreeing with the Forest Service that this project is not likely to adversely affect 

federally listed terrestrial wildlife. 

 Forest Service Sensitive Species 

Terrestrial wildlife species found on Olympic National Forest system lands that are included in the Region’s 

“Special Status/Sensitive Species Program” are listed in Table 45. The “Special Status/Sensitive Species 

Program” and the Regional Forester’s Sensitive Species List are proactive approaches 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 FWS as “candidates” for listing under the ESA, and meeting 

the Forest Service criteria for protection, are included on the Regional Forester’s Sensitive Species Lists. 

Table 45-Regional Forester Sensitive Terrestrial Wildlife Species 

Common Name Scientific Name Occurrence on National Forest 

System Lands* 

Mammals 

Townsend’s big-eared bat Corynorhinus townsendii Documented 

Pacific fisher Martes pennanti Extirpated, historically Documented 

Mazama pocket gopher Thomomys mazama melanops Suspected 
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Common Name Scientific Name Occurrence on National Forest 

System Lands* 

Birds 

Bald eagle28 Haliaeetus leucocephalus Documented 

Common loon Gavia immer Documented 

American peregrine falcon Falco peregrinus anatum Documented 

Amphibians 

VanDyke’s salamander Plethodon vandykei Documented 

Cope’s giant salamander Dicamptodon copei Documented 

Olympic torrent salamander Rhyacotriton olympicus Documented 

Terrestrial Invertebrates (also Northwest Forest Plan Survey and Manage Species) 

Puget Oregonian Cryptomastix devia Documented 

Burrington’s jumping slug Hemphillia burringtoni Documented 

Warty jumping slug+ Hemphillia glandulosa Documented 

Malone’s jumping slug Hemphillia malonei Suspected 

Blue-gray taildropper Prophysaon coeruleum Suspected 

Hoko vertigo Vertigo n. sp. Suspected 

*Documented/Suspected: Documented means that an organism that has been verified to occur in or reside on an administrative unit. 

Suspected means that an organism that is thought to occur, or that may have suitable habitat, on Forest Service land or a particular 

administrative unit, but presence or occupation has not been verified. 

+ The warty jumping slug was removed from the Survey and Manage list for Olympic National Forest in the 2001 annual species review. 

The Pacific fisher and the California wolverine do not currently occur on Olympic National Forest system lands. 

The wolverine occurrence is a mistake in the 2004 Regional Forester’s Sensitive Animal List which will be 

corrected in the next version (Piper, 2005, personal communications). The Pacific fisher is extirpated from the 

entire state of Washington (WDFW, 2005). The Pacific fisher and California wolverine will not be discussed 

further in this analysis. 

Brief general descriptions of the species’ life history and their occurrence on the Olympic National Forest are in 

Appendix C. 

Survey and Manage Species 

“Survey and Manage” species were identified in the 1994 Northwest Forest Plan. In 2001 (2001 ROD) and again 

in 2004 (2004 ROD), the agencies sought to make changes in this mitigation measure. The 2004 ROD was 

litigated and on January 9, 2006, Judge Pechman signed an Order that reinstated the 2001 ROD. Thus, the Survey 

and Management Mitigation Measure currently applies to all species that were included in the program in 2001. 

Species that were added to the Regional Forester’s Sensitive Species Program in 2004 remain in both programs 

and are discussed above, with further information in Appendix C. 

For the Olympic National Forest, mollusks were the only fauna included in the Survey and Manage program in 

the 2001 ROD. All Survey and Manage mollusks were added to the Sensitive Species Program, except for 

evening fieldslug (Deroceras hesperium) and are therefore listed above. 

Evening fieldslug 

This slug has been reported to be associated with wet meadows in forested habitat in a variety of low vegetations, 

litter, and debris; rocks may also be used (Pillsbury 1944). Little is known about this species or its habitat, but it 

is thought to be most associated with perennial wetlands, springs, seeps in riparian areas (Duncan et al. 2003). It 

is one of the least known slugs in the western U.S. (Duncan 2005). Most of the 19 documented sites for this 

species occur on the eastern slope of the Oregon Cascades (Duncan 2005). 

 

28The bald eagle was removed from the endangered species list (delisted) on June 28, 2007 (U.S. Fish and Wildlife Service 

2007). Effects and PDFs would not be affected by the delisting; as per Forest Service policy, it is now included on the 

Region 6 Regional Forester’s Sensitive Species List. No changes to PDFs were made. 
Final Environmental Impact Statement 

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 No known sites are reported in Washington. From 1998-2002, the Olympic National Forest conducted extensive 

surveys for this species, as well as other mollusks, across the forest in a range of habitat conditions. Because the 

evening fieldslug has not been documented on the Olympic National Forest, no effects are conceivable and this 

species will not be discussed further in this document. 

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 1979). Table 46 includes those species that were identified as 

MIS for the Olympic National Forest (USDA 1990). Aquatic MIS are discussed in the aquatic species 

specialist’s report. 

Table 46-Terrestrial Wildlife Management Indicator Species 

Common name Scientific Name 

Bald eagle Haliaeetus leucocephalus 

Northern Spotted owl Strix occidentalis caurina 

Pileated woodpecker Dryocopus pileatus 

“Primary cavity excavators” see below 

Columbian black-tailed deer Odocoileus hemionus columbianus 

Roosevelt elk Cervus canadensis roosevelti 

Pine marten Martes americana 

Species identified as MIS for the Olympic National Forest, with the exception of the Roosevelt elk and Columbia 

black-tailed deer, represent a suite of species that are dependent on mature and old-growth forest habitat. The 

black-tailed deer and elk represent wildlife associations that require a mix of vegetative age classes. 

Pileated woodpecker 

The pileated woodpecker represents species that inhabit mature coniferous forest habitats. The pileated 

woodpecker is the largest woodpecker species in the western United States and nests in cavities of large trees or 

snags. 

It is a denizen of mature forests, relying on dead and decaying trees for foraging and nesting. Pileated 

woodpeckers can act as a keystone habitat modifier by excavating large numbers of cavities that are depended 

upon by several other species, and by influencing ecosystem processes such as decay and nutrient cycling (Aubry 

and Raley 2002). Pileated woodpeckers will return to areas after timber harvesting (Ehrlich 1988), however, past 

management in the Pacific Northwest has lead to relatively few snags and down logs, especially of large 

diameters, remaining in many watersheds. Previous timber harvest, as opposed to wildfire events, has had the 

greatest effect on the availability of large diameter standing dead trees in the Olympic National Forest.

Primary Cavity Excavators 

A large number of species rely on cavities in trees for shelter and nesting. The Olympic National Forest has 

designated a group of species for this Management Indicator category. This group of species represents snagdependent cavity nesters, and includes animals dependent on dead or dying trees for nest sites. “Primary cavity 

excavators” comprise a broad group of species associated with standing dead trees or snags and down logs, and 

that excavate their own nests. Species included in this MIS group are listed in Table 47. 

Table 47-Primary Excavator Species 

Primary Excavators Occurrence on Olympic National Forest 

Lewis’ woodpecker transient 

Red-breasted sapsucker common 
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Primary Excavators Occurrence on Olympic National Forest 

red-napped sapsucker transient 

downy woodpecker very common 

hairy woodpecker very common 

three-toed woodpecker very rare 

black-backed woodpecker transient 

northern flicker very common 

pileated woodpecker common 

black-capped chickadee common 

mountain chickadee very rare 

chestnut-backed chickadee very common 

red-breasted nuthatch very common 

white-breasted nuthatch transient 

northern flying squirrel common 

Brief general descriptions of the cavity excavator’s life history and their occurrence are in Appendix C 

Roosevelt Elk and Columbian Black-tailed Deer 

These two species are known throughout the Olympic National Forest and Peninsula. There are several 

established herds of Roosevelt elk that reside on the Forest as year-round residents, as well as many that are 

migratory, for example, moving into the Olympic National Park during the summer. Deer occur throughout the 

forest, and both species use a combination of habitats comprised of cover and forage areas that are not too 

fragmented by road systems. Taber and Raedeke (1980) reported that winter mortality, legal harvest, and 

poaching were the primary causes of elk mortality. Poaching is the second leading cause of mortality to elk in 

Washington State and is prevalent on the Olympic Peninsula (WDFW 2004). As one might expect, a high 

density of roads, common throughout much of the Peninsula, would have a negative impact on elk with increased 

disturbance from legal hunting and poaching (CEMG 1999). 

On the Olympic Peninsula, winter range is typically defined as land below 1500 feet in elevation (USDA 1995). 

The Olympic Land and Resource Management Plan (USDA 1990) provides interim direction that in those areas 

managed for winter survival, habitat should be managed to provide 10-15 percent of the area in openings (natural 

and created) and the remainder in thermal and hiding cover, 20 percent of which should be optimal cover (the 

Land and Resource Management Plan also recommends managing roads to reduce wildlife disturbance). 

Preferred forage areas are in natural openings or managed stands that have been harvested no later than 30 years 

ago. 

Pine Marten 

The pine marten (also known as the American marten) represents species that inhabit mature coniferous forest 

habitats. Pine martens occur in forests containing snags and down logs, which provide suitable denning sites. 

Pine marten are most closely associated with heavily forested east and north-facing slopes that contain numerous 

windfalls (Maser 1998). They tend to avoid areas that lack overhead protection and the young are born in nests 

within hollow trees, stumps, or logs. According to a Washington Department of Fish & Wildlife study (Sheets 

1993), which combined trapper interviews with remote camera surveys in various locations on the Peninsula, it 

was concluded that marten may only be found within the Olympic National Park, and in surrounding low 

elevation wilderness areas and un-fragmented mature timber on the Olympic National Forest adjacent to the park. 

National Forest land, in general, has perhaps become too fragmented to support a population. 

Historic fire and intensive forest stand management within the national forest has lead to relatively few large 

snags and down logs, resulting in lower densities relative to historic levels. Much of the area is less than 60 

years old and is interspersed with small patches of old growth. 

The Olympic National Park has conducted surveys for pine marten in recent years using smoked track plates and 

remote camera stations. No pine marten have been detected within the park during these surveys. Given these 

survey results, it is unlikely that they would occur on the Olympic National Forest, but they could be present in 

more remote wilderness areas, or in contiguous mature forest, where forest has not been fragmented. 
Final Environmental Impact Statement 

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Birds of Conservation Concern 

Olympic National Forest System lands are included in Bird Conservation Region Five (Northern Pacific Forests). 

Within this region, Olympic National Forest System lands may provide significant habitat, based on range maps 

in NatureServe Explorer (NatureServe 2005, Ridgely et al. 2003) and forest survey information) for five species 

listed by the United States Department of Interior Fish and Wildlife Service (FWS) as “Birds of Conservation 

Concern.. These species include black swift (Cypseloides niger), rufous hummingbird (Selasphorus rufus), and 

olive-sided flycatcher (Contopus cooperi). Peregrine falcons (Falco peregrinus) are included in Bird 

Conservation Region Five and occur on the Olympic Peninsula, but they are not known to nest on Olympic 

National Forest System lands, based on recent surveys. Brief descriptions of these species’ life history are found 

in Appendix C. 

Landbirds 

In 1999, Partners in Flight released a conservation strategy for landbirds in coniferous forests of western Oregon 

and Washington (Altman 1999). The strategy identifies a select group of focal species and their associated 

habitat attributes that can be used to identify desired forest landscapes. All of the focal species identified 

(Altman 1999, Table 3, p. 20) are found on the Olympic National Forest. The strategy is intended to help 

facilitate land management planning for healthy populations of native landbirds. The document focuses on 

landscape-scale forest management, with emphasis on habitat structure. The conservation options recommended 

in the strategy are not relevant to invasive plant treatments because the treatments proposed in this FEIS do not 

involve modifying forest habitat structure or any other modifications to native habitat. 

Amphibian Decline 

Many species of amphibians in many parts of the world have experienced alarming population declines in the 

past two decades. International task forces have been formed and scientists have researched causes. A number of 

studies have documented declines, even in relatively undisturbed habitats (Drost and Fellers 1996, Lips 1998), 

while other studies have found some populations to be stable (Pechmann et al. 1991). However, detecting actual 

population declines in amphibian populations is difficult due to the extreme annual variation in populations 

caused by environmental factors, such as drought (Pechmann et al. 1991, Reed and Blaustein 1995). 

Potential causes of amphibian declines investigated include ultraviolet radiation (Starnes et al. 2000, Adams et al. 

2001), pesticides (Bridges and Semlitsch 2000), global warming (Blaustein et al. 2001, Crump 2005) habitat loss, 

non-native predators (e.g. Drost and Fellers 1996, Knapp and Matthews 2000), and disease (Muths et al. 2003, 

Berger et al. 1998, Berger et al. 1999), among others. Results of studies are variable and some populations are in 

decline while others are not. There is no “smoking gun” and all the causes are implicated to some degree 

(Halliday 2005). 

Hayes et al. (2003, 2006) found that exposure to the herbicide atrazine caused hermaphroditism and testicular 

oocytes in African clawed frogs and wild leopard frogs and suggested that this could be concern in regard to 

amphibian declines. Population level effects to amphibians from atrazine exposure are unclear as wild leopard 

frogs were abundant at collection sites for the Hayes et al. study (2003). 
Final Environmental Impact Statement 

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3.3.3 Environmental Consequences 

Introduction 

Effects of invasive plant treatment methods to wildlife were evaluated and discussed in detail in the R6 2005 

FEIS and its Appendix P, the corresponding Biological Assessment (USDA Forest Service 2005c), project files, 

and SERA risk assessments (2001, 2003, 2004). These documents indicate that disturbance from manual and 

mechanical treatment pose greater risks to terrestrial wildlife species of local interest than herbicide use. 

Exposure scenarios used to analyze potential effects from herbicides are discussed in Appendix P of the 2005 R6 

FEIS (pp. 15-17). The potential effects to birds from herbicide are listed in Table 4-9 of the R6 2005 FEIS. 

A summary of direct and indirect effects to terrestrial wildlife Species of Local Interest follows: 

For spotted owls and marbled murrelets, loud and sudden noises above background or ambient levels (those 

above 92 dB) can cause disturbance that might flush a bird off the nest or abort a feeding attempt. Vehicles used 

to spray roadside vegetation with herbicides do not make noise above 92 dB, based on recent field 

measurements, so no “injury” or “harassment” from noise will occur. Other mechanical devises proposed for use 

on invasive plants include brushing machines, mowers, chainsaws, and string trimmers. These tools have the 

potential to create noise above background levels that may disturb owls or murrelets if used close to nests during 

the early nesting season. Bald eagles could be disturbed by these same tools, as well as human presence, but 

eagles are quite variable in their responses to activity and noise in the vicinity of their nests or roosts. 

Small species that lack rapid mobility (e.g. mollusks and salamanders) are vulnerable to crushing or injury from 

people or equipment. Invasive plant treatments will not alter native habitat structure or composition for MIS, or 

bird species included in Birds of Conservation Concern or the Partners in Flight strategy for landbirds (Altman 

1999). 

Risk from herbicide exposure was determined using data and methods outlined in the SERA risk assessments. 

Tables 8 and 9 in the Biological Assessment for the R6 2005 FEIS (USDA Forest Service 2005c, pp. 138-140) 

list the toxicity indices used as the thresholds for potential adverse effects to mammals and birds (respectively) 

from each herbicide. A quantitative estimate of dose using a “worst case” scenario was compared to these 

toxicity indices. There is insufficient data on species-specific responses to herbicides for free-ranging wildlife, 

so wildlife species were placed into groups based on taxa type (e.g. bird, mammal), body size, and diet (e.g. 

insect eaters, fish eaters, herbivores). 

Under “worst case” scenarios, mammals and birds that eat insects or grass may be harmed by some herbicides 

and surfactants. Amphibians also appear to be at higher risk of adverse effects due to their permeable skin and 

aquatic or semi-aquatic life history. 

The SERA and Bakke risk assessments and the R6 2005 FEIS indicated that for typical application rates, 

triclopyr and NPE surfactants produced doses that exceeded toxicity indices for birds and mammals. NPE 

surfactant exceeded the toxicity index for direct spray of a small mammal, large mammal and large bird that 

consumed contaminated vegetation (acute), and small mammal and small bird that consume contaminated 

insects. 

The “worst case” exposure scenarios do not account for factors such as timing and method of application, animal 

behavior and feeding strategies, seasonal presence or absence within a treatment area, and/or implementation of 

Project Design Features. Therefore, risk is overestimated when compared to actual applications proposed in this 

EIS. 

Nonetheless, caution in the design and implementation of the project is warranted. In many cases, insufficient 

data is available to allow quantitative risk assessment. For instance, data was insufficient to assess risk of 

chronic exposures for a large grass-eating bird from NPE exposure, or insect-eating birds and mammals for 

several herbicides. Data was also lacking on potential adverse effects of herbicides to mollusks and amphibians. 
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Some data suggested that amphibians may be as sensitive to herbicides as fish (Berrill et al. 1994; Berrill et al. 

1997; Perkins et al. 2000). 

The limited spatial extent of infestations, which are limited primarily to disturbed roadsides (see Section 2.5), 

and the limits placed on herbicide applications will reduce exposure of wildlife to herbicides. Standards 19 and 

20 adopted in the R6 2005 ROD require that adverse effects to wildlife species of local interest from invasive 

plant treatments be minimized or eliminated through project design and implementation. In addition, Standard 

16 restricts broadcast use of triclopyr, which eliminates plausible exposure scenarios. All action alternatives 

must be designed to comply with these standards. 

To account for uncertainty, the Project Design Features, for example, eliminate broadcast herbicide treatments 

near perennial streams; minimize disturbance to certain habitats during certain times of the year; and limit the 

amount or proportion of certain habitats that may be treated in a 30-day period. These Forest Plan Standards and 

Project Design Features ensure that no alternative adversely affects federally listed species; results in a trend 

toward listing of any sensitive species; nor adversely impacts the habitat of Management Indicator Species, 

landbirds, or Birds of Conservation Concern. 

Direct and Indirect Effects on Federally Listed Species: Spotted Owls, Marbled 

Murrelets 

This project is not likely to adversely affect northern spotted owl and marbled murrelet. Marbled murrelets feed 

upon fish, however their prey is not found on National Forest System land. Even if they fed on contaminated fish 

for a lifetime, the estimated dose for herbicide or NPE does not exceed a threshold of concern for potential 

effects (i.e. the toxicity index). 

For spotted owls, no herbicide or NPE dose from feeding on prey that had been directly sprayed exceeded the 

toxicity index for typical application rates. In addition, exposure of spotted owl prey to herbicide, and the 

consumption of contaminated prey by spotted owls are not plausible because of the life history and habitat of the 

prey. The owl’s arboreal and nocturnal prey, which does not feed upon invasive plants, has almost no 

opportunity to become exposed to herbicide or NPE surfactants. 

Northern Spotted Owl 

Disturbance 

Invasive plant treatments may disturb spotted owls during the nesting season. Direct effects from invasive plant 

treatment include disturbance caused by noise, people, vehicles and equipment. The potential for visual 

disturbance to cause harassment of spotted owls is low. Noise-generating activities above ambient could 

potentially cause enough disturbance to result in harassment of northern spotted owls during the breeding season. 

Noise or visual stimuli may interrupt or preclude essential nesting and feeding behaviors, cause flushing from the 

nest or missed feedings of young (U.S. Fish and Wildlife Service, 2003). 

Projects that generate noise or activity above ambient levels and occur within the 35 yards (for heavy 

equipment), or 65 yards (for chainsaws or motorized tools), from an active spotted owl nest may cause these 

harassment effects (U.S. Fish and Wildlife Service, 2003). Some equipment used to treat invasive plants could 

create noise above ambient levels, depending upon site-specific conditions. Engines used to pump herbicide and 

other liquids through nozzles for roadside spraying operations, normally in the back of a pick up truck, may 

generate noise levels that could disturb spotted owls. Because noise levels of this type of equipment were not 

known, two diesel pump engines used for roadside spraying were evaluated for noise level. Two separate 

readings of different pump engines using different decibel meters produced readings of 72-75 decibels within 10 

yards, dropping to 64-67 decibels at 35 yards (observations in the project file). The threshold for noticeable 

noise is 70 decibels and the threshold for disturbance causing “injury” or “harassment” is 92 decibels (U.S. Fish 

and Wildlife Service 2003). Vehicles used to spray roadside vegetation with herbicides do not make noise above 

92 dB, based on the measurements taken, so no effect to the northern spotted owl from noise disturbance will 

occur. Within 10 yards of a nest or un-surveyed suitable habitat, roadside spraying could create a brief noise of 
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notice to spotted owls (e.g. slightly above 70 dB), but not loud enough to create disturbance (U.S. Fish and 

Wildlife Service 2003, project file data). County Weed Coordinators also reported that the noise of diesel pump 

engines measured for this analysis was greater than the noise of gasoline-powered pump engines used by some 

operators (D Sherwin personal communication 2005, D. Durfey personal communication 2005). The gasolinepowered pump engines are likely quieter than the diesel pump engines in the study. 

On Olympic National Forest System lands, five known spotted owl activity centers are located within 65 yards of 

treatment areas where brushing or mowing is currently prescribed. There is also an abundance of unsurveyed 

suitable habitat on the Olympic National Forest where spotted owls could nest. Mowing and brushing uses 

machinery that can create louder noise, so treatment areas with these methods was considered a potential 

disturbance effect for owls. 

Treatment areas that may use brushing or mowing include 3,442 acres of suitable habitat for spotted owls and/or 

marbled murrelets. The mandatory PDF for spotted owls (PDF J2) requires that these methods, or others that 

generate sufficient noise (greater than 92 dB), to be conducted farther away than 35 yards for heavy equipment or 

motorized hand tools, and 65 yards for chainsaws, or outside the breeding season. This PDF is also included in a 

Programmatic Biological Opinion for the Olympic National Forest (U.S. Fish and Wildlife Service, 2003) and 

will minimize effects to spotted owls because it minimizes or eliminates the source of disturbance near nests or 

suitable habitat. 

Therefore, noise from mechanical and manual methods to control invasive plants, including equipment used to 

spray roadside vegetation, “may affect, but is not likely to adversely affect” spotted owls. 

Effects of Herbicides 

Exposure scenarios used to analyze potential effects from herbicides are discussed in R6 2005 FEIS, Appendix B, 

p. 461. None of the herbicides proposed for use in this EIS nor NPE surfactants, applied at typical application 

rates, pose a risk to northern spotted owls. 

Spotted owls are not likely to be directly sprayed, or encounter vegetation that has been directly sprayed, because 

no aerial applications are proposed. No ground applications of herbicide would reach the upper canopies of 

mature trees where the owls nest and forage. 

Spotted owls within Douglas-fir/Hemlock forests prey on red tree voles and flying squirrels, which are nocturnal 

and chiefly arboreal. Voles feed on the needles of Douglas-fir trees and the flying squirrels feed primarily on 

fungi and lichen. Arboreal owls or their prey are unlikely to be exposed to herbicides used within their activity 

centers in this forest type. However, a worst-case exposure scenario for the spotted owl was conducted using 

consumption of prey that had been directly sprayed and assuming 100 percent absorption of the herbicide. 

The following interpretations of the exposure scenario results are made with the reservation that toxicity data was 

generated from laboratory animals which may not accurately represent potential effects to free-ranging wildlife. 

At typical application rates, the estimated doses from the exposure scenarios are all less than the reported 

NOAELs (no-observable adverse effect levels) for all herbicides and NPE. Therefore, there is no basis for 

asserting or predicting that adverse effects to spotted owls from NPE or the herbicides considered in this EIS are 

plausible. 

Critical Habitat 

Invasive plant treatments do not remove or modify any of the primary constituent elements that define critical 

habitat. The action alternatives will have “no effect” to critical habitat for the northern spotted owl. 
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Marbled Murrelet

Disturbance 

Invasive plant treatments are associated with disturbance that may occur during the marbled murrelet nesting 

season. Direct effects from invasive plant treatment include disturbance caused by noise, people, equipment and 

vehicles. However, the potential for visual disturbance to cause harassment of marbled murrelet is low. 

Noise-generating activities above 92 dB could potentially cause enough disturbance to result in harassment 

during the breeding season (U.S. Fish and Wildlife Service 2003). Vehicles used to spray roadside vegetation 

with herbicides do not make noise above 92 dB, based on the measurements taken, so no effect to the marbled 

murrelet from noise disturbance will occur. Within 10 yards of a nest or un-surveyed suitable habitat, roadside 

spraying could create a brief noise of notice to marbled murrelets (e.g. slightly above 70 dB), but not loud 

enough to create disturbance resulting in “harassment” or “injury” (U.S. Fish and Wildlife Service 2003, project 

file data, see spotted owl section above). 

Mowing and brushing uses machinery that can create louder noise, so treatment areas with these methods may 

disturb murrelets. Treatment areas that may use brushing or mowing include 3,442 acres of suitable habitat for 

spotted owls and/or marbled murrelets. 

Mandatory PDFs (J3a and J3b) for marbled murrelets require that these methods, or others that generate 

sufficient noise, be conducted farther away than 35 yards for heavy equipment or motorized hand tools, and 45 

yards for chainsaws, or outside the breeding season. This will minimize any potential disturbance. There are 20 

known or historic marbled murrelet sites within 65 yards of treatment areas that are currently prescribed for 

brushing or mowing. These PDFs have been included in a Programmatic Biological Opinion for the ONF (U.S. 

Fish and Wildlife Service, 2003) and will minimize effects marbled murrelets because it minimizes or eliminates 

the source of disturbance near nests or suitable habitat. 

Therefore, noise from mechanical and manual methods to control invasive plants, including equipment used to 

spray roadside vegetation, “may affect, but is not likely to adversely affect” marbled murrelets. 

Effects of Herbicide 

Exposure scenarios used to analyze potential effects from herbicides are discussed in USDA Forest Service 

2005b, Appendix B. None of the herbicides proposed for use in this EIS nor NPE surfactants, applied at typical 

application rates, pose a risk to marbled murrelets. 

Marbled murrelets are not likely to be directly sprayed, or encounter vegetation that has been directly sprayed, 

because no aerial applications are proposed. No ground applications of herbicide would reach the upper canopies 

of mature trees where murrelets nest. 

Murrelets feed on marine fish, which will not be exposed to herbicides or NPE from control of invasive plants on 

lands administered by the Forest Service. It is not plausible for their primary prey to be exposed to herbicides or 

NPE considered in this analysis. However, some murrelets in some locations have been reported to feed upon 

some freshwater fish (Carter and Sealy 1986). Therefore, in order to investigate a worst-case scenario for 

exposure, a scenario involving the consumption of contaminated fish was analyzed. The potential for the 

herbicides included in the action alternatives to adversely affect marbled murrelets was determined using 

quantitative estimates of exposure from worst-case scenarios. The dose estimates for fish-eating birds were 

calculated using herbicide or NPE concentrations in fish that have been contaminated by an accidental spill of 

200 gallons into a small pond. 

Assumptions used include no dissipation of herbicide, bioconcentration is equilibrium with water, contaminant 

level in whole fish is used, and upper estimate assumes 15 percent of body weight eaten/day. For chronic 

exposures, we used a scenario where the bird consumes fish from water contaminated by an accidental spill over 
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a lifetime. All estimated doses used in effects analysis were the upper levels reported in the Forest Service/SERA 

risk assessments. 

The following interpretations of the exposure scenario results are made with the reservation that toxicity data was 

generated from laboratory animals that may not accurately represent potential effects to free-ranging wildlife. 

The results of the exposure scenarios indicate that no herbicide or NPE surfactant poses any 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 NOAEL (see R6 2005 ROD, Appendix B). Even if they fed, for a lifetime, upon fresh-water 

fish that had been contaminated by an accidental spill of herbicide or NPE, they would not receive a dose that 

exceeds any known NOAEL. Therefore, marbled murrelets would not be adversely affected by herbicide use in 

any alternative. 

Critical Habitat 

Invasive plant treatments do not remove or modify any of the primary constituent elements that define critical 

habitat. The action alternatives will have no effect to critical habitat for the marbled murrelet. 

Summary of Effects Determinations – Federally Listed Species 

Table 48-Effects Determinations on Federally Listed Species (All Action Alternatives) 

Species Status Effects Determinations 

Northern Spotted Owl Threatened May Affect, Not Likely to Adversely Affect 

Marbled Murrelet Threatened May Affect, Not Likely to Adversely Affect 

Direct and Indirect Effects on Regional Forester Sensitive Species 

Under all alternatives, two primary effects on sensitive wildlife species are plausible: 1) disturbance and 

trampling from machinery or people treating invasive plants; and 2) risk from herbicide contact, particularly to 

species for which data is not sufficient to allow quantitative estimates of risk. 

Sensitive species’ habitat would be protected in all alternatives because invasive plant treatments do not remove 

suitable habitat for any species, and the majority of the treatments will occur along highly disturbed roadsides 

which do not provide suitable habitat in most cases. Some species on the Olympic National Forest may have 

suitable habitat along roads, although in small amounts relative to the amount of suitable habitat that is not within 

a road corridor. 

Bald Eagle 

Disturbance 

Potential effects of invasive plant treatment methods on bald eagles are associated with disturbance that may 

occur during the nesting season. Direct effects from invasive plant treatment include disturbance caused by 

noise, people and vehicles. Human and vehicle presence can disturb bald eagles during the breeding season, 

causing the birds to leave nests, or stay away from the nest long enough to have detrimental effects to eggs or 

young (U.S. Fish and Wildlife Service, 1986). Effects from mechanical methods (e.g. tractors, bulldozers, 

chainsaws, or string trimmers) may be more likely to occur at greater distances from the project site, because 

machinery creates louder noise. 

The critical period in Washington when human activities could disturb occupied nests extends from January 1 to 

August 15 (U.S. Fish and Wildlife Service, 2003, p.9). Bald eagles are sensitive to human disturbance during 

this time, particularly within sight distance of nest sites. Invasive plant treatments will avoid conducting projects 

that create noise or disturbance above ambient levels in proximity to an occupied nest during the nesting season, 

as required by PDF J1a. This same PDF is included in a Programmatic Biological Opinion for the Olympic 
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National Forest (U.S. Fish and Wildlife Service, 2003) and will minimize effects to bald eagles because it 

minimizes or eliminates the source of disturbance near nests. 

Invasive plant treatments will not result in the removal of bald eagle nest or roost trees, or suitable habitat, 

because invasive plants do not provide habitat. Projects could occur within suitable habitat. 

Eleven bald eagle nests occur within 0.25 mile of proposed treatment areas. Because disturbance is a plausible 

occurrence, all action alternatives may affect bald eagle. However, the project design features included in all 

alternatives would minimize the likelihood that disturbance to nesting eagles would actually occur. Therefore, all 

alternatives “May Impact Individuals, but Would Not Likely Lead to a Trend toward Federal Listing.” 

Wintering bald eagles on the Olympic National Forest can be sensitive to disturbance from October 31 to March 

31 (U.S. Fish and Wildlife Service, 2003, p. 9). Disturbance near winter roost sites is not likely to occur in any 

alternative because invasive plant treatments generally do not occur during the winter and PDF J1b will minimize 

or eliminate the source of disturbance near winter roosts. 

Effects of Herbicides 

Herbicides and surfactants applied according to PDFs, pose no risk to bald eagles. Bald eagles are not likely to 

be directly sprayed, or encounter vegetation that has been directly sprayed, because no aerial application is 

proposed. No ground applications of herbicide would reach the upper canopies of mature trees where bald eagles 

nest. 

The potential for the herbicides to adversely affect bald eagles was determined using quantitative estimates of 

exposure from worst-case scenarios. The dose estimates for fish-eating birds were calculated using herbicide or 

NPE concentrations in fish that have been contaminated by an accidental spill of 200 gallons into a small pond. 

Assumptions used include no dissipation of herbicide, bioconcentration is equilibrium with water, contaminant 

level in whole fish is used, and upper estimate assumes 15 percent of body weight eaten/day. For chronic 

exposures, we used a scenario where the bird consumes fish from water contaminated by an accidental spill over 

a lifetime. All estimated doses used in effects analysis were the upper levels reported in the Forest Service/SERA 

risk assessments. 

The following interpretations of the exposure scenario results are made with the reservation that toxicity data was 

generated from laboratory animals, which may not accurately represent potential effects to free-ranging wildlife. 

The results of these exposure scenarios indicate that no herbicide or NPE surfactant poses any 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 R6 2005 FEIS, Appendix B). The weight 

of evidence suggests that adverse effects to bald eagles from NPE or the herbicides included in the action 

alternatives are not plausible. 

Townsend’s big eared bat 

This bat is known to have roosts on bridges within or near treatment areas. Traffic along the roads and the 

bridges used for roosting was well-established when the bats colonized the bridges. Roadside treatments 

typically consist of a boom or nozzle spray attached to a pick-up truck, or a person with a backpack sprayer 

conducting spot sprays of plants. Both treatment methods only take a couple minutes to conduct, do not generate 

noise much beyond the background noise of the road and bridge use, and do not occur in close proximity to the 

bats themselves. Therefore, the likelihood of disturbing roosting bats during treatment of roadside invasive 

plants is remote. Invasive plant treatments in the treatment areas near bridges known to be utilized by 

Townsend’s big-eared bats are not likely to adversely impact Townsend’s big-eared bats. 

The bats forage over large areas catching insects (primarily moths) in flight or by gleaning from vegetation. The 

small amount of acreage proposed for treatment, scattered in small patches, make it unlikely that the bats would 

forage within treatment areas and on insects that have been inadvertently sprayed by herbicides and NPE 
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surfactant. If contaminated insects were ingested, only NPE surfactants resulted in a dose that exceeds the 

toxicity index. In order to receive this dose, the bat would have to consume nothing but contaminated insects for 

an entire nights feeding. Given the bats foraging habits, it is unlikely that bats would be exposed to this level of 

NPE. In addition, because the bats roost in crevices well above ground level during the day, it is not plausible 

that they could be directly exposed to spray of herbicides or NPE. 

Data is lacking on risk from chronic exposure to contaminated insects. The likelihood of a chronic exposure to 

contaminated insects is remote, given the small acreages treated and the relatively large areas in which bats 

forage. 

The bats are not likely to forage exclusively within treated areas over a 90-day period (the chronic exposure) so 

there does not appear to be a plausible risk from chronic exposure. Therefore, “no impact” to Townsend’s bigeared bats will occur for all action alternatives. 

Mazama (Olympic) Pocket Gopher 

Mazama (Olympic) pocket gopher is not known to occur on the Olympic National Forest, but there may be 

suitable habitat within the higher elevations in Buckhorn Wilderness. Treatment areas 9H-01 and 9H-Three 

O’Clock Botanical Area are adjacent to the wilderness, but occur at the lower elevations than inhabited by 

Mazama pocket gophers. Since there are no proposed treatment areas within suitable habitat, no alternatives 

would impact the Mazama pocket gopher. 

Common Loon 

The loon has been documented on Lake Quinault and Wynoochee Lake within Olympic National Forest system 

lands. They are winter visitors and are not known as breeding residents. Proposed invasive plant treatment sites 

(9P-32, 9P-32a, and 9H-27) are located within Forest Service campgrounds that are adjacent to Lake Quinault 

and Wynoochee Lake. Invasive plant treatments are planned to be a combination of herbicide and manual 

techniques and would occur during spring and summer. No dose of herbicide or NPE exceeded toxicity indices 

even in a “worst case” scenario. Since the treatments would occur when loons are not likely to be present, and 

herbicide effects are not plausible, there will be “no impact” to common loons from proposed treatments, 

regardless of alternative chosen. 

American Peregrine Falcon 

No current nest sites for peregrine falcon occur within 1.5 miles of any proposed treatment area, the mandatory 

PDF will avoid disturbance, and no herbicide or NPE dose exceeded the toxicity indices for fish-eating birds 

even in a “worst case” scenario, so there would be “no impact” to peregrine falcons regardless of alternative 

chosen. 

Cope’s giant, Olympic Torrent and Van Dyke’s Salamander 

The Copes’ giant and Olympic torrent salamanders are highly aquatic and found in streams. There are 12 known 

sites for Cope’s giant salamander documented on the Olympic National Forest, but none occur within treatment 

areas. There are 27 known sites for the Olympic torrent salamander on National Forest system lands, 2 of which 

are in treatment areas. Van Dyke’s salamander is associated with moist areas, including streams, seeps, and 

springs and is active when soil moisture is high and temperatures are cool. There are 22 known sites for Van 

Dyke’s salamander on the Olympic National Forest, 1 of which is within a treatment area. 

Suitable habitat for all three of these salamanders exists on the forest; much of it has not been surveyed. Suitable 

habitat has not been mapped but can be considered to be most closely associated with riparian areas. For 

purposes of this analysis, the Aquatic Influence Zone (the inner half of Riparian Reserves) is used as an indicator 

of suitable salamander habitat that has not been surveyed. This will greatly overestimate the actual suitable 

habitat for these rare salamanders, which have quite specific habitat associations. Treatments are proposed for 

approximately half of one percent of Aquatic Influence Zones across the Forest. 
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Mechanical treatments near streams and springs can create ground disturbance that could introduce silt into 

salamander habitat, potentially clogging the gills of the salamanders and resulting in mortality. Little is known 

about the effects of herbicides other than the potential for herbicides to cause mortality or result in malformations 

of amphibian larvae. Effects of herbicides to amphibians are discussed in the Appendix P of the R6 2005 FEIS 

(pp. 28-31). 

Project Design Features H1, H1a, H6-11, and J5 limit broadcast application of herbicides would minimize 

exposure of salamanders to the herbicides most likely to have adverse effects. Limiting broadcast application of 

herbicides within potential salamander habitat reduces the likelihood and amount of herbicide that could 

contaminate water, soil or rocks used by salamanders. Broadcast spray buffers apply wherever and whenever 

water is present, which is where and when salamanders are most likely to occur. In addition, there is little 

overlap between the habitat for these salamanders and locations of infestations to be treated, as suggested by the 

Aquatic Influence Zone acres described above. Most invasive plants occur in more open, drier, and previously 

disturbed sites. 

Because there is minimal overlap between actual treatment sites and salamander habitat, and project design 

feature minimize exposure to herbicides, this project may adversely impact individuals, but is not likely to lead to 

a trend toward federal listing of these salamanders. 

Puget Oregonian, Hoko Vertigo, Malone Jumping Slug, and Blue-Gray Taildropper 

These four mollusks are not located within any treatment areas, and likely do not occur on Olympic National 

Forest System lands, so there would be “no impact” to these mollusk species from any alternative. 

Burrington’s and Warty Jumping Slug 

Both these mollusks are associated with a variety of moist forest and they retreat into down wood, leaf litter and 

moist areas during the dry summer months (May or June through September). There are 10 known sites for 

Burrington’s jumping slug on the Olympic National Forest, 8 of which are within treatment areas that may have 

herbicide use. The warty jumping slug is locally common and abundant with 605 known sites on the Olympic 

National Forest; 478 (or 79 percent) of which are within treatment areas that may have herbicide use. The 

majority of the proposed treatment areas are along disturbed roadsides that do not provide suitable habitat for 

these mollusks. Roadsides conditions are more dry and harsh than is suitable for mollusks. While many known 

site locations coincide with treatment areas, the actual invasive plant treatments would occur in microhabitats 

that are not suitable for mollusks (Joan Ziegltrum, personal communication, 2006). Mollusk habitat and 

populations occur off the roads in adjacent suitable habitat. 

No invasive plant treatments will remove habitat for jumping slugs nor will treatments cause large-scale 

microclimate changes within their suitable habitat. Habitat components for jumping slugs, such as down logs, 

will remain in place on treatment sites. 

In all action alternatives, PDF J-6 requires that treatments avoid known sites or high potential habitat when soil 

moisture is high and these slugs are most likely to be at or near the surface. This will minimize their exposure to 

herbicides and reduce the risk of mortality by trampling. Most mechanical and herbicide treatments would occur 

along disturbed roadsides, which are often drier conditions and not suitable mollusk habitat (Joan Ziegltrum, 

personal communication, 2006). Although the Project Design Features minimize risk to these species from 

manual, mechanical, and herbicide treatments, all action alternatives may adversely impact some individuals, but 

would not likely to lead to a trend toward federal listing. 

Table 49-Impact Determinations for Sensitive Wildlife Species 

Wildlife Common Name Impact Determination 

Townsend’s Big-Eared Bat No Impact 

Mazama Pocket Gopher No Impact 

Common Loon No Impact 
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Wildlife Common Name Impact Determination 

American Peregrine Falcon No Impact 

Bald Eagle May Impact Individuals, But Would Not Likely To Lead To A Trend 

Toward Federal Listing. 

Vandyke’s Salamander May Impact Individuals, But Would Not Likely To Lead To A Trend 

Toward Federal Listing. 

Cope’s Giant Salamander May Impact Individuals, But Would Not Likely To Lead To A Trend 

Toward Federal Listing. 

Olympic Torrent Salamander May Impact Individuals, But Would Not Likely To Lead To A Trend 

Toward Federal Listing. 

Puget Oregonian No Impact 

Burrington’s Jumping Slug May Impact Individuals, But Would Not Likely To Lead To A Trend 

Toward Federal Listing. 

Warty Jumping Slug May Impact Individuals, But Would Not Likely To Lead To A Trend 

Toward Federal Listing. 

Malone’s Jumping Slug No Impact 

Blue-Gray Taildropper No Impact 

Hoko Vertigo No Impact 

Direct and Indirect Effects on Survey and Manage Species 

As discussed previously, the Burrington’s jumping slug is the only wildlife species currently included in the 

Survey and Manage list that is likely to occur on the Olympic National Forest. Other species are listed for 

Survey and Manage, but have not been detected on the Olympic National Forest in any previous or ongoing 

survey. Further discussion on these species is in Appendix C. Effects to the Burrington’s jumping slug are 

discussed above under Direct and Indirect Effects to Regional Forester Sensitive Species. 

Surveys for Burrington’s jumping slug are unlikely to be needed for this project, particularly within roadside 

treatment areas. The 2001 Survey and Manage ROD (USDA and USDI 2001, p. 22) states, “The line officer 

should seek specialists’ recommendations to help determine the need for a survey based on site-specific 

information. In making such determination, the line officer should consider the probability of the species being 

present on the project site, as well as the probability that the project would cause a significant negative effect on 

the species habitat or the persistence of the species at the site.” Pre-project surveys for Burrington’s jumping 

slug are not required for roadside treatment areas, regardless of alternative, for two reasons: 

1. These areas are not considered suitable habitat (Ziegltrum, Forest Ecologist, personal 

communication 2006). 

2. Roadside treatment would not negatively impact adjacent suitable habitat or species persistence. 

While individual mollusks may be found on roadsides, they would not be there if not for the adjacent 

[unaffected] natural habitat (2003 USDA/USDI Survey Protocol for Survey and Manage Terrestrial Mollusk 

Species from the Northwest Forest Plan, v.3.0, 70page). In addition, invasive plant treatments can be considered 

routine road maintenance similar to cleaning ditches removing encroaching vegetation, which are not considered 

habitat-disturbing activities in the 2001 ROD (p. 22). 

The need for pre-project surveys in other types of treatment sites would be evaluated during the annual 

implementation planning process (see Section 2.5, Implementation Planning). 

Direct and Indirect Effects on Management Indicator Species 

The invasive plant treatments proposed in all alternatives focus on treating the target non-native plants and avoid 

or minimize effects to non-target native vegetation. No treatments will remove native trees or alter native habitat 

structure. Proposed treatments will improve cover of native plants within treatment areas and could contribute to 

improved habitat conditions for deer and elk in some select sites. Habitat for pileated woodpecker, primary 
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cavity excavators, and pine marten is not substantially affected by invasive plants, nor would it be affected by 

invasive plant treatments. 

Pileated woodpecker and Primary Excavators 

Invasive plant treatments would not affect pileated woodpeckers or the primary cavity excavator group. These 

birds nest in cavities in dead limbs and forage on trees and shrubs. Black-capped chickadee, Lewis’ woodpecker, 

and flicker may encounter contaminated insects due to their foraging habits. 

Appendix P of the 2005 R6 FEIS included an assessment of risk from use of herbicides to insectivorous birds. 

The exposure scenarios for insectivorous birds indicate that only NPE doses would exceed a threshold of concern 

in acute exposures at typical application rates. In order to receive this dose, the birds would have to feed 

exclusively on contaminated insects for an entire day’s feeding. The above-mentioned species forage in 

relatively large areas, sometimes several acres or more, and forage on a variety of plants and locations (e.g. tree 

limbs and boles, understory shrubs, bare ground, and bird feeders). Proposed broadcast application of herbicides 

is proposed only along roadsides. Other application methods treat individual plants and are unlikely to 

contaminate significant amounts of forage insects or seed. The patchy nature of proposed invasive plant 

treatments would make it unlikely for a single bird to feed exclusively on insects from treated patches, even in 

roadsides treated with broadcast applications. However, adverse effects on some individual birds cannot be ruled 

out, due to lack of data on occurrence and foraging area within treatment areas. 

Data on chronic exposure of birds to contaminated insects is lacking. Very conservative assumptions regarding 

herbicide residue on insects would indicate that several herbicides could exceed a threshold of concern in a 

chronic exposure scenario. However, chronic exposure thresholds of concern were established by daily doses for 

90 days or more in laboratory studies. It seems highly unlikely that wild birds would feed exclusively on insects 

from treated patches of invasive plants along a roadside for the length of time needed to acquire a chronic dose of 

concern. 

The northern flicker regularly forages for ants on the ground and ants can be active during herbicide applications. 

However, even if a flicker ate contaminated ants, it would have to eat nothing but contaminated ants for an entire 

day’s feeding to be exposed to enough NPE-based surfactant to be a concern. Given that the vast majority of 

proposed treatments are along roadsides, and that flickers would move among various foraging sites throughout 

the day, this scenario is not plausible. Given varied diet, foraging strategies, and movement of black-capped 

chickadees and Lewis’ woodpecker, actual doses exceeding level of concern are unlikely. 

Northern flying squirrel is arboreal but feeds on underground fungi. It could encounter some contaminated soil 

or vegetation but it is unlikely to feed exclusively within treated patches of ground. Even if it fed exclusively on 

contaminated vegetation for an entire day, or on 20 percent contaminated vegetation over 90 days, it would not 

receive a dose that exceeded any toxicity indices for any herbicide proposed or NPE. Direct spray is not feasible 

due to the squirrel’s arboreal and nocturnal behavior. An herbicide dose of concern is not plausible. None of the 

action alternatives would alter habitat for these species. No adverse effects are plausible to populations. 

Roosevelt elk and Black-tailed deer 

Invasive plant treatments will not reduce available habitat for deer or elk, but could contribute to improved 

habitat quality in the long term (see Rice et al. 1997, for example). 

The grazing and browsing habits of elk and deer make it possible for them to consume vegetation that has been 

sprayed with herbicide. Quantitative estimates of risk using “worst-case” scenarios found that none of the 

herbicides considered for use, at typical application rates, would result in a dose that exceeds the toxicity indices 

in either acute or chronic scenarios. The dose for NPE surfactant exceeds the toxicity index only in an acute 

scenario. The deer or elk would have to consume an entire day’s diet of contaminated grass in order to receive 

this dose. Deer and elk do not forage extensively on the invasive plants found on the Olympic National Forest, 

they are not likely to forage exclusively on the patches of invasive plants that have been treated with herbicide, 

and the treated sites comprise a very small proportion of the available foraging area for these species. Backpack 

spot sprays and roadside broadcast applications would only contaminate very small amounts of forage, if any, 
Final Environmental Impact Statement 

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122

because forage species are not the target of the applications. The “worst case” exposure scenario for NPE is not 

plausible for the treatments proposed in any of the alternatives. Therefore, no plausible adverse effects to deer or 

elk would result regardless of alternative chosen. 

Pine Marten 

On the Olympic National Forest, pine martens are most likely to occur in remote wilderness areas or contiguous 

old-growth forest. Most treatment areas are on roadsides and are unlikely to disturb pine martens, do not alter 

suitable habitat, and are unlikely to expose their prey. Even if pine martens consumed for an entire day nothing 

but prey that had been directly sprayed, they would not receive a dose that exceeded the toxicity indices for any 

herbicides or NPE (R6 2005 FEIS, Appendix P). No plausible effects would result from any alternative. 

Direct and Indirect Effects to Landbirds 

Invasive plant treatments proposed on the Olympic National Forest will not remove habitat of the focal species 

for coniferous forests. No trees will be removed and forest structure will not be altered by proposed treatments. 

Only species that forage or nest near the ground are likely to be exposed to disturbance from treatments or 

herbicides. Of the coniferous forest focal species identified in Altman (1999), the following species are most 

likely to forage or nest near the ground: varied thrush, Wilson’s warbler, winter wren, black-throated gray 

warbler, Hutton’s vireo, olive-sided flycatcher, western bluebird, orange-crowned warbler, rufous hummingbird 

(Source: Altman 1999, Marshall et al. 2003). Because these species are not reported to nest in invasive plant 

species targeted for treatment, manual and mechanical treatments are not likely to disturb nests of these species. 

As discussed above for Primary Cavity Excavators, analysis in the 2005 R6 FEIS (Appendix P) indicated that 

only NPE poses a risk to insectivorous birds at typical application rates for acute exposures. Exposures resulting 

in a dose of concern do not appear plausible for the proposed treatments, as detailed above for Primary Cavity 

Excavators, although risk to some individual birds cannot be ruled out. 

In conclusion, invasive plant treatments will not alter habitat for focal species in the Partner’s In Flight land bird 

conservation strategy. Manual and mechanical treatments are not likely to disturb nests of focal species. Some 

individuals of focal species could be exposed to herbicides by foraging on contaminated insects, but the 

likelihood of any dose of concern is remote. 

Direct and Indirect Effects to Birds of Conservation Concern 

For all species included in the Birds of Conservation Concern, invasive plant treatments proposed on the 

Olympic National Forest will not remove or degrade their habitat. Removal of invasive plants will likely 

contribute to the integrity of habitat areas, although no specific habitat elements for these species are currently 

being affected by invasive plants on the Olympic National Forest. 

The black swift and olive-sided flycatchers are insectivorous birds. They do not nest in close proximity to the 

ground and are not sensitive to the short-term disturbance that most invasive plant treatments would create. The 

exposure scenarios for insectivorous birds indicate that only NPE doses would exceed a threshold of concern in 

acute exposures at typical application rates (see 2005 R6 FEIS, Appendix P). In order to receive this dose, the 

birds would have to feed exclusively on contaminated insects for an entire day’s feeding. Black swifts feed 

primarily on flying aquatic insects like mayflies, stoneflies, and caddis flies, catching them high in the air. These 

insects are unlikely to be directly sprayed because broadcast spray of herbicide is limited or prohibited in their 

habitats. Therefore, any exposure of concern for black swift is unlikely. Olive-sided flycatchers also catch their 

flying insect prey high in the air, launching from a high perch in a snag or tree. Proposed broadcast spraying is 

along infested roadsides and the infestations occur in patches rather than long solid infestations. The patchy 

nature of proposed invasive plant treatments would make it unlikely for a single flycatcher to feed exclusively on 

insects from treated patches. While some of their insect prey may become contaminated by broadcast spraying, 

it seems unlikely that they would forage exclusively on contaminated insects. Chronic doses are even more 

unlikely, as described above in the effects to Landbirds. Therefore, negative effects to olive-sided flycatchers are 

unlikely. 
Final Environmental Impact Statement 

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123

The rufous hummingbird inhabits open areas and meadows, catching insects and sipping nectar. A small amount 

of exposure to herbicides or NPE could amount to a dose of concern because of the very small body size of the 

rufous hummingbird. These hummingbirds could forage in open areas where invasive plants have been treated 

and possibly glean contaminated insects. It is unlikely that they would forage exclusively within a patch of 

invasive plants. These hummingbirds are not known to heavily utilize invasive plants for a nectar source and 

they prefer tubular flowers where the nectar is deep inside the corolla. Native forage plants would not be treated 

so the nectar is unlikely to be contaminated with herbicide. Rufous hummingbirds breed from Alaska south to 

Oregon. The patchy nature of the invasive plant infestations and the multi-state breeding range for this bird 

indicate that while adverse effects to some individual birds cannot be ruled out, there is not likely to be any 

population-level effect to the species from proposed invasive plant treatments on the Olympic NF. 

Herbicide Use and Amphibian Decline 

Information on the effect of pesticides on amphibian populations is limited, and the studies that are available 

often focus on the most toxic compounds like insecticides (e.g. Taylor et al. 1999, Bridges and Semlitsch 2000, 

Boone and Semlitsch 2001, Relyea and Mills 2001). Some herbicides are known to have adverse effects on 

amphibians (e.g. Hayes 2002, Wojtaszek et al 2005). 

To date, atrazine is the only herbicide active ingredient that has been implicated in overall amphibian declines 

(Hayes 2002). This herbicide is not proposed for use in this project. 

Relyea (2005) implicate the glyphosate formulation Roundup in amphibian decline, but the formulation studied 

contains a toxic surfactant. Numerous previous studies have attributed the toxicity of this formulation to the 

surfactant and not the glyphosate active ingredient (e.g. Mann and Bidwell 1999; Perkins et al. 2000). 

 The pesticides investigated (e.g. carbaryl, PCB’s, atrazine) all have much higher propensity to accumulate in the 

fatty tissues than the herbicides proposed in this document. For example, Atrazine has an octanol/water partition 

coefficient (Kow) of 481 while the highest Kow for any herbicide proposed is 45.1 for sethoxydim, and all the 

other herbicides have Kow ranging from 2.1 to much less than 1. There is a substantial data gap regarding 

effects of the herbicides included in this analysis and the potential for effects to amphibian populations, but 

current data on these herbicides do not suggest a risk to amphibian populations because they do not accumulate 

in animal tissues and are less persistent, less mobile, and less widely used than pesticides that have been 

implicated in amphibian declines. 

Project design features and buffers have been proposed that respond to uncertainty about effects to amphibians 

from herbicide exposure. Broadcast spraying is prohibited and selective application methods are specified near 

streams, and the herbicide ingredients that can be used are limited within certain distances of amphibian habitat. 

Cumulative Effects Analysis for All Alternatives 

The Project Design Features common to all action alternatives are likely to effectively reduce risk of adverse 

effects to terrestrial wildlife because they minimize or eliminate disturbance and herbicide exposure scenarios of 

concern. The types of treatments that are proposed, implemented according to Project Design Features, have a 

low likelihood of contributing to cumulative effects from other projects on and off the Olympic National Forest. 

Invasive plant treatments are likely to have an overall beneficial impact to wildlife to the extent that invasive 

plants are replaced with native vegetation. All of the environmental standards, policies and laws related to 

wildlife would be met in all alternatives. 

3.4 Soils and Water 

3.4.1 Introduction 

The effect of invasive plant treatment on soils and water is a primary public issue (Issue Group 5). Federal and 

state laws, policies and regulations control the use of herbicides on National Forest System lands, including the 

Clean Water Act and the Federal Water Pollution Control Act. Section 208 of the 1972 amendments to the 
Final Environmental Impact Statement 

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124

Federal Water Pollution Control Act (Public Law 92-500) specifically mandated identification and control of 

non-point source pollution. Clean Water Act Section 303(d) directed the State of Washington to list Water 

Quality Limited Waterbodies (listed streams) and develop Total Daily Maximum Loads (TMDL) to control the 

non-point source pollutant causing loss of beneficial uses. 

The Olympic National Forest has completed a TMDL for the Upper Humptulips Watershed (includes the West 

Fork Humptulips and East Fork Humptulips Watersheds). The Forest and Washington Department of Ecology 

have discussed development of a Forest-wide TMDL, but have not yet set dates to initiate development of this 

plan. 

The Olympic National Forest Plan (USDA 1990 as amended by the 1994 Northwest Forest Plan ROD, and the 

R6 2005 ROD) provides direction to protect and manage resources. The Forest Plan Goal for soils is to “Protect, 

conserve, and enhance the long-term productivity of forest soils for the multiple uses of the Forest”. Forest Plan 

Goals for water resources are to “provide water quality needs for municipal and domestic supply, and to protect 

rivers, streams, shorelines, lakes, wetlands, flood plains, and other riparian areas during implementation of 

management activities.” 

Forest Management Objectives for soil, riparian areas and water resources include IV-12 and IV-18: 

• The primary goal for water quality is to provide high quality water by minimizing soil erosion and the 

introduction of chemicals and bacteria. 

• All riparian areas are to be managed to protect and maintain their unique values as they relate to wildlife, 

fish habitat and water quality. 

This project would comply with all Washington State water quality standards and requirements detailed in Water 

Quality Standards for the State of Washington, Chapter 173-201A WAC 1997 & 2003 and Forest Chemicals 

Chapter 222-38 WAC. 

Waters on the Olympic National Forest are considered AA (extraordinary) under State of Washington 173-

201A120 list. Beneficial uses for these waters include: 

• Water Supply (Domestic, Industrial, Agricultural) 

• Stock Watering 

• Commerce and Navigation 

• Wildlife habitat 

• Recreation 

• Salmonid, clam, oyster, mussel, crustacean and other shellfish migration, rearing, spawning, and 

harvesting. 

3.4.2 Affected Environment 

Geology and Soils 

The geology of the Olympic National Forest is complex. The bedrock is a combination of volcanic and 

sedimentary rocks, altered by planetary plate tectonics and heavily eroded by glaciation and runoff, leaving deep 

glacial deposits in the larger valleys. 

Uplift is ongoing and many steeper slopes are unstable and prone to mass movements. Many of the volcanic and 

sedimentary rocks are highly deformed and fractured. Where these fractures are exposed they can have high 

permeability, which may serve to transfer herbicide from soils to groundwater. 

Soils are formed from four broad categories of parent materials. These are: (1) recent alluvium; (2) glacial 

deposits; (3) hard sedimentary and meta-sedimentary rocks; and (4) hard volcanic and meta-volcanic rocks. 
Final Environmental Impact Statement 

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There are 183 different soil types within areas containing invasive plants. Of particular concern for the Olympic 

National Forest are the soils listed as hydric (poorly drained, have a high groundwater table or are frequently 

ponded or flooded). Potential hydric soils were identified from the Olympic Soil Resource Inventory (SRI) soils 

layer on floodplains and low stream terrace sites, glacial deposits and small wet depressions with a high seasonal 

water table. Approximately 684 acres of hydric soils are within treatment areas, with about 110 acres estimated 

as being infested. 

Invasive plants can affect soils in many ways. They can cause changes in soil properties such as pH, nutrient 

cycling and changes in composition or activity of soil microbes. For example, spotted knapweed has been 

implicated in reducing available potassium and nitrogen (Harvey and Nowierski, 1989). 

A reduction in soil nutrient levels makes it difficult for native plants to compete with invasive plants, and may 

also affect the soil biotic community. The long-term effects of these changes are not known. Indirect effects of 

changes in soil biology include sedimentation of streams and reduced recharge rates for groundwater. 

Presence of non-native plants also leads to changes in the mycorrhizal fungus community (ibid). Plants and 

mycorrhizal fungi are strongly dependent on each other, and species of fungi are associated with specific plants. 

These changes could increase the difficulty of reestablishing native vegetation after the invasive plants are 

removed. 

Municipal Watersheds and Domestic Water Supplies 

There are nine municipal watersheds on the Olympic Forest that range in size from 293 acres to 108,785 acres 

(two watersheds for the City of Port Townsend have been combined in Table 50). An estimated 210 acres are 

currently infested within municipal watersheds. These invasives are found primarily along roads and in 

plantations and other disturbed areas. The Lake Sutherland Water District water intake is potentially within 

1,000 feet downstream of a treatment area. All other municipal watershed intakes are at least 1,000 feet 

downstream from proposed treatment areas. 

To be classified as a municipal watershed, a water source must meet one of the following criteria: 1) at least 25 

individuals are served at least 60 days per year, or 2) at least 15 service connections are provided. 

The 1990 Olympic National Forest Plan states that the primary goal for municipal watershed management is to 

provide high quality water by minimizing soil erosion and the introduction of chemicals or bacteria. A Forest 

Plan standard for municipal watersheds states: 

“Herbicides and pesticides should not be used. Chemicals should be used as a last resort, and only when 

site-specific analysis indicates water quality will not be adversely affected.” 

The Olympic National Forest has not used herbicides in municipal watersheds since this standard was adopted in 

the Forest Plan in 1990. Since that time, the invasive plant problem has grown, and new chemical methods of 

treatment have become available. The type of treatments proposed for municipal watersheds are not likely to 

adversely affect drinking water quality due to the low amount of herbicide use overall, the characteristics of the 

herbicides proposed for use and the cautious way that they would be applied. Infestations of invasive plants in 

most municipal watersheds are minimal, except for the large watersheds serving Sequim and Port Townsend 

(Table 50). 

Municipal watersheds are governed by agreements (on file at Olympic National Forest). Two of the agreements 
Final Environmental Impact Statement 

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126

specifically mention herbicides: 

City of Port Townsend - “Until such time as the Cooperative Watershed Protection Program is fully 

implemented, the Forest Service shall not use any pesticides or herbicides within the watershed without 

the city’s concurrence.” 

City of Aberdeen - “The use of herbicides are not contemplated in this open water source watershed. 

However, in the event herbicides are needed to control a catastrophic outbreak of insects, the City and 

the public will become involved in the decision-making process.” 

Herbicide use within these watersheds would need to be coordinated with the city watershed managers. Less than 

one acre is currently known to be infested in the City of Aberdeen watershed. 

Table 50-Acres of Invasive Plants in Municipal Watersheds 

Municipal Watershed Acres of Infestation 

Proposed for Treatment 

Water Source 

Black Diamond Water District <1 South Branch Little River 

City of Aberdeen <1 Wishkah River 

City of Port Townsend 51 Little Quilcene River; Big Quilcene 

River 

City of Sequim 135 Dungeness River 

Iskra Bros. Logging Company Water System 8 Twin Culvert 

Lake Sutherland Water District 14 Falls Creek 

Meadowland Water Association <1 Hathaway Creek 

Neilton Cooperative Water Company <1 McCall Creek 

Total Approximately 212 acres 

In addition to the municipal watersheds, there are approximately 113 appropriated Washington State Surface 

Water Rights for on and off-forest water withdrawals. There are 30 special use permits for surface water intakes 

on National Forest System lands for individual homes. These intakes are used for fish propagation, irrigation and 

domestic water sources. 

Approximately 50 forest campgrounds, work sites and guard stations use surface or ground water sources on the 

Olympic National Forest; a map showing locations of both the municipal watersheds and the forest water sources 

is in the project record. Validation of the water rights is underway on the Forest. 

Washington State law 246-290-315 requires that herbicide use be avoided within 100 feet of wells and 200 feet 

of springs used as domestic water sources. 

Clean Water Act

Approximately 23,377 miles of streams flow on the Olympic National Forest. Approximately 30 percent are 

perennial and 70 percent are intermittent. The Washington State 303(d) list of water quality limited streams lists 

seven streams (21 segments) on the Forest for temperature (Table 51). None of the water quality limited streams 

on the Forest are listed for chemical contaminants. 
Final Environmental Impact Statement 

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Table 51-Streams on the 303(d) List for Temperature 

Stream Name Within Treatment Area? 

Calawah River S.F. No 

Deep Creek No 

Lebar Creek Yes 

Matheny Creek Yes 

Sams River No 

Sitkum River Yes 

Skokomish River S.F. No 

Three 303(d) listed streams are within treatment areas. The Sitkum River flows through treatment area 9P-27. 

Lebar and Matheny Creek flow through areas 9H-18 and 9P-27 respectively, both with roadside treatments. The 

main invasive plants to be treated at these sites are Canadian thistle, bull thistle, tansy ragwort and scotchbroom. 

None of these target species provide any stream shade that would have a positive affect on stream temperature or 

riparian habitat. 

Aquatic Conservation Strategy 

The Aquatic Conservation Strategy (ACS) is an integral part of the 1994 Northwest Forest Plan. The ACS was 

developed to restore and maintain the ecological health of watersheds and aquatic ecosystems within public 

lands. The ACS is intended to meet several objectives toward meeting the goal of healthy ecosystems and 

watersheds. Aquatic Conservation Strategy Objectives are applied over time at watershed and broader scales. 

The Aquatic Conservation Strategy established a system of Key Watersheds to protect areas of high water quality 

and habitat for wild fish populations. Key Watersheds are intended to serve as refugia for at risk stocks of native 

and anadromous fish. Activities to protect and restore aquatic habitat in Key Watersheds are higher priority than 

similar activities in other watersheds. About 70 percent of the invasive plant sites are sparsely distributed within 

Key Watersheds. 

Watershed analysis has been conducted between 1994 and 2005 for South Fork Skokomish River, Sitkum and 

South Fork Calawah River, North Fork Calawah River, Matheny Creek, Boulder and Cooks Creeks, Big 

Quilcene River, Hamma Hamma River and Hood Canal tributaries, East and West Forks Humptulips River, 

Quinault River, Snow and Salmon Creeks, Upper Wynochee River, Salmon River, Sams River, Dosewallips 

River, Soleduck River, Deep Creek and East and West Twin Rivers, Dungeness River and the West Fork Satsop 

River. Appropriate treatment is urged in Watershed Analysis documents that address noxious weeds or other 

non-native invasives. 

Table 52 displays the relative distribution of the invasive plants at the 6th field watershed scale. In many of these 

watersheds there are fewer than ten acres of invasive plant sites. Key Watersheds are italicized. 
Final Environmental Impact Statement 

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Table 52-Sixth Field Watersheds on Olympic National Forest 

National Forest Systems Lands within each 

Watershed 

Sixth Field Watersheds 

Acres Percent of 

Watershed29 

Infested 

Acres 

Infested Acres in 

Riparian 

Reserves 

Big Creek/Upper Quinault River 8,479 24 0.5 0.07

Bockman Creek 3,679 22 1.9 0.57

Calawah River 2,065 21 0.3 0.08

Canyon Creek/Pats Creek 8,230 41 91.4 24.98

Cook Creek 8,082 27 28.3 7.71

Crescent Lake/Lyre River 1,964 5 2.3 0.19

Deep Creek 5,483 44 82.4 29.16

East Fork Humptulips River 19,508 66 184.2 67.48

East Twin River 4,095 33 2.8 0.79

Fulton Creek/Waketickeh Creek 7,332 43 39.6 7.78

Headwaters Sol Duc River 9,539 28 66.1 13.77

Hoko River 344 1 < 0.1 0

Jefferson Creek 12,866 92 108.5 45.39

Jimmy-Come-Lately Creek 9,010 73 5.1 1.54

Lilliwaup Creek 2,546 8 42.4 8.20

Little Quilcene River 9,989 44 28.8 6.28

Lower Big Quilcene River 8,061 61 2.8 1.00

Lower Bogachiel River 5,724 12 0.2 0.08

Lower Dosewallips River 21,553 60 17.6 5.66

Lower Duckabush River 14,295 70 49.7 15.43

Lower Elwha River 5,719 31 1.5 0.11

Lower Gray Wolf River 12,400 79 3.9 0.79

Lower North Fork Skokomish River 2,698 17 27.5 4.71

Lower Sol Duc River 2,996 11 0.1 0.04

Lower South Fork Skokomish River 16,145 57 69.6 24.67

Mainstem Hamma Hamma River 28,207 71 110.9 37.72

Matheny Creek 20,338 84 79.6 22.84

McDonald Creek/Siebert Creek 2,588 7 0.6 0.11

Middle Clearwater River 250 1 0.1 0.01

Middle Dungeness River 14,693 100 9.9 1.86

Middle Fork Satsop River 13,023 34 89.4 26.15

Middle Hoh River 413 1 12.6 3.27

Middle North Fork Skokomish River 13,206 48 81.5 19.90

Middle Queets River 3,258 15 4.3 1.22

Middle Quinault River 6,208 13 42.9 9.2

Middle Sol Duc River 14,047 47 128.1 48.22

Middle Wynoochee River 13,426 32 39.0 7.14

North Fork Calawah River 19,267 63 237.9 69.98

Pysht River 4,876 14 1.2 0.39

Quinault Lake 13,684 56 274.9 89.49

Salmon River 5,789 28 13.1 3.52

 

29 National Forest System lands comprise a portion of each watershed. The remainder of the watershed is managed by the 

National Park Service, Tribal Governments, private landowners, etc.. 
Final Environmental Impact Statement 

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National Forest Systems Lands within each 

Watershed 

Sams River 16,170 82 8.0 1.07

Sequim Bay Tributaries 89 1 < 0.1 0

Snow Creek/Salmon River 7,724 31 27.7 7.78

South Fork Calawah River 27,463 59 436.9 211.16

Spencer Creek/Marple Creek 4,616 46 8.7 1.96

Stevens Creek 1,644 6 9.8 3.59

Tshletshy Creek 188 1 0.0 0

Upper Big Quilcene River 30,333 96 33.2 5.31

Upper Bogachiel River 10 <1 0.1 0

Upper Duckabush River 1,253 4 <0.1 0

Upper Dungeness River 20,296 65 119.3 13.54

Upper North Fork Skokomish River 5,096 16 0.9 0.10

Upper Sol Duc River 15,625 68 246.1 47.26

Upper South Fork Skokomish River 36,733 95 121.4 39.49

Upper West Fork Satsop River 20,135 52 213.9 94.53

Upper Wishkah River 1,412 6 0.5 0.03

Upper Wynoochee River 24,677 94 125.7 31.27

West Fork Humptulips River 33,826 72 265.4 96.80

West Twin River 4,934 61 222.3 88.90

Total 630,610 3,380 1,251

Riparian Reserves in Treatment Areas 

Table 53 displays the estimated infested acres by treatment area. Total treatment areas range from 9 (distinct 

invasive plant population) to more than 4,000 acres (roadsides). The average treatment area size is about 600 

acres. Riparian reserves are estimated to average 33 percent of treatment area acreage. The distribution of 

infested sites within the treatment areas and riparian reserves is scattered. An average of seven percent of each 

treatment area is estimated to currently have invasive plants. These populations are small and scattered and are 

not concentrated in any one riparian area. 

Table 53-Treatment Area Information 

Treatment Area Total Treatment Area 

Acres 

Treatment Area Acres in 

Riparian Reserves 

Estimated 

Infested Acres 

Estimated Infested 

Acres in Riparian 

Reserves 

9H-01 1,319 368 6.5 1.8

9H-02 277 43 80.3 12.5

9H-03 254 99 2.9 1.1

9H-04 267 80 2.0 0.6

9H-05 1,484 408 27.4 7.5

9H-06a 269 58 1.2 0.3

9H-06b 419 93 1.7 0.4

9H-06c 302 72 28.5 6.8

9H-07 315 104 65.8 21.7

9H-08a 642 137 3.6 0.8

9H-08b 421 141 17.2 5.8

9H-09b 3,358 911 1.6 0.4

9H-10 788 210 2.6 0.7
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Treatment Area Total Treatment Area 

Acres 

Treatment Area Acres in 

Riparian Reserves 

Estimated 

Infested Acres 

Estimated Infested 

Acres in Riparian 

Reserves 

9H-11 255 88 16.4 5.7

9H-12 24 0 6.8 0.0

9H-13 1,269 394 49.7 15.4

9H-14 799 163 31.7 6.5

9H-15 440 125 119.2 33.9

9H-16a 471 142 1.9 0.6

9H-16b 389 201 106.6 55.1

9H-17 689 139 80.7 16.3

9H-17a 333 58 33.4 5.8

9H-18 765 242 23.3 7.4

9H-19 153 60 1.2 0.5

9H-20 424 132 38.8 12.1

9H-21 501 54 16.5 1.8

9H-22 194 36 8.9 1.7

9H-23 1,571 603 63.5 24.4

9H-24 268 46 174.4 29.9

9H-25 1,033 464 269.0 120.8

9H-25a 176 102 36.4 21.1

9H-26 613 170 21.8 6.0

9H-27 187 48 0.7 0.2

9H-28 51 16 26.7 8.4

9H-29 Buckhorn BA 3,076 185 44.7 2.7

9H-30 57 24 7.3 3.1

9H-31 9 9 9.3 9.3

9H-32 21 18 20.8 17.8

9H-Cranberry Bog BA 105 35 6.1 2.0

9H-Pats Prairie BA 410 70 0.2 0.0

9H-Three O'Clock BA 480 63 0.1 0.0

9H-Three Peaks BA 865 138 1.7 0.3

9H-Tyler Peak BA 346 116 0.7 0.2

9H-Wet Weather Ck BA 1,066 167 4.6 0.7

9P-01 411 110 1.9 0.5

9P-02 315 90 0.4 0.1

9P-03 4,294 1,876 28.6 12.5

9P-04 100 32 100.0 32.0

9P-05 471 112 292.5 69.6

9P-06 401 96 1.9 0.5

9P-06a 117 6 2.2 0.1

9P-07 297 42 0.9 0.1

9P-08 291 96 6.5 2.1

9P-09 1,012 271 182.8 49.0

9P-10 1,042 226 67.1 14.6

9P-11 352 144 2.3 0.9

9P-12 1,211 226 17.0 3.2

9P-13 303 70 0.4 0.1

9P-14 316 104 137.1 45.1

9P-15 849 186 31.0 6.8

9P-16 465 146 0.4 0.1
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Treatment Area Total Treatment Area 

Acres 

Treatment Area Acres in 

Riparian Reserves 

Estimated 

Infested Acres 

Estimated Infested 

Acres in Riparian 

Reserves 

9P-17 398 176 145.5 64.3

9P-18 418 201 1.7 0.8

9P-19 380 180 288.6 136.7

9P-19a 300 19 67.6 4.3

9P-20 281 62 47.3 10.4

9P-21 217 67 0.3 0.1

9P-22 68 13 0.6 0.1

9P-23 188 65 11.3 3.9

9P-24 735 277 17.2 6.5

9P-25 269 8 12.5 0.4

9P-26 543 200 29.8 11.0

9P-27 909 225 19.1 4.7

9P-28 249 52 4.0 0.8

9P-29 209 23 6.7 0.7

9P-30 53 10 44.1 8.3

9P-31 98 7 18.1 1.3

9P-32 120 92 95.8 73.4

9P-32a 93 34 92.7 33.9

9P-33 2,045 630 50.3 15.5

9P-34 308 94 81.6 24.9

9P-35 188 56 55.1 16.4

9P-36 517 206 20.1 8.0

9P-37 1,159 412 95.6 34.0

9P-38 1,323 501 96.8 36.7

9P-39 164 12 1.5 0.1

9P-40 119 29 4.9 1.2

9P-41_POCU 33 9 12.6 3.4

9P-42 325 57 5.2 0.9

9P-43 761 145 12.7 2.4

9P-44 2,320 811 49.9 17.4

9P-45 197 168 38.8 33.1

9P-46 Quinault RNA 1,478 355 55.9 13.4

9P-BillsBog BA 49 31 0.7 0.4

9P-MthnyPr BA 151 24 0.3 0.0

9P-MthnyRdg Ba 181 28 0.7 0.1

9P-NF Matheny Ponds BA 107 23 0.3 0.1

9P-PineMt BA 596 103 3.9 0.7

9P-SFkCal BA 123 109 0.7 0.6

Totals 57,074 16,179 3,830 1,251 

Aquatic Emergent Invasive Plants 

Approximately 12.5 acres of Japanese knotweed and 0.2 acres of giant knotweed are estimated within treatment 

areas. Japanese knotweed has poor bank holding capacity, which leads to more bank erosion and sedimentation 

of streams in high winter flows (USDA Forest Service 2005). While knotweed may provide shade, native 

streamside hardwoods and conifers are much taller, so knotweed dominated areas may be associated with higher 

water temperatures than areas with native forest communities. 
Final Environmental Impact Statement 

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While the known extent of knotweed on the forest is small at this time, knotweed spreads rapidly in flood prone 

areas such as the Pacific Northwest. Knotweeds tolerate a wide variety of substrates from cobbles to fine soils 

(Tu and Sol, 2004). 

Knotweed is documented as a long standing major invasive plant in Great Britain and throughout the United 

States; however, it has only been recognized as a major problem for the last five years in the Pacific Northwest. 

In the eastern United States Japanese knotweed has been found along the banks of the Ohio and Allegheny Rivers 

and in islands of these rivers where it occupies hundreds of acres of wetlands, stream banks and hillsides 

(http://www.invasive.org). 

Approximately 156 acres of reed canary grass are mapped along streams and wetlands on the Forest. Reed 

canarygrass is extremely aggressive and often forms persistent monocultures in wetlands and riparian areas. 

Infestations threaten the diversity of these areas, since the plant chokes out native plants and grows too densely to 

provide adequate cover for small mammals and waterfowl. Where reed canary grass grows in water, it can slow 

the movement of water carrying sediment and lead to increased siltation along drainage ditches and streams. 

Once established, reed canarygrass is difficult to control because it spreads rapidly by rhizomes 

http://www.ecy.wa.gov/programs/wq/plants/weeds/aqua011.html). 

Purple loosestrife is on the Nature Conservancy’s list of “worst invasive species.” Purple loosestrife, nicknamed 

the purple plague, is another aggressive invasive species that out-competes native vegetation and forms 

monocultures. It grows quickly and spreads by roots, stem fragments or seeds (ibid). Like reed canary grass, 

purple loosestrife can increase fine sediment deposition and decrease channel capacity (USDA Forest Service, 

2005). This plant is also found within the project area and occupies streambanks, canals and shallow ponds. 

On the Olympic National Forest, if these riparian species continue to grow without being treated, they are 

expected to continue to spread. Where they spread, banks could become less stable leading to changes in 

suspended sediment, and substrate character and embeddedness. Potentially this could lead to effects on pool 

frequency and quality. 

Invasive plants can adversely affect the function of riparian areas. If invasive plants replace riparian conifers and 

hardwood trees, large woody material inputs could be reduced, affecting stream stability, morphology and fish 

habitat. Himalayan blackberry and knotweed can act as a sediment trap and fish barrier (for more information 

see Chapter 3.5 Aquatic Organisms). 

Streams are complex and dynamic systems that reflect the balance between stream flow, sediment input and 

substrate/bank composition. Riparian vegetation stabilizes stream banks, and acts as a filter to prevent the run-off 

of soil into streams. Riparian vegetation also provides large and small wood to streams, adding to habitat 

complexity and providing cover and food sources for aquatic organisms. Aquatic ecosystems have evolved with 

certain vegetation types; invasive plants do not necessarily provide similar habitat. 

Lakes, wetlands and floodplain areas are often popular for recreation, and so are at risk from invasive plants 

brought in by visitors. Wetlands can be inundated with water year-round, and others are wet only seasonally. 

Some areas that are wet only seasonally can be infested with upland invasive species, as well as invasive plants 

specifically adapted to wetlands. Three acres of wetlands and two acres of floodplains are identified as infested 

with invasives. 

The Forest includes extensive acreage of soils seasonally inundated with water. Approximately 110 acres of 

these hyrdric soils are identified as infested with invasive plants. 

Lake Quinault has many summer homes, and with these homes are a large number of invasive species 

intentionally or unintentionally planted by summer visitors. These include patches of Japanese knotweed, herb 

Robert, English ivy and English holly, estimated to cover approximately 96 acres. The Japanese knotweed grows 

below the high water mark in some places and many of the other infestations are close to the lake. About 26 

acres of invasive plants are currently mapped within 100 feet of the lake. 
Final Environmental Impact Statement 

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133

Roads Having High Potential for Herbicide Delivery 

Roads are the primary vector for invasive plants to enter the Forest. Approximately 85 percent of the identified 

invasive plants are along roads or in disturbed areas near roads, such as recreation sites, administrative sites, and 

skid trails in second growth forest. Native soil has been removed along roads, and fill and surfacing have been 

placed within the road prism. Ditches have been compacted, allowing them to deliver run-off to streams, which 

may include herbicides used in broadcast treatments along the roads. Road cutbanks can be a combination of 

disturbed soil and exposed bedrock. Approximately 16 percent of roadside treatment area acres are within the 

aquatic influence zone. 

The R6 2005 FEIS (Chapter 3.5) describes roadside ditches as an herbicide delivery mechanism; potentially 

posing a high risk of herbicides reaching concentrations of concern for listed aquatic species. Ditches may 

extend the stream network and act as delivery routes or intermittent streams during high rainfalls, or as settling 

ponds following rainfall events. 

The 2003 Olympic National Forest Roads Analysis identified roads that pose a high risk to aquatic resources, 

specifically streams. Aquatic risk factors used to identify high risk roads in the Roads Analysis were: geologic 

hazard, proximity (delivery) to fish habitat, stream crossing density, stream proximity, and upslope hazard. 

Of the five categories used to identify “high aquatic risk” roads, three relate directly to processes that contribute 

to the potential delivery of herbicides to streams: proximity (delivery) to fish habitat, stream crossing density, 

and stream proximity. Sediment delivery can be used as a surrogate for herbicide delivery. Thus, these three 

categories were used to identify roads with high potential for herbicide delivery. 

Appendix D includes a list of roads within treatment areas that have a high potential for herbicide delivery. 

Nearly all watersheds on the Olympic National Forest contain roads that have a high potential for herbicide 

delivery; invasive plants are widely scattered along these roads. Not all perennial stream crossings are on roads 

identified as high risk of herbicide delivery. 

Roadside treatment areas include compacted ditch lines, disturbed soils, and thin soils near exposed bedrock. 

Due to the extensive reworking of the properties of soils along roads, the SRI may be misleading for roadside 

treatment areas. As roads and ditchlines are compacted, roadside soils are assumed to function with a high runoff 

rate, and PDFs were developed accordingly. 

An estimated 1,420 acres of infestations are on roads considered high potential for herbicide delivery. Table 54 

displays the infested acres of roadside and other treatment areas and the portions within Riparian Reserves and 

Aquatic Influence Zones. 
Final Environmental Impact Statement 

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Table 54-Infested Acres by Treatment Area Description 

Treatment Area 

Description 

Estimated 

Infested Acres 

Infested Acres 

Likely Within 

Riparian Reserve 

Infested Acres Within 

Aquatic Influence Zone 

Infested Acres within 

Roadside Treatment 

Areas High Potential 

For Herbicide Delivery 

to Streams 

Roadside 3,270 1,051 525 1,420

Administrative Sites, 

Campgrounds, 

Summer Homes 

130 95 48 0

Meadows, Wetlands, 

and Floodplains30 

80 10 6 0 

Forests 215 50 25 0

Trails 135 45 23 0

Total Acres 3,830 1,251 627 1,420

3.4.3 Environmental Consequences 

Effects on Soils 

Manual and Mechanical Treatment 

Manual and mechanical treatments, along with site restoration activities, are approved in all alternatives. While 

the relative amounts of such treatments vary between the alternatives, the differences in terms of effects from 

such treatments are negligible. In lower intensity infestations, non-target vegetation could provide erosion 

control as well as a seed source for establishing native vegetation. This would be encouraged through restoration 

activities as needed establish competitive native vegetation post-treatment in areas of bare ground. 

Removal of plant roots will break mycorrhizal hyphae in the soil and may cause a transient reduction of 

mycorrhizal function. Studies on crop plants have shown that leaving an undisturbed mycorrhizal network in the 

soil after harvest (e.g. zero-till agriculture) significantly increases the nutrient uptake of the subsequent crop 

(Evans and Miller, 1990). Establishment of native plants may be more successful on undisturbed soil. 

Manual removal of plant roots along a streambank may cause some ground disturbance and introduce some 

sediment to streams. For example, weed wrenching of scotch broom may loosen soil and accelerate erosion in a 

small area for approximately one season until vegetation was reestablished (scotch broom currently covers about 

200 acres within treatment areas, including Cranberry Bog Botanical Area). The amount of sediment likely to be 

delivered to water from such treatments is nominal compared to the natural, background level of erosion across 

the Forest. 

Mowing may be done in compacted or previously disturbed areas such as roadsides. Soils are not likely to be 

mobilized from this treatment since the invasive plant root mass will not be displaced through mowing (or other 

mechanical treatment such as chainsaw work). 

 

30 These treatment areas contain wet and dry meadows, wetlands and/or floodplains. The treatment area is larger than the 

meadows, wetlands or floodplains themselves. Some of these areas occur on the drier east side of the Olympic National 

Forest where Riparian Reserves make up less proportion of a watershed. 
Final Environmental Impact Statement 

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135

Herbicide Treatment 

The effect of herbicide treatment to the soil depends on the particular characteristics of the chemical used, how it 

is applied, and the physical, chemical and biological condition of the soil medium. These characteristics were 

used to develop the Project Design Features that minimize adverse effects to soil from the use of herbicides. Soil 

qualities at greatest risk from chemicals are erosion from the removal of ground cover, and damage to soil 

organisms. General characteristics for the proposed herbicides are displayed below; these were compiled from 

the R6 2005 FEIS, label information and SERA Risk Assessments. 

Chlorsulfuron 

Studies on the effects of chlorsulfuron on soil biota include lab and field studies on nematodes; fungi; 

populations of actinomycetes, bacteria, and fungi; and soil microorganisms. 

• No effects of chlorsulfuron were found for soil biota at recommended application rates, with the 

exception of transient decreases in soil nitrification. 

• The ‘no observable effects concentration’ for soil is 10 mg/kg, based on cellulose and protein 

degradation. 

• Chlorsulfuron degrades in aerobic soil. 

• Non-microbial hydrolysis plays an important role in chlorsulfuron breakdown, and hydrolysis rates 

increase as pH increases. 

• Adsorption to soil particles, which affects the runoff potential of chlorsulfuron, is strongly related to the 

amount of organic material in the soil. 

• Chlorsulfuron adsorption to clay is low. 

• Chlorsulfuron is moderately mobile at high pH. 

• Leaching is reduced when pH is less than six. 

• Modeling results indicate that runoff would be negligible in sandy or loamy soils. 

• In clay soils, off-site loss could be substantial (up to about 55 percent of the applied amount) in regions 

with annual rainfall rates of 15 to 250 inches. 

Clopyralid 

Studies of clopyralid effects on soil invertebrates have been conducted, including field studies on the effects to 

microorganisms. 

• Soil concentrations from USDA Forest Service applications are expected to be 1,000 less than 

concentrations that would cause toxic effects. Therefore, no effects to soil invertebrates or 

microorganisms are expected from use of clopyralid. 

• Clopyralid is degraded by soil microbes, with an estimated half-life of 14 to 29 days. 

• Increased soil moisture decreases degradation time. 

• Clopyralid is weakly adsorbed and has a moderate leaching potential overall but high leaching potential 

in sandy soils. 

• Modeling results indicate clopyralid runoff is highest in clay soils with peaks after rainfall events. 

• Clopyralid percolation is highest in sandy loam soils. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

136

Glyphosate 

Numerous soil bacteria, fungi, invertebrates, and other microorganisms have been studied for effects of 

glyphosate application. 

• Studies suggest glyphosate does not adversely affect soil organisms. 

• Glyphosate is readily metabolized by soil microorganisms and some species can use glyphosate as a sole 

source of carbon. 

• It is degraded by microbial action in both soil and water. 

• Sylvia and Jarstfer (1997) found that after 3 years, pine trees in plots with grassy invasive plants had 75 

percent fewer mycorrhizal root tips than plots that had been treated 3 times per year with a mixture of 

glyphosate and metsulfuron methyl to remove invasive plants. 

• Glyphosate degrades in soil, with an estimated half-life of 30 days. 

• Glyphosate is highly soluble, but adsorbs rapidly and binds tightly to soil. 

• Glyphosate has low leaching potential because it binds so tightly to soil. 

• Modeling results indicate glyphosate runoff is highest in loam soils with peaks after the first rainfall. 

Imazapic 

Imazapic is a relatively new herbicide, and there are no studies on the effects of imazapic on either soil 

invertebrates or soil microorganisms. 

• If imazapic was extremely toxic to soil microorganisms, it is reasonable to assume that secondary signs 

of injury to microbial populations would have been reported. 

• Imazapic degrades in soil, with a half-life of about 113 days. 

• Half-life is decreased by the presence of microflora. 

• Imazapic is primarily degraded by microbes and it does not degrade appreciably under anaerobic 

conditions. 

• Imazapic is weakly adsorbed in high soil pH, but adsorption increases with lower pH (acidic soils) and 

increasing clay and organic matter content. 

• Field studies indicate that imazapic remains in the top 12 to 18 inches of soil and do not indicate any 

potential for imazapic to move with surface water. 

• Modeling results indicate imazapic runoff is highest in clay and loam soils with peaks after the first 

rainfall. 

• Imazapic percolation is highest in sandy soils. 

Imazapyr 

There are no studies on the effects of imazapyr on soil invertebrates, and incomplete information on the effects 

on soil microorganisms. 

• One study indicates cellulose decomposition, a function of soil microorganisms, can be decreased by soil 

concentrations higher than concentrations expected from USDA Forest Service applications. 

• There is no basis for asserting adverse effects to soil microorganisms. 

• Imazapyr degrades in soil, with a half-life of 25 to 180 days. 

• Degradation rates are highly dependent on microbial action. 

• Anaerobic conditions slow degradation. 

• Adsorption increases with time as soil dries and is reversible. 

• Field studies indicate that imazapyr remains in the top 20 inches of soil and do not indicate any potential 

for imazapyr to move with surface water. 
Final Environmental Impact Statement 

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137

• In forest field studies, imazapyr did not run off and there was no evidence of lateral movement. 

• Modeling results indicate imazapyr runoff is highest in clay and loam soils with peaks after the first 

rainfall. 

• Imazapyr percolation is highest in sandy soils 

Metsulfuron methyl 

Studies on the effects of metsulfuron methyl on soil biota are limited to Pseudomonas species, though there are a 

few studies of insects that live in soil. The lowest observed effect concentration is 5 mg/kg, based on the 

Psuedomonas study. At recommended use rates, no effects are expected for insects. 

• Effects to soil microorganisms appear to be transient 

• Metsulfuron methyl degrades in soil, with a variable half-life up to 120 days. 

• Half-life is decreased by the presence of organic matter though microbial degradation of metsulfuron 

methyl is slow. 

• Non-microbial hydrolysis is slow at high pH but rapid at lower pH. 

• Adsorption to soil particles, which affects the runoff potential of metsulfuron methyl, increased with 

increased pH and organic matter. 

• Metsulfuron methyl has low adsorption to clay. 

• Modeling results indicate that off-site movement due to runoff could be significant in clay soils. 

• Metsulfuron methyl percolates in sandy soils. 

Picloram 

Picloram is a restricted use pesticide in the state of Washington, meaning it may only be used by a certified 

applicator (this is also a standard for all herbicide use on the National Forest). The persistence of picloram 

increases with soil concentration, thus increasing the likelihood that it becomes toxic to soil microorganisms in 

the short-term. 

• Since picloram is toxic to microorganisms at low levels, toxic effects can last for some time after 

application. 

• Persistence in soils could affect soil microorganisms by decreasing nitrification. 

• Long-term effects to soil microorganisms are unknown. 

• Picloram applied at a typical application rate is likely to change microbial metabolism, though detectable 

effects to soil productivity are not expected. 

• Field studies have not noted substantial adverse effects associated with the normal application of 

picloram that might be expected if soil microbial activity were substantially damaged. 

• Substantial effects to soil productivity from the use of picloram over the last 40 years have not been 

noted. 

• Picloram has been studied on a number of soil invertebrates. 

• Metabolites may increase toxicity for some soil microorganisms. 

• Picloram has a typical half-life of 90 days. 

• However, picloram soil degradation rates vary in soil, depending on application rate and soil depth. 

• Picloram is water soluble, poorly bound to soils that are low in clays or organics, has a high leaching 

potential, and is most toxic in acidic soil. 

• Picloram should not be used on coarse-textured soils with a shallow water table, where groundwater 

contamination is most likely to occur. 

• Picloram percolation is highest in loam and sandy soils. However, modeling results indicate picloram 

runoff (not percolation) is highest in clay soils. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

138

Sethoxydim 

Sethoxydim has not been studied on soil invertebrates. 

• Assays of soil microorganisms noted transient shifts in species composition at soil concentration levels 

far exceeding concentrations expected from Forest Service applications. 

• No adverse effects to soil organisms are expected. 

• Sethoxydim is degraded by soil microbes, with an estimated half-life of 1 to 60 days. Adsorption of 

sethoxydim varies with organic material content. 

• Modeling results indicate sethoxydim runoff is highest in clay and loam soils with peaks after the first 

rainfall. 

Sulfometuron methyl 

There are no studies on the effects of sulfometuron methyl on soil invertebrates. However, it is toxic to soil 

microorganisms. Microbial inhibition is likely to occur at typical application rates and could be substantial. Soil 

residues may alter composition of soil microorganisms. 

• Sulfometuron methyl mobility is generally greater at higher soil pH and lower organic matter content. 

• The typical half-life for sulfometuron methyl varies from 10 to 100 days, depending on soil texture. 

Half-life decreases as soil particle size decreases. Presence of soil microorganisms also decreases halflife, though microbial breakdown occurs slowly. Sulfometuron methyl degradation occurs most rapidly 

at lower pH soils where rates are dominated by hydrolysis. 

• Modeling results indicate sulfometuron methyl runoff is highest in clay and loam soils with peaks after 

the first rainfall. Sulfometuron methyl percolation is highest in sandy soils. Monitoring results generally 

support modeling results. 

• Sulfometuron methyl applied to vegetation at typical application rates would probably be accompanied 

by secondary changes to vegetation that affect the soil microbial community more certainly than direct 

toxic action of sulfometuron methyl on soil microorganisms. 

Triclopyr 

The five commercial formulations of triclopyr contain one of two forms of triclopyr, BEE (butoxyethyl ester) or 

TEA (triethylamine). Triclopyr has not been studied on soil invertebrates. 

• Soil fungi growth was inhibited at concentrations 2 to 5 times higher than concentrations expected from 

USDA Forest Service application rates. 

• Triclopyr has an average half-life in soil of 46 days. Warmer temperatures decrease the time to degrade 

triclopyr. 

• Soil adsorption is increased as organic material increases and decreased as pH increases. Triclopyr is 

weakly adsorbed to soil, though adsorption varies with organic matter and clay content. Both light and 

microbes degrade triclopyr. 

Summary of Soils Concerns and Project Design Features 

Table 55 shows the project design features related to use of clopyralid, chlorsulfuron, picloram and sulfometuron 

methyl so that adverse effects on soil productivity and/or groundwater are avoided or minimized. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

139

Table 55-Soil Property and Project Design Features 

Soil Properties of Concern Special Project Design Features in 

All Action Alternatives 

Chlorsulfuron does not adhere to clay and 

therefore is available to leach or run off. 

H-7 Avoid use of chlorsulfuron on soils with high clay content (finer than loam). 

Clopyralid has high potential mobility in 

sandy soils. It can be persistent in 

groundwater. 

H-6 Avoid use of clopyralid on high-porosity soils (coarser than a loamy sand). 

Picloram is persistent in soil and water, and 

has high potential mobility in sandy soils. 

H-8 Avoid use on shallow or coarse soils (coarser than loam.) No more than 

one application of picloram would be made within a two-year period, except to 

treat areas missed during initial application. 

Sulfometuron methyl is persistent in soil 

and water, and has high potential mobility 

in sandy soils. 

H-9 Avoid use on shallow or coarse soils (coarser than loam.) No more than one 

application within a one-year period, except to treat areas missed during initial 

application. 

Effects on Water Quality 

Non-herbicide 

None of the alternatives have the potential to influence stream flow and channel morphology due to the small 

portion of any watershed that would be treated. Treating invasive plants such as knotweeds that have colonized 

along stream channels and out-competed native species would improve riparian stability. All invasive plant 

treatments bear some risk that removing invasive plants could exacerbate stream instability; the restoration plan 

accounts for these areas and prescribes mulching, seeding and planting as needed to revegetate riparian and other 

treated areas. 

Manual and mechanical treatments, along with restoration activities within riparian areas could accelerate 

sediment delivery to streams through ground disturbance. However, most of the treatments areas are previously 

disturbed roadways and trails so ground disturbance is not a significant concern. Modification of surface ground 

cover can also change the timing of run-off. For all alternatives, treatment areas comprise a small portion of any 

watershed and are relatively short-lived. 

Herbicide 

The routes for herbicide to contaminate water are; direct application, drift into streams from spraying, runoff 

from a large rain storm soon after application, and leaching through soil into shallow ground water or into a 

stream. No direct application of herbicide to water is intended in any alternative; however invasive plant 

treatments in wetlands or stream channels may result in some herbicide entering surface waters. The NMFS 

2007 BO identified three exposure mechanisms from herbicide due to 1) runoff from riparian application, 2) 

application within perennial streams (i.e. emergent invasive plants), and 3) runoff from treated [roadside] ditches 

and dry intermittent streams. 

Drift is the most likely vector for herbicides coming in contact with water from riparian area or emergent 

vegetation treatment sites. The potential for drift varies with the herbicide application method. Spot and hand 

application methods substantially reduce the potential for herbicide contact with water because there is little 

potential for drift. Drift is mainly associated with broadcast treatments. Potential for drift can be mitigated to 

some extent by the applicator (see section 3.2 for more information about drift). 
Final Environmental Impact Statement 

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140

All of the alternatives apply a high degree of caution to herbicide use (for details on the layers of caution see 

Chapter 2: tables 12, 13, 14 and 16, and Chapter 3: tables 29 and 30 and figure 2). The types of application 

methods proposed (mainly spot and hand treatment and limited roadside broadcasting) have low potential to 

harm beneficial uses of water. The closer to water the treatments are, the more limited the choice of specific 

herbicide ingredients and the manner that they may be applied. Label restrictions; restrictions on application 

rate, type of herbicide, and application method; buffers; and the use of adjuvants all factor in to limiting the 

potential amount of drift. In addition, roads that have a high potential for herbicide delivery have been identified 

and have added restrictions, such as no broadcasting. Although there will be no herbicide applied directly to the 

water column for purposes of treating submerged vegetation, there may be some fine droplets from spot 

applications coming in contact with water as a result of treating emergent vegetation. 

Herbicide can move from the treatment location into adjacent areas through runoff. Some runoff can enter 

streams either through road or slope drainage. Roadside ditches can act as herbicide delivery routes to streams 

during high rainfalls or as settling ponds following rainfall events. 

Previous Herbicide Run-Off Monitoring Results 

Berg (2004) compiled monitoring results for broadcast herbicide treatments given various buffers along 

waterbodies. The results showed that any buffer helps lower the concentration of herbicide in streams adjacent to 

treatment areas. In California, when buffers between 25 and 200 feet were used, herbicides were not detected in 

monitored streams (detection limits of 1to 3 mg/m3) (ibid). 

In South Carolina, buffers of 30 meters (comparable to 100 feet) during ground applications of the herbicides 

imazapyr, picloram and triclopyr resulted in no detectable concentrations of herbicide in monitored streams 

(ibid). No detection limits were given. 

Even smaller buffers have successfully protected water quality. For example, where imazapyr was aerial sprayed 

without a buffer, the stream concentration was 680 mg/ml. With a 15-meter buffer, the concentration was below 

detectable limits (ibid.). No detection limits were given. 

Berg also reported that herbicide applied in or along dry ephemeral or intermittent stream channels may enter 

streams through run-off if a large post-treatment rainstorm occurred soon after treatment. This risk is minimized 

if intermittent and ephemeral channels are buffered (ibid.). Risk may also be minimized by limitations on 

herbicide selection and application method. 

If a large rainstorm occurs sediment contaminated by herbicide could be carried into streams. As most ditch lines 

on the National Forest are heavily vegetated, this is less likely to occur than in a drier environment. 

The United States Geological Service, in partnership with the Oregon Department of Transportation, studied 

runoff of herbicides along roads (Wood, 2001). The study was conducted on runoff associated with sulfometuron 

methyl and glyphosate along a road in western Oregon. Water (simulated rainfall) was applied at 1/3 inches an 

hour at 1, 7 and 14 days after treatment. Samples were collected at the shoulder of the road and found 

concentrations of several hundred ppb of sulfometuron-methyl and nearly 1,000 ppb of glyphosate that could 

potentially leave the road shoulder. 

In the fall, the road was again sprayed and the ditch line of the road was checked during natural rainstorms for 

three months. Sulfometuron-methyl was found in concentrations of 0.1 to 1 parts per billion (ppb) along the 

shoulder and from 0.3 to 0.1 ppb in the ditch line, but below detectable limits in the stream. Glyphosate was not 

found at the shoulder, ditch line or stream. 
Final Environmental Impact Statement 

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141

Results from the simulated rainfall experiment suggested that a heavy rainstorm occurring soon after application 

could generate concentrations in the runoff leaving the road shoulder of nearly 1 mg/L glyphosate (above level of 

concern for fish = 0.5 mg/L), and concentrations on the order of a few hundred micrograms per liter of 

sulfometuron-methyl (ibid). The concentration in the direct runoff from the road should provides an upper limit 

for the mixing waters that converge in the roadside ditch from the entire drainage, but probably overestimates the 

concentration in the ditch itself (ibid). 

The road shoulder was again sprayed with sulfometuron-methyl and glyphosate at the end of September during 

natural rainfall conditions, in order to measure the loadings of the compounds to Bull Creek, a small tributary in 

the Willamette Valley, from the drainage ditch under realistic conditions. Sulfometuron-methyl was detected up 

to 0.001 mg/L in the runoff from the road shoulder throughout a 3-month sampling period, and in the drainage 

ditch decreased from 0.001 mg/L in October and November to about 0.0003 mg/L in January (ibid). 

Sulfometuron-methyl was never detected in Bull Creek, and mass balance calculations confirmed that the load of 

this compound to Bull Creek from the drainage ditch would not have resulted in detectable concentrations in the 

stream. 

Glyphosate was never detected in any of the fall samples from the road shoulder, the drainage ditch, or the 

stream. This is an important finding because of the concern surrounding the potential for glyphosate to be 

delivered at amounts that impact critical habitat for fish from roadside treatments on National Forest System 

lands. Herbicide concentrations from the simulated rainfall experiments and the stream and ditch discharges 

measured during natural rainfall indicated that in Bull Creek, a small stream with a fall and winter discharge 

between 10 and 20 cfs (cubic feet per second) ODOT operations could, conceivably, result in herbicide 

concentrations on the order of 0.001 mg/L (ibid), which is far below levels of concern for aquatic organisms. 

This would require a heavy rainfall immediately after application, a situation that certified and trained herbicide 

applicators avoid and is not routine. 

Results from this study are representative of a rural setting with relatively little impervious area, well-drained 

soils, and an unpaved drainage system to deliver runoff from the road and shoulder to a receiving stream. Based 

on the results of this study, it appears that sulfometuron-methyl may persist in the environment as it was detected 

in the runoff from the shoulder, and in the drainage ditch. However, sulfometuron-methyl was never detected in 

Bull Creek and it is believed that loadings from the drainage ditch would not have resulted in detectable 

concentrations in the stream. 

The amounts detected under natural rainfall conditions were well below levels of concern for aquatic organisms. 

Because the total area that proposed for treatment is a small fraction of any given drainage basin, and the 

implementation of specific PDC for roads with high potential for herbicide delivery, the potential for herbicide 

concentrations in all but the most undiluted roadside drainage ditches would likely be immeasurable. In addition, 

this study represents a worst case scenario that is rarely seen along road systems on National Forest System 

lands. 

In the event of a rainstorm, there is a large component of overland flow from the road surface, rather than 

percolation and subsurface flow. So there is more water delivered to the edge of the ditch area into a vegetated 

segment that has been treated, thus further diluting herbicides in the ditch than the Wood (2001) study indicates. 

The resulting herbicide concentration in the ditch as a result of instantaneous runoff cannot be the same as the 

concentration in a connecting stream because of dilution, entrainment of herbicide into sediment, and breakdown 

properties. The Wood (2001) study indicated that runoff from ditches into a stream made up at most, 17 percent 

of the stream flow. Thus, there would be significant dilution compared to the study results. 

The Washington State Department of Agriculture (WSDOA 2004, 2005 and 2006) monitored residual 

concentrations of aquatic labeled herbicides for treatment of emergent noxious and quarantine weeds. Ten out of 

the sixteen sites sampled between the years 2003 and 2005 showed residual herbicide levels that were below a 

level of concern for drinking water. The rest showed no detectable level of herbicide. 
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Roadside Ditches 

Herbicide may be used in or along roadside ditches in some alternatives. Known treatments within ditchlines are 

small and scattered across large road and stream networks. The potential for herbicide to collect in ditches and 

enter streams in concentrations of concern is low due to the low number of treatment acres proposed in any 

watershed. 

The primary determinants of exposure include herbicide properties, application rate, extent of application, 

application timing, and precipitation amount and timing, and proximity to stream crossings. The highest 

concentrations of herbicides resulting from application to ditches and intermittent channels are likely to occur 

early in storm runoff. The most significant exposure locations are at or near confluences with perennial streams 

(NMFS BO 2007). 

Accidental Spill 

Concentrations of herbicides in the water as a result of an accidental spill depend on the rate of application and 

the stream’s ratio of surface area to volume. The persistence of the herbicide in water depends on the length of 

stream where the accidental spill took place, velocity of stream flow, and hydrologic characteristics of the stream 

channel. The concentration of herbicides would decrease rapidly down-stream because of dilution and 

interactions with physical and biological properties of the stream system (Norris et al.1991). 

Project design features would reduce the potential for spills to occur, and if an accident were to occur, minimizes 

the magnitude and intensity of impacts. An herbicide transportation and handling plan (See Table 12, PDF G) is 

a project requirement. This plan would address spill prevention and containment. Extensive monitoring of 

herbicide application using similar treatment methods has occurred over the last few years in northwest Oregon 

and western Washington. All personnel applying the herbicides are well trained and licensed. No accidental 

spills have been reported. 

Municipal Watersheds and Domestic Water Supplies 

Coordination with water boards and users would occur, and herbicide use within 1000 feet upstream (slope 

distance) of known water intakes would be coordinated with the water manager or owner. In all alternatives, 

existing municipal watershed agreements would be followed. 

Most of the infestations in municipal watersheds are along roads. Some of these roads are currently proposed for 

broadcast treatment, assuming density of invasive plants warrant this method. Herbicide use may be excluded or 

limited to spot and/or hand treatments according to memoranda of understanding. 

All alternatives comply with the Olympic National Forest Standard related to using herbicides only as a last 

resort and only when water quality will not be adversely affected, because: 

• Herbicides are proposed for target species that cannot be effectively controlled using other methods. 

• All alternatives protect drinking water supplies. There are no plausible scenarios that could lead to 

drinking water contamination sufficient to affect public health, given the types of herbicide proposed and 

the manner they will be used. Concentrations of herbicides that may reach groundwater or streams are 

low and below levels of concern for people. 

• Approximately 210 acres are proposed for treatment within municipal watersheds, about half of which 

are estimated to be within the Aquatic Influence Zone. This is a very small scale of herbicide use in 

relation to the size of the municipal watersheds. One small infestation lies within 1000 feet of the Lake 

Southerland Water District intake; otherwise all infestations are more than 1000 feet from intakes). 
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Aquatic Conservation Strategy 

Treatment of invasive plants is consistent with recommendations in watershed analysis done for key watersheds 

on the Olympic National Forest. Invasive plant treatments in the scope of this document are not likely to retard 

achievement of ACS objectives because the scale of treatment is small and the potential for harm is low: 

• Less than one percent of the National Forest System lands across all watersheds is currently infested. 

• Less than six percent of National Forest Service System lands within any single 6th field watershed are 

currently infested. These infestations cover less than three percent of any single 6th field watershed when 

other ownership acreage is added. 

Alternative D is associated with the greatest risk of herbicide delivery to streams (see alternative comparison 

below). Broadcast treatments along intermittent streams and roadside ditches in Alternative D would have the 

potential to deliver herbicides to streams and other water bodies, which could retard achievement of ACS 

objectives. 

An analysis of each alternative relative to ACS objectives is in the following section. 

Alternative Effects Comparison 

Alternative A (No Action) 

Direct and Indirect Effects 

Under the No Action alternative, manual and mechanical treatments would occur on about 672 acres (in 

combination with herbicides on 86 of these acres). The herbicides currently available for use under this 

alternative are glyphosate, picloram and dicamba. The primary non-herbicide treatments would be hand pulling 

and mowing. 

Effects to soils from invasive plant treatments could result in small areas of localized erosion and sedimentation. 

These effects would be minimal given the small amount of land treated, especially within Aquatic Influence 

Zones, and the scattered nature of the treatments. These effects would last one season until vegetation became 

re-established. 

The treatments proposed are unlikely to result in significant amounts of decaying plants or nutrients entering a 

stream at one time, and therefore no measurable effect to oxygen levels is anticipated. Most invasive plants 

provide little shade; therefore removing them would not lead to a measurable change in temperature. Knotweeds 

and other invasive plants would continue to destabilize stream banks. 

Measurable chemical contamination is unlikely. No effect to stream flows is expected under this alternative. The 

acreage that would be treated using herbicide along road segments with high risk of herbicide delivery to surface 

waters is estimated to be less than 40 acres. 

Cumulative Effects 

The spatial scale for cumulative effects analysis for soils and water is the 6th field watershed level. This scale 

was chosen because it allows for consideration of whether herbicide use in all alternatives, when added to other 

actions in the watershed, result in adverse effects beyond those disclosed in the direct and indirect effects 

analysis. Some of the watersheds are primarily Forest Service land and others are mostly private land. National 

Forest System lands cover about 35 percent of the average 6th field watershed in the project area. 

Land management activities, including treatment of invasive plants, would continue to occur on other ownerships 

within 6th field watersheds. Counties commonly treat roadsides with herbicide and non-herbicide methods. 

Herbicides are also used on private farmland, golf courses, and private timberlands. The extent and type of 

herbicide use on private lands was estimated in Chapter 4.1 of the R6 2005 FEIS. 
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None of the streams in the project area are currently 303(d) listed for chemical contamination. The No Action 

Alternative would not contribute to chemical contamination due to the low use of herbicides near water or along 

higher risk roadsides. The minor amount of sediment associated with treatments under No Action is very low 

and would be negligible at the watershed scale, due to the limited acreage treated and the low impacts of these 

treatments at any one site. 

Aquatic Conservation Objectives 

The following discussion is focused on the existing condition relative to invasive plants in the treatment area and 

their impact on meeting ACS objectives. The No Action Alternative assumes ongoing treatment; however, the 

effects of treatments approved under No Action are minor, short-lived and insignificant relative to ACS 

objectives. 

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to 

ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted. 

The diversity of watershed scale features may be impacted over time by the spread of invasive plants. Invasive 

plants found growing adjacent to or within aquatic influence areas can invade, occupy, and dominate riparian 

areas and indirectly impact aquatic ecosystems and fish habitat. About 33 percent of the currently infested sites 

are found within Riparian Reserves. About 70 percent of the invasive plant sites are within Key Watersheds. 

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, 

and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact 

refugia. These network connections must provide chemically and physically unobstructed routes to areas critical 

for fulfilling life history requirements of aquatic and riparian-dependent species. 

No action would not affect chemical or physical routes to areas critical for fulfilling life history requirements of 

aquatic and riparian-dependent species, at any scale. Small obstructions are possible from emergent target 

species (reed canary grass, knotweed, purple loosestrife). Blackberries established along streambanks may 

result in roots aggrading the channel and blocking fish access during low flow. 

Some invasive plant treatments can have positive effects on floodplains and streambanks when infestations of 

invasive plants on valley bottom areas are removed. Valley-bottom infestations often encroach floodplains where 

road-related and recreational activities have led to the establishment of invasive plant populations. Removal of 

such infestations is expected to benefit aquatic and terrestrial communities in the long term by increasing 

floodplain area available for nutrient, sediment and large wood storage, and flood flow refugia. 

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom 

configurations. 

Approximately 12.5 acres of Japanese knotweed and 0.2 acres of giant knotweed are estimated within treatment 

areas on the Olympic National Forest. Japanese knotweed has poor bank holding capacity, which can result in 

bank erosion and sedimentation of streams in high winter flows. 

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. 

Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the 

system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian 

communities. 

Invasive plants do not currently affect water quality. The range and extent of target species in aquatic influence 

zones is relatively small (about 600 acres across the Forest as a whole, no more than 70 acres in any one 6th field 

watershed). No streams on the Forest are water quality listed (303d) for chemical contamination. 
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5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment 

regime include the timing, volume, rate, and character of sediment input, storage, and transport. 

Target species such as knotweed, blackberry, purple loosestrife and reed canarygrass can choke streams, become 

sediment traps and cause stream aggradation, and block fish access. Spawning gravels locked up in the root 

masses are unavailable for fish, and the stream areas around the root masses have such accelerated flows that 

gravels are not retained, resulting in a net loss of fish habitat. Banks could become less stable, leading to 

changes in suspended sediment and substrate character and embeddedness. Potentially this could lead to 

changes in pool frequency and quality. 

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and 

to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial 

distribution of peak, high, and low flows must be protected. 

Invasive plants can change stand structure and alter future inputs of wood and leaves that provide the basic 

foundation of the aquatic ecosystem food webs. Hydrologic changes from invasive plant treatments would never 

be large enough to cause effects at a subwatershed scale. There is no risk of increasing water yield at any scale 

as a result of treating invasive plants. 

7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in 

meadows and wetlands. 

Reed canary grass, purple loosestrife, or knotweed emerging from wetlands can alter water table elevation. 

8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas 

and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of 

surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody 

debris sufficient to sustain physical complexity and stability. 

Riparian vegetation stabilizes stream banks, and acts as a filter to prevent the run-off of soil into streams. 

Riparian vegetation also provides large and small wood to streams, adding to habitat complexity and providing 

cover and food sourced for aquatic organisms. Aquatic ecosystems have evolved with certain vegetation types; 

invasive plants do not necessarily provide similar habitat. 

While knotweed may provide shade, native streamside hardwoods and conifers are much taller, so knotweed 

dominated areas may be associated with higher water temperatures than areas with native forest communities. 

Approximately 156 acres of reed canary grass are mapped along streams and wetlands on the Forest. Reed 

canarygrass is extremely aggressive and often forms persistent, monocultures in wetlands and riparian areas. 

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate 

riparian-dependent species. 

Native vegetation growth may change as a result of infestation, and the type and quality of litter fall, and quality 

of organic matter may decline, which can alter or degrade habitat for aquatic organisms. For example, native 

vegetation regeneration was reduced as a result of knotweed infestations (Urgenson personal communication). 

The amount of nitrogen to aquatic ecosystems through riparian litter fall may be compromised because knotweed 

retains more nitrogen than native species. The availability of nitrogen to aquatic biota and native vegetation 

may be significantly reduced because knotweed can uptake or hold on to 75 percent of leaf nitrogen in the root 

system (ibid). Primary and secondary consumers that form the basic food source for fish and other aquatic 

organisms may be indirectly affected. Reed canarygrass infestations threaten the diversity of these areas, since 

the plant chokes out native plants and grows too densely to provide adequate cover for small mammals and 

waterfowl.
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Alternative B 

Direct and Indirect Effects 

Under Alternative B, all 3,830 infested acres would be treated using herbicides, manual, and mechanical 

methods. Herbicides would be a part of the prescription on most acreage, particularly the first few years of 

treatment. The proposed use of herbicides combined with manual and mechanical methods reduces the potential 

for significant soil disturbance as compared to manual and mechanical methods alone. 

A minor localized increase in fine sediments could result from invasive plant removal along streams, particularly 

if vegetation is removed from stream banks. These effects would be temporary (one season or shorter) until 

vegetation became re-established. Active restoration is proposed on approximately 65 percent of the sites to 

ensure revegetation occurs and erosion is controlled. Forest BMPS, standards and guidelines, and herbicide use 

buffers would be followed to ensure that water resources were protected. 

Broadcast application of herbicides has more potential than other application methods to contact soil and affect 

soil organisms and/or productivity. Broadcast treatments are also associated with a risk of leaving large areas of 

soil bare. Mulching, seeding, and planting would occur as described in the restoration plan, which would reduce 

the risk of erosion or other adverse soil conditions in bare areas. 

In Alternative B, no broadcast treatment would occur on roads having a high potential for herbicide delivery (see 

list and map in Appendix D – this covers 66 percent of the roadside treatment areas). Broadcast application 

would be allowed only on the remaining 34 percent of the treatment areas. No picloram would be used on roads 

having a high potential for herbicide delivery (not even with hand or spot treatments). Broadcast treatments 

within aquatic influence zones would be limited to herbicides posing low levels of concern for aquatic 

organisms. Herbicides considered high risk to aquatic organisms would not be applied using any method within 

15 feet of ditches that feed streams, or 50 to 100 feet from intermittent streams, even when ditches or intermittent 

streams are dry. These buffers are considered adequate to minimize herbicide concentrations in water because, 

buffer studies in forested areas (Berg, 2004) show that [broadcast] buffers greater than 25 feet commonly lower 

herbicide concentrations below detectable limits. Spot and hand treatments require smaller buffers because the 

potential for off site movement using these methods is much less than with broadcasting. 

This project takes into account the delivery mechanism of road side ditches, something most projects do not take 

in to account. By applying buffers for broadcast treatments to the ditches with high potential to deliver 

herbicides through the ditchline to streams, and eliminating the use of herbicides considered high risk to aquatic 

organisms, adverse effects from treating these areas is minimized. 

Given the buffers for broadcast applications on both perennial and intermittent streams, if rain occurred soon 

after application, herbicide would be filtered before entering the water. Spot and hand treatments use small 

amounts of herbicide and sites are scattered; therefore, even if a large rain event occurs soon after treatment, it is 

unlikely that substantial amounts of herbicide would enter water bodies. 

The PDFs were developed considering herbicide and soil properties and are expected to control movement of 

herbicides off-site. Treatments would occur during times of the year when soils are driest. If herbicide treatment 

is necessary when soils are wet, aquatic-labeled herbicides or those that pose low risk to aquatic organisms would 

be used according to label directions. 

Most of the herbicides used under this alternative do not negatively affect soil organisms at typical application 

rates. Of the ten herbicides available for use, two (picloram and sulfometuron methyl) have the potential to 

affect soil organisms at typical application rates. These herbicides have half-lives of 90 days and 10-100 days 

depending on soil conditions. Soil productivity is protected by the PDFs that restrict the amount of these two 

herbicides and the frequency of application. Thus, at any one site, herbicides would be degraded before more 

would be used, and no cumulative chemical loading would occur in the soil. Therefore, cumulative impacts to 

soil productivity would be avoided in all situations. 
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PDFs also minimize the chance of herbicides reaching streams or wetlands. Buffer widths vary depending on 

herbicide ingredients and application method. Wetlands would be treated using non-herbicide methods where 

such treatments are likely to be effective. Non-herbicide treatments are not effective for treating knotweed; 

therefore, some hand application of herbicide would occur in or near stream channels. Where invasive plants are 

emergent from water, herbicide would be applied through hand and selective methods. Effective treatment of 

knotweed and replacement with native vegetation would lead to increased bank and channel stability in these 

sites. 

Effects of Riparian Treatment at the Site Scale 

The potential for run off to result in herbicide contamination to water (associated with treatments within Riparian 

Reserves) was analyzed at the site scale using the SERA Worksheets (SERA 2007). The worksheet model is 

sensitive to the behavior of each herbicide in soil and water. Potential concentrations from emergent vegetation 

treatments were also calculated (see Chapter 3.5 below for more information). The model and calculation were 

used to indicate whether treatments near streams and wetlands could enter water in concentrations above a level 

of concern for beneficial uses, including drinking water and fish. More information on the methodology used is 

in SERA 2007, the Biological Assessment for this project (available on our website or hard copy by request), and 

Chapter 3.5 below. 

Cranberry Bog Botanical Area and the Middle Hoh River treatment areas have the greatest likelihood of 

herbicides coming in contact with water as a result of treatment of emergent wetland vegetation. The worst-case 

analysis indicated a relatively low risk of adverse effects from herbicide delivery at the site scale. While some 

herbicide is predicted to contact water at these sites despite cautious practices, the amount would be much 

smaller than the amount that could cause concern to water quality, watershed processes or aquatic organisms. In 

the analysis, all invasive plants within these treatment areas were assumed to lie near or within a stream, 

floodplain or wetland. In reality, treatment areas contain upland and riparian target species. 

The PDFs, buffers and Implementation Planning process ensures that potential for harm to the aquatic ecosystem 

remains low for future treatments under the Early Detection Rapid Response approach (see Chapter 2.5). No 

more than 6 acres of aquatic emergent invasive vegetation would be treated annually per 6th field watershed. 

Delivery to Streams via Roadside Ditches 

The PDFs and buffers under Alternative B minimize the potential for herbicide to be delivered to streams via 

roadside ditches. No broadcast of herbicide would occur on any roadside with high potential to deliver herbicide 

to streams. Buffers eliminate broadcast treatments and use of certain herbicides where roads cross wet or dry 

streams and/or wetlands (see Chapter 2.5). The distribution of invasive plant infestations in ditches is patchy and 

there are not likely to be treatments of large, contiguous areas. High application rates would be avoided in 

Aquatic Influence Zones, except where necessary to effectively treat target species using selective methods such 

as stem injection. 

Early Detection-Rapid Response 

The PDFs limit the extent of treatment annually within riparian areas and aquatic influence zones, and along 

roads with high potential to deliver herbicide to streams. The PDFs ensure that effects are the same whether new 

or existing infestations are being treated. No adverse cumulative effects are expected from implementation of 

this alternative due to these limitations regardless of the location of future treatments. 

Cumulative Effects 

Buffering waterbodies lowers the potential for herbicide to enter water. While some herbicide delivery to water 

is possible, the amount of herbicide would not exceed any threshold of concern relative to water quality and 

beneficial uses. The herbicides selected for use under this alternative minimize adverse effects while still giving 

a range of treatment options. 
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Less than one percent of the National Forest System land in the project area is proposed for treatment. No more 

than 5 percent of the National Forest System lands allocated to riparian reserves in any 6th field watershed is 

proposed to be treated, and in most cases is far less. This small scale of treatment compared with the watershed 

size is one reason that effects to water quality are unlikely. 

The following ten 6th-field watersheds currently contain at least ten acres of estimated treatment within the 

Aquatic Influence Zones in the upper 70 percent of the watershed. The upper 70 percent is the portion of the 

watershed most likely to contain small, high elevation streams. 

South Fork Calawah River: Approximately 74 infested acres are estimated to lie within Aquatic 

Influence Zones in the upper 70 percent of the watershed. These acres are not concentrated within a 

single part of the watershed. Many of the roads in this watershed are associated with high risk for 

delivery of herbicide to streams. 

Upper West Fork Satsop River Watershed: About 33 infested acres are estimated to lie within 

Aquatic Influence Zones in the upper 70 percent of the watershed. A road with high potential to deliver 

herbicide parallels Spoon Creek. The treatments are all high in the watershed where the streams tend to 

be smaller with less flow but are not concentrated within a single part of the watershed. 

West Fork Humptulips River Watershed: Approximately 34 acres are estimated to lie within Aquatic 

Influence Zones in the upper 70 percent of the watershed. Many of the treatment areas are along roads 

that follow the West Fork Humptulips River or are tributaries to the river. The river is much larger than 

the stream simulated in the GLEAMS modeling. 

East Fork Humptulips River Watershed: The treatments are a combination of roads and plantations. 

Many of the roads parallel the River or tributary streams. About 24 acres are estimated to lie within 

Aquatic Influence Zones in the upper 70 percent of the watershed. These acres are not concentrated 

within a single part of the watershed. Many of the roads in this watershed are associated with high risk 

for delivery of herbicide to streams. 

Quinault Lake: Most of the treatment areas are on roads, developed areas of summer homes and 

campgrounds. Approximately 31 acres are estimated to lie within Aquatic Influence Zones in the upper 

70 percent of the watershed. Few of the roads in this area are considered high risk for delivery of 

herbicide to streams. 

Jefferson Creek Watershed: Approximately 16 acres are estimated to lie within Aquatic Influence 

Zones in the upper 70 percent of the watershed. The treatments are along roads that parallel both 

Jefferson and Washington Creeks. The treatments areas are not concentrated in one area of the watershed 

and the river is much larger than the stream simulated in the GLEAMS modeling. 

Middle Sol Duc River Watershed: Approximately 17 treatment acres are estimated to lie within 

Aquatic Influence Zones in the upper 70 percent of the watershed. The treatments are scattered across 

the watershed along Bear Beaver and Cold Creeks. They are primarily along roads but include other 

disturbed areas including part of the Saddle/Bear planned timber sale. 

Upper South Fork Skokomish River: Approximately 15 acres are estimated to lie within Aquatic 

Influence Zones in the upper 70 percent of the watershed. These treatments are primarily along the 

South Fork Skokomish River, Brown Creek, Pine Creek, Cedar Creek and Lebar Creek. The intermittent 

streams within project areas in this watershed feed into many different perennial streams and are not 

concentrated in any part of the watershed. 

Main Stem Hamma Hamma River Watershed: The treatments parallel the river for over seven miles 

and also follow Boulder Creek. The roads are high risk for delivery of herbicide to the streams. 
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Approximately 13 acres are estimated to lie within Aquatic Influence Zones in the upper 70 percent of 

the watershed and are scattered along miles of treatment areas. 

North Fork Calawah River Watershed: Approximately 24 acres are estimated to lie within Aquatic 

Influence Zones in the upper 70 percent of the watershed. The roads in this watershed are at high risk for 

delivery of herbicide to streams. These acres are not concentrated within a single part of the watershed. 

In all of these 6th field watersheds, treatments are small and scattered. Treatments are unlikely to affect 

functioning of wetlands or water bodies, and there is no risk of retarding achievement of Aquatic Conservation 

Strategy (ACS) objectives because of the limited extent and range of treatments allowed in aquatic influence 

zones. The PDFs limit the amount of treatment that could occur annually in aquatic influence zones (PDFs H13 

and H14) so that future treatments under EDRR do not result in greater potential effects. In all action 

alternatives, no more than 6 acres of aquatic emergent vegetation would be treated in any 6th field watershed, nor 

would more than 10 riparian acres per 1.5 miles of stream be treated in any given year. 

PDFs were developed considering watershed conditions. The PDFs ensure that treatments would not adversely 

affect watershed quality or function, even if invasive plants were to spread further into aquatic influence zones in 

these or other watersheds, or further along roads with high potential to deliver herbicide to surface waters. 

The primary indirect, adverse effects resulting from the proposed action are expected to be of varying duration 

(weeks to years). Degraded water quality from herbicide applications, reflected by primary and secondary 

productivity loss, will last a maximum of a few weeks. Recovery of algae and aquatic macrophytes can take 

weeks to months. Riparian disturbance and disturbed soils resulting from accessing work sites will stabilize and 

begin to revegetate in one year (NMFS 2007 BO). 

Aquatic Conservation Objectives 

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to 

ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted. 

Alternative B would restore the diversity of watershed scale features by removing invasive plants found growing 

adjacent to or within aquatic influence areas. Invasive plant treatment under Alternative B would follow 

recommendations in watershed analysis. 

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, 

and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact 

refugia. These network connections must provide chemically and physically unobstructed routes to areas critical 

for fulfilling life history requirements of aquatic and riparian-dependent species. 

Alternative B would not likely affect chemical or physical routes to areas critical for fulfilling life history 

requirements of aquatic and riparian-dependent species. The amount of treatment in any given watershed is 

small. Less than six percent of National Forest Service system lands within any single 6th field watershed are 

currently infested. These infestations cover less than three percent of any single 6th field watershed. 

The routes for herbicide to contaminate water are treatments of emergent vegetation and potential runoff from a 

large rain storm soon after application, especially from treated roadside ditches. Treatment of emergent 

vegetation is not intended to be a direct application of herbicide to water. However, treatment of emergent 

vegetation may result in some minor drift to surface waters (particularly at the Cranberry Bog Botanical area 

and Middle Hoh River Floodplain site). Previous monitoring efforts from the State of Washington have not 

detected exceedance of State drinking water standards for spot treatment of emergent vegetation. Concentrations 

of herbicide that could reach streams from these treatments would be far below levels of concern. 

Invasive plant treatments will not create physical barriers or otherwise degrade access to aquatic habitat. 
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3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom 

configurations. 

Alternative B would restore the physical integrity of shorelines and streambanks by replacing invasive plants 

with native plant communities. The types of treatments proposed could result in minor streambank erosion, but 

since no heavy equipment would be used, impacts would be localized and short-lived. There is no risk of 

negatively impacting channel condition and dynamics as a result of treating invasive plants. 

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. 

Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the 

system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian 

communities. 

The extent and range of infestations currently found in aquatic influence zones is relatively small (about 600 

acres over the National Forest as a whole, no more than 74 acres in any 6th field watershed). No more than ten 

acres would be treated within any 1.5 miles of stream. The amount of treatment that could occur annually in 

aquatic influence zones is limited by PDFs H14 and H15, so that future treatments under EDRR would not result 

in greater potential effects. Some herbicide may enter water bodies, but not in quantities sufficient to reduce 

water quality at any scale. 

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment 

regime include the timing, volume, rate, and character of sediment input, storage, and transport. 

Treatment of invasive plants has a low probability for producing sediment because very little ground disturbance 

will take place when invasive plants are treated with spot-spray or hand applications. Manual, mechanical, and 

restoration treatments are extremely unlikely to contribute sediment. The integration of 

manual/mechanical/herbicide treatments would limit the potential for excessive trampling and not solely rely on 

manual labor. Manual labor such as hand pulling and the use of mechanical equipment to control invasive 

plants may result in localized soil disturbance, but increases of sediment to streams would likely be undetectable. 

Not all vegetation in a treated area would be pulled or removed, so some ground cover plants would remain. Not 

all sediment from pulling weeds along roads or use of mechanical equipment to cut weeds would reach a stream 

because many relief culverts intercept ditch flow and drain it on to the forest floor away from streams. 

Handpulling is very labor intensive and costly. Thus, few acres per year could be treated using this technique 

across a watershed. The amount of sediment created by manual, mechanical, and restoration treatments is 

anticipated to be insignificant because the methods of treatments do not include ground disturbing activities by 

heavy equipment. When compared to the total acres within a watershed, project-related soil disturbance from 

handpulling would be negligible. 

Removal of invasive plants and replacement with native plant communities would restore sediment regime 

affected by knotweed and other target species. Projects may result in small amounts of sediment, especially 

related to manual and mechanical treatments, but the limited overall extent would not result in watershed-scale 

impacts. No heavy equipment would be used off roads in riparian reserves. 

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and 

to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial 

distribution of peak, high, and low flows must be protected. 

Removal of invasive plants and replacement with native plant communities would restore future inputs of wood 

and leaves that provide the basic foundation of the aquatic ecosystem food webs. Treatment of invasive plants in 

riparian reserves would not impact current wood debris in streams. The PDF that establishes a 100 ft buffer for 

broadcast applications provides protection to the recruitment of conifer seedlings within riparian areas which 

will sustain channel and habitat features in the future. With the treatment of invasive plants, riparian stands in 

time would develop larger recruitment trees and would increase the size of inchannel debris. 
Final Environmental Impact Statement 

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7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in 

meadows and wetlands. 

Removal of invasive plants and replacement with native plant communities would restore floodplain habitat and 

water table elevation in meadows and wetlands. The Hoh River Floodplain was analyzed for a worst-case 

scenario involving herbicide use. Results indicated a low level of risk from proposed treatments (see Chapter 3.5 

of the FEIS). 

8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas 

and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of 

surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody 

debris sufficient to sustain physical complexity and stability. 

Removal of invasive plants and replacement with native plant communities would restore species composition 

and structural diversity in riparian areas and wetlands. Herbicide application near streams may result in some 

minor non-target vegetation impacts at the site scale; however, the amount of herbicide that could contact 

streams would not be enough to species or structural diversity. 

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate 

riparian-dependent species. 

Removal of invasive plants and replacement with native plant communities would restore habitat for species 

dependant on riparian and aquatic habitats. The use of spot-spray applications of aquatic glyphosate and 

aquatic imazapyr near wet streams may result in some minor non-target vegetation impacts at the site scale. 

However, the amount necessary to affect to affect habitat for populations of plants, invertebrates and vertebrates 

in riparian areas is not possible with spot-spray applications.

Alternative C 

Direct and Indirect Effects 

This alternative includes no broadcast application of herbicides and no herbicide use in Riparian Reserves or 

along any road having a high potential to deliver herbicide (see Appendix D for a map and list of these roads). 

About 1,025 acres would be treated with herbicides, all outside of aquatic influence zones. Thus, there would 

also little risk of runoff carrying herbicide to streams. 

Alternative C has the greatest potential for erosion and sediment delivery to streams due to reliance on nonherbicide methods in riparian reserves and along many of the roads across the Forest. Alternative C increases the 

risk of trampling and instability of stream banks due to its reliance on non-herbicide treatments, particularly in 

areas where Scotch broom or other invasives grows directly along stream banks. The greatest likelihood of 

measurable erosion within the scope of any alternative is associated with weed wrenching scotch broom without 

accompanying herbicide use. 

About half of the scotch broom acreage to be treated under the current inventory is along roads identified as 

having a risk of herbicide delivery to streams and may be within Riparian Reserves. Herbicide use would be 

excluded in these areas, thus there would be increased risk of erosion from non-herbicide methods. Ironically, 

these are the areas where erosion could lead to stream sedimentation. However, treatment sites are currently 

small and scattered across the Forest, so the likelihood of significant adverse impacts is remote. Effects would be 

minor, localized and short-term effect and passive and or active revegetation would occur. 

Invasive plants provide little shade therefore removing them would not lead to a measurable change in 

temperature. The treatments proposed are unlikely to result in significant amounts of decaying plants or nutrients 

entering a stream at one time and therefore no measurable effect to oxygen levels is anticipated. In the long-term 

temperature would be improved on streams currently impacted by invasive plants because native, shadeproducing vegetation could be restored. 
Final Environmental Impact Statement 

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152

Effects of Riparian Treatment at the Site Scale 

No herbicide would be used in any riparian area, so there would be no potential for SERA predicted results to 

actually occur. 

Delivery to Streams via Roadside Ditches 

Alternative C virtually eliminates risk of herbicide delivery to streams from roadside ditches by prohibiting 

herbicide use on high risk road segments or in Riparian Reserves. 

Early Detection-Rapid Response 

Future treatments under EDRR would follow the PDFs for Alternative C. Thus, the potential for herbicide 

delivery to streams would be very low regardless of the extent or location of treatment under EDRR. Nonherbicide treatment in aquatic influence zones and along certain roads could result in increased erosion, 

depending on the location and extent of treatment. 

Cumulative Effects 

The cumulative effects of Alternative C are similar to Alternative A within Aquatic Influence Zones and roadside 

treatment areas that have a high risk of delivering herbicide to streams. The cumulative effects of Alternative C 

are similar to Alternative B outside these areas. 

Aquatic Conservation Objectives 

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to 

ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted. 

Alternative C would restore he diversity of watershed scale features by removing invasive plants found growing 

adjacent to or within aquatic influence areas. Invasive plant treatment under Alternative C would follow 

recommendations in watershed analysis. Alternative C is less cost-effective than Alternative B in restoring native 

plant communities so it would take longer and cost more to restore desired conditions. 

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, 

and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact 

refugia. These network connections must provide chemically and physically unobstructed routes to areas critical 

for fulfilling life history requirements of aquatic and riparian-dependent species. 

Alternative C would not likely affect chemical or physical routes to areas critical for fulfilling life history 

requirements of aquatic and riparian-dependent species. The amount of treatment in any given watershed is 

small. Less than six percent of National Forest System lands within any single 6th field watershed are currently 

infested. These infestations cover less than three percent of any single 6th field watershed when other ownership 

acreage is added. 

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom 

configurations. 

Alternative C would restore the physical integrity of shorelines and streambanks by replacing invasive plants 

with native plant communities. The types of treatments proposed could result in minor streambank erosion, but 

since no heavy equipment would be used, impacts would be localized and short-lived. Alternative C is less costeffective than Alternative B in restoring native plant communities so it would take longer and cost more to restore 

desired conditions. In addition, because no herbicide would be used on shorelines or streambanks, greater 

reliance on manual and mechanical treatments could lead to increased erosion compared to Alternative B. 
Final Environmental Impact Statement 

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153

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. 

Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the 

system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian 

communities. 

The extent and range of infestations currently found in aquatic influence zones is relatively small (about 600 

acres over the National Forest as a whole, no more than 74 acres in any 6th field watershed). No more than ten 

acres would be treated within any 1.5 miles of stream. The amount of treatment that could occur annually in 

aquatic influence zones is limited by PDFs H13 and H14, so that future treatments under EDRR would not result 

in greater potential effects. No herbicide would enter water bodies so no chemical contamination would be 

possible. 

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment 

regime include the timing, volume, rate, and character of sediment input, storage, and transport. 

Removal of invasive plants and replacement with native plant communities would restore sediment regime 

affected by knotweed and other target species. Projects may result in small amounts of sediment, especially 

related to manual and mechanical treatments, but the limited overall extent would not result in watershed-scale 

impacts. No heavy equipment would be used off roads in riparian reserves. Alternative C is less cost-effective 

than Alternative B in restoring native plant communities so it would take longer and cost more to restore desired 

conditions. In addition, because no herbicide would be used on shorelines or streambanks, greater reliance on 

manual and mechanical treatments could lead to increased erosion compared to Alternative B. 

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and 

to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial 

distribution of peak, high, and low flows must be protected. 

Removal of invasive plants and replacement with native plant communities would restore future inputs of wood 

and leaves that provide the basic foundation of the aquatic ecosystem food webs. Alternative C is less costeffective than Alternative B in restoring native plant communities so it would take longer and cost more to restore 

desired conditions. 

7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in 

meadows and wetlands. 

Removal of invasive plants and replacement with native plant communities would restore floodplain habitat and 

water table elevation in meadows and wetlands. Alternative C is less cost-effective than Alternative B in 

restoring native plant communities so it would take longer and cost more to restore desired conditions. 

8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas 

and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of 

surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody 

debris sufficient to sustain physical complexity and stability. 

Removal of invasive plants and replacement with native plant communities would restore species composition 

and structural diversity in riparian areas and wetlands. Alternative C is less cost-effective than Alternative B in 

restoring native plant communities so it would take longer and cost more to restore desired conditions. 
Final Environmental Impact Statement 

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154

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate 

riparian-dependent species. 

Removal of invasive plants and replacement with native plant communities would restore habitat for species 

dependant on riparian and aquatic habitats. Alternative C is less cost-effective than Alternative B in restoring 

native plant communities so it would take longer and cost more to restore desired conditions. 

Alternative D 

Direct and Indirect Effects 

Alternative D allows broadcast of herbicide along roadsides with high potential to deliver herbicide to streams. It 

also does not require buffers where roads cross dry streams. Therefore, Alternative D has the greatest risk of 

herbicide delivery to surface waters. It increases risk compared to the Proposed Action because buffers for dry 

streams (Table 14 and PDF H3 (Table 12) regarding roads having high potential for herbicide delivery would not 

be applied. All other PDFs for perennial streams, municipal watersheds, wetlands, ponds and lakes would be 

applied. 

Aquatic emergent treatments and treatments near streams would have similar aquatic use restrictions as to 

Alternative B. Thus, Alternative D would not necessarily meet all Forest Plan Standards for Riparian Reserves. 

To meet the standards, either broadcast treatments would need to be eliminated in these areas, or herbicides 

selected for broadcasting would have to be among those of lower risk to aquatic organisms (see Aquatic 

Organism section 3.5), or additional monitoring would have to occur to ensure that herbicides do not enter water 

in concentrations of concern relative to aquatic organisms. 

Effects of Riparian Treatment at the Site Scale 

The potential for run off to result in herbicide contamination to water (associated with treatments within Riparian 

Reserves) was analyzed at the site scale using the SERA Worksheets (SERA 2007). The analysis for Alternative 

B also applies to Alternative D relative to treatments near wet streams, lakes and wetlands. As in Alternative B, 

the PDFs, buffers and Implementation Planning process ensure that potential for harm to the aquatic 

ecosystem remains low for future treatments under the Early Detection Rapid Response approach (see 

Chapter 2.5). 

Delivery to Streams via Roadside Ditches 

Alternative D allows broadcast of herbicide along roadsides with high potential to deliver herbicide to streams. It 

also does not require buffers where roads cross dry streams. Thus, potential for herbicides to be delivered to 

streams in concentrations of concern via roadside ditches and dry streams is highest for Alternative D than the 

other alternatives. The distribution of invasive plant infestations in ditches is patchy and there are not likely to be 

treatment of large, contiguous areas. Use of maximum herbicide application rates would be rare and only in 

isolated situations. Thus, while the potential for harmful concentrations of herbicides to reach streams is greatest 

in this alternative, the likelihood of an actual adverse effect is low. Under a worst-case scenario, herbicide use 

preceding a “first flush” type storm could mobilize harmful concentrations of some herbicides allowed for use 

under Alternative D. 

The Olympic LRMP as amended by the R6 2005 ROD Standard 19 requires that direct or indirect negative 

effects to water quality be minimized through project design. Therefore, while Alternative D allows for greater 

flexibility in herbicide use, mitigation would have to be added during implementation planning to ensure that no 

significant adverse effects to water quality would occur. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

155

Early Detection-Rapid Response 

The effects of treatment would be the same whether new or existing target species were being treated. Broadcast 

applications on roads having high potential for herbicide delivery, and increased flexibility near dry streams 

would continue to pose additional risk that is avoided in the Proposed Action. Herbicide would not likely enter 

water in concentrations over a level of concern because the infestations are predicted to continue to be small and 

scattered. There would be an annual cap on treatments within aquatic influence zones; however there would be 

no specific cap on herbicides applied along roads having high potential to deliver herbicide. The risk of water 

quality degradation would be greatest with continuous use of certain herbicides within roadside ditches. 

Cumulative Effects 

Similarly to the Proposed Action, the properties of the herbicides proposed for use, the types of treatments 

proposed, and the limitations associated with PDFs and buffers reduces the likelihood for impacts to actually 

occur or contribute to cumulative effects. While there would be increased risk of herbicide delivery on some 

roadsides, the amount of herbicide that could actually enter water would be comparatively small and rapidly 

diluted. 

Alternative D would have the potential to contribute to significant cumulative adverse effects if rainfall occurred 

soon after extensive broadcast treatments and other landowners or managers simultaneously used herbicides on 

neighboring lands. Such a scenario is possible, but unlikely to occur. This would be more likely in watersheds 

having more than 10 acres of treatment within the aquatic influence zone in the upper 70 percent of a watershed 

(see watersheds listed under Alternative B above). 

The upper 70 percent is the portion of the Forest most likely to contain small, high elevation streams where 

effects of lower risk project could trigger a higher level of risk (R6 2005 Monitoring Framework). Broadcast 

application along roads with high potential to deliver herbicide to streams, would pose a greater level of risk in 

these watersheds. 

Aquatic Conservation Strategy Objectives 

1. Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to 

ensure protection of the aquatic systems to which species, populations and communities are uniquely adapted. 

Alternative D would restore the diversity of watershed scale features by removing invasive plants found growing 

adjacent to or within aquatic influence areas. Invasive plant treatment under Alternative B would follow 

recommendations in watershed analysis. 

2. Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, 

and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact 

refugia. These network connections must provide chemically and physically unobstructed routes to areas critical 

for fulfilling life history requirements of aquatic and riparian-dependent species. 

Alternative D would not likely affect chemical or physical routes to areas critical for fulfilling life history 

requirements of aquatic and riparian-dependent species. The amount of treatment in any given watershed is 

small. Less than six percent of National Forest Service system lands within any single 6th field watershed are 

currently infested. These infestations cover less than three percent of any single 6th field watershed. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

156

The routes for herbicide to contaminate water are treatments of emergent vegetation and potential runoff from a 

large rain storm soon after application, especially from treated roadside ditches. Treatment of emergent 

vegetation is not intended to be a direct application of herbicide to water. However, treatment of emergent 

vegetation may result in some minor drift to surface waters (particularly at the Cranberry Bog Botanical area 

and Middle Hoh River Floodplain site). Previous monitoring efforts from the State of Washington have not 

detected any exceedance of State drinking water standards for spot treatment of emergent vegetation. 

Concentrations of herbicide that could reach streams from these treatments would be far below levels of concern. 

Invasive plant treatments will not create physical barriers or otherwise degrade access to aquatic habitat. 

3. Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom 

configurations. 

Alternative D would restore the physical integrity of shorelines and streambanks by replacing invasive plants 

with native plant communities. The types of treatments proposed could result in minor streambank erosion, but 

since no heavy equipment would be used, impacts would be localized and short-lived. There is no risk of 

negatively impacting channel condition and dynamics as a result of treating invasive plants. 

4. Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. 

Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the 

system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian 

communities. 

The extent and range of infestations currently found in aquatic influence zones is relatively small (about 600 

acres over the National Forest as a whole, no more than 74 acres in any 6th field watershed). No more than ten 

acres would be treated within any 1.5 miles of stream. The amount of treatment that could occur annually in 

aquatic influence zones is limited by PDFs H14 and H15, so that future treatments under EDRR would not result 

in greater potential effects. Broadcast treatments along intermittent streams and roadside ditches in Alternative 

D could deliver herbicides to streams and other water bodies in sufficient quantity to affect water quality. 

5. Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment 

regime include the timing, volume, rate, and character of sediment input, storage, and transport. 

Treatment of invasive plants has a low probability for producing sediment because very little ground disturbance 

will take place when invasive plants are treated with spot-spray or hand applications. Manual, mechanical, and 

restoration treatments are extremely unlikely to contribute sediment. The integration of 

manual/mechanical/herbicide treatments would limit the potential for excessive trampling and not solely rely on 

manual labor. Manual labor such as hand pulling and the use of mechanical equipment to control invasive 

plants may result in localized soil disturbance, but increases of sediment to streams would likely be undetectable. 

Not all vegetation in a treated area would be pulled or removed, so some ground cover plants would remain. Not 

all sediment from pulling weeds along roads or use of mechanical equipment to cut weeds would reach a stream 

because many relief culverts intercept ditch flow and drain it on to the forest floor away from streams. 

Handpulling is very labor intensive and costly. Thus, few acres per year could be treated using this technique 

across a watershed. The amount of sediment created by manual, mechanical, and restoration treatments is 

anticipated to be insignificant because the methods of treatments do not include ground disturbing activities by 

heavy equipment. When compared to the total acres within a watershed, project-related soil disturbance from 

handpulling would be negligible. 

Removal of invasive plants and replacement with native plant communities would restore sediment regime 

affected by knotweed and other target species. Projects may result in small amounts of sediment, especially 

related to manual and mechanical treatments, but the limited overall extent would not result in watershed-scale 

impacts. No heavy equipment would be used off roads in riparian reserves. 
Final Environmental Impact Statement 

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157

6. Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and 

to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial 

distribution of peak, high, and low flows must be protected. 

Removal of invasive plants and replacement with native plant communities would restore future inputs of wood 

and leaves that provide the basic foundation of the aquatic ecosystem food webs. 

7. Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in 

meadows and wetlands. 

Removal of invasive plants and replacement with native plant communities would restore floodplain habitat and 

water table elevation in meadows and wetlands. 

8. Maintain and restore the species composition and structural diversity of plant communities in riparian areas 

and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of 

surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody 

debris sufficient to sustain physical complexity and stability. 

Removal of invasive plants and replacement with native plant communities would restore species composition 

and structural diversity in riparian areas and wetlands. The use of spot-spray applications of aquatic glyphosate 

and aquatic imazapyr near wet streams may result in some minor non-target vegetation impacts at the site scale. 

However, the amount necessary to affect to kill trees in a riparian area is not possible with spot-spray 

applications. Invasive plant treatments could temporarily reduce streamside vegetation (albeit non-native and 

low quality) that provides cover for fish. Risk of adverse herbicide effects would be increased from broadcast 

treatments near dry streams in Alternative D, however sediment, nutrient, and wood routing would not be 

affected at any scale. 

9. Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate 

riparian-dependent species.

Removal of invasive plants and replacement with native plant communities would restore habitat for species 

dependant on riparian and aquatic habitat.
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

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Alternative Comparison – Soil and Water 

Table 56-Comparison of Herbicide Use within Aquatic Influence Zones 

Alternative Amount and Character of Herbicide Use 

Within Aquatic Influence Zones 

Estimated 

Proportion of 

Project Area 

Where 

Broadcast 

Methods May 

Be Considered 

Estimated 

acreage of project 

where herbicide 

treatment may 

occur on roads 

with high 

potential to 

deliver herbicides 

to streams 

Estimated proportion of 

project where broadcast 

may occur on roads with 

high potential to deliver 

herbicides to streams 

No Action 

(Alternative A) 

Fewer than 30 acres of spot and hand 

treatment 0 % Fewer than 40 acres 

0 %. 

Proposed 

Action 

(Alternative B) 

Buffers restrict broadcasting near 

perennial and intermittent streams; 

treatment of wetland emergent or 

streamside target vegetation would 

require low aquatic risk or aquatic 

labeled herbicides. 

34% 1,420 0 % 

Alternative C None 0 % 0 0 % 

Alternative D 

Buffers restrict broadcasting near wet 

streams; treatment of wetland emergent 

or streamside target vegetation would 

require low aquatic risk or aquatic 

labeled herbicides. No restrictions 

beyond herbicide label advisories would 

apply to dry streams. 

86% 1,420 37% 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

159

3.5 Aquatic Organisms and Habitat 

The potential effect of invasive plant treatments on aquatic organisms is a primary public issue (Issue Group 5). 

Many people have expressed concern about the effects of herbicide use on fish and the aquatic ecosystem. Many 

laws, policies, standards and guidelines relate to aquatic ecosystems and activities near streams. The discussion 

below focuses on the likelihood of potential effects on aquatic organisms and their habitat should any alternative 

result in herbicides coming in contact with water. The analysis complements the Soil and Water section above. 

All alternatives (including No Action) “May Impact” sensitive aquatic species, but none will affect the viability 

of any species or cause any species to be listed under the Endangered Species Act. All alternatives “May Affect” 

aquatic species listed or proposed for listing under the Endangered Species Act, but none will jeopardize the 

continued existence of any species. All alternatives would result in long-term restoration where natural plant 

communities and disturbance regimes have been altered by weeds is noted by all. None of the chemicals 

proposed for use would result in long-term adverse alteration of habitat (NMFS 2007 BO). 

Consultation with the Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS, also 

referred to as NOAA Fisheries) has been completed for this project. The Forest Service worked with these 

agencies from project inception throughout the planning process. NMFS submitted a comment letter expressing 

concerns about the Proposed Action and its potential effects on listed fish (see Appendix H). Over the course of 

2006 and into early 2007, there were a series of meetings and negotiations between the Forest Service, FWS and 

NMFS staff to develop the project description and finalize the Biological Assessment (FWS 2007 BO.). 

The Biological Assessment was submitted in January 2007, covering proposed actions that were considered both 

“not likely” and “likely” to adversely affect aquatic species listed or proposed for listing under the Endangered 

Species Act. Each agency (FWS and NMFS) prepared its own documents in response to the BA, including 

letters of concurrence on the portions of the project they considered “not likely” to adversely affect the species 

(FWS April 2007 and NMFS May 2007) and Biological Opinions (BOs) for portions of the project they 

considered “likely” to affect such species (FWS September 2007 and NMFS October 2007). The BOs concluded 

that the project is not likely to jeopardize the continued existence of bull trout, Puget Sound Chinook, Hood 

Canal summer-run chum, or Puget Sound steelhead, or result in the adverse modification or destruction of 

designated critical habitat. 

FWS and NMFS have authorized incidental take on the known sites as well as the EDRR approach for future 

detections. “Reasonable and Prudent Measures” necessary to minimize the taking of federally listed fish are 

documented in the BOs. The BA, letters of concurrence and BOs are available hard copy on request or via the 

Forest Service website: http://www.fs.fed.us/r6/olympic. 

3.5.1 Affected Environment 

Effects of Invasive Plants on Aquatic Ecosystems 

As described previously, invasive plants found growing adjacent to or within aquatic influence areas can invade, 

occupy, and dominate riparian areas and indirectly impact aquatic ecosystems and fish habitat. Target species 

such as knotweed and blackberry can choke streams, become sediment traps and cause stream aggradation, 

and/or block fish access. Spawning gravels locked up in the root masses are unavailable for fish, and the stream 

areas around the root masses have such accelerated flows that gravels aren’t retained, resulting in a net loss of 

fish habitat. 

Invasive plants can change stand structure and alter future inputs of wood and leaves that provide the basic 

foundation of the aquatic ecosystem food webs. Native vegetation growth may change as a result of infestation, 

and the type and quality of litter fall, and quality of organic matter may decline, which can alter or degrade 

habitat for aquatic organisms. For example, native vegetation regeneration was reduced as a result of knotweed 

infestations (Lauren Urgenson, personal communication). The amount of nitrogen to aquatic ecosystems through 

riparian litter fall may be compromised because knotweed retains more nitrogen than native species. 
Final Environmental Impact Statement 

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160

The availability of nitrogen to aquatic biota and native vegetation may be significantly reduced because 

knotweed can uptake or hold on to 75 percent of leaf nitrogen in the root system (ibid). Primary and secondary 

consumers that form the basic food source for fish and other aquatic organisms may be indirectly affected.

Aquatic Species of Local Interest 

The Olympic National Forest has many Aquatic Species of Local Interest including the List Of Aquatic 

Species Proposed Or Listed As Endangered Or Threatened Under The Endangered Species Act (Table 

57) and the Regional Forester’s Sensitive Species list (July 2004, see Table 60). 

Fish distribution data is from WDFW and local Forest fish biologists. Appendix C displays brief 

summaries regarding the life history and other information for each of these species, compiled from a 

variety of sources. Additional information related to life history and status of populations at the 

Evolutionary Significant Unit (ESU) or Distinct Population Segment (DPS) scale can be found in the 

following sources: 

• R6 2005 FEIS Fisheries Biological Assessment (BA), Environmental Baseline 

• NMFS and USFWS Federal Register documents (http://www.nwr.noaa.gov/ESA-SalmonListings/Salmon-Populations/Index.cfm), (http://www.fws.gov/pacific/bulltrout/), 

• Shared Strategy for Puget Sound for Puget Sound Chinook Salmon, Hood Canal summer chum salmon, 

and bull trout population in the Puget Sound area (http://www.sharedsalmonstrategy.org/plan/docs/) 

• Draft Coast Puget Sound Bull Trout Recovery Plan (http://www.fws.gov/pacific/bulltrout/recovery.html) 

• http://www.nativefish.org/articles/OlympicMudminnow.php

• http://wlapwww.gov.bc.ca/wld/documents/salishsucker.pdf

Federally Listed Aquatic Species 

The following species are listed as Proposed or Threatened under the Federal Endangered Species Act (ESA). 

Critical habitat has also been designated for some of these species. A Biological Assessment was submitted in 

January 2007 including actions that were considered both “not likely” and “likely” to adversely affect aquatic 

species listed or proposed for listing under the Endangered Species Act. Each agency (FWS and NMFS) 

prepared its own documents in response to the BA, including letters of concurrence on the portions of the project 

they considered “not likely” to adversely affect the species and Biological Opinions (BO) for portions of the 

project they considered “likely” to affect such species. The BOs authorize incidental take on the known sites as 

well as the EDRR approach for future detections. 

Table 57 gives the status and watersheds providing habitat for species listed or proposed for listing under the 

ESA. Table 58 provides life cycle information on these species. Discussions about critical habitat and a list of 

treatment areas within 100 feet of listed fish bearing streams follow. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

161

Table 57-Species Listed and Proposed For Listing ESA and their Critical Habitat within the Project Area 

Species 

DPS or 

Critical 

Habitat 

Status/ 

Federal 

Register 

Reference 

5th Field Watersheds on 

NF (Critical Habitat) Habitat and Life History 

Steelhead Puget Sound 

Proposed/ 

71 FR 15666 

3/29/06 

Big Quilcene River, Elwha 

River*, Discovery Bay, 

Dungeness River, 

Dosewallips River, 

Duckabush River, Hamma 

Hamma River*, Lower 

West Hood Canal*, 

Sequim Bay, Skokomish 

River, Upper West Hood 

Canal 

The most widespread run type of steelhead on 

Olympic National Forest is the winter (oceanmaturing) steelhead. Winter steelhead are 

found in nearly all coastal rivers of 

Washington. Impassable barriers in streams 

on Olympic National Forest limit their 

distribution. Winter run steelhead typically 

enter streams for spawning between 

November and April (Wydoski and Whitney 

2003). Fry emerge in April through June and 

generally spend one to two years in 

freshwater, preferring riffle areas in the 

summer and occupying pools during the rest of 

the year (ibid). 

Puget Sound 

Threatened/ 

64 FR 14308 

3/24/99 

Chinook 

Salmon Puget Sound 

Critical 

Habitat 

Designated/ 

70 FR 52629 

09/02/05 

Elwha River*, Dungeness 

River, Dosewallips River, 

Duckabush River, Hamma 

Hamma River*, 

Skokomish River 

Because of the size of Chinook, they prefer 

spawning habitats that includes deeper water 

and larger gravels than for most other salmon 

species. Two life history types – ocean and 

stream – are recognized in Chinook salmon, 

based upon the length of time the juvenile fish 

spend rearing in streams and rivers. Oceantype Chinook move relatively quickly into 

saltwater following emergence. Some fry 

enter marine environments almost 

immediately, but most inhabit the shallow side 

margins and side sloughs for up to two 

months. It is unlikely that ocean-type Chinook 

(mostly fall Chinook) on Olympic National 

Forest would be exposed to disturbance and 

herbicides from emergent vegetation 

treatments. Stream-type Chinook overwinter 

in fresh water, typically migrating to the ocean 

the following spring. 

Hood Canal 

Summer-run 

Threatened/ 

64 FR 14508 

03/25/99 

Chum 

Salmon Hood Canal 

Summer-run 

Critical 

Habitat 

Designated/ 

70 FR 52629 

09/02/05 

Dungeness*, Sequim 

Bay*, Discovery Bay*, 

Dosewallips River*, 

Duckabush River, Big 

Quilcene River*, Upper 

West Hood Canal 

Frontal*, Hamma Hamma 

River*, Skokomish River** 

Freshwater migration in the Pacific Northwest 

is typically short in distance (<50 miles). 

Chum salmon utilize low gradient (1-2%), 

sometimes tidally-influenced reaches of 

streams for spawning, which limits their 

spawning distribution on Olympic National 

Forest. Most tidally-influenced areas have 

been disturbed in some form, which has 

introduced invasive species, such as knotweed 

along the streambanks or gravel bars. 

Coastal 

PugetSound 

Threatened/ 

64 FR 58910 

11/01/99 

Hoh River, Queets River, 

Upper Quinault River, 

Lower Quinault River*, 

Wishkah River*, Satsop 

River**, Wynoochee 

River**, Humptulips River, 

Skokomish River, 

Dungeness River, Elwha 

River 

Bull Trout 

Coastal 

PugetSound 

Critical 

Habitat 

Designated/ 

70 FR 56212 

09/26/05 

Does not include ONF 

lands 

Bull trout move upstream in late summer and 

early fall to spawn in September and October 

– or in November at higher elevations 

(Wydoski and Whitney 2003). Extended 

incubation periods (4 to 5 months) make eggs 

and fry particularly susceptible to increases in 

fine sediments. Fry remain in the streambed 

for up to 3 weeks before emerging. Fry are 

typically found in shallow, backwater side 

channels and eddies in proximity to instream 

cover. Juveniles are typically found in 

interstitial spaces in the substrate, and 

subadults in deeper pools of streams or in the 

deep water of lakes. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

162

*These species are present lower in watershed off National Forest lands. 

**There was historic distribution within these watersheds on National Forest System lands. 

Life Cycle Timing for Federally Listed Fish Species 

Table 58-Life Cycle Timing of Federally Listed Fish Species in the Project Area 

Stock Migration Spawning Incubation Rearing 

Puget Sound Chinook August to September September to 

November 

September to February Saltwater only 

Hood Canal Summer Chum Late August to 

mid-October 

September to 

October 

September to 

February 

Saltwater only 

Bull Trout Mid-June to 

November 

Mid-September to 

mid-December 

Mid-September to June Year round 

Puget Sound Steelhead Late November to 

April 

December to 

April 

December to June Year round 

Designated Critical Habitat for Pacific Salmon 

Critical habitat was designated for Puget Sound chinook salmon and Hood Canal summer-run chum salmon on 

February 16, 2000 (65 FR 7764), but vacated by court order on April 30, 2002. Critical Habitat for this species 

was proposed on December 14, 2004 (69 FR 74572) and designated on September 2, 2005 (70 FR 52629). 

Fifth field watersheds on Olympic National Forest with designated critical habitat are the Dungeness/Elwha, 

Hood Canal, Dosewallips, Duckabush, Hamma Hamma, and Skokomish Rivers. 

NMFS designates critical habitat based on physical and biological features that are essential to the listed species. 

Essential features of designated critical habitat are: (1) substrate, (2) water quality, (3) water quantity, (4)water 

temperature, (5) water velocity, (6) cover/shelter, (7) food for juveniles, (8) riparian vegetation, (9) space, and 

(10) safe passage conditions (50 CFR 226.212). The three freshwater primary constituent elements of critical 

habitat are: 

3. Freshwater spawning sites with water quantity and quality conditions and substrate supporting 

spawning, incubation and larval development; 

4. Freshwater rearing sites with water quantity and floodplain connectivity to form and maintain 

physical habitat conditions and support juvenile growth and mobility; water quality and forage 

supporting juvenile development; and natural cover such as shade, submerged and overhanging large 

wood, log jams and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and 

undercut banks; 

5. Freshwater migration corridors free of obstruction with water quantity and quality conditions and 

natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and 

boulders, side channels, and undercut banks supporting juvenile and adult mobility and survival. 

Recent designated critical habitat on the Olympic National Forest includes the stream channels in each 

designated reach, and a lateral extent as defined by the ordinary high water line (Sept. 2, 2005; 70 FR 52629). 

The primary constituent elements essential for conservation of listed ESUs are those sites and habitat 

components that support one or more fish life stages, including freshwater spawning sites, freshwater rearing 

sites, and freshwater migration corridors. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

163

Designated Critical Habitat for Coastal Puget Sound Bull Trout 

The FWS proposed to designate critical habitat for the Coastal Puget Sound DPSs on June 25, 2004 (69 FR 

35768). A final ruling was made on September 26, 2005 (70 FR 56212) to designate critical habitat for the 

Klamath river, Columbia River, Jarbridge River, Coastal Puget Sound, and Saint Mary-Belly River populations 

of bull trout in the coterminous United States. Lands proposed for critical habitat for Coastal-Puget Sound bull 

trout excludes National Forest System lands. 

The FWS determined that PACFISH, INFISH, the Interior Columbia Basin Ecosystem Management Project 

(ICBMP) strategy, and the Northwest Forest Plan (NWFP) Aquatic Conservation Strategy (ACS) provide a level 

of conservation and adequate protection and special management for the PCEs essential to the conservation of 

bull trout at least comparable to that achieved by designating critical habitat. As a result, those lands are not 

being designated critical habitat as they do not meet the statutory definition. In many specific ways these plans 

are superior to a designation in that they require enhancement and restoration of habitat, acts not required by the 

designation. 

Areas related to the scope of this EIS and exempt from designated critical habitat are NF lands under the 

Northwest Forest Plan. However, downstream impacts from activities on NF lands may affect critical habitat and 

is therefore assessed in this EIS and January 2007 Fish and Wildlife Biological Assessment and other 

consultation documents. 

Critical habitat extends from the bankfull elevation on one side of the stream channel to the bankfull elevation on 

the opposite side. Adjacent floodplains are not proposed as critical habitat. The lateral extent of proposed lakes 

and reservoirs is defined by the perimeter of the water body as mapped on standard 1:24,000 scale maps. 

The FWS critical habitat designation identified those physical and biological features of the habitat that are 

essential to the conservation of the species and that may require special management consideration or protection. 

These physical and biological features include, but are not limited to: space for individual and population growth, 

and for normal behavior; food, water, or other nutritional or physiological requirements; cover or shelter; sites for 

breeding, reproduction, or rearing of offspring; and habitats that are protected from disturbance or are 

representative of the historic geographical and ecological distribution of a species. 

All areas proposed as critical habitat for bull trout are within the historic geographic range of the species and 

contain one or more of these physical or biological features essential to the conservation of the species. The 

FWS also included a list of known primary constituent elements with the critical habitat description. The 

primary constituent elements may include, but are not limited to, features such as spawning sites, feeding sites, 

and water quality or quantity. 

The FWS determined the primary constituent elements for bull trout from studies of their habitat requirements, 

life-history characteristics, and population biology, as outlined above. These primary constituent elements are: 

6. Permanent water having low levels of contaminants such that normal reproduction, growth and 

survival are not inhibited; 

7. Water temperatures ranging from 2 to 15 °C (36 to 59 °F), with adequate thermal refugia available 

for temperatures at the upper end of this range. Specific temperatures within this range will vary 

depending on bull trout life history stage and form, geography, elevation, diurnal and seasonal 

variation, shade, such as that provided by riparian habitat, and local groundwater influence; 

8. Complex stream channels with features such as woody debris, side channels, pools, and undercut 

banks to provide a variety of depths, velocities, and instream structures; 

9. Substrates of sufficient amount, size, and composition to ensure success of egg and embryo 

overwinter survival, fry emergence, and young-of-the-year and juvenile survival. A minimal amount 

of fine substrate less than 0.63 cm (0.25) in diameter and minimal substrate embeddedness are 

characteristic of these conditions; 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

164

10. A natural hydrograph, including peak, high, low and base flows within historic ranges or, if 

regulated, a hydrograph that demonstrates the ability to support bull trout populations; 

11. Springs, seeps, groundwater sources, and subsurface water connectivity to contribute to water quality 

and quantity; 

12. Migratory corridors with minimal physical, biological, or chemical barriers between spawning, 

rearing, overwintering, and foraging habitats, including intermittent or seasonal barriers induced by 

high water temperatures or low flows; 

13. An abundant food base including terrestrial organisms of riparian origin, aquatic macroinvertebrates, 

and forage fish; and 

14. Few or no predatory, interbreeding, or competitive nonnative species present. 

Treatment Areas near Streams with Listed Fish 

Treatment areas (mapped infestations) within 100 feet of streams with proposed or listed fish are shown in the 

following table (see Appendix A for maps). Treatment areas that are not included are further than 100 feet from 

streams with listed fish. 

Table 59-Treatment Areas within 100 Feet of Streams with Proposed or Listed Fish Species 

Fifth Field 

Watershed Name 

Stream Name Treatment Area 

Identification 

Listed Fish Species* and Life Stages found 

within Stream* 

Big Quilcene River Mainstem of Big Quilcene 

River 

9H-09b road-related HCS – presence/migration 

PSS – presence/migration, spawning and rearing 

Discovery Bay Salmon Creek 9H-05 road-related PSS – presence/migration 

unnamed 9H-11 road-related. PSS – presence/migration 

Mainstem of Dosewallips 

River 

9H-11 road-related. PSS, PSC – presence/migration, spawning, 

rearing 

Dosewallips River 

Gamm Creek 9H-11 road-related. PSS – presence/migration, spawning 

Duckabush River Mainstem of Duckabush 

River 

9H-13 road-related. PSS, PSC – presence/migration, spawning, 

rearing 

Canyon Creek 9H-01 road-related BT – presence/migration 

9H-02 road-related. BT – presence/migration 

9H-06a road-related PSS – presence/migration, spawning 

PSC – presence/migration, spawning, rearing 

BT – presence/migration, rearing 

Mainstem of Dungeness 

River 

9H-30 meadow PSS – presence/migration, spawning 

PSC – presence/migration, spawning, rearing 

BT – presence/migration 

9H-02 road-related PSS – presence/migration, spawning 

PSC – presence/migration, spawning, rearing 

BT – presence/migration 

Dungeness River 

Gray Wolf River 

9H-06a road-related PSS – presence/migration, spawning 

PSC – presence/migration, spawning, rearing 

BT – presence/migration, rearing 

Mainstem of 

Elwha River 

Elwha River 9P-40 road-related PSS, PSC, BT- presence/migration 

Little River 9P-40 road-related PSS, PSC, BT- presence/migration 

Lindner Creek 9P-41_POCU 

FloodPlain. 

Hoh River BT – presence/migration 

Tower Creek 9P-41_POCU 

FloodPlain 

BT – presence/migration 

East Fork 9P-37 road-related. BT – potential feeding/migratory habitat 

Humptulips River 9P-38 road-related. BT – potential feeding/migratory habitat 

Stevens Creek 9P-36 road-related. BT - potential feeding/migratory habitat 

Humptulips River 

West Fork 9P-33 road-related. BT – potential feeding/migratory habitat 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

165

Fifth Field 

Watershed Name 

Stream Name Treatment Area 

Identification 

Listed Fish Species* and Life Stages found 

within Stream* 

 Humptulips River 9P-34 road-related. BT – potential feeding/migratory habitat 

9P-45 trails BT - potential feeding/migratory habitat 

Cook Creek 9P-43 road-related BT – presence/migration 

9P-42 road-related BT – presence/migration 

Lower Quinault 

Boulder Creek 

9P-46 Quinault RNA BT – presence/migration 

Salmon River 9P-28 road-related. BT – presence/migration 

9P-23 road-related BT – presence/migration 

9P-24 road-related BT – presence/migration 

9P-26 road-related BT – presence/migration 

Queets River 

Matheny Creek 

9P-27 road-related BT – presence/migration 

West Fork 

Satsop River 

9H-25a road-related BT – potential feeding/migratory habitat; historic 

distribution 

Satsop River 

Walter Creek 9H-23 road-related BT – potential feeding/migratory habitat; historic 

distribution 

Sequim Bay Unnamed 9H-03 road-related. PSS – presence/migration 

Jimmycomelately Creek 9H-03 road-related. PSS – presence/migration, spawning, rearing 

HCS – presence/migration 

Big Creek 9H-17 road-related. PSS, BT – presence/migration 

9H-17a road-related PSS, BT – presence/migration 

9H-18 road-related. PSS – presence/migration, spawning, rearing 

PSC – presence/migration 

BT – presence/migration, spawning 

Brown Creek 

9H-20 road-related BT – presence/migration 

Cedar Creek 9H-19 road-related PSS, BT – presence/migration 

9H-23 road-related BT – presence/migration 

Church Creek 9H-19 road-related. BT – presence/migration, spawning, rearing 

Le Bar Creek 9H-18 road-related. PSS – presence/migration, spawning, rearing 

PSC, BT – presence/migration 

North Fork 

Skokomish River 

9H-17a road-related PSS – presence/migration 

PSC, BT – presence/migration, rearing 

Skinwood Creek 9H-17 road-related. PSS – presence/migration 

Pine Creek 9H-19 road-related. BT – presence/migration 

Rock Creek 9H-23 road related BT – presence/migration 

9H-18 road-related. PSS – presence/migration, spawning, rearing 

PSC, BT – presence/migration 

9H-22 road-related. PSS – presence/migration, spawning, rearing 

PSC, BT – presence/migration 

South Fork 

Skokomish River 

9H-23 road-related. PSS – presence/migration, spawning, rearing 

PSC, BT – presence/migration 

Skokomish River 

Steel Creek 9H-18 road-related. BT – presence/migration 

Gatton Creek 9P-32 SummerHome BT – presence/migration 

9P-32a trails BT – presence/migration 

9P-32 SummerHome BT – presence/migration 

Upper Quinault River 

Willaby Creek 

9P-32a trails BT – presence/migration 

Wynoochee River Wynochee River 9H-27 road-related BT – presence/migration 

*PSC = Puget Sound Chinook, PSS = Puget Sound Steelhead, HCS = Hood Canal summer-run Chum, BT = 

Coastal Puget Sound Bull Trout 

Essential Fish Habitat (Magnuson-Stevens Act) 

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the Sustainable 

Fisheries Act of 1996 (Public Law 104-267), established procedures designed to identify, conserve, and enhance 

essential fish habitat (EFH) for those species regulated under a Federal fisheries management plan. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

166

Essential Fish Habitat is defined in the Act as “those waters and substrate necessary to fish for spawning, 

breeding, feeding, or growth to maturity.” Essential Fish Habitat includes all freshwater streams accessible to 

anadromous fish (Chinook, coho, and Puget Sound pink salmon), marine waters, and inter-tidal habitats. 

Olympic National Forest may incorporate an EFH assessment into this EIS pursuant to 40 CFR section 1500. 

NEPA and ESA documents prepared by the Olympic National Forest should contain sufficient information to 

satisfy the requirements in 50 CFR 600.920(g) for EFH assessments and must clearly be identified as an EFH 

assessment. 

The geographic extent of EFH on the Olympic National Forest is specifically defined as all currently viable 

waters and most of the habitat historically accessible to Chinook, coho, and pink salmon within the watersheds 

identified in Table 59. Salmon EFH excludes areas upstream of longstanding naturally impassible barriers (i.e., 

natural waterfalls in existence for several hundred years). Salmon EFH includes aquatic areas above all artificial 

barriers. 

Regional Forester Sensitive Aquatic Species 

The following table identifies Regional Forester’s Sensitive species in the project area. Regional Forester’s 

Sensitive Species are managed to maintain species viability. 

Table 60-Regional Forester's Sensitive Species within the Project Area 

Species ESU or DPS 5th Field Watersheds on NF Habitat and Life History 

Chinook 

Salmon 

Washington 

Coast 

Soleduck River, Calawah River, 

Bogachiel River, Hoh River, 

Clearwater River*, Queets River, 

Whale Creek/Raft River*, Upper 

Quinault River, Lower Quinault 

River*, Humptulips River, 

Wishkah River*, Wynoochee 

River, Satsop River* 

Because of the size of Chinook, they prefer spawning habitats 

that includes deeper water and larger gravels than for most 

other salmon species. Two life history types – ocean and 

stream – are recognized in Chinook salmon, based upon the 

length of time the juvenile fish spend rearing in streams and 

rivers. Ocean-type Chinook move relatively quickly into 

saltwater following emergence. Some fry enter marine 

environments almost immediately, but most inhabit the 

shallow side margins and side sloughs for up to two months. 

Stream-type Chinook overwinter in fresh water, typically 

migrating to the ocean the following spring. 

Coho 

Salmon 

Puget 

Sound/Strait of 

Georgia 

Elwha River*, Dungeness River, 

Sequim Bay, Discovery Bay, 

Upper West Hood Canal Frontal, 

Big Quilcene River, Dosewallips 

River, Duckabush River, Hamma 

Hamma River*, Lower West 

Hood Canal Frontal*, Skokomish 

River 

Coho salmon are found in a broader diversity of habitats than 

any other anadromous salmonid, from small tributaries of 

coastal streams to inland tributaries of major rivers (Meehan 

and Bjornn 1991). In the autumn, as water temperatures 

decrease, juvenile coho move into available side channels, 

spring-fed ponds and other off-channel sites to avoid winter 

floods. Streams with more structure (logs/rootwads, boulders, 

undercut banks) support more coho because they provide 

both food and cover. 

Puget 

Sound/Strait of 

Georgia 

Elwha River*, Dungeness*, 

Sequim Bay*, Discovery Bay*, 

Upper West Hood Canal 

Frontal*, Big Quilcene River*, 

Dosewallips* River, Duckabush 

River, Hamma Hamma River*, 

Lower West Hood Canal 

Frontal*, Skokomish River 

Chum 

Salmon 

Pacific Coast Pysht River/Clallam River*, Lyre 

River/Twin River*, Hoh River, 

Clearwater River*, Whale 

Creek/Raft River*, Upper 

Quinault River, Lower Quinault 

River*, Humptulips River, 

Wishkah River*, Wynoochee 

River*, Satsop River*, Queets 

River, 

Freshwater migration in the Pacific Northwest is typically short 

in distance (<50 miles). Chum salmon utilize low gradient (1-

2%), sometimes tidally-influenced reaches of streams for 

spawning, which limits their spawning distribution on Olympic 

National Forest. Most tidally-influenced areas have been 

disturbed in some form, which has introduced invasive 

species, such as knotweed along the streambanks or gravel 

bars. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

167

Species ESU or DPS 5th Field Watersheds on NF Habitat and Life History 

Lake Pleasant 

Sockeye 

Soleduck River* Populations of lake spawning sockeye are found in Quinault 

Lake on Olympic National Forest and in Lake Pleasant below 

National Forest boundary. Most sockeye spawning occurs in 

rivers and streams that are tributaries to lakes, but often 

substantial numbers of sockeye salmon spawn along lake 

shores in areas where ground water percolates through 

gravel. Generally, sockeye utilize areas along lake shores 

where the gravel is small enough to be readily dislodged by 

digging. Sockeye, however, may also utilize lake shore areas 

with other substrate types and sizes, depending largely on the 

presence or absence of upwelling. Lake Pleasant sockeye 

salmon ascend the Quillayute and Sol Duc Rivers and Lake 

Creek to spawn in Lake Pleasant, Washington but have not 

extended up onto lands within Olympic National Forest. The 

Forest boundary is about 2.5 miles upstream from the lake. 

Sockeye 

Salmon 

Quinault Lake Upper Quinault River Quinault sockeye spawn in the Quinault River drainage and 

rear in Quinault Lake, Washington. The southern shoreline of 

Quinault Lake is bordered by summer home tracts which are 

included in the 9P-32 treatment area. Treatment area 9P-32a 

includes a trail system above the summer home tracts and 

crosses three major creeks that flow through treatment area 

9P-32; Willaby Creek, Falls Creek, and Gatton Creek. These 

three creeks contain natural barrier falls in the lower reaches. 

Treatment area 9P-32 includes patches of Japanese 

knotweed, herb Robert, English ivy and English holly, 

estimated to cover approximately 96 acres. The treatment of 

emergent Japanese knotweed or other emergent invasives 

below the high water mark along the shoreline of Lake 

Quinault may impact individual sockeye. 

Coastal 

Cutthroat 

Trout 

Puget Sound Elwha River, Dungeness River, 

Sequim Bay, Discovery Bay, 

Upper West Hood Canal Frontal, 

Big Quilcene River, Dosewallips 

River, Duckabush River, Lower 

West Hood Canal Frontal, 

Hamma Hamma River, 

Skokomish River 

The Puget Sound populations of coastal cutthroat trout enter 

protected marine waters in northwestern Washington, which 

includes waters draining the east side of the Olympic National 

Forest. Coastal cutthroat trout exhibit diverse life histories 

with four distinct life history patterns. The life history patterns 

include anadromous populations, which migrate to the ocean 

or estuary for usually less than one year before returning to 

freshwater; fluvial populations that migrate between small 

spawning tributaries and main rivers downstream; adfluvial 

populations migrate between spawning tributaries and lakes 

or reservoirs; and nonmigratory resident forms (Quigley and 

Arbelbide 1997). In Washington, the anadromous cutthroat is 

typically referred to as “searun” cutthroat and is widely 

distributed in the lower Columbia River and the Coastal and 

Puget Sound drainages. Cutthroat typically spawn in small 

streams with juveniles remaining in freshwater. The 

anadromous juveniles undergo the morphological, 

physiological and behavioral changes required for migration 

and adaptation to salt water, much like the anadromous 

salmonids. In Washington, most coastal cutthroat spawn from 

January up to July, depending on life form. Spawning occurs 

in riffles where the water depth is about 15 to 45 cm, in areas 

of low gradient and low flow (WDFW 2000). Newly-emerged 

fry move quickly to low velocity water at stream margins and 

backwaters and remain there through the summer to feed. 

However, in the presence of coho juveniles, which emerge 

earlier and at a larger size, cutthroat are often driven into 

higher-velocity waters (ibid). Juveniles tend to move to log 

jams and overhanging banks to shelter during winter. They 

tend to remain in small streams for about a year then begin to 

migrate over longer distances within their natal river system 

(ibid). They are also known to hybridize with steelhead. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

168

Species ESU or DPS 5th Field Watersheds on NF Habitat and Life History 

Coastal 

Cutthroat 

Trout 

Olympic 

Peninsula 

Pysht River/Clallam River, Lyre 

River/Twin River, Soleduck 

River, Calawah River, Bogachiel 

River, Hoh River, Clearwater 

River, Queets River, Whale 

Creek/Raft River, Upper Quinault 

River, Lower Quinault River, 

Olympic Peninsula cutthroat are found from the Strait of Juan 

de Fuca west of the Elwha River and coastal streams south 

to, but not including, streams that drain into Grays Harbor. 

See above for further discussion about coastal cutthroat trout. 

Olympic 

Mudminno

w 

N/A Lower Quinault River, Satsop 

River* 

The center of abundance of the Olympic mudminnow is on the 

west coast of the Olympic peninsula, where its habitat extends 

from the Chehalis River system north to the Quinalt River. 

Although these fish are known to live primarily in wetland 

habitats, they are also found in slow-moving streams and 

ponds, and have been collected from a shallow drainage ditch 

off state Highway 9 along the sandy beaches of the Pacific 

Ocean. It has a surprisingly wide tolerance for temperature 

extremes (from 0 C. to about 30 C.) and it can live at oxygen 

levels so low that they would be lethal to most other fishes. It 

appears, however, that this species is very selective as far as 

salinity and water current are concerned. Required habitat 

characteristics are several centimeters of soft mud bottom 

substrate, little to no water flow, and abundant aquatic 

vegetation. Currently there are no treatment sites that include 

known locations of Olympic mudminnows. Invasion by exotic 

plants and animals have resulted in wetland loss and habitat 

degradation for the Olympic mudminnow (Mongillo and 

Hallock 1999). 

Salish 

Sucker 

N/A Skokomish River* The only known salish sucker populations in Washington 

occur in lake and slough habitats. Salish sucker inhabit Lake 

Cushman, which is within the Skokomish river and located in 

the Hood Canal District of the Olympic National Forest. Most 

suckers spend the majority of their time at the bottom of lakes 

or other quiet waters, feeding on invertebrates (Wydoski and 

Whitney 2003). Treatment area 9H-17a is road-related 

treatment located along the northwestern portion of Lake 

Cushman and crosses several small tributaries to the lake. 

*These species are present lower in watershed off National Forest lands. 

**Species historically present within these watersheds on National Forest lands. 

3.5.2 Environmental Consequences 

The following section discusses effects from non-herbicide and herbicide treatment methods occurring near 

streams that provide habitat for fish. A Biological Assessment (BA) was prepared for this project and submitted 

to the FWS and NMFS as a part of ESA Consultation (January 2007). The BA is summarized in this chapter. 

FWS and NMFS responded to the BA with letters of concurrence and formal Biological Opinions (BOs). The 

BOs authorize incidental take for known sites and the EDRR program. All consultation documents are available 

on our website: http://www.fs.fed.us/r6/olympic or in hard copy by request.31 

Several lengthy documents are incorporated by reference including the R6 2005 FEIS and accompanying 

Fisheries Biological Assessment, Biological Opinions, and SERA Risk Assessments (1997a, 1997b, 1999a, 

1999b, 2001a, 2001c, 2003a, 2003b, 2003c, 2003d, 2003e, 2003f). Details about the risk assessment 

methodologies, toxicity indices for fish and other aquatic organisms, and Hazard Quotient values are not repeated 

in the project level FEIS. The SERA Risk Assessment scenarios were used as indicators of situations where 

PDFs and buffers would be necessary to minimize adverse effects on the aquatic ecosystem. 

 

31 Each regulatory agency completed a Letter of Concurrence (FWS April 2007, NMFS May 2007) and a Biological Opinion 

(FWS September 2007, NMFS October 2007). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

169

The impacts of invasive plants on the environment can last decades, while the impacts of treatment tend to be 

short term (one year or less). Passive and active restoration would accelerate native vegetative recovery in 

treated sites. 

Effects from Non-Herbicide Treatments 

Manual and mechanical invasive plant treatments occurring near streams and wetlands pose risk of disturbing the 

aquatic ecosystem.32 All alternatives, including No Action, allow hand pulling and other treatments that may 

result in minor, short term disturbances to fish and other aquatic organisms. 

Manual and mechanical treatments can result in increased erosion, stream sedimentation, and disturbance to 

aquatic organisms if carried out over a large enough area. Sedimentation can cover eggs or spawning gravels, 

reduce prey availability, and harm fish gills. Soil can also become compacted and prevent the establishment of 

native vegetative cover. 

Manual and mechanical treatments can reduce insect biomass, which would result in a decrease in the supply of 

food for fish and other aquatic organism. The presence of people or crews with hand-held tools along 

streambanks could lead to localized, short-term adverse effects to fish habitat because of trampling, soil 

sloughing due to stepping on banks and removal of invasive plant roots. However, the Implementation Planning 

Process and PDFs would identify and mitigate this potential effect through site specific design considerations. 

Sediment/turbidity generated at the localized scale would be greatest under Alternative C because of the reliance 

on manual and mechanical methods and exclusion of herbicides, which has the potential to increase the amount 

of people working an area and soil disturbance. These impacts are known to be short term and relatively 

insignificant (see Appendix J of the R6 2005 FEIS). Effective invasive plant treatment and restoration of treated 

sites would improve the function of riparian areas and lead to improved fish habitat conditions in the years 

following passive and active restoration. 

Invasive plant treatments may decrease riparian vegetative shading in discrete areas, thereby increasing the 

amount of solar radiation striking the water. Acres of target vegetation along a stream would need to be removed 

(without any shade-producing vegetation remaining) for water temperature to increase. This situation is unlikely 

to occur and there are no known invasive plants providing important riparian shade. 

Herbicides in Aquatic Ecosystems 

As discussed in Chapter 3.4, herbicide treatments along streams and roadside ditches may result in herbicide 

reaching water bodies through drift, runoff, and/or leaching. The movement, persistence, and fate of an herbicide 

in the environment determine the likelihood and the nature of the exposure fish and other aquatic organisms may 

receive. The primary determinants of exposure of herbicide to fish are herbicide properties, application rate, 

extent of application, application timing, precipitation amount and timing, and proximity to habitat (NMFS 2007 

BO). Herbicides coming in contact with water would be infrequent and limited in extent (small, scattered 

infestations) and duration (minutes to hours). Even if toxicity indices for fish are temporarily exceeded at a 

treatment site, [lethal] exposure to bull trout [and other fish species] is unlikely to occur due to high base flows 

and the limited duration and extent of effects associated with invasive plant treatments (FWS 2007 BO). 

Herbicides can alter the structure and biological processes of both terrestrial and aquatic ecosystems; these 

effects of herbicides may have more profound influences on communities of fish and other aquatic organisms 

than direct lethal or sublethal toxic effects (Norris et al. 1991). Stream and lake sediments may be contaminated 

with herbicides by deposition of soils carrying adsorbed herbicides from the land or by adsorption of herbicides 

from the water. Reductions in cover, shade, and sources of food from riparian vegetation could result from 

herbicide deposition in a streamside zone (ibid.). 

 

32 These effects of non-herbicide methods are not of particular concern to the public (see Appendix G for Public Comments 

and Responses). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

170

Residues in food from direct spraying are likely to occur during and shortly after application. Drift from 

herbicides considered for use may affect aquatic vegetation at low concentrations, however it shows little 

tendency to bioaccumulate and is likely to be rapidly excreted by organisms as exposure decreases (ibid.). 

The application rate and method, along with the behavior of the herbicide in the environment, influence the 

amount and length of time an herbicide persists in water, sediment, or food sources. Once in contact, the 

herbicide must be taken up by the organism and moved to the site of biochemical action where the chemical must 

be present in an active form at a concentration high enough to cause a biological effect (ibid.). 

Herbicides have been shown to affect aquatic ecosystem components; however, concentrations of herbicides 

coming in contact with water following land-base treatments are unlikely to be great enough to cause such 

changes (ibid). While the herbicides considered for use in this project kill aquatic plants, aquatic habitats and the 

food chain would not be adversely impacted because 

• The amount of herbicide that could be delivered is relatively low in comparison with levels of concern 

• The duration to which any non-target organism (including aquatic plants) would be exposed is very 

short-lived and impacts to aquatic plants would be localized 

Herbicide Ingredients 

Table 61 characterizes the sensitivity of elements of the aquatic ecosystem to herbicide impacts, based on worst 

case exposure scenarios in the SERA risk assessments. The risk assessments indicate that two herbicides 

proposed for use in this project (glyphosate and triclopyr) may cause sublethal effects on adult fish. Several of 

the ten herbicides proposed for use may also impact aquatic invertebrates, macrophytes and plants. Sublethal 

effects can include changes in behaviors or body functions that are not directly lethal to the aquatic species, but 

could have consequences to reproduction, juvenile to adult survival, or other important components to health and 

fitness of the species. The results of SERA risk assessments were quantified in the R6 2005 FEIS and associated 

BA. For brevity, the range of hazard quotient values predicted based on this model are not repeated here. 

Table 61-Summary of Herbicide Aquatic Risk Assessment 

Herbicide Aquatic Risks 

Chlorsulfuron (Telar, Glean, 

Corsair) 

Exposure to fish and aquatic invertebrates far below levels of concern (no effects to 

egg and fry); peak exposures could damage aquatic plants at typical and high 

application rates; algae may be damaged at high rates 

Clopyralid (Transline) Exposures very far below levels of concern for fish and aquatic invertebrates; aquatic 

plants and algae are not susceptible. 

Glyphosate 

(Accord XRT, Rodeo, Roundup, 

Roundup Pro, Aquamaster, etc, 

including 35 formulations) 

Aquatic formulation could exceed level of concern for fish at typical and highest 

application rate; exposures below level of concern for aquatic invertebrates, algae, and 

plants. 

Surfactants (tallow amine or POEA) in non-aquatic use formulations very toxic to 

aquatic organisms, surfactant formulations may cause fish mortality at high application 

rate only, low toxicity to aquatic invertebrates; aquatic plants and algae are susceptible 

to glyphosate but exposures are below levels of concern; 

Imazapic (Plateau) Exposures far below level of concern for fish (no effects to egg & fry); potential risk to 

aquatic plants at highest application rate only; no risk to algae. 

Imazapyr (Arsenal, Arsenal AC, 

Chopper, Stalker, Habitat) 

Exposure to fish and invertebrates very far below levels of concern; potential risk to 

aquatic plants at typical and high application rate, no risk to algae. 

Metsulfuron Methyl (Escort XP) Exposures to fish very far below level of concern (no effects to egg & fry); can damage 

aquatic plants in acute exposures, no risk to algae. 

Picloram (Tordon K, Tordon 22K) Exposures exceeded level of concern for listed fish at typical and highest application 

rate; salmonids appear to be marginally more sensitive to technical grade picloram 

(acid) than other fish species. 

Sethoxydim (Poast, Poast Plus) Highly toxic to fish due to petroleum inert; exposure exceeds level of concern for 

federally listed fish at typical rate and maximum exposure assumptions. 

Sulfometuron methyl (Oust, Oust 

XP) 

Exposures below level of concern to fish (highly toxic to embryo hatch). 
Final Environmental Impact Statement 

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171

Herbicide Aquatic Risks 

Triclopyr (Garlon 3A, Garlon IV, 

Forestry Garlon IV, Pathfinder II, 

Remedy, Remedy RTU, Redeem 

R&P) 

Ester formulation (Garlon IV) and Metabolite TCP is toxic to fish and aquatic 

invertebrates; salt/acid formulation low toxicity to fish; exposures exceed level of 

concern for federally listed fish at typical rate but not other fish even at highest 

application rate; no TCP exposures exceed level of concern; only salt from exceeds 

level of concern for aquatic plants, and algae not at risk. 

The PDFs and buffers were developed based on the relative risk of each herbicide to the aquatic environment. The PDFs minimize or 

eliminate potential for herbicides to enter water at concentrations of concern by limiting the rate, extent, or herbicide application method. For 

instance, PDF H14 limits extent of annual treatment to about 18 percent of any aquatic influence zone, which would result in at least a fivefold reduction in herbicide exposure compared to the worst case modeled scenarios. In addition, limitations on broadcasting would result in 

much spottier coverage compared to the modeled assumptions. Broadcasting is greatly restricted near streams in all alternatives and would 

never exceed the typical application rate. 

No methodology is available to quantify the effect of PDFs and site-specific restricted herbicide use buffers in reducing predicted HQ values 

under SERA risk assessment scenarios. SERA worksheets are available to refine some site-specific parameters; however the effect of the 

PDFs in restricting the timing, extent, location, herbicide selection, and application rate cannot be modeled. 

 Inert Ingredients-Adjuvants, Impurities and Surfactants 

Inert ingredients, including adjuvants, impurities and surfactants, were studied as a part of SERA risk assessment 

for all herbicides (see section 3.1 this Chapter). POEA surfactant may be toxic to aquatic species (SERA, 2003-

Glyphosate, p. 4-14). In the SERA risk assessment, the toxicity of non-aquatic glyphosate is considered together 

with this surfactant, either in the formulation or added as an adjuvant in a tank mixture (SERA, 2003- 

Glyphosate, p. 4-14). NPE based surfactants were classified as a low risk to aquatic organisms because predicted 

concentrations were less than the estimated or measured “no observable effect concentration”. Other surfactants 

did not influence the risk assessment findings. 

SERA Worksheets 

SERA has developed Risk Assessment Worksheets (SERA 2004c) to refine worst-case herbicide delivery 

analysis from riparian treatments, using site-specific information. The worksheets incorporate the behavior of 

the various herbicides in the environment, along with local soil and weather information, to estimate herbicide 

concentration in a stream. Methodology of the SERA Worksheets is discussed in detail in the 2007 BA and in 

SERA 2004c. 

The results can be compared to toxicity indices for fish, invertebrates and aquatic plants to indicate degree of 

hazard associated with herbicide predicted to enter water. The toxicity thresholds were developed in laboratory 

studies, often measuring the results of herbicide exposure to fish over a 96 hour period. 

As discussed previously, hazard quotients less than one would indicate a very low potential for impact to aquatic 

organisms. Site-specific SERA Worksheets were run for two sites proposed for treatment within the aquatic 

influence zone, the Cranberry Bog and Middle Hoh River Floodplain treatment areas. While treatments would 

be preferred during dry times of the year, when herbicide is least likely to contact water, these areas may remain 

wet year round. 

Results are described under the Proposed Action (Alternative B) below. The SERA worksheets indicate the 

potential for herbicides to be delivered in concentrations that exceed the toxicity threshold for fish and other 

aquatic organisms. 

Emergent Vegetation Analysis 

The SERA Worksheets do not explicitly address treatments of emergent vegetation below bankfull of a stream or 

wetland. Slower backwater areas may not dilute herbicides as quickly, and herbicide may remain in lentic water 

bodies (i.e. ponds) longer than predicted. These factors lead to some uncertainty about whether the SERA 

Worksheets adequately estimate the risk associated with emergent vegetation treatments. 

The Forest Service also conducted an “emergent vegetation analysis” developed in collaboration with NMFS to 

estimate peak concentrations from treatments below bankfull of a small stream or wetland. The "emergent 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

172

vegetation" analysis estimated of the potential concentration in water of aquatic labeled herbicides applied to one 

acre given two stream flow rates. Herbicide concentration within one square foot of water was also calculated. 

The emergent vegetation analysis indicates the potential for herbicides to reach a level of concern for fish and 

other aquatic organisms. 

Results of the emergent vegetation analysis are operationally infeasible and unrealistic, because an applicator 

would have to pour or spray herbicide directly into a foot of water to approach the calculated concentration levels 

(direct application to water is not proposed for this project). The emergent vegetation analysis has not been peerreviewed and is a relative indicator of potential effects. It is imprecise and does not account for PDFs and 

buffers. The calculation does not incorporate local soil or weather information, foliar interception, nor does it 

integrate the behavior of the different herbicides in the environment. 

Results of the emergent vegetation analysis are described for the Proposed Action (Alternative B) below. 

Ditches and Intermittent Channels 

NMFS 2007 BO reported that herbicides applied within ditches and intermittent stream channels may be 

delivered to places where fish or their food might be exposed by leaching into soil, dissolving directly into ditch 

or stream channel flow (when present), and erosion of exposed soil. The primary determinants of exposure risk 

from ditch or intermittent channel treatments are herbicide properties, application rate, extent of application, 

application timing, precipitation amount and timing, and proximity to habitat. 

NMFS 2007 BO also reported that glyphosate, sethoxydim, and triclopyr use modeled for this project exceeded 

the fish HQ threshold level of 1, causing likely adverse effects on listed salmonids and their habitat from rain 

within 24 hours after application at ditch and intermittent channel confluences with perennial streams. 

NMFS assumed that this would occur for complete treatment of up to 660 feet of a ditch or dry channel that 

discharges to a perennial stream containing listed fish. NMFS also reported that several herbicides delivered 

through application near dry streams and/or roadside ditches would adversely affect aquatic macrophytes, 

invertebrates and plants (NMFS 2007 BO). 

NMFS findings do not consider that glyphosate would be bound to soil present in the dry stream or ditch and 

therefore would not be plausibly delivered to a stream 660 feet away from the site of application. These findings 

assume “complete treatment” of a long stretch of dry stream or roadside ditch, which does not account for the 

patchy distribution of known infestations, topography of Forest Service roads, nor the presence of ditch relief 

pipes. NMFS findings also do not account for the mitigating effects of PDFs and buffers specific to dry streams 

and roadside ditch networks. Finally, NMFS findings do not consider the short period of time that fish could 

possibly be exposed to herbicides at the concentrations predicted in their analysis. The threshold of concern for 

fish in the SERA Risk Assessments assumed that fish would be exposed to a given herbicide concentration for 96 

hours. Any herbicide delivered from roadside ditches would be diluted in a matter of minutes. 

The FWS 2007 BO reported that treatment area 9H-20 parallels Brown Creek for 1.2 miles and crosses 7 

tributary streams within the aquatic influence zone. This road segment was not identified as having a highpotential for sediment delivery, so some of the minimization measures associated with high delivery roads may 

not be applied in this area. Under the right conditions (extensive spot spray applications, immediately followed 

by a rain event) roadside treatments in this area could result in bull trout exposure to herbicide, and individual 

bull trout may suffer short-term impairments associated with herbicide applications in ditches and intermittent 

streams under these conditions. Actual exposure concentrations and durations at or near confluences with 

perennial streams will depend on a variety of factors, including the extent of the herbicide application within the 

ditch/intermittent stream, application rate, extent of riparian applications, and rainfall timing, intensity, and 

amount. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

173

Direct, Indirect and Cumulative Effects by Alternative 

The alternatives vary as to the degree of risk to aquatic organisms from herbicide and non-herbicide treatments. 

All action alternatives minimize or avoid adverse effects to some degree. The PDFs and buffers related to aquatic 

influence zones and roads having high potential to deliver herbicide vary between alternatives, leading to 

differences in degree of risk. None of the alternatives would likely result in direct mortality to fish or 

measurable, observable impacts. 

Alternative A (No Action) 

The No Action Alternative A would continue the currently approved use of herbicides on 86 acres of the Olympic 

National Forest. Aquatic-labeled glyphosate may be injected in streamside knotweed as part of the existing 

program. Otherwise, treatments with herbicide would be unlikely to occur near fish habitat. Alternative A does 

not allow any use of herbicides other than the 86 identified acres (no early detection or rapid response approach 

included). Little potential exists for herbicides to enter water in concentrations above any threshold of concern 

that could adversely affect aquatic organisms or ecosystems. This alternative does not include an Early 

Detection-Rapid Response Component. 

SERA Worksheets and Emergent Vegetation Calculation 

The SERA Worksheet and Emergent Vegetation Analysis was not conducted for Alternative A because the 

herbicide use currently approved is unlikely to result in herbicide delivery to streams. 

Effects to Aquatic Species Proposed or Listed under ESA 

No adverse effects would be associated with existing treatments under the current NEPA documents. Treatments 

are mainly minor non-herbicide treatments that occur within and outside riparian areas. Treatments are limited in 

extent across the Forest. 

Effects on Designated Critical Habitat and Essential Fish Habitat 

No adverse effects from treatment would occur on Designated Critical or Essential Fish Habitat. However, under 

Alternative A, invasive plants are more likely to continue to degrade these habitats because so little of the 

infestations would be treated. Non-herbicide methods may also have adverse effects on aquatic organisms (see 

discussion below under Alternative C). However the low acreage currently approved for treatment limits the 

potential significance of these effects – ground disturbance would remain minor, short-lived, limited extent and 

have negligible adverse effects. 

Effects to Regional Forester’s Sensitive Fish Species 

Minor upland ground disturbance associated with Alternative A would not affect any sensitive fish species. 

Existing treatments are not extensive enough in riparian areas to affect aquatic organisms or habitat. 

Cumulative Effects 

Alternative A would not contribute to significant cumulative effects at any scale. Sediment delivery would be 

negligible and would not accumulate downstream. There would be no discernable effect to fish or aquatic 

organisms from treatments. 

To the extent that invasive plants occupy riparian habitats, over time, fish habitat may be adversely affected. 

This potential is greatest under Alternative A because it would not effectively treat invasive plants that impact 

fish habitat. 

Alternative B (Proposed Action) 

The Proposed Action was designed to limit the potential for higher or moderate risk herbicide to come in contact 

with water where fish or other aquatic organisms are present, even if an unexpected storm occurred shortly after 

treatment. The amount of herbicide that would be available for runoff, leaching and/or drift is necessarily limited 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

174

by restrictions on broadcast use. Spot and hand/select treatments do not have high potential to deliver herbicide 

because the treatments are directed at target vegetation and herbicide is quickly taken up by the plant. 

The probability that fish would be exposed to non-aquatic formulations of herbicide is very low due to PDFs and 

buffers that require aquatic formulations for spot applications near perennial streams and wetlands. The 

probability of hand-select methods, such as foliar painting a knotweed leaf, resulting in herbicides coming in 

contact with water is low. Localized effects to individual aquatic plants are possible as a result of treatments that 

occur within the bankfull channel. These localized effects would not disrupt aquatic ecosystem function of the 

aquatic food web because of the low potential to reach toxicity levels for each trophic level under spot and 

hand/select applications with glyphosate and imazapyr. Spot applications of aquatic formulations of glyphosate 

and imazapyr are not likely to result in harmful amounts coming in contact with water and harming fish, 

invertebrates, and algae. However, some aquatic plants would be damaged at the immediate spot spray locations 

if enough herbicide comes in contact with the aquatic plant. It is believed that there will not be enough herbicide 

coming in contact with water to result in extensive aquatic plant mortality. For example, the use of glyphosate 

will not be applied directly to water for weed control, but if it does enter the water it is bound tightly to dissolved 

and suspended particles and to bottom sediments, and quickly becomes inactive. 

In general, juvenile and adult fish will avoid the presence of human beings and will more than likely swim away 

from predator like shadows overcasting waterbodies. The possibility of a fish being present in the immediate 

water column where spot spray applications may be taking place up to the water’s edge is low. However, fry 

avoid faster flows and tend to rear along the shoreline or around large substrate/wood where flow is slower. Fry 

tend to avoid overcasting shadows as well but can return to their previous location after being disturbed if a 

human stands still enough near the stream margin. It is unlikely that an applicator will stand still for a period of 

time when treating emergent vegetation. 

Fish may be exposed to aquatic formulations of glyphosate and imazapyr where there is emergent vegetation 

treatment in smaller streams where they are present. Fish in the mainstem of rivers and streams would have 

substantially less risk of exposure because of a river’s large flow and the relatively low proportion of fish that 

occur immediately along a river’s edge. Smaller streams however, do not have as much flow and may not dilute 

herbicides as quickly. Fish in smaller streams tend to be juveniles and fry. Although there will be no herbicide 

applied directly to the water column for purposes of treating submerged vegetation, there may be some fine 

droplets from spot applications coming in contact with water as a result of treating emergent vegetation. See 

water contamination from drift discussion above. 

Under the Proposed Action, spot-spray applications of aquatic glyphosate can occur directly within ditches and 

dry stream channels. Hand/select applications of clopyralid, imazapic, imazapyr (aquatic formulation), 

metsulfuron methyl, and triclopyr (aquatic formulation) is also proposed within ditches and dry intermittent 

channels. Based on the information presented above, it is reasonable to assume that aquatic organisms may be 

briefly exposed to toxic levels of glyphosate or other herbicide compounds if a rainfall event occurs shortly after 

an application. To be exposed, individuals would need to be near the confluence where a ditch or intermittent 

stream channel is located when the “first flush” event occurred (FWS 2007 BO). 

SERA Worksheets 

Local conditions at the Cranberry Bog and Middle Hoh floodplain site were analyzed for the potential amount of 

herbicide coming in contact with water using the SERA Risk Assessment Worksheets, assuming that water at 

both these locations was at bankfull. This analysis addresses the riparian area from bankfull to upland and 

assumes a 10 acre treatment area (approximately 50 foot wide and 1.5 miles long). Local information gathered 

for the worksheets was soil texture and precipitation. Soil texture in both areas is predominantly loam and 

annual precipitation of 50 inches for the Cranberry Bog, and 150 inches for the Middle Hoh floodplain site. 

Modeled concentrations of imazapyr, glyphosate, and triclopyr TEA were derived from tables in the respective 

risk assessments for average and peak water contamination rates based on soil and precipitation, for small 

streams and small pond scenarios. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

175

The SERA Worksheets indicated that all hazard quotient (HQ) values would be below 1; therefore, no levels of 

concern were exceeded. The worst case assumptions for the scenario are not possible on the ground under the 

proposed action because there will be no broadcasting within at least 50 feet of wet or dry streams. No 

broadcasting would occur on roads that have high risk of herbicide delivery through their ditch networks. In 

addition, triclopyr would not be broadcast under any conditions. These PDFs greatly reduce the potential for 

herbicide delivery compared to the modeled predictions (see monitoring results Berg 2004, ODOT 2003-2005). 

The R6 2005 FEIS notes that as HQ increases above 1, the margins of safety decrease, compared to the most 

sensitive toxic effect shown in laboratory studies. 

Strategies for reducing risks include: reducing the application rate of the herbicide; applying buffers; restricting 

applications to more favorable site conditions and/or using an application method with less exposure. Treatments 

with estimated HQ’s greater than 10 would be of particular concern. 

The water contamination rates (mg/L per lb/acre), peak concentrations in water, and range of Hazard Quotients 

for worst case scenario in the Cranberry Botanical bog and Middle Hoh River floodplain site, for aquatic 

glyphosate, aquatic imazapyr, and aquatic triclopyr at the typical application rate are shown below. 

The toxicity indices shown in Table 62 are based on laboratory studies, often measuring the results of 96 hours of 

exposure to fish at a certain herbicide concentration level. This duration of exposure is impossible given the 

mixing and dilution that occurs in the aquatic environment. 

Table 62-Precipitation Rates, Peak Water Contamination Rates, Range of Concentration in Water, and 

Hazard Quotients for Listed Fish 

Herbicide/ 

location 

Annual 

Precipitation 

(inches) 

Peak Water 

Contam. Rate 

(mg/L per lb/acre)

Range of 

Concentration in 

water (dose) (mg/L)

Toxicity Index for 

Listed Fish 

(mg/L) 

Range of 

Hazard 

Quotients 

Glyphosate (2 lbs/acre) 

Cranberry Botanical Bog 

(pond) 

50 0.002 - 0.004 0.004 - 0.008 0.5 

0.1 (Tierney) 

0.008 - 0.02 

Middle Hoh (stream) 150 0.104 - 0.161 0.209 - 0.322 0.5 

0.1 (Tierney) 

0.4 - 0.6 

Imazapyr (0.45 lbs/acre) 

Cranberry Bog (pond) 50 0 – 0.00002 0 – 0.000011 5.0 0 – 0.000002 

Middle Hoh (stream) 150 0.00009 – 0.0001 0.000042 – 0.000047 5.0 0.000008 – 

0.00001 

Triclopyr TEA (1 lbs/acre) 

Cranberry Bog (pond) 50 0.042 – 0.074 0.042 – 0.074 0.26 0.2 – 0.3 

Middle Hoh (stream) 150 0.195 – 0.245 0.195 – 0.245 0.26 0.8 – 0.9 

The low values modeled in the worksheet are not likely be approached given that treatment methods for the 

Cranberry Bog and Middle Hoh floodplain site are limited to spot and hand/selective methods. Hand/selective 

methods have less likelihood of herbicides coming in contact with water than spot spray (which far reduces 

exposure potential compared to broadcast treatment). Under the proposed action, spot treatments using aquatic 

glyphosate and aquatic imazapyr could occur within the Cranberry Botanical Bog and Middle Hoh River 

floodplain sites. 

New information has come to light since the release of the DEIS. Tierney et al. (2006) studied the effects of five 

herbicides, including aquatic glyphosate, on coho salmon olfaction (i.e. smell). Coho salmon olfaction ability 

was reduced within 10 minutes of exposure to 1.0 mg/L of aquatic glyphosate, and more rapidly to higher 

concentrations. There was no effect to olfaction ability when the aquatic glyphosate concentration was reduced 

to 0.1 mg/L. No concentrations were tested between 1.0 and 0.1 mg/L, which means that the true NOEC value 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

176

may have been anywhere between 1.0 and 0.1 mg/L. This NOEC value is based on laboratory studies or pure 

water and thus may not be applicable to stream situations where soil is present in the water. 

Given this new information, hazard quotients from the SERA risk assessment worksheets for glyphosate were 

recalculated using 0.1 mg/L as the NOEC value with the understanding that the true NOEC value is somewhere 

between 1.0 and 0.1 mg/L. Hazard quotient values using the upper range of concentrations in water from Table 

62 range from 1 to 3. This new information confirms that potential non-lethal impacts to fish cannot be entirely 

discounted. However, given the ground conditions and application methods, along with PDFs and buffers, the 

potential for harm to the aquatic ecosystem is low. The Tierney 2006 paper described the reaction of fish to 

glyphosate added directly to water in a tank, with no consideration given to the behavior of glyphosate in the 

environment. Glyphosate binds readily to soil, even in water, so the olfactory effects may not be applicable to 

actual field conditions. 

NMFS 2007 BO reported that within aquatic influence zones, triclopyr used at maximum application rates by 

hand or selective methods (in locations with rainfall rates between 50 to 100 inches per year), and glyphosate 

applied at both typical and maximum rates, are likely to cause effects on listed salmonids. NMFS also reported 

potential HQ exceedences to aquatic macrophytes, invertebrates and/or algae for riparian application of 

chlorsulfuron and metsulfuron methyl. Development of the proposed action included PDFs and buffers using 

results of the SERA risk assessment information to minimize the potential for herbicides to reach streams in 

concentrations high enough to cause these effects. 

Emergent Vegetation Analysis Results 

The following table shows the results of the emergent vegetation analysis developed in collaboration with 

NMFS. The emergent vegetation calculation indicates a low estimated maximum concentration below toxicity 

indices for most elements of the aquatic ecosystem (calculated concentration of imazapyr exceeded level of 

concern for macrophytes). Given the new information from Tierney et al. (2006), glyphosate would have an 

estimated Hazard Quotient of 1.5 for the Cranberry Bog. This HQ indicates risk slightly above a level of concern 

for sublethal effects to fish. 

The Middle Hoh Floodplain Site was modeled using two different flow rates. At lower flows, glyphosate 

exceeded a level of concern and triclopyr approached but did not exceed a level of concern for fish and imazapyr 

exceeded a level of concern for algae and aquatic macrophytes. At higher flow rates (1 cubic meter per second), 

no exceedences for fish were calculated (slight exceedance for imazapyr for algae). However, given the new 

information from Tierney et al. (2006), glyphosate applied at typical rates would have an estimated Hazard 

Quotient of up to 5 for the Cranberry Bog.33 This indicates a risk above a level of concern for sublethal effects 

to fish. 

Table 63-Estimated Herbicide Concentrations for the Cranberry Bog Botanical Area 

Aquatic Acute toxicity indices 

formulations 

Estimated maximum 

concentration 

Fish Invertebrates Algae Macrophytes 

Glyphosate 0.149 Mg/L 0.5 Mg/L (1/20th 

of LC50) 

0.1 Tierney 

78 Mg/L (1/10th of 

LC50) 

3 Mg/L (NOEC) 3 Mg/L (NOEC) 

Imazapyr 0.034 Mg/L 5 Mg/L (1/20th 

of LC50) 

100 Mg/L (NOEC) 0.02 Mg/L 

(1/10th of 

EC50) 

0.013 Mg/L 

(EC25) 

Triclopyr 0.075 Mg/L 0.26 Mg/L 

(1/20th of LC50)

13.3 Mg/L (1/10th 

of LC50) 

4.2 Mg/L 

(NOEC) 

0.42 Mg/L (1/10th 

of EC50) 

 

33 Hand/selective applications may occur at rates greater than typical, specifically, stem injection of knotweed with 

glyphosate may require higher concentrations to be effective. However, the potential for herbicide to be delivered to streams 

is minimized through the high degree of operator control exercised during selective applications. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

177

 Table 64-Estimated Herbicide Concentrations for Middle Hoh Site at Two Flows 

Aquatic Acute toxicity indices 

formulations and 

two different flows 

Estimated maximum 

concentration 

Fish Invertebrates Algae Macrophytes 

Glyphosate 

0.25 m3/sec 0.50 Mg/L 

1.0 m3/sec 0.13 Mg/L 

0.5 Mg/L (1/20th 

of LC50) 

0.1 (Tierney) 

78 Mg/L (1/10th of 

LC50) 

3 Mg/L (NOEC) 3 Mg/L (NOEC) 

Imazapyr 

0.25 m3/sec 0.11 Mg/L 

1.0 m3/sec 0.03 Mg/L 

5 Mg/L (1/20th of 

LC50) 

100 Mg/L (NOEC) 0.02 Mg/L 

(1/10th of 

EC50) 

0.013 Mg/L 

(EC25) 

Triclopyr 

0.25 m3/sec 0.25 Mg/L 

1.0 m3/sec 0.06 Mg/L 

0.26 Mg/L (1/20th 

of LC50) 

13.3 Mg/L (1/10th 

of LC50) 

4.2 Mg/L 

(NOEC) 

0.42 Mg/L (1/10th 

of EC50) 

In the 2007 BO, NMFS displayed potential HQ values associated with emergent vegetation treatment, referred to 

as “Exposure from Applications within Perennial Streams.” NMFS reported that “glyphosate exhibits HQ 

exceedances at both typical and maximum application rates...and triclopyr exhibits HQ exceedences at typical 

and maximum application rates.” NFMS also reported “instream and gravel bar application of imazapyr can have 

direct lethal effects on aquatic macrophytes at both typical and maximum application rates...” 

The estimated peak concentrations reported in Tables 63 and 64 above, and referenced in the NMFS BO, are 

unlikely to represent real life situations under Alternative B. An applicator would have to pour herbicide directly 

into a foot of water to approach the calculated concentration levels (direct application to water is not proposed for 

this project). The calculation does not incorporate local soil or weather information, nor does it integrate the 

behavior of the different herbicides in the environment. The emergent vegetation analysis has not been peerreviewed and represents an extreme, unrealistic worst case scenario compared to expected field conditions. 

Effects to Aquatic Species Proposed or Listed under ESA 

Alternative B has a low potential to adversely affect federally listed aquatic species within the project area. 

Treatments are not likely to adversely affect listed fish or critical habitat because it is unlikely that herbicides 

would come in contact with water at amounts calculated above or of concern at treatment sites listed in Appendix 

A. However, the effects of herbicide treatment of aquatic emergent vegetation under EDRR cannot be entirely 

discounted. Refer to Table 59 for a list of treatment sites that are within 100 feet of specific anadromous fish 

populations. 

As discussed above, treatments of emergent vegetation in small streams may disturb fish. Spot and hand 

herbicide applications may result in exposures, likely to be below a level of concern. The current invasive plant 

inventory may be treated during times of the year when fish would not be present. However, there remains 

uncertainty about whether fish may be present during treatments under EDRR. Thus, Alternative B is associated 

with the finding of “may affect” for the following federally listed aquatic species: Puget Sound steelhead, Puget 

Sound chinook, Hood Canal summer-run chum, and bull trout. Critical habitat for chum and chinook may also 

be affected. 

Invasive plant treatment would have many beneficial effects on critical habitat for federally listed fish species. In 

the long-term, treatment of invasive weeds on the Olympic National Forest would increase riparian vegetation 

growth and natural successional patterns resulting in cover and food. 

The potential for direct disturbance and/or herbicide exposure to federally listed fish species is low under the 

Proposed Action. However, the following listed species may be affected by treatments through negligible 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

178

sediment and disturbance. Should emergent treatments result in worst-case predicted herbicide, individual bull 

trout, chum, chinook and steelhead could be adversely affected. 

Chinook. Ocean-type chinook (mostly fall run) are the predominate run type on Olympic National Forest. 

Ocean-type Chinook are unlikely to be exposed to disturbance and herbicides from emergent vegetation 

treatments because the fry migrate to salt water shortly after emerging in the spring. Stream-type chinook 

overwinter in fresh water, typically migrating to the ocean the following spring. Treatments of emergent 

vegetation may result in short term disturbance or limited herbicide exposure to stream-type chinook. 

Chum. Summer, fall, and winter chum fry emerge from gravels in March and April, and quickly outmigrate to 

the estuary for rearing. Invasive plant treatment during this period is not likely to impact chum because emergent 

vegetation treatments are not extensive enough to impact outmigrating juveniles. 

Steelhead Trout. Treatment of emergent vegetation in small streams could disturb juvenile steelhead. Herbicide 

exposure is not likely to exceed a level of concern for fish; however there is uncertainty about herbicide exposure 

from treatment of emergent vegetation.

Bull Trout. Bull trout fry are more susceptible to impacts from invasive plant treatments during the spring 

because of the potential for disturbance and loss of vegetative cover. 

Potential impacts to juvenile bull trout as a result of non-lethal herbicide exposure are not known. There is 

uncertainty about herbicide exposure from treatment of emergent vegetation. 

The FWS reported that the protective riparian buffers, minimization measures, and restricted application methods 

will prevent herbicides from causing incidental take of bull trout under most treatment scenarios. However, 

some treatment actions may cause incidental take of bull trout. The incidental take is expected to be in the form 

of non-lethal harm, caused by short-term exposures of bull trout to sub-lethal concentrations of herbicides and 

associated compounds. Sub-lethal effects include short-term impairments (hours) of normal functions and 

behaviors such as olfaction, respiration, and feeding. These effects may occur as a result of herbicide 

applications (e.g., emergent vegetation treatments, riparian applications, or applications in roadside ditches and 

intermittent streams which connect directly to bull trout rearing habitat). Herbicides proposed for use by the 

ONF are not expected to reach streams in concentrations that would kill bull trout (FWS 2007 BO). 

Effects on Designated Critical Habitat 

In 1996, NMFS developed a methodology for making ESA determinations for individual or grouped activities at 

the watershed scale, termed the “Habitat Approach”. A Matrix of Pathways and Indicators (MPI) was 

recommended under the Habitat Approach to assist with analyzing effects to listed species. The MPI was used 

by Olympic National Forest in previous years to analyze project effects on listed fish species. When using the 

MPI, project effects to the Pathways (significant pathways by which actions can have potential effects on 

anadromous salmonids and their habitats) and Indicators (numeric ratings or narrative descriptors for each 

Pathway) are used to determine whether proposed actions would damage habitat or retard the progress of habitat 

recovering towards properly functioning condition. 

Table 65 displays a “cross-walk” between the MPI Indicators and PCE’s of the Sept. 2, 2005 designated critical 

habitat used to assess effects on designated critical habitat. Section 3.4 of this Chapter contains additional 

information on potential effects to specific physical parameters. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

179

Table 65-Pathway, Indicator, and PCE Crosswalk 

Analysis of PCE Relative To Alternative B 

Pathway: Water Quality 

Indicator: Temperature 

PCE Crosswalk: 

Spawning, Rearing, 

Migration Habitat 

Removal of invasive plants along small streams may increase solar radiation at a localized level 

(i.e. on a small portion of a stream) where invasive plants are the only source of shade. The 

precise effects to water temperature from treating invasive plants will depend on the size of the 

stream, how close to the stream a treatment site is, how much is treated along the stream, and 

what vegetation is currently available to shade the stream. A significant amount of vegetation 

would need to be removed to change water temperature in the stream, and shade would have to 

be provided only by the invasive plant removed – a situation that is not likely on Olympic National 

Forest. Many of the treatment sites in previously disturbed areas requiring herbicide use had 

riparian harvest or other ground disturbing activities (i.e. flood) that removed most of trees that 

provided stream shade. This implies that the greatest changes to water temperature may have 

already taken place. 

One reason treatment of invasive plants is being proposed is to recover stand structure and, in 

time, provide more stream shade with the establishment of native coniferous and deciduous 

trees. The PDFs prohibits broadcast applications within 100 ft. of wet perennial and intermittent 

waterbodies, and along roads that have a high likelihood of delivering herbicides to streams in 

order to prevent any potential adverse affects to stream channels or water quality conditions. 

This PDF will protect overhanging vegetation and smaller trees that are currently providing shade 

closest to the stream and other waterbodies. 

The treatment of invasive plants with broadcast applications outside of the 100 ft buffer should 

have little affect on stream temperature because the invasive plants treated would be no taller 

than the ones left within the buffered area. 

Spot-spray applications would not be large enough to impact enough vegetation influencing water 

temperature. Any short term impacts occurring from loss of small shade provided by invasive 

plants at the treatment site would not elicit an effect and would far outweigh the long term benefits 

of the restored and increased growth of native riparian vegetation, specifically coniferous and 

deciduous trees. 

Pathway: Water Quality 

Indicator: 

Sediment/Turbidity 

PCE Crosswalk: Spawning 

habitat 

Treatment of invasive plants has a low probability for producing sediment because very little 

ground disturbance will take place when invasive plants are treated with spot-spray or hand 

applications. If sediment is produced, it would be as a result of heavy manual labor related to 

uprooting invasive plants or excessive trampling along streambanks. Manual labor such as hand 

pulling to control invasive plants may result in localized soil disturbance, but increases of 

sediment to streams would likely be undetectable. Not all vegetation in a treated area would be 

pulled or removed, so some ground cover plants would remain. Not all sediment from pulling 

weeds along roads would reach a stream because many relief culverts intercept ditch flow and 

drain it on to the forest floor away from streams. Handpulling is very labor intensive and costly. 

Thus, only a few acreas per year could be treated using this technique across a watershed. 

When compared to the total acres within a watershed, project-related soil disturbance from 

handpulling would be negligible. 

Pathway: Channel 

Condition & Dynamics 

Indicator: Floodplain 

Connectivity 

PCE Crosswalk: Rearing 

habitat 

Some invasive plant treatments can have 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 and recreational activities have led to the 

establishment of invasive plant populations. Removal of such infestations is expected to benefit 

aquatic and terrestrial communities in the long term by increasing floodplain area available for 

nutrient, sediment and large wood storage, and flood flow refugia. There is no risk of negatively 

impacting channel condition and dynamics as a result of treating invasive plants. 

Pathway: Habitat Access 

Indicator: Physical Barriers 

PCE Crosswalk: Migration 

habitat 

Invasive plant treatments will not create physical barriers or otherwise degrade access to aquatic 

habitat. On the contrary, where blackberries have been established along streambanks, lack of 

treatment may result in the increase of their root system which could cross the stream channel 

resulting in an aggaded channel blocking fish access during low flow. 

Pathway: Habitat Elements 

Indicator: 

Substrate/Sediment 

PCE Crosswalk: 

Spawning, Rearing habitat 

Invasive plant treatmetns is not expected to affect substrate composition. All PDFs that minimize 

sediment would be implemented, such as no heavy equipment within riparian areas. These 

practices would reduce, but not eliminate sediment. Some sediment may enter stream channels 

as a result of extensive manual labor and could result in exposed soils. The amount of sediment 

that enters a stream is expected to be small, infrequent, short duration, and at a localized level. 

Short- term effects such as localized increases in fine sediment in gravels or along channel 

margins may be seen at the immediate treatment site. However, substrate quality would not 

decrease over time because treatment of invasive plants would not result in a chronic sediment 

source. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

180

Analysis of PCE Relative To Alternative B 

Pathway: Habitat Elements 

Indicator: Large Woody 

Debris, and Pool Area, 

Quality and Frequency 

PCE Crosswalk: Spawning 

habitat 

Treatment of invasive plants would not impact pool area, quality and frequency. Treatment of 

invasive plants in riparian reserves would not impact current wood debris in streams. The PDF 

that establishes a 100 ft buffer for broadcast applications provides protection to the recruitment of 

conifer seedlings within riparian areas which will sustain channel and habitat features in the 

future. With the treatment of invasive plants, riparian stands in time would develop larger 

recruitment trees and would increase the size of inchannel debris. The use of spot-spray 

applications of aquatic glyphosate and aquatic imazapyr may result in some minor non-target 

vegetation impact because of drift. However, the amount necessary to drift into the entire riparian 

area and kill trees is not possible with spot-spray applications. 

Pathway: Flow/Hydrology 

Indicator: Change in 

Peak/Base Flows 

PCE Crosswalk: 

Spawning, Rearing, 

Migration habitat 

Hydrologic changes from invasive plant treatments would never be large enough to cause effects 

at a subwatershed scale. There is no risk of increasing water yield at the subwatershed scale as 

a result of treating invasive plants. The only negative effect on designated critical habitat would 

result from the short term, localized increases in turbidity and sedimentation due to people 

implementing non-herbicide treatment methods along the waters edge. As previously discussed, 

the levels of fine sediment and turbidity increases at the project scale are expected to be 

insignificant and discountable, a one time event, and short-term. Any fines as a result of nonherbicide treatment methods are expected to be washed out by the end of the high flow period. 

However, the majority of fine sediment deposition is expected to be deposited in low-velocity 

areas including the pool tail crest regions on top of LCR chinook redds in the lower reaches of 

watersheds. 

However, the small increase in fine sediment does not have a negative effect on any PCE of 

critical habitat. All spawning gravel in the action area, including the pool tail crest regions, is 

expected to be usable for the next LCR chinook and LCR coho fall spawning. 

The potential for increased erosion into aquatic areas as a result of removing the protective cover 

and rooting along streambanks or waterbodies is reduced by establishing a 50’ buffer for 

broadcast sprays of aquatic labeled herbicides. The 50’ buffer along waterbodies was 

established to avoid the potential for some erosion that could occur, at least in the short term, 

from the use of aquatic labeled glyphosate and aquatic labeled imazapyr (known to be nonselective) as a result of killing both weeds and native vegetation. Broadcast spray of aquatic 

labeled triclopyr is not allowed. 

Effects on Essential Fish Habitat 

Non-herbicide treatment methods would have localized effects to habitat indicators for Essential Fish Habitat 

(EFH) at the project scale. Herbicide treatment methods may result in insignificant amounts of herbicides 

coming in contact with water as a result of drift and runoff from roadside ditches. Effects from both nonherbicide and herbicide treatment methods would be insignificant and discountable under Alternative B because 

of PDFs and established buffers along perennial and intermittent streams, and roads that have the potential to 

deliver herbicides to waterbodies. As discussed above under direct and indirect effects from herbicide and nonherbicide treatment methods, EFH for Chinook, coho, and pink salmon would not be adversely affected. 

Effects to Regional Forester’s Sensitive Fish Species 

Alternative B is associated with a finding of “may impact individuals but not likely contribute to a trend towards 

federal listing or loss of viability to their population or species” for the following sensitive aquatic species: Coho 

salmon, Lake Quinault sockeye salmon, Olympic mudminnow, Salish sucker, Puget Sound coastal cutthroat 

trout, and Olympic Peninsula coastal cutthroat trout.34 The “may effect” finding is because non-herbicide and 

herbicide treatments within the scope of this project could result in small scale, localized disturbance to fish and 

other aquatic organisms. 

Under Alternative B, aquatic organisms may be exposed to herbicides used to treat riparian (especially emergent 

target vegetation) have the potential to result in herbicide exposure to fish and the aquatic ecosystem. Treatments 

may result in loss of individual non-target plants within the riparian zone; however, treatments would not be 

extensive enough to substantially alter fish habitats. 

 

34 There would be no effect on Lake Pleasant sockeye salmon because treatments on National Forest would be over 2.5 

miles from its habitat. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

181

Adverse effects would be minimal because 1) wetland treatments are limited to 6 acres per year per 6th field 

watershed; 2) wetland treatments are limited to hand or spot treatments with a limited herbicide selection and 3) 

the infested areas are scattered across long roadside distances and are not concentrated in any one area. Sitespecific modeling for emergent vegetation treatments indicate exposures would be below any level of concern for 

fish. Disturbance would not persist and vegetation impacts would not last more than a season or two. There 

would be a long-term benefit from restoration of native plants. 

The potential for disturbance and/or herbicide exposure to sensitive fish species is described below. Please see 

“Effects to Aquatic Species Proposed or Listed under ESA” above for Washington Coast Chinook, Puget 

Sound/Straight of Georgia Chum, and Pacific Coast Chum. 

Coho salmon. Spot and hand/selective herbicide treatments could occur along side channels or ponds while 

juvenile coho are rearing. However, there is low potential for herbicide exposure above a level of concern to 

coho. Non-lethal effects of low-level exposure to juvenile fish is not well understood. 

Sockeye Salmon. The treatment of emergent or shoreline knotweed or other invasive plants may impact 

individual Lake Quinault sockeye. Sockeye spawns in shallow gravelly areas in rivers and lakes, thus may be 

disturbed or displaced by treatments near the lake shore. Herbicide use is proposed along the lakeshore 

according to PDFs and buffers. Spot and hand applications of aquatic labeled herbicides are proposed near the 

lake shoreline However the extent of treatment is small and sockeye food source and habitat would not be 

altered. 

Olympic Mudminnow. There are no treatment sites that include known locations of Olympic mudminnows. 

Under EDRR, slow moving wetlands and wet road ditches that provide mudminnow habitat may be treated. PDF 

H14 limits the extent of emergent invasive plant treatment to six acres per 6th field watershed per year. This 

restriction ensures that treatments would not impact a large area of mudminnow habitat. 

In addition, no broadcasting would occur near wet ditches or wetlands. Herbicide use is limited to aquatic 

labeled and lower aquatic risk herbicides. 

Salish Sucker. Invasive plants currently grow along the shore of Lake Cushman, home of the Salish sucker. 

Overhanging target vegetation may provide cover, so a short term loss of cover may occur if the target vegetation 

is removed or killed. This effect would be limited in extent and native vegetation would likely replace the cover 

within a season or two. Adverse impacts would be short-term an limited in extent given PDF H10. 

Coastal cutthroat trout. Herbicides would not be applied during peak spawning periods because these occur in 

winter and invasive plant treatments do not occur this time of year. Some disturbance and loss of individual nontarget plants could occur in smaller streams. The extent of treatment areas along stream margins containing 

coastal cutthroat trout would be small compared to the available habitat for this species. 

Early Detection Rapid Response 

Treating emergent vegetation in a wetland or within the bankfull portion of a small stream may result in herbicide 

exposure to aquatic organisms. Treating emergent invasive vegetation during spawning and/or when redds are 

present could result in disturbance and/or herbicide exposure to fish. Although activities would be planned and 

scheduled to avoid disturbance of spawning fish or damage to redds, a worker may displace a spawning fish or 

step on a redd. Uncertainty about the location and extent of treatment is addressed through PDFs and buffers. 

However, the uncertainty inherent in EDRR results in an ESA effects determination of Likely to Adversely Affect 

for some SOLI (see Table 68). 

Cumulative Effects 

Cities, Counties, and Washington State all have ongoing weed treatment programs operating in the region that 

can affect conditions in the action area. While programs for the prevention of offsite or off-target herbicide 

spread are not known, the agencies presumed that the programs do not have prevention measures similar to the 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

182

ONF. Weeds are treated along road rights-of-way annually by city, state, and county transportation departments, 

sometimes several times a year. Any herbicide contamination that occurs from the proposed ONF action could 

potentially combine with contaminants from other non-Federal activities, and contribute to formation of chemical 

mixtures or concentrations that could kill or harm listed steelhead or salmon. In addition, fish stressed by 

elevated sediment and temperatures and limited habitat due to lack of accessibility are more likely to be 

susceptible to toxic effects of herbicides. While the mechanisms for cumulative effects are clear, the actual 

effects cannot be quantified (NMFS 2007 BO). 

For all known infestations considered in the analysis. PDFs and buffers reduce the potential for herbicide to reach 

a level of concern at any scale. There would be no potential for herbicide to accumulate with use downstream 

and reach a threshold of concern. This is because the amount of treatment proposed compared to the size of the 

watershed and extent of the aquatic ecosystem is very low and effects to habitat are likely to be negligible. 

Treatment of emergent vegetation under EDRR is associated with some uncertainty that herbicide may enter 

streams and affect fish habitat or an individual fish. The cumulative effects of other pesticide use downstream of 

the Olympic National Forest enhances the exposure risks to both juvenile and adult fish, and brings in the factor 

of pesticide mixtures, further adding to the potential for sublethal effects. While it is reasonably certain that 

individual PSC will express impaired normal behavioral patterns, be injured, or suffer ecological death, these 

outcomes will be limited because exposures will be intermittent, based on the proposed action and PDFs and are 

not likely to produce an observable change in the abundance, distribution, diversity, or productivity of these 

species at either the population or species level (ibid). 

To deal with the issue of invasive species in the region, the ONF expects local county noxious weed boards to 

continue to focus on priority weeds that pose risks to areas, such as riparian corridors and recreational lakes. 

Knotweed is a common priority species within all counties. It is expected that the counties will work with ONF 

and ONP cooperatively to control invasive plants. If agreements are established with counties for noxious weed 

control outside of the boundaries of the ONF, FS standards will be incorporated into those agreements (ibid). 

FWS 2007 BO reported that non-federal actions that could affect bull trout are reasonably certain to occur within 

the action area. These actions include residential development, road management, small-scale agriculture, and 

bank stabilization projects. FWS found that the effects to bull trout associated with these actions would be 

limited and widely dispersed. 

Alternative C 

Alternative C eliminates most use of herbicides in Riparian Reserves (twice the size of the Aquatic Influence 

Zone); eliminates use of herbicides within roadside treatment areas having high potential for herbicide delivery, 

and does not allow any broadcast of any herbicide in any situation. No direct or indirect effects on fish and other 

aquatic organisms from herbicide use would be anticipated; effects would be similar to No Action regards 

herbicide use. 

The PDFs for Alternative C completely eliminate concerns related to herbicide use. Non-herbicide methods 

would be favored, so more disturbance from manual crews or mechanical equipment would be likely. However, 

even under the most ambitious conceivable program, effects on aquatic organisms from non-herbicide treatments 

would be similar to the Proposed Action. The increased manual/mechanical acreage, treated according to PDFs, 

would not trigger any threshold of concern. This is true for known sites as well as new sites detected in the 

future. 

SERA Worksheets and Emergent Vegetation Calculation 

The SERA Worksheet and Emergent Vegetation Analysis was not conducted for Alternative C because the 

herbicide use currently approved does not result in herbicide delivery to streams. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

183

Effects to Aquatic Species Proposed or Listed under ESA and Critical Habitat 

Alternative C may have beneficial effects on critical habitat for federally listed fish species. It would be difficult 

in the long-term to effectively eradicate or control invasive weeds on Olympic National Forest that are currently 

posing threats to the growth of native vegetation along intermittent streams and/or roadside treatment areas that 

have high potential to deliver herbicide. Because intermittent streams are associated with debris flows, where 

most large wood and spawning gravel is delivered, invasion of weeds can interrupt natural patterns of debris 

flows if invasions are extensive enough. 

Alternative C is not likely to adversely affect proposed or listed fish, nor their habitat. Minor ground disturbance 

may result in small amounts of sediment to enter streams but this is unlikely to be extensive enough to affect 

critical habitat. 

Effects on Designated Critical Habitat 

Table 66 below displays the analysis of Primary Constituent Elements of Critical Habitat for Alternative C. 

Table 66-Alternative C, PCEs of Critical Habitat 

Pathway, Indicator, and 

PCE Crosswalk 

Analysis of PCE Relative To Alternative C 

Pathway: Water Quality 

Indicator: Temperature 

PCE Crosswalk: 

Spawning, Rearing, 

Migration Habitat 

Removal of invasive plants along small streams may increase solar radiation at a localized level 

(i.e. on a small portion of a stream) where invasive plants are the only source of shade. The 

precise effects to water temperature from treating invasive plants will depend on the size of the 

stream, how close to the stream a treatment site is, how much is treated along the stream, and 

what vegetation is currently available to shade the stream. A significant amount of vegetation 

would need to be removed to change water temperature in the stream, and shade would have to 

be provided only by the invasive plant removed – a situation that is not likely on Olympic National 

Forest. Many of the treatment sites in previously disturbed areas requiring herbicide use had 

riparian harvest or other ground disturbing activities (i.e. flood) that removed most of trees that 

provided stream shade. This implies that the greatest changes to water temperature may have 

already taken place. 

One reason treatment of invasive plants is being proposed is to recover stand structure and, in 

time, provide more stream shade with the establishment of native coniferous and deciduous trees. 

Pathway: Water Quality 

Indicator: 

Sediment/Turbidity 

PCE Crosswalk: 

Spawning habitat 

Alternative C has a low probability for producing sediment as a result of heavy manual labor 

related to uprooting invasive plants or excessive trampling along streambanks. Manual labor such 

as hand pulling to control invasive plants may result in localized soil disturbance, but increases of 

sediment to streams would likely be undetectable. Not all vegetation in a treated area would be 

pulled or removed, so some ground cover plants would remain. Not all sediment from pulling 

weeds along roads would reach a stream because many relief culverts intercept ditch flow and 

drain it on to the forest floor away from streams. Handpulling is very labor intensive and costly. 

Thus, only a few acreas per year could be treated using this technique across a watershed. When 

compared to the total acres within a watershed, project-related soil disturbance from handpulling 

would be negligible. 

Pathway: Channel 

Condition & Dynamics 

Indicator: Floodplain 

Connectivity 

PCE Crosswalk: Rearing 

habitat 

Some invasive plant treatments can have 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 and recreational activities have led to the 

establishment of invasive plant populations. Removal of such infestations is expected to benefit 

aquatic and terrestrial communities in the long term by increasing floodplain area available for 

nutrient, sediment and large wood storage, and flood flow refugia. There is no risk of negatively 

impacting channel condition and dynamics as a result of treating invasive plants. 

Pathway: Habitat Access 

Indicator: Physical 

Barriers 

PCE Crosswalk: 

Migration habitat 

Invasive plant treatments will not create physical barriers or otherwise degrade access to aquatic 

habitat. On the contrary, where blackberries have been established along streambanks, lack of 

treatment may result in the increase of their root system which could cross the stream channel 

resulting in an aggaded channel blocking fish access during low flow. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

184

Pathway, Indicator, and 

PCE Crosswalk 

Analysis of PCE Relative To Alternative C 

Pathway: Habitat 

Elements 

Indicator: 

Substrate/Sediment 

PCE Crosswalk: 

Spawning, Rearing 

habitat 

Invasive plant treatmetns is not expected to affect substrate composition. All PDFs that minimize 

sediment would be implemented, such as no heavy equipment within riparian areas. These 

practices would reduce, but not eliminate sediment. Some sediment may enter stream channels 

as a result of extensive manual labor and could result in exposed soils. The amount of sediment 

that enters a stream is expected to be small, infrequent, short duration, and at a localized level. 

Short- term effects such as localized increases in fine sediment in gravels or along channel 

margins may be seen at the immediate treatment site. However, substrate quality would not 

decrease over time because treatment of invasive plants would not result in a chronic sediment 

source. 

Pathway: Habitat 

Elements 

Indicator: Large Woody 

Debris, and Pool Area, 

Quality and Frequency 

PCE Crosswalk: 

Spawning habitat 

Treatment of invasive plants would not impact pool area, quality and frequency. Treatment of 

invasive plants in riparian reserves would not impact current wood debris in streams. With the 

treatment of invasive plants, riparian stands in time would develop larger recruitment trees and 

would increase the size of inchannel debris. 

Effects on Essential Fish Habitat (EFH) 

Non-herbicide treatments under Alternative C would have localized effects to habitat indicators for EFH at the 

project scale. Because herbicide treatment methods are not allowed in riparian areas, there will be more reliance 

on non-herbicide treatment methods. The use of non-herbicide treatment methods may result in increased 

sediment at the project scale, however, it is unlikely that it would lead to an adverse affect because perennial 

streams remain buffered and the likelihood of significant amounts of sediment being delivered to fish-bearing 

streams is extremely low. As discussed above under direct and indirect effects from herbicide and non-herbicide 

treatment methods, EFH for Chinook, coho, and pink salmon would not be adversely affected under Alternative 

C. 

Effects to Regional Forester’s Sensitive Fish Species 

Alternative C avoids all herbicide use near sensitive fish species and their habitat. Thus, there would be no 

potential impact from herbicide. However, manual and mechanical treatments may result in disturbance to 

individual fish. Such disturbance would be limited in extent and of short duration. 

Sediment delivery from non-herbicide treatments is not likely to be significant. Passive and active restoration of 

native vegetation would be a long term benefit to sensitive fish. 

Early Detection and Rapid Response 

The effects to the aquatic environment from treating unknown future populations would be similar to the effects 

of treating the known inventory. PDFs would be applied and non-herbicide methods would continue within 

Riparian Reserves and along higher risk road segments. Non-herbicide treatments of aquatic emergent 

vegetation could result in short-lived, localized disturbance to redds. Such disturbances may be more frequent in 

Alternative C than the Proposed Action due to the lack of treatment effectiveness and presumable increased need 

for repeated treatments. However, none of the treatments in Alternative C are likely to adversely impact listed 

species (see Table 68). 

Cumulative Effects 

The lack of potential significant adverse direct and indirect effects from treatments under Alternative C reduces 

the potential for cumulative effects, even when this project is considered with other past, present and future 

projects. No herbicide would be delivered to area streams, so none could accumulate with others’ use. Sediment 

from minor ground disturbance would be so small as to be negligible and would not contribute to accumulation 

of downstream sediment. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

185

Alternative D 

Alternative D has a higher probability of adverse effects than the other alternatives due to greater likelihood that 

broadcast treatments or higher risk herbicides would be used along dry intermittent streams and roadside 

treatment areas with high potential to deliver herbicide. Label directions would still need to be followed relative 

to herbicide application near any surface waters. Alternative D adopts similar PDFs as the Proposed Action to 

avoid harm to soil, water and aquatic organisms. 

However, herbicides coming in contact with water could kill aquatic vegetation, especially from broadcast 

treatments across intermittent streams and along roadside ditches. The worst case scenario would involve 

broadcast spraying of a higher risk herbicide along a road that has a high potential of delivering herbicides to 

streams with fish and other aquatic organisms. A storm soon after herbicide application could wash herbicide 

into streams and result in concentrations exceeding levels of concern for fish and other aquatic organisms. 

Localized, short-term adverse effects to aquatic plants from use of herbicide in this situation would be possible 

under this alternative. This would be localized and not likely to result in significant adverse effects to the aquatic 

ecosystem. However, as discussed under Alternative B, effects to fish cannot be entirely discounted. Risks are 

similar to Alternative B, although greater due to the lack of restrictions on roads with high potential to deliver 

herbicide to streams and dry streams. 

SERA Worksheets and Emergent Vegetation Calculation 

The SERA Worksheet and Emergent Vegetation Calculation discussed under Alternative B above also applies to 

Alternative D. These models are not sensitive to the differences between the two alternatives. 

To the extent that Alternative D allows more broadcast treatment, it more closely reflects the SERA Worksheet 

assumptions and findings for the Proposed Action in the BA and BOs. However, Alternative D includes PDFs 

and buffers for wetlands and wet streams, thus herbicide concentrations in water approaching the modeled results 

would be unlikely. 

Effects on Species Proposed or Listed under the Endangered Species Act 

Alternative D may have similar beneficial effects on critical habitat for federally listed fish species as Alternative 

B but would have greater likelihood of herbicide reaching level of concern for aquatic organisms. In particular, 

summer run chum and Puget Sound chinook are more likely to be adversely affected by Alternative D because of 

the potential effects on aquatic plants from broadcast treatment along roadside ditches and dry streams. 

Effects on Designated Critical Habitat 

Table 67 below displays the analysis of Primary Constituent Elements of Critical Habitat for Alternative D. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

186

Table 67-Alternative D, PCEs of Critical Habitat 

Pathway, Indicator, and 

PCE Crosswalk 

Analysis of PCE Relative To Alternative D 

Pathway: Water Quality 

Indicator: Temperature 

PCE Crosswalk: 

Spawning, Rearing, 

Migration Habitat 

Removal of invasive plants along small streams may increase solar radiation at a localized level 

(i.e. on a small portion of a stream) where invasive plants are the only source of shade. The 

precise effects to water temperature from treating invasive plants will depend on the size of the 

stream, how close to the stream a treatment site is, how much is treated along the stream, and 

what vegetation is currently available to shade the stream. A significant amount of vegetation 

would need to be removed to change water temperature in the stream, and shade would have to 

be provided only by the invasive plant removed – a situation that is not likely on Olympic 

National Forest. Many of the treatment sites in previously disturbed areas requiring herbicide 

use had riparian harvest or other ground disturbing activities (i.e. flood) that removed most of 

trees that provided stream shade. This implies that the greatest changes to water temperature 

may have already taken place. 

Under Alternative D, there would be no PDF prohibiting broadcast applications near dry streams 

or along roads that have a high likelihood of delivering herbicides to streams. However, any 

short term impacts occurring from loss of small shade provided by invasive plants at the 

treatment site would not elicit an effect and would far outweigh the long term benefits of the 

restored and increased growth of native riparian vegetation, specifically coniferous and 

deciduous trees. 

Pathway: Water Quality 

Indicator: 

Sediment/Turbidity 

PCE Crosswalk: 

Spawning habitat 

Treatment of invasive plants has a low probability for producing sediment because very little 

ground disturbance will take place when invasive plants are treated with spot-spray or hand 

applications. If sediment is produced, it would be as a result of heavy manual labor related to 

uprooting invasive plants or excessive trampling along streambanks. Manual labor such as hand 

pulling to control invasive plants may result in localized soil disturbance, but increases of 

sediment to streams would likely be undetectable. Not all vegetation in a treated area would be 

pulled or removed, so some ground cover plants would remain. Not all sediment from pulling 

weeds along roads would reach a stream because many relief culverts intercept ditch flow and 

drain it on to the forest floor away from streams. Handpulling is very labor intensive and costly. 

Thus, only a few acreas per year could be treated using this technique across a watershed. 

When compared to the total acres within a watershed, project-related soil disturbance from 

handpulling would be negligible. 

Pathway: Channel 

Condition & Dynamics 

Indicator: Floodplain 

Connectivity 

PCE Crosswalk: Rearing 

habitat 

Some invasive plant treatments can have 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 and recreational activities have led to the 

establishment of invasive plant populations. Removal of such infestations is expected to benefit 

aquatic and terrestrial communities in the long term by increasing floodplain area available for 

nutrient, sediment and large wood storage, and flood flow refugia. There is no risk of negatively 

impacting channel condition and dynamics as a result of treating invasive plants. 

Pathway: Habitat Access 

Indicator: Physical 

Barriers 

PCE Crosswalk: 

Migration habitat 

Invasive plant treatments will not create physical barriers or otherwise degrade access to 

aquatic habitat. On the contrary, where blackberries have been established along streambanks, 

lack of treatment may result in the increase of their root system which could cross the stream 

channel resulting in an aggaded channel blocking fish access during low flow. 

Pathway: Habitat 

Elements 

Indicator: 

Substrate/Sediment 

PCE Crosswalk: 

Spawning, Rearing 

habitat 

Invasive plant treatmetns is not expected to affect substrate composition. All PDFs that minimize 

sediment would be implemented, such as no heavy equipment within riparian areas. These 

practices would reduce, but not eliminate sediment. Some sediment may enter stream channels 

as a result of extensive manual labor and could result in exposed soils. The amount of sediment 

that enters a stream is expected to be small, infrequent, short duration, and at a localized level. 

Short- term effects such as localized increases in fine sediment in gravels or along channel 

margins may be seen at the immediate treatment site. However, substrate quality would not 

decrease over time because treatment of invasive plants would not result in a chronic sediment 

source. 

Pathway: Habitat 

Elements 

Indicator: Large Woody 

Debris, and Pool Area, 

Quality and Frequency 

PCE Crosswalk: 

Spawning habitat 

Treatment of invasive plants would not impact pool area, quality and frequency. Treatment of 

invasive plants in riparian reserves would not impact current wood debris in streams. With the 

treatment of invasive plants, riparian stands in time would develop larger recruitment trees and 

would increase the size of inchannel debris. 

Some minor non-target vegetation impact may occur because of drift. However, the amount 

necessary to drift into the entire riparian area and kill trees is unlikely. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

187

Pathway, Indicator, and 

PCE Crosswalk 

Analysis of PCE Relative To Alternative D 

Pathway: 

Flow/Hydrology 

Indicator: Change in 

Peak/Base Flows 

PCE Crosswalk: 

Spawning, Rearing, 

Migration habitat 

Hydrologic changes from invasive plant treatments would never be large enough to cause 

effects at a subwatershed scale. There is no risk of increasing water yield at the subwatershed 

scale as a result of treating invasive plants. The only negative effect on designated critical 

habitat would result from the short term, localized increases in turbidity and sedimentation due 

to people implementing non-herbicide treatment methods along the waters edge. As previously 

discussed, the levels of fine sediment and turbidity increases at the project scale are expected 

to be insignificant and discountable, a one time event, and short-term. Any fines as a result of 

non-herbicide treatment methods are expected to be washed out by the end of the high flow 

period. However, the majority of fine sediment deposition is expected to be deposited in lowvelocity areas including the pool tail crest regions on top of LCR chinook redds in the lower 

reaches of watersheds. 

However, the small increase in fine sediment does not have a negative effect on any PCE of 

critical habitat. All spawning gravel in the action area, including the pool tail crest regions, is 

expected to be usable for the next LCR chinook and LCR coho fall spawning. 

The potential for increased erosion into aquatic areas as a result of removing the protective 

cover and rooting along streambanks or waterbodies is reduced by establishing a 50’ buffer for 

broadcast sprays of aquatic labeled herbicides. The 50’ buffer along waterbodies was 

established to avoid the potential for some erosion that could occur, at least in the short term, 

from the use of aquatic labeled glyphosate and aquatic labeled imazapyr (known to be nonselective) as a result of killing both weeds and native vegetation. Broadcast spray of aquatic 

labeled triclopyr is not allowed. 

See table 67 for ESA determinations for critical habitat 

Effects on Essential Fish Habitat (EFH) 

Non-herbicide treatments would have localized effects to habitat indicators for EFH at the project scale. 

Herbicide treatment methods may result in a certain amount of herbicides coming in contact with water as a 

result of drift and runoff from roadside ditches and intermittent streams. Although amounts may not be toxic to 

adult fish, water contamination does have an influence on quality of habitat, impacting EFH to some extent 

because some vegetation may die. Effects from both non-herbicide and herbicide treatment methods would be 

insignificant, however under EFH definitions and criteria there could be an adverse affect to water necessary for 

chinook and coho yolk-sac fry. Thus, EFH for Chinook, coho, and pink salmon would be adversely affected 

under Alternative D. 

Herbicide use as designed under Alternative D might not comply with water quality standards, given that 

glyphosate, picloram and triclopyr may harm aquatic organisms at concentrations modeled assuming average 

parameters for broadcast near streams (based on analysis in the R6 2005 FEIS). Such use may occur near dry 

streams in Alternative D. 

The patchy distribution of invasive plants would serve to limit the risk, but under worst-case scenarios herbicides 

may adversely affect fish and other aquatic organisms. Effects from use of herbicide on wetland emergent target 

vegetation would be similar to the Proposed Action. However, Alternative D is associated with a much greater 

level of risk assuming an unexpected storm followed broadcast treatment of high or moderate risk herbicides in 

or near dry intermittent streams, and within roadside treatment areas having high risk of herbicide delivery. 

Herbicide treatments in this situation under Alternative D are likely to adversely affect fish species of local 

interest. 

For Alternative D to comply with standards, additional Project Design Features would have to be adopted for dry 

intermittent streams and roadside treatment areas having a high potential for herbicide delivery, including 

restrictions on use or application methods approved for herbicides of moderate or greater concerns to aquatic 

organisms. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

188

Effects to Aquatic Species on Regional Forester’s Sensitive Species List 

Alternative D would have similar effects on sensitive species as Alternative B. Mudminnow that use roadside 

ditch habitats are more likely to be exposed to broadcast in this alternative under EDRR, but no known 

mudminnow areas would be affected. Small amounts of herbicides coming in contact with water would not 

necessarily adversely affect adult fish, but could have a negative effect on juveniles or their habitat. 

Early Detection and Rapid Response 

Treating emergent vegetation in a wetland or within the bankfull portion of a small stream may result in herbicide 

exposure to aquatic organisms. Treating emergent invasive vegetation during spawning and/or when redds are 

present could result in disturbance and/or herbicide exposure to fish. Although activities would be planned and 

scheduled to avoid disturbance of spawning fish or damage to redds, a worker may displace a spawning fish or 

step on a redd. Uncertainty about the location and extent of treatment is addressed through PDFs and buffers. 

However, the uncertainty inherent in EDRR results in an ESA effects determination of Likely to Adversely Affect 

for some SOLI (see Table 68). 

Cumulative Effects 

Alternative D is associated with a much greater level of risk assuming an unexpected storm followed broadcast 

treatment of high or moderate risk herbicides in or near dry intermittent streams and within roadside treatment 

areas having high risk of herbicide delivery. However, there would be low potential for herbicide to accumulate 

with use downstream and reach a threshold of concern because the amount of treatment proposed compared to 

the size of the watershed and extent of the aquatic ecosystem is low. 

Treatment of riparian and emergent vegetation under EDRR is associated with some uncertainty that herbicide 

may enter streams and affect fish habitat or an individual fish. However, the potential for cumulative effects 

would still be low because the extent of riparian vegetation treatment, even under EDRR, is limited to 6 acres 

below bankfull and/or 10 acres above bankfull per 1.5 mile of stream in a 6th field watershed per year. This 

reduces the potential for significant amounts of herbicide to accumulate downstream. However, other pesticide 

use downstream of the Olympic National Forest enhances the exposure risks to both juvenile and adult PSS, and 

brings in the factor of pesticide mixtures, further adding to the potential for sublethal effects (NMFS 2007 BO). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

189

Alternative Comparison 

Table 68-Effects to Aquatic Organisms Alternative Comparison 

No Action (A) Proposed Action (B) Alternative C Alternative D 

Potential for fish to be 

exposed to harmful 

concentrations of 

herbicide 

Very Low Low Very Low Moderate to High 

Species Findings and Determinations for Listed Species and Critical Habitat 

Puget Sound Steelhead No Effect 

Minor ground mainly 

disturbance limited 

to upland acres, very 

small amount of 

stem injection 

LAA 

Uncertainty related to 

herbicide use under 

EDRR for emergent 

vegetation. Sediment 

and disturbance same as 

other action alternatives

NLAA 

Negligible sediment and 

disturbance 

LAA 

Greater likelihood of 

herbicide reaching level of 

concern for aquatic 

organisms. 

Puget Sound Chinook No Effect 

Minor ground 

disturbance limited 

to upland acres 

LAA 

Uncertainty related to 

herbicide use under 

EDRR for emergent 

vegetation. Sediment 

and disturbance same as 

other alternatives 

NLAA 

Negligible sediment and 

disturbance 

LAA 

Greater likelihood of 

herbicide reaching level of 

concern for aquatic 

organisms. 

Critical Habitat for Puget 

Sound Chinook 

No Effect 

Minor ground 

disturbance limited 

to upland acres 

NLAA 

Negligible sediment and 

disturbance; low potential 

for individual aquatic 

plants to die as a result 

of herbicide . 

NLAA 

Negligible sediment and 

disturbance 

LAA 

Greater likelihood of 

herbicide reaching level of 

concern for aquatic 

organisms. 

Hood Canal Summerrun Chum No Effect 

Minor ground 

disturbance limited 

to upland acres 

LAA 

Uncertainty related to 

herbicide use under 

EDRR for emergent 

vegetation. Sediment 

and disturbance same as 

other alternatives 

NLAA 

Negligible sediment and 

disturbance 

LAA 

Greater likelihood of 

herbicide reaching level of 

concern for aquatic 

organisms. 

Critical Habitat for Hood 

Canal Summer-run 

Chum 

No Effect 

Minor ground 

disturbance limited 

to upland acres 

NLAA 

Negligible sediment and 

disturbance; low potential 

for individual aquatic 

plants to die as a result 

of herbicide . 

NLAA 

Negligible sediment and 

disturbance 

LAA 

Greater likelihood of 

herbicide reaching level of 

concern for aquatic 

organisms. 

Coastal Puget Sound 

Bull Trout 

No Effect 

Minor ground 

disturbance limited 

to upland acres 

LAA 

Uncertainty related to 

herbicide use under 

EDRR for emergent 

vegetation. Sediment 

and disturbance same as 

other alternatives 

NLAA 

Negligible sediment and 

disturbance 

LAA 

Likelihood of herbicide 

reaching some level of 

concern for aquatic 

organisms. 

Critical Habitat for 

Coastal Puget Sound 

Bull Trout 

No Effect 

No delivery of 

herbicide or 

sediment expected 

downstream off 

National Forest 

lands 

No Effect 

Herbicide or sediment 

that entered stream 

would be below any 

threshold of concern by 

the time it reached 

critical habitat. 

Same as Proposed 

Action 

Same as Proposed Action 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

190

3.6 Effects of Herbicide Use on Workers and The Public 

3.6.1 Introduction 

The effect of herbicides on human health is a primary public issue (Issue Group 1). This section focuses on 

plausible effects to workers and the public from herbicide exposure. The R6 2005 FEIS evaluated human health 

risks from herbicide and non-herbicide invasive plant treatment methods. Hazards normally encountered while 

working in the woods (strains, sprains, falls, etc) are possible during herbicide and non-herbicide invasive plant 

treatment operations. Such hazards are mitigated through worker compliance with occupational health and safety 

standards and are not a key issue for this project-level analysis. 

Many people express concern about the effects of herbicides on human heath. Workers and the public may be 

exposed to herbicides used to treat invasive plants under all alternatives in this project; however no exposures 

exceeding a threshold of concern are predicted. 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 R6 2005 FEIS considered potential hazards to human health from herbicide active ingredients, metabolites, 

inert ingredients, and adjuvants. As a result, the R6 2005 ROD standards were adopted to minimize herbicide 

exposures of concern to workers and the public. Site-specific Project Design Features (PDFs) were developed to 

further minimize or eliminate exposures of concern to workers and the public plausible given the regional 

standards. The PDFs ensure that herbicides and surfactants are used in rates low enough, or methods selective 

enough, to avoid exposures of concern. 

The R6 2005 FEIS relied on professional risk assessments completed Syracuse Environmental Research 

Associates, Inc (SERA) using peer-reviewed articles from the open scientific literature and current EPA 

documents, including Confidential Business Information. 

The SERA Risk Assessment full citations are listed in Chapter 3.1.5. Appendix Q of the R6 2005 FEIS provides 

detailed information about the human health hazards associated with the herbicides considered for invasive plant 

treatments. 

3.6.2 Affected Environment 

Many people live near, spend time, work in, drink water from, or depend on forest products from the Olympic 

National Forest. Several municipal watersheds lie on the Forest (see Soil and Water section in this Chapter). 

Public concern for drinking water quality in these watersheds is high. 

These people may be inadvertently exposed to chemicals from invasive plant management projects on the 

National Forest. Municipal watersheds, dispersed and developed recreation areas (trailheads, campgrounds, 

picnic areas, recreation sites, boat ramps, ski areas, work centers, etc) and special forest product collection areas 

currently occur in the vicinity of invasive plant sites. 

All kinds of people gather special forest products such as blackberries, huckleberries, salal, bear grass, 

mushrooms and herbs, for personal use and commercial sale. Some of these products are target species 

(blackberries, St. John’s wort) but most are not. Special forest product harvesters may have more contact with 

contaminated vegetation than the general public. A recent unpublished study of commercial permit holders on 

the Gifford Pinchot National Forest demonstrated that the largest ethnic groups involved with forest product 

gathering were Hispanics and Southeast Asians (Khmer, Khmer Krom, Laotian and Vietnamese). National 

Forest System lands are adjacent to other land ownerships; the majority of watersheds on the Forest also contain 

Olympic National Park, American Indian Lands, commercial forestlands, and other private parcels. 

Infested sites are scattered and occupy less than one percent of Olympic National Forest System lands. Invasive 

plant treatments on the Olympic National Forest are implemented in partnership with the local counties. Crews 

most often come from the communities in and around the National Forest boundary. Herbicide applicators are 

well-trained in safe herbicide handling and transportation practices (Lucero presentation May 2005). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

191

3.6.3 Environmental Consequences 

Worker Herbicide Exposure Analysis 

Herbicide applicators are more likely than the general public to be exposed to herbicides. 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. Appendix Q: Human Health Risk Assessment 

in the R6 2005 FEIS displayed risks for typical and maximum label rates under a range of conditions. Four 

potential exposure levels were evaluated for workers, ranging from predicted average exposure (typical 

application rate-typical exposure variables) to a worst-case predicted exposure (maximum application ratemaximum exposure variables). 

In routine broadcast and spot applications, workers may contact and internalize herbicides mainly through 

exposed skin, but also through the mouth, nose or lungs. Contact with herbicide formulations may irritate eyes 

or skin. 

The ten herbicides proposed for use under the action alternatives, used at rates and methods consistent with 

PDFs, have little potential to harm a human being. Appendix Q of the R6 2005 FEIS lists the HQ values for all 

herbicides considered for this project. In most cases, even when maximum rates and exposures are considered, 

HQ values were below the threshold of concern (HQ values ranged from 0.01 to 1). 

Risk assessments indicate concern for worker exposure to triclopyr, especially the Garlon 4 formulation. This is 

one reason why broadcast application of triclopyr is not allowed under R6 2005 ROD Standard 16. However, a 

potential worst-case scenario exists exceeding a level of concern for workers given a backpack (spot) application 

of the Garlon 4 formulation of triclopyr. PDFs eliminate this scenario by favoring use of Garlon 3A, minimizing 

application rates of all triclopyr formulations, and following safe work practices and label advisories. 

For all other herbicides and surfactants, the amount of plausible worker exposure is below levels of concern for 

all application methods, including broadcast. Project Design Features for all action alternatives reduce both the 

application rate and the quantity of drift if triclopyr and/or NPE are used. Broadcast of triclopyr is not permitted 

in any situation (as per Standard 16), and non-NPE surfactants would always be favored where effective. 

Chronic (daily over 90 days) worker exposure was also considered in SERA Risk Assessments; chronic 

exposures also 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). 

Public Herbicide Exposure Analysis 

The general public would not be exposed to substantial levels of any herbicides used in the implementation of 

this project. R6 2005 FEIS Appendix Q considered plausible direct, acute and chronic exposures from herbicide 

ingredients. Few plausible scenarios exist that exceed even the most conservative threshold of concern for public 

health and safety. Appendix Q shows Risk Assessment results assuming a human being contacts sprayed 

vegetation or herbicide or consumes sprayed vegetation, contaminated water, and/or fish. 

Direct Contact 

There is virtually no chance of a person being directly sprayed given broadcast, spot and hand/select methods 

considered for this project. A person could brush up against sprayed vegetation soon after herbicide is applied. 

Such contact is unlikely because public exposure would be discouraged during and after herbicide application. 

For all herbicides except triclopyr, even if a person were directly sprayed with herbicide applied at typical 

broadcast rates, chemical exposure would not exceed a level of concern. 

Exposures exceeding a conservative level of concern could occur if a person accidentally contacts vegetation 

spot-sprayed with triclopyr (especially Garlon 4). However, such contact is implausible because no broadcast 

spraying with triclopyr would occur under any alternative (the R6 2005 ROD added Standard 16 to the Olympic 

National Forest Plan to only allow spot or hand/selective treatment if triclopyr is used). 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

192

The use of Garlon 4 is further limited by the PDFs (for instance, no use of Garlon 4 would be allowed within 150 

feet of any water body or stream channel; Garlon 4 would be avoided in special forest product gathering areas, 

campgrounds, or administrative sites). Public areas, campgrounds and administrative sites would be closed 

immediately after triclopyr application to eliminate accidental exposures. Project design features such as K1 and 

K2 require public notification and posting signs about herbicide use to help people avoid inadvertent exposure. 

Eating Contaminated Fish, Berries or Mushrooms 

The public may also be exposed to herbicide if they eat contaminated fish, berries, or mushrooms (etc). Several 

exposure scenarios for recreational and subsistence fish consumption were considered in the SERA Risk 

Assessments; none are near any herbicide exposure level of concern. Fish contamination is unlikely given the 

Project Design Features that reduce potential herbicide delivery to water. 

Members of the public could eat invasive blackberries that have been sprayed, however the target vegetation 

would quickly be browned and unappetizing. Non-target, native berries or mushrooms may be affected by drift 

or runoff. Treatment areas would be posted with signs to help people avoid inadvertent exposures. 

The R6 2005 FEIS considered exposure scenarios for both short term and chronic consumption of contaminated 

berries. The herbicide dose from eating a quantity of mushrooms would be greater than for the same quantity of 

berries (Durkin and Durkin, 2005). The dose, however, would be less than the dose from a dermal contact with 

sprayed vegetation scenario, and below the threshold of concern (HQ <1). 

Appendix Q displayed the exposure scenarios and HQ values associated with eating berries or other herbicide 

contact. Of the ten herbicides considered in this project, triclopyr remains the single herbicide with exposure 

scenarios exceeding a level of concern if berries or mushrooms containing herbicide residue are consumed. To 

respond to this concern, PDFs limit the application methods and rate of application for triclopyr (especially 

Garlon 4). In addition, under worst-case scenarios and maximum label rates, exposure to NPE surfactant may 

also exceed a level of concern. Thus PDFs limit the rate of NPE that may be applied. Special forest product 

gathering areas may be closed to public use immediately after triclopyr application to avoid inadvertent exposure. 

People who both harvest and consume special forest products may be exposed both through handling 

contaminated plant material and chewing or eating it. Chewing and eating contaminated plant material cause 

different exposure and dose patterns. Such doses would be additive, but are unlikely to exceed a threshold of 

concern (see cumulative effects, below). 

Drinking Contaminated Water 

Acute exposures and longer-term or chronic exposures from direct contact or consumption of water, fruit or fish 

following herbicide application were evaluated in the R6 2005 FEIS. Risks from two hypothetical drinking 

water sources were evaluated: 1) a stream, which herbicide residues have contaminated by runoff or leaching 

from an adjacent herbicide application; and 2) a pond, into which the contents of a 200-gallon tanker truck that 

contains herbicide solution is spilled. The only herbicide scenarios of concern would involve a person drinking 

from a pond contaminated by a spill of a large tank of herbicide solution. The risk of a major accidental spill is 

not linked in a cause-and-effect relationship to how much treatment of invasive plants is projected for a particular 

herbicide; a spill is a random event. A spill could happen whenever a tank truck involved in an herbicide 

operation passes a body of water. The potential risk of human health effects from large herbicide spills into 

drinking water are mitigated by Project Design Features that require an Herbicide Transportation and Handling 

Plan be developed as part of all project safety planning, with detailed spill prevention and remediation measures 

to be adopted. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

193

Endocrine Disruption 

 In 2007, the Environmental Protection Agency released a draft list of 73 pesticides, based on the high potential 

for human exposure, which will be tested for potential to cause endocrine disruption. Glyphosate is the only 

herbicide considered for use on the Olympic National Forest that is included in the EPA testing. Endocrine 

disruption and glyphosate was studied by SERA in 2002 (SERA 2002) and considered in the R6 2005 FEIS, 

Appendix Q. 

SERA reported “Three specific tests on the potential effects of glyphosate on the endocrine system have been 

conducted and all of these tests reported no effects. The conclusion that glyphosate is not an endocrine disruptor 

is reinforced by epidemiological studies that have examined relationships between occupational farm exposures 

to glyphosate formulations and risk of spontaneous miscarriage, fecundity, sperm quality, and serum reproductive 

hormone concentrations... the approach taken in the SERA risk assessment used by the Forest Service is highly 

conservative and no recent information has been encountered suggesting that this risk assessment is not 

adequately protective of any reproductive effects that might be associated with glyphosate exposure.

Environmental Justice and Disproportionate Effects 

The R6 2005 FEIS found that some minority groups may be disproportionately exposed to herbicides, either 

because they are disproportionately represented in the pool of likely forest workers, or they are 

disproportionately represented in the pool of special forest product or subsistence gatherers. 

The R6 2005 FEIS suggested that Hispanic forest workers and American Indians may be minority groups that 

could be disproportionately affected by herbicide use. 

Hispanic and non-Hispanic herbicide applicators would be more likely to be exposed to herbicides than other 

people. Contractors for the Forest and/or County would likely implement herbicide treatments. County invasive 

plant control departments do not indicate that they employ any specific population group that could be 

disproportionately affected during invasive plant treatments. Regardless, effects to all County or contract 

employees engaged in invasive plant control would be negligible due to Project Design Features and compliance 

with occupational health and safety standards. 

People of Hispanic and Southeast Asian (Khmer, Khmer Krom, Laotian and Vietnamese) descent are minority 

groups that tend to gather mushrooms. However, no mushrooms are target species and Project Design Features 

are in place to protect fungi. Whenever herbicide treatment is going to happen, the Forest will notify tribes, plant 

collectors and the general public with media postings, handouts attached to permits, annual tribal contacts and 

on-the-ground signing (PDFs K1 and K2). Information about invasive plant treatments would be added to 

existing multi-lingual mushroom gathering permit material to eliminate inadvertent exposures if appropriate. 

Some areas may be closed to gathering following treatment to avoid exposures. Even given plausible inadvertent 

exposures, the HQ values would not exceed the threshold of concern. 

Direct and Indirect Effects of the Alternatives 

No Action 

The herbicide applications approved in No Action were previously analyzed in the 1998 EA and found to pose no 

significant potential risks to health for workers or the public. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

194

Action Alternatives 

All alternatives similarly resolve issues related to human health. No individual worker or public exposures of 

concern are predicted for any alternative. Alternative C has the least risk of adverse effects from herbicide use of 

all action alternatives because it eliminates or severely restricts herbicide on an estimated two-thirds of the 

project acreage. However, the Project Design Features, particularly the perennial stream buffers, limitations on 

application rate of some herbicides also eliminate plausible exposures of concern in Alternatives B and D. No 

adverse effects to public drinking water supplies or health and safety are predicted in any alternative. Exposures 

of concern would be minimized on inventoried and currently unknown sites because the Project Design Features 

would be applied to all situations. 

Table 69-How Human Health Concerns are Addressed 

Human Health 

Concern Project Design Feature to Minimize Exposures of Concern 

Workers Reduced application rates of some herbicides; limitations on broadcast of triclopyr as per 

Standard 16. 

Public 

Reduced application rates of some herbicides; limitations on broadcast of triclopyr as per 

Standard 16. These limitations reduce risks to the general public, even considering multiple 

exposures. 

Special 

Forest 

Products 

Reduced application rates of some herbicides; posting areas, supplying info to permittees; 

Using flagging to mark treated areas; Ensuring some areas are available that will not be 

treated. Detectable impacts are implausible except in the event of an unpredictable 

exposure. Even multiple exposures (eating contaminated fish, drinking contaminated water, 

skin irritation) would not result in exposure levels of concern. 

Drinking 

Water 

Detectable impacts are implausible except in the event of a spill. Transportation and 

Handling Safety Plan and Spill Plan. 

Cumulative Effects of All Alternatives 

The proposed use of herbicides in all 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. 

A person could be exposed to herbicide repeatedly over the course of their lifetime. Appendix Q of the R6 2005 

FEIS evaluated chronic exposure scenarios, including repeated drinking of contaminated water, repeated 

consumption of contaminated berries, and repeated consumption of contaminated fish over a 90-day period. The 

HQ values for chronic exposures of all herbicides considered for this project were below 1. 

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 HQ values for each individual exposure scenario. An example of this scenario was considered for this 

cumulative effects analysis: the scenario assumes glyphosate contacts a person’s bare skin (HQ for dermal 

exposure is less than 0.01), and that person immediately eats contaminated berries and fish (HQ values for oral 

exposure are less than 0.01). Even if these three exposures occurred simultaneously, the combined HQ values are 

still far below a threshold of concern (HQ < 1). 

Some of the herbicides considered for use in this project have HQ values greater than glyphosate; however, the 

combined HQ values for dermal and oral exposure are still likely to be very low. The body would metabolize 

some of the initial dose before receiving the second dose, thus reducing the cumulative dose. The risk of adverse 

effects to human health is low because the herbicides proposed for this project are water-soluble, are quickly 

eliminated from the body, and do not bioaccumulate in the human body. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

195

Risk assessments indicated a cause for concern about the health effects from exposure to triclopyr; Project 

Design Features avoid broadcast with this herbicide and severely restrict the use of its more toxic formulation 

(Garlon 4). In addition, risk assessments indicate a concern regarding use of NPE surfactant. NPE surfactant use 

is also restricted by the Project Design Features, which would ensure that no thresholds of concern would be 

exceeded, even if the most ambitious treatment scenario was implemented. All alternatives comply with 

standards, policies and laws aimed at protecting worker safety and public health.

3.7 Project Costs, Financial Efficiency and Jobs 

3.7.1 Introduction 

The treatments proposed by the Forest Service are likely to be funded through a variety of mechanisms and 

partnerships including county, state, federal and private sources. The economic efficiency analysis compares the 

relative total and average costs of implementing each alternative. Concerns about project cost, financial 

efficiency, and jobs were expressed during scoping (Issue Group 3). 

The differences between alternatives also result in differences in labor force required to complete the work. 

Members of the public expressed that job creation is a positive indirect effect of the project that should be 

presented in the EIS. 

The following project cost, economic efficiency and job analysis considers the most ambitious conceivable 

program discussed throughout this chapter. It also characterizes the costs of treating the highest priority 

infestations found on about 32 percent of the project area (see Chapter 2, Treatment Area Priority). The 

following assumptions are built into the economic analysis: 

• Eradicate/control acres will be harder to treat and will cost 1.5 times as much as containment acres to 

effectively treat each year. 

• Each year’s treatment is expected to be 80 percent effective where herbicides are in the range of 

available methods, and 25 percent effective if herbicide use is severely restricted as in No Action (see 

Botany and Treatment Effectiveness for rationale for these percentages). 

• Alternative B has 34 percent of its herbicide treatment acres modeled for broadcast treatment and 

Alternative D has 84 percent of its herbicide treatment acres modeled for broadcast treatment. These 

estimates likely include more broadcasting than would actually occur, based on the nature of the current 

infestations. However, this assumption helps show the maximum increased efficiency that could be 

gained by allowing the flexibility gained by relaxing some Project Design Features in Alternative D. 

Broadcast to spot/hand ratio remains the same in Alternatives D and B through the life of the project. 

• Non-herbicide treatments that are combined with herbicide treatments are modeled to start occurring in 

the second year of treatment. The first year is assumed to be 100 percent herbicide, even though the final 

prescriptions are likely to include some manual and mechanical treatment during or before herbicide 

application. This assumption allows for the maximum differentiation between the impacts of herbicide 

use in the alternatives. 

• Over time, the proportion of herbicide use compared to non-herbicide methods is expected to decrease in 

Alternatives B and D. These alternatives are assumed to follow a pattern of declining herbicide use over 

time, as shown in Table 70 and Figure 3. No Action and Alternative C maintain the same proportion of 

herbicide to non-herbicide (13 and 30 percent respectively). 

Table 70-Pattern of Herbicide to non-Herbicide over Time, Alternatives B and D 

Year Percent Herbicide Use Percent Non-Herbicide Use 

2007 96% 4% 

2008 75% 25% 

2009 50% 50% 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

196

Year Percent Herbicide Use Percent Non-Herbicide Use 

2010 0% 100% 

3.7.2 Treatment Costs by Method 

The following costs were used in the analysis: 

• Base cost for broadcast is $100 per acre, increased for eradicate/control by 1.5 to $150 

• Base cost for Spot/Hand is $250 per acre, increased for eradicate/control by 1.5 to $375 

• Base cost for Manual is $340 per acre, increased for eradicate/control by 1.5 = $460 

• Base cost for Mechanical is $100 per acre, increased for eradicate/control by 1.5 to $150 

• Annual inventory and monitoring was estimated to cost $20,000 per year. 

• Active restoration was estimated to cost about $500 per acre, applied to two-thirds of the project acreage. 

Active restoration was assumed to occur on approximately 650 acres per year in Alternatives B and D 

and about 371 acres per year under Alternative C. 

Base costs were used for acreage with a treatment strategy of containment, and applied to all acreage treated 

under No Action. 

Most Ambitious Program - Declining Reliance on 

Herbicides over Time, Alternatives B and D

0%

25%

50%

75%

100%

2007 2008 2009 2010

Nonherbicide

Methods

Herbicide

Methods

Figure 3-Declining Reliance on Herbicides over Time 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

197

3.7.4 Total and Average Project Costs 

This section reveals the results of the economic analysis, including the total cost of the most ambitious 

conceivable treatment scenario, projected from 2007 to 2011. 

Table 71-Cost Comparisons by Alternative 

Alternative Total Cost 

2007-2011 

Maximum Annual Cost Average Annual Cost Average Cost Per Acre

A 

(No Action)

$664,000 $255,340 $149,000 $988

B 

(Proposed Action) 

$2,183,000 $751,785 $490,000 $570 

C $3,496,000 $1,247,700 $785,000 $ 1,025 

D $2,070,000 $657,300 $465,000 $540

Table 72 and Figure 4 display the range of annual funding that would be required for the most ambitious 

treatment scenarios. 

Table 72-Estimated Acres Treated and Cost By Year 

Year Acres Treated 

(Herbicide, Manual, Mechanical) 

Cost ($) 

No Action 

2007 672 255,340

2008 504 159,110

2009 378 124,430 

2010 284 98,350 

2011 213 62,260 

Proposed Action (Alternative B) 

2007 3,830 751,785 

2008 765 532,520 

2009 148 376,935 

2010 29 342,920 

2011 0 311,500 

Alternative C 

2007 3,410 1,247,700

2008 1,979 1,169,400

2009 1,133 487,300

2010 657 445,500

2011 381 324,700

Alternative D 

2007 3,830 657,285

2008 765 514,47

2009 148 374,985

2010 29 342,920

2011 0 311,500
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

198

The most ambitious treatment scenarios are unlikely to be accomplished, unless funding is increased severalfold. Assuming the current funding estimate of $100,000 was available for invasive plant treatments and 

restoration each year over five years, approximately 20 percent of the total current infested acreage (750 acres) 

would be effectively treated. High priority sites would likely be treated, but other infestations would continue 

to spread. Cost of treating existing infestations would continue to increase. 

3.7.3 Jobs by Alternative 

Some members of the public expressed that job creation is a valuable indirect effect of invasive plant treatment. 

They expressed that manual treatments are more likely to involve manual labor than other treatment methods, 

and thus should be favored. Indeed, nearly all of the costs associated with manual treatments involve labor costs 

and alternatives with a greater proportion of this treatment compared to other methods would tend to create more 

jobs per treatment acre. 

Assuming full funding, the most ambitious treatment scenarios in each alternative would result in short-term 

employment opportunities. Employment opportunities would diminish over time as the invasive plants are 

eradicated, controlled, contained, or suppressed and treated sites are restored. 

The alternative comparisons above reflect total estimated costs of labor, equipment, and supplies; these vary 

depending on treatment type (manual, mechanical, and/or herbicide) and herbicide application method (spot/hand 

vs. broadcast). 

0

200

400

600

800

1000

1200

2007

2009

2009

2010

2011

A

B

C

D

Figure 4-Projected Costs (in Thousands) of Most Ambitious Conceivable 

Program, 2007-2011, Alternatives A, B, C, and D 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

199

Table 73 displays the assumptions used to determine the number of worker days per year (2007-2011) associated 

with the most ambitious treatment scenario under each alternative. These assumptions are based on methodology 

established on the Mount Hood National Forest in their Invasive Plant DEIS (USDA 2006), adapted to local 

conditions. Wages were estimated as 80 percent of labor cost (assuming the other 20 percent applies to taxes and 

benefits). Wages were assumed to average of $160 per worker day; actual wages range widely for machine 

operators, herbicide applicators, and hand laborers. 

Table 73-Assumptions for Worker Days per Treatment Acre 

Treatment Method Total Cost Per 

Acre 

Wage Cost as 

Percent of Total 

Worker Day per 

Containment 

Treatment Acre 

Worker Day per 

Control/Eradicate 

Treatment Acre 

Herbicide- Broadcast 100 24 .15 .23 

Herbicide- Spot/Hand 250 85 1.06 1.6 

Mechanical 100 40 .2 .3 

Manual 340 100 2 3 

Restoration 500 50 1.18 1.18 

Table 74-Number of Jobs for First Year of Most Ambitious Treatment Scenario 

Alternative Total Acres 

Total 

Worker Days 

Number of Jobs 

Assuming 6 Month Season 

Alternative A 672 1,047 8 

Alternative B 3,830 2,320 18 

Alternative C 3,410 6,982 54 

Alternative D 3,830 1,745 13 

Future years’ job numbers would decline rapidly after the first year of the most ambitious conceivable treatment, 

because less treatment would be needed in following years. However, restoration under Alternatives B and D 

would occur on approximately 623 acres per year in the years 2008 through 2011. Jobs associated with 

restoration in these years amount to about six additional jobs per six-month year. Restoration under Alternative 

C would occur on approximately 371 acres per year in the years 2008 through 2011. Jobs associated with 

restoration in these years amount to about three additional jobs per six-month year. 

The project alternatives would require services of 3 to 12 people per six month year over a period of five years, 

assuming a constant budget of $100,000 per year; following a similar distribution to Table 74. Alternative C 

creates the most jobs due to its reliance on manual treatment methods. 

This job level is not significant to the economy of the counties surrounding the Olympic National Forest, 

although the most ambitious treatment scenario may require the help of workers from outside the local area. 

3.8 Additional Environmental Effects 

3.8.1 Heritage (Cultural) Resources 

The USDA, Forest Service, Advisory Council on Historic Preservation and the Washington State Historic 

Preservation Office (SHPO) (Office of Archaeology and Historic Preservation), have a programmatic agreement 

addressing the management of cultural resources on national forests in the state of Washington (Agreement 

Number 97-06-59-10). There are several actions that were determined to have little or no potential to affect 

historic properties. Examples of these actions include fence construction, planting on disturbed areas, aerial 

seeding, pre-commercial thinning, encroachment thinning using hand methods to lop branches and cut small 

trees, and reforestation planting by hand. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

200

While invasive plant treatments within the scope of this EIS are not specifically itemized in the Programmatic 

Agreement between the Forest Service and the Washington SHPO, the techniques, methods and effects are 

generally similar. Forest Service staff has coordinated with the Washington SHPO and affected Tribes to classify 

all actions within the scope of this EIS as having no effect on heritage resources. 

One exception is weed wrenching of Scotch broom proposed within undisturbed, unsurveyed areas of the 

National Forest. Such treatments could occur under all action alternatives. 

While most Scotch broom infestations occur in disturbed areas (roadsides), some infestations are in less disturbed 

areas. Weed wrenching of larger-sized Scotch broom has the potential to disturb heritage resources in 

undisturbed sites. To mitigate for this possible effect, weed wrenching sites would be evaluated by a heritage 

resource specialist prior to and/or during treatment to eliminate disturbance to heritage resources. 

3.8.2 Tribal and Treaty Rights 

Several of the tribes are using similar herbicide treatments themselves and support the prescriptions on the forest. 

Executive Order 12898 directs the agencies to consider patterns of subsistence hunting and fishing if an action 

will affect fish and wildlife. 

The Chehalis, Jamestown S’Klallam, Hoh, Lower Elwha Klallam, Nisqually, Makah, Port Gamble S’Klallam, 

Quileute, Quinault, Shoalwater Bay, Skokomish, Squaxin Island and Suquamish Indian Tribes utilize the 

Olympic National Forest for recreation, hunting, fishing and gathering cultural plants. Minority groups use the 

forest to collect personal use and commercial forest products like huckleberries, salal, bear grass, mushrooms and 

herbs. The probability that Alternative B would directly or indirectly affect these people in any way is very low 

because of the various benign treatments with their built-in Project Design Features and public notifications. The 

majority of herbicide treatments would be along roadsides. The plants that people come to collect and utilize are 

usually found in more natural settings vs. a disturbed roadside, so most gathering will occur away from treatment 

areas. Invasive species would be treated selectively to minimize effects on non-target plants. Cultural plants are 

would be protected by barriers or avoidance similar to other botanical species of local interest. 

No adverse effects are expected on fish and wildlife populations on which the thirteen Indian tribes rely. Many 

of the tribes have expressed support for herbicide treatments to combat invasive plants because the long-term 

benefits of controlling the invasive plants outweigh the few short-term risks or disruptions. 

3.8.3 Environmental Justice and Civil Rights 

Low income and minority groups would see no change to their use of the Forest under this alternative. There 

currently are no disparate effects on these populations by forest management activities. 

Executive Order 12898 directs federal agencies to identify and address the problem of adverse environmental 

effects by agency programs on minority and low income populations. 

Contractors for the Forest and/or County would likely implement herbicide treatments. County invasive plant 

control departments do not indicate that they employ any specific population group that could be 

disproportionately affected during invasive plant treatments. Regardless, effects to all county or contract 

employees engaged in invasive plant control would be negligible given the counties are licensed herbicide 

applicators that follow label precautions. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

201

3.8.4 Recreation and Scenery 

Direct beneficial effects would include the limitation of non-native species in the viewshed, maintenance of 

diverse community of native grasses, forbs, and shrubs, and maintenance of conditions consistent with the 

ecological setting that supports the desired landscape character of mosaic forested canopy and grassland 

openings. The alternative would meet the existing visual quality objectives and be beneficial to the landscape 

character by reducing risks of altered plant species composition and related effects. The scenic integrity and 

scenic stability would be maintained. 

There are herbicide and manual treatments of invasive plants proposed in campground and recreation residence 

tracts. The Forest would utilize a notification process so people knew in advance what plants are to be treated, so 

that people can avoid areas that have been sprayed. 

The holders of special use permits for recreation residences on the Forest (e.g., Lake Quinault), are familiar with 

the problem of invasive plants like English Ivy and knotweed and have been actively engaged in efforts to 

control the plants around their cabins. Most would likely welcome safe herbicides. 

The only negative effect anticipated is if some forest visitors feel they must go elsewhere to avoid chemicals that 

have been applied to invasive plants in their favorite recreation spot. However, should the public still use the 

recreation sites just before, during or right after treatment, the risk of an adverse impact to visitors from treated 

plants is very low (see risk assessment). 

Aggressive action proposed to control or eradicate invasive species would help sustain the landscape character 

with some short term effects to scenic integrity. Dead vegetation would be visible for at least one growing 

season would be a short-term negative effect. The unnatural appearance of mowed and brushed areas seen from 

immediate foreground distances (300 feet) would also be a short-term negative effect. Some treatment areas 

stretch for miles along the sides of roads. 

Direct beneficial effects would include the limited amount of non-native species in the viewshed, maintenance of 

diverse community of native grasses, forbs, and shrubs, and maintenance of conditions consistent with the 

ecological setting that supports the desired landscape character of mosaic forested canopy and grassland 

openings. The alternative would meet the existing visual quality objectives and be beneficial to the landscape 

character by reducing risks of altered plant species composition and related effects. The scenic integrity and 

scenic stability would be maintained. 

The 672 acres of invasive plant treatments currently happening on the forest (No Action, Alternative A) have a 

manual and mechanical component with some herbicide use (up to 86 acres.) The treatments have not affected 

recreationists or scenery. Recreation uses have not been displaced by treatments, and the treatments have not led 

to visual impacts in the form of large areas of dead plants or de-vegetated zones along visually sensitive road 

corridors. 

Alternative A would not keep up with the aggressive invasion of non-native species. Effects to scenic resources 

would include changing the landscape character to a homogeneous species composition in certain areas and in 

the forest understory, which is inconsistent with the valued landscape character. The No Action Alternative 

would not be sufficient to fully maintain the native species. As discussed in Chapter 3.2, native pant species 

diversity could be reduced. Japanese knotweed may overtake riparian vegetation and river banks altering the 

scenic pattern, form and texture of open areas and the forest understory extensively. The scenic integrity would 

be reduced. 

3.8.5 Congressionally Designated Areas: Wilderness and Wild and Scenic Rivers 

Five wilderness areas occur on the Olympic National Forest, four of these likely contain invasive plants 

(Buckhorn, Colonel Bob. the Mt. Skokomish and the Brothers Wilderness). The Wonder Mountain Wilderness 

has a low potential for invasive species. Invasive plants have adverse effects to wilderness values since they 

disrupt natural processes. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

202

Treatments may also adversely affect wilderness values. Spot and selective herbicide applications, along with 

manual treatments such as hand pulling, would occur as needed in wilderness areas. Wilderness visitors may 

notice the effects of invasive plant treatments as browned out vegetation may be obvious. A visitor’s sense of 

solitude may be affected if they came upon an invasive plant worker pulling or spraying individual plants. These 

encounters would be brief, and no mechanized treatment methods would be approved for wilderness application. 

The wilderness areas would continue to be free to evolve and respond without interference from invasive plant 

treatments. 

No Wild and Scenic Rivers have been designated on the Olympic National Forests. A number of streams are 

eligible for consideration under the Wild and Scenic Rivers program, and the Dungeness, Grey Wolf and 

Duckabush Rivers have been recommended for listing. The overriding resource value being managed for all of 

the rivers is scenery. 

As discussed above, invasive plant treatments with herbicides can temporarily affect scenery if large numbers of 

target plants are together and are seen in the dying or dead phase. They will not be noticed the following 

growing season when the residual live, green native vegetation dominates the view. 

3.8.6 Energy Requirements and Conservation Potential 

No unusual energy requirements are associated with this project. No unusual equipment would be used. Fossil 

fuels would be used in a prudent manner. 

3.8.7 Irreversible or Irretrievable Use of Resources 

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. 

3.8.8 Effects on Long-term Productivity 

Positive effects on site productivity would be expected as native vegetation is restored. Some herbicides have 

potential to reduce soil productivity; Project Design Features are intended to avoid use of such herbicides where 

soil productivity is already low. 

3.8.9 Consistency with Forest Service Policies and Plans 

The proposed project is consistent with all Forest Service policies and existing plans, with the exception of 

Alternative D, which is associated with herbicide use that has the potential to exceed concentrations of concern 

for aquatic SOLI. The conclusions and findings in this analysis are supported by the best scientific information 

available. The FEIS (and the broader scale R6 2005 FEIS to which it is tiered) identifies methods used, discusses 

responsible opposing views, and discloses incomplete or unavailable information, scientific uncertainty, and risk 

(See 40 CFR, 1502.9 (b), 1502.22, 1502.24). 

Invasive plant treatments are no longer subject to the requirements of the 1989 Mediated Agreement that affected 

removal of unwanted vegetation in Region Six. The R6 2005 ROD vacated the mediated agreement; replacing it 

with management direction for invasive plant prevention, treatment, restoration and monitoring. In April 2007, 

Northwest Coalition for Alternatives to Pesticides, the lead signer in the 1989 Mediated Agreement, agreed it was 

willing to dissolve the Mediated Agreement for purposes of controlling invasive plants in Region 6. The 

Portland Audubon Society (July 2, 2007) and the Oregon Environmental Council (October 15, 2007) have also 

agreed in writing to dissolve the Mediated Agreement for invasive plant control." 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

203

3.8.10 Conflicts with Other Plans 

No conflicts with existing plans have been noted. Jefferson County reportedly does not use herbicides on lands 

outside of National Forests (personal communication with Carol Dargatz, Field Trip Notes August 2005). Use of 

herbicides in this county would be coordinated with the noxious weed board. 

“Survey and Manage” species were identified in the 1994 Northwest Forest Plan. In 2001 (2001 ROD) and again 

in 2004 (2004 ROD), the agencies sought to make changes in this mitigation measure. The 2004 ROD was 

litigated and on January 9, 2006, Judge Pechman signed an Order that reinstated the 2001 ROD. Thus, the Survey 

and Management Mitigation Measure currently applies to all species that were included in the program in 2001. 

Species that were added to the Regional Forester’s Sensitive Species Program in 2004 remain in both programs. 

Surveys and management protocols required at the time of implementation will be applied. 

3.8.11 Adverse Effects That Cannot Be Avoided 

Most of the significant issues are resolved through adherence to Project Design Features that minimize 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 treatment. 

• Herbicide exposures to fish exceeding thresholds of concern are unlikely but possible given an herbicide 

spill or unpredictable weather event. 

• Minor to moderate physical injuries due to forestry work are possible. 

• Some common non-target plants are likely to be killed by treatments in close proximity. 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. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

204
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

205

CHAPTER 4. List of Preparers, Consultation and 

Coordination with Others (Tribes, Agencies) 

4.1 List of Preparers 

The following people were the primary authors of this EIS. Many other Forest Service employees and others 

reviewed the document and provided input. 

Shawna L. Bautista 

Wildlife Specialist, 

R6 Invasive Plant Program, 

B.S .Wildlife Management, 

M.S. Zoology and Physiology, 

Wildlife Analysis and ESA Consultation 

Rochelle Desser 

Environmental Coordinator, 

TEAMS Enterprise 

A.S. Geo-technology; Interdisciplinary Studies 

Team Leader, Writer-Editor, Economics 

Mike Ferris 

Public Affairs Officer, 

Columbia River Gorge National Scenic Area 

B.A. Psychology and Sociology 

Public Involvement 

Doug Jones 

Recreation/Lands Forester, 

Mt. Hood National Forest 

B.S. Outdoor Recreation and Forestry 

Recreation, Scenery and Social Analysis 

Diana Perez-Rose 

Forest Fisheries Biologist, 

Gifford-Pinchot National Forest 

B.S. Wildlife Biology 

M.S. Fisheries Biology 

Fisheries Analysis and ESA Consultation 

Ron Pfeifer 

Geographic Information Services (GIS) 

Pacific Northwest Region 

B.S. Forest Management 

GIS Analyst 

Janice Schultz 

Writer-Editor, 

TEAMS Enterprise 

Editorial Assistant 

Cecile Shohet 

Botanist, 

Columbia River Gorge National Scenic Area 

MS Plant Sciences, BS Biology 

Botanical Analysis 

Gary Smith 

Invasive Plant Program Manager, 

State and Private Forestry, Washington D.C. 

MS Silviculture, BS Forestry 

Human Health Risk Assessment 

Carol Thornton 

Hydrologist, TEAMS Enterprise 

B.S. Geology, 

M.S. Hydrology/Hydro-geology 

Soil and Water Specialist 

Irene Ward 

GIS Analyst 

Pacific Northwest Region. 

AA Water Resources, Forestry, BS Geography, 

GIS Analyst 

Erika Wittmann 

Biological Science Technician, 

Olympic National Forest 

B.A. in Environmental Education/Mass 

Communications, 

M.E.S. Environmental Studies 

Editorial Assistant 

Joan Ziegltrum 

Forest Ecologist, Olympic National Forest 

Ph. D. Forest Ecology and Management 

Olympic National Forest Liaison 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

206

4.2 Consultation with Regulatory Agencies 

The Forest Service has completed consultation with the US Fish and Wildlife Service (FWS) and NOAA 

Fisheries (NMFS) regarding potential adverse effects on federally listed or proposed Threatened or Endangered 

Species. The process and results of consultation are discussed at length in Chapter 3.3 and 3.5. 

Over the course of 2006 and into early 2007, there were a series of meetings and negotiations between the Forest 

Service, FWS, and NMFS staff to develop the project description and finalize a Biological Assessment (FWS 

2007 BO). The FWS concurred that the project is not likely to adversely affect any federally listed terrestrial 

wildlife species (FWS LOC, April 2007). FWS and NMFS also prepared letters of concurrence that portions of 

the project area (away from listed fish habitat) are not likely to adversely affect fish species listed under ESA. 

Portions of the project close to listed fish habitat were found likely to adversely affect listed fish species under 

ESA. However, in their respective Biological Opinions (FWS 2007 BO, NMFS 2007 BO), the regulatory 

agencies concluded that the action, as proposed, is not likely to jeopardize the continued existence of bull trout, 

Puget Sound Chinook salmon, Hood Canal summer-run chum, salmon, or Puget Sound steelhead or result in the 

destruction or adverse modification of designated critical habitat for any listed fish species. The regulatory 

agencies documented terms and conditions for the project to minimize the taking of any listed fish species. The 

terms and conditions are consistent with the Proposed Action description in Chapter 2. 

Consultation records are available online at the project website: http://www.fs.fed.us/r6/olympic, or hard copy by 

request. 

4.3 Consultation with Tribal Governments 

Government to government consultation is ongoing with several tribes including: Chehalis Confederated Tribes, 

Hoh Tribe, Jamestown S’Klallam Tribe, Lower Elwha, S’Klallam Tribe, Makah Tribe, Port Gamble S’Klallam 

Tribe, Quileute Tribe, Quinault Indian Nation, Shoalwater Bay Tribe, Skokomish Tribe, Squaxin Island Tribe, 

and the Suquamish Tribe. Letters have been sent to all tribal chairs, and follow up presentations and meetings 

have occurred at the request of the tribes. 

No tribal members (who have identified themselves as such) have expressed disapproval of the project. In fact, 

the Quileute Tribe expressed full support of the Forest Service’s intention to “address invasive weeds head-on.” 

Informally, tribal representatives have stated they believe the long-term benefits of treating and controlling 

invasive plants outweigh the short-term risks to localized populations of culturally significant plants. 

4.4 Consultation with Counties and Municipal Water Boards 

The Forest Service has worked closely with the Clallam, Grays Harbor, Jefferson, and Mason County Weed 

Boards. County staff have presented information to the Forest Service and participated in field visits. The 

Counties often implement projects for the Forest Service and other land managers in the area and fully support 

this project. 

Coordination with municipal water boards would occur as a part of implementation planning to ensure 

compliance with the Olympic National Forest Plan standards and Municipal Watershed Agreements. 

4.5 Consultation with Others 

Scoping has occurred on this project since 2004. The public has been apprised of project progress through the 

newspaper, direct mailings, Notices of Intent published in the Federal Register in 2004 and again in 2005, the 

Forest Schedule of Proposed Actions, informal meetings and discussions, and other media. Many organizations 

and individuals have expressed interest in the project; everyone who expressed interest was offered a hard copy 

or CD containing the EIS and Appendices. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

207

The full FEIS and Appendices are also available electronically by website: http://www.fs.fed.us/r6/olympic or on 

request (see cover page for more information or to request a CD or hard copy). 

Hard copies have been distributed to Forest Service offices throughout the area. CDs and hard copies have been 

sent to the Environmental Protection Agency (who commented during scoping and on the DEIS) and other 

federal agencies as required. The following is a list of individuals, organizations, agencies and tribal 

governments and groups to whom this FEIS was sent: 

Individuals 

Barbara and David Adams 

Kenn Adcock 

Nancy Alderson 

Robert Amundson 

Jim Anderson 

Lynn Bergeron 

Walter Blendermann 

B. Boyles 

Jack Burkhalter 

Jean Cameron 

Felix Capoeman 

Betty Captein 

F.Stuart Chapin 

Carolee Colter 

James Crudele 

Ted Davenport 

Jean Day 

Jean Dunlop 

John Edmundson 

Stan Fouts 

Michelle Franz 

Enid Griffin 

C.J. Guthrie 

Donald and Alice Hack 

Emery Ingham 

John Irwin 

Richard Johnson 

Pam Kenyon 

Kurt Kessler 

Irene Kocher 

Jack Konner 

M.A. Kruse 

Russell Kysar 

Leroy Layton 

Eugene Lynch 

Ned Marshall 

C.J. McClellan 

Moyers 

Lewis Nickerson 

Pellissier 

Charlotte Portner 

Tim Plein 

Nancy Russell 

Michael Ryan 

Michael Rysavy 

A.L. Schwiesow 

Greg Short 

Sandra Smith 

C.G. Spies 

Phyllis Stuart 

Nita Sullivan 

Aubrey Taylor 

Cheryl Thoen 

Chris Thompson 

Ray Triplett 

Jim and Barbara Scott Trusky 

Roberta Vandehey 

Kathryn Venator 

Carol Volk 

Mitchell Williams
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

208

Organizations 

German Shorthair Pointer Club 

Strategic Analysis 

Freres Lumber Co. Inc. 

Max Merlich 

Black Butte Ranch 

Nelson Tree Farm 

Mt. Hood Study Group 

Lewis and Clark College 

Olympic Forest Coalition 

Ochoco Lumber Co. 

Longevity Herb Company 

Greenworks PC Landscape Architecture 

American Forest Resource Council 

Washington Native Plant Society 

The Ptarmigans 

Glacier View Enterprises 

Portland General Electric 

BARK 

NCAP 

Gifford Pinchot Task Force 

Physicians for Social Responsibility 

WA State Director 

Pacific NW Four Wheel Drive Assoc 

Kettle Range Group 

NW Ecosystem Alliance 

Agencies 

Bonneville Power Administration 

Environmental Protection Agency Region 10 

Wash Dept of Nat. Res. 

Mason County Deputy Prosecutor 

Wash Nox Weed Board 

Olympic National Park 

Grays Harbor County Commision 

Wash. Dept. of Transportation 

Klickitat Cty Nox. Weed Control Brd. 

USDI-FWS Nat'l Fish Hatchery 

City of Stevenson 

USDA, National Agricultural Library 

USDI, Office of Environmental Policy and 

Compliance 

County Weed Boards 

Municipal Water Boards 

Tribal Governments and Groups 

Chehalis Confederated Tribes 

Hoh Tribe 

Jamestown S’Klallam Tribe 

Lower Elwha S’Klallam Tribe 

Makah Tribe 

Port Gamble S’Klallam Tribe 

Quileute Tribe 

Quinault Nation 

Puyallup Tribal Council 

Shoalwater Bay Tribe 

Skokomish Tribe 

Squaxin Island Tribe 

Suquamish Tribe 

Nisqually Tribe 

Point No Point Treaty Council 

NW Indian Fisheries Commission 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

209

CHAPTER 5. REFERENCES, INDEX, ACRONYMS AND 

GLOSSARY 

5.1 References 

Adams, M.J. and R.B. Bury. 2002. The endemic headwater stream amphibians of the American Northwest: 

associations with environmental gradients in a large forested preserve. Global Ecology and Biogeography 

11:169-78. 

Allison, S.D., and P.M. Viousek. 2004. Rapid nutrient cycling in leaf litter from invasive plants in Hawai'i. 

Oecologia 141:612-9. 

Altman, B. 1999. Conservation Strategy for Landbirds in Coniferous Forests of Western Oregon and Washington. 

Altman, B. 2003. Olive-sided flycatcher Contopus cooperi. Pp. 374-376 In . D.B. Marshall, etl al, eds. Birds of 

Oregon. Corvallis, OR. Oregon State University Press. 752 pp. 

Anderson, J. D. 1968. Rhyacotriton and R. olympicus. Catalogue of American amphibians and reptiles. 68: 1-

68.2. 

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Wilke, T. 2004. Genetic and anatomical analyses of the jumping slugs: final report. Report submitted to: USDA 

Forest Service, Olympic National Forest, Olympia, WA. Contract # 43-05G2-1-10086. 

Wilkins, R. N., and N. P. Peterson. 2000. Factors related to amphibian occurrence and abundance in headwater 

streams draining second-growth Douglas-fir forests in Southwestern Washington. Forest Ecology and 

Management. 139: 79-91. 

Wojtaszek, BF, TM Buscarini, DT Chartrand, GR Stephenson, and DG Thompson. 2005. Effect of release 

herbicide on mortality, avoidance response, and growth of amphibian larvae in two forest wetlands. 

Environmental Toxicology and Chemistry 24(10):2533-2544. 

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. 
Final Environmental Impact Statement 

Beyond Prevention: Site-Specific Invasive Plant Treatment Project 

226

Wydoski, R. S., and R. R. Whitney. 1979. Inland fishes of Washington. Seattle, WA: University of Washington 

Press. 

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. 

Ziegltrum, Joan. Forest Ecologist, Olympic National Forest. 2005. [Personal communication with Cecile 

Shohet.] June 7. Portland, OR.: USDA Forest Service, Pacific Northwest Region. Proximity of any Species of 

Local Interest to proposed treatment areas. 

Ziegltrum, Joan. 2001. Olympic National Forest Monitoring Report: Survey and Manage Mollusks. Unpublished 

paper on file at: USDA Forest Service, Supervisor’s Office, Olympia, WA. 

5.2 Index 

Aquatic Influence Zone, 142, 158 

Biological Assessment, 107, 112 

Biological Control, 31, 94 

Herbicide Drift, 21, 22, 29, 99, 100, 101, 102, 103, 

104 

Herbicide Exposure Scenario, 63, 112, 114, 116, 

117, 123 

Herbicide Risk Assessments, 73, 112, 116, 117 

SOLI’s, 

Integrated Weed Management, 32 

Key Watersheds, 127 

Municipal watersheds, 125 

Notice of Intent, 16 

Olympic National Park, 9, 67, 68, 85, 86, 110, 190 

Prevention of Invasive Plants, i, 5, 6, 7, 11, 12, 13, 

31, 32, 61, 69, 95, 96, 97, 99, 142, 192, 237 

Quinalt Indian Nation, 68 

Species of Local Interest, 24, 64, 65, 88, 90, 91, 96, 

101, 102, 103, 104, 105, 106, 112, 189, 

Treatment Site Restoration, 5, 7, 11, 12, 13, 14, 23, 

27, 40, 44, 70, 94, 139, 146, 169, 196, 198, 199 

Riparian Reserves, 16, 59, 67, 133, 134, 151 

Treatment Strategies, 11, 12 

5.3 Acronyms 

a.i. – Active ingredient 

ACHP – Advisory Council on Historic Preservation 

APHIS – Agricultural Plant Health and Insect 

Service 

AQ – Aquatic 

ATSDR – Agency for Toxic Substances and 

Disease Registry 

ATV – All Terrain Vehicle

AWA – Administratively Withdrawn Areas

BCF – Bioconcentration factor 

BEE – Butoxyethyl Ester 

BIA – US Department of the Interior, Bureau of 

Indian Affairs 

BLM – US Department of the Interior, Bureau of 

Land Management 

BMP – Best Management Practices 

BPA – Bonneville Power Administration 

CAS – Chemical Abstract Service 

CBI – Confidential Business Information 

CE – Cumulative Effect 

CFR – Code of Federal Regulations 

CHU – Critical Habitat Unit 

CTWS – Confederate Tribes of Warm Springs 

CWA – Clean Water Act 

DEIS – Draft Environmental Impact Statement 

DEQ – Department of Environmental Quality 

DPS – Distinct Population Segment 

EDRR – Early Detection/ Rapid Response 

EA – Environmental Assessment 

EFH – Essential Fish Habitat

EIS – Environmental Impact Statement 

ESU – Evolutionary Significant Unit 

EO – Executive Order 

EPA – Environmental Protection Agency 

ESA – Endangered Species Act 

FDA – US Food and Drug Administration 

FEIS – Final Environmental Impact Statement 

FEMAT – Forest Ecosystem Management 

Assessment Team 

FHP – Forest Health Protection 

FIRFA – Federal Insecticide, Fungicide, and 

Rodenticide Act 
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FSH – USDA Forest Service Handbook 

FSM – Forest Service Manual 

FWS – Fish and Wildlife Service 

FY – Fiscal Year 

GIS – Geographic Information Systems 

GLEAMS – Groundwater Loading Effects of 

Agricultural Management 

GMA – General Management Area 

HQ – Hazard Quotient 

ICBEMP – Interior Columbia Basin Ecosystem 

Management Project 

IDT – Interdisciplinary Team 

IWM – Integrated Weed Management 

LFL – Likely to Cause a Trend to Federal Listing or 

Loss of Viability 

LOAEL – Lowest-Observed-Adverse-Effect Level 

LOC – Level of Concern 

LSR – Late-Successional Reserve 

MA-LAA – May Affect, Likely to Adversely Affect 

MA-NLAA – May Affect, Not Likely to Adversely 

Affect 

MI-NLFL – May Impact Individual, but Not Likely 

to Cause a Trend to Federal Listing 

or Loss of Viability 

MIS – Management Indicator Species 

MSDS – Materials Safety Data Sheet 

NAA – Not Adversely Affected 

NC – Nature Conservancy 

NE – No Effect 

NEPA – National Environmental Policy Act 

NFMA – National Forest Management Act 

NHPA – National Historic Preservation Act 

NI – No Impact 

NIS – Non-Ionic Surfactants 

NLAA – Not Likely to Adversely Affect 

NMFS – National Marine Fisheries Service 

NOAA – National Oceanic and Atmospheric 

Administration, US Department of Commerce 

NOEC – No Observable Effects Concentration 

NOAEL – No-Observed-Adverse-Effect Level

NOEL – No-Observed-Effect-Level 

NOI – Notice of Intent 

NPE – Nonylphenol Polyethoxylate 

NRF – Nesting, Roosting and Foraging Habitat 

NRIS – National Resource Information System 

NVUM – National Visitor Use Monitoring 

NWFP – Northwest Forest Plan 

ORV – Outstandingly Remarkable Values 

OSHA – Occupational Safety and Health 

Administration 

OSS – Oregon Slender salamander 

PAYCO – Payments to Counties 

PCE – Primary Constituent Elements 

PDFs – Project Design Features 

PIF – Partners in Flight 

POEA – Polyethoxylated Tallow Amine 

PPE – Personal Protective Equipment 

PVT – Potential Vegetation Type

RfD – Reference Dose 

R6 – USDA Forest Service, Pacific Northwest 

Region (Washington and Oregon) 

ROD – Record of Decision 

SERA – Syracuse Environmental Research 

Associates, Inc. 

SHPO – State Historic Preservation Office 

SMA – Special Management Area 

SRI – Soil Resource Inventory 

TCP – 3,5,6-Thrichloro-2-Pyridinol 

TEA – Triethylamine 

TES – Threatened, Endangered and Sensitive 

species 

USDA Forest Service – United States Department 

of Agriculture Forest Service 

USDI – United States Department of the Interior
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5.4 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 dependant 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. 

Adaptation - Changes in an organism's physiological structure or function or habits that allow it to survive in 

new surroundings. 

Adapted - How well organisms are physiologically or structurally suited for survival, growth, and resistance to 

pests and diseases in a particular environment. 

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. 

Administratively Withdrawn Areas (AWA) - Areas removed from the suitable timber base through agency 

direction and land management plans. 

Adsorption - The tendency of one chemical to adhere to another material such as soil. 

Aerobic - Life or processes that require, or are not destroyed by, the presence of oxygen. (See also, anaerobic.) 

Affected Environment - Existing biological, physical, social, and economic conditions of an area subject to 

change, both directly and indirectly, as the result of a proposed human action. 

Agent - Any substance, force, radiation, organism, or influence that affects the body. The effects may be 

beneficial or injurious. 

Agency for Toxic Substances and Disease Registry (ATSDR) - Federal agency within the Public Health 

Service charged with carrying out the health-related analyses under Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) and Superfund Amendments and Reauthorization Act (SARA). 

Alien species - “With respect to a particular ecosystem, any species, including its seeds, eggs, spores, or other 

biological material capable of propagating that species, that is not native to that ecosystem” (Executive Order 

13122, 2/3/99). (See also, invasive, noxious, and weed species.) 

Allelopathy - The suppression of growth of one plant species due to the release of toxic substances by another 

plant. 

Alluvial - Relating to clay, silt, sand, gravel, or similar detrital material deposited by flowing water. 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) intermediate in many characteristics between fishes and reptiles and having gilled aquatic larvae 

and air-breathing 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. 
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Annuity - Payment or receipt of a series of equal amounts at stated intervals for a specified number of time 

periods. An “annuity due” is a series of equal value outputs or inputs occurring for N equal time periods with 

“payments” made at the beginning of each period. 

Anoxia - Literally, "without oxygen.” A deficiency of oxygen reaching the tissues of the body especially of such 

severity as to result in permanent damage. 

Aquatic Influence Zone – The inner half of a Riparian Reserve.

Aqueous - Describes a water-based solution or suspension. 

Aquifer - An underground geological formation, or group of formations, containing usable amounts of 

groundwater that can supply wells and springs. 

Arid - A terrestrial region lacking moisture, or a climate in which the rainfall is not sufficient to support the 

growth of most vegetation. 

Background level - In pollution, the level of pollutants commonly present in ambient media (air, water, soil.) 

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. 

Basal application - In pesticides, the spreading of a chemical on stems or trunks of plants just above the soil 

line. 

Base - Substances that (usually) liberate hydroxyl (OH-) anions when dissolved in water and weaken a strong 

acid. 

Benchmark - A dose associated with a defined effect level or designated as a no effect level. 

Benthic region - The bottom layer of a body of water. 

Benthos - The plants and animals that inhabit the bottom layer of a water body. 

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.) 

Bioassay - (1) To measure the effect of a substance, factor, or condition using living organisms. (2) A test to 

determine the toxicity of an agent to an organism. 

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. 

Biodegradability - Susceptibility of a substance to decomposition by microorganisms; specifically, the rate at 

which compounds may be chemically broken down by bacteria and/or natural environmental factors. 

Biodiversity or biological diversity - The diversity of living things (species) and of life patterns and processes 

(ecosystem structures and functions). Includes genetic diversity, ecosystem diversity, landscape and regional 

diversity, and biosphere diversity. 

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. 

Biologically sensitive - A term used to identify a group of individuals who, because of their developmental stage 

or some other biological condition, are more susceptible than the general population to a chemical or biological 

agent in the environment. 

Biomass - The amount of living matter. 

Biota or Biome - All living organisms of a region or system. 

Body Burden - The amount of a chemical stored in the body at a given time, especially a potential toxin in the 

body as the result of exposure. 

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. 
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Buffer Zone - A strip of untreated land that separates a waterway or other environmentally sensitive area from 

an area being treated with pesticides. 

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. 

Capillary fringe - The zone above the water table within which the soil or rock is saturated by water under less 

than atmospheric pressure. 

Carcinogen - A chemical capable of inducing cancer. 

Carrier - A non-pesticidal substance added to a commercial pesticide formulation to make it easier to handle or 

apply. 

Chemical Abstracts Service (CAS) Registry Number - An assigned number used to identify a chemical. 

Chemical Abstracts Service is an organization that indexes information published in Chemical Abstracts by the 

American Chemical Society and that provides index guides to help locate information about particular substances 

in the abstracts. Sequentially assigned CAS numbers identify specific chemicals. The numbers have no chemical 

significance. The CAS number is a concise, unique means of chemical identification. 

Cations - Positively charged ions in a solution. (See also, anion.) 

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 - Treatment method; most effective after weed populations have been reduced by other 

control actions.

Congressionally Reserved Areas (CRA) - 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. 

Conifer - An order of the Gymnospermae, comprising a wide range of trees and a few shrubs, mostly evergreens 

that bear cones and have needle-shaped or scale-like leaves. Conifer timber is commercially identified as 

softwood. 

Connected actions - Exposure to other chemical and biological agents, in addition to exposure to a specific 

pesticide formulation in a field application to control pest organisms. 

Contaminants - For chemicals, impurities present in a commercial grade chemical. For biological agents, other 

agents that may be present in a commercial product. 

Control - Means, as appropriate, eradicating, suppressing, reducing, or managing invasive species populations, 

preventing spread of invasive species from areas where they are present, and taking steps such as restoration of 

native species and habitats to reduce the effects of invasive species and to prevent further invasions (Executive 
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231

Order 13122, 2/3/99). 

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. 

Discount - In economics, discounting is the process of carrying an end value backward in time at compound 

interest. 

Distance Zones - Landscape areas denoted by specified distances from the observer. Used as a frame of 

reference in which to discuss landscape attributes or the scenic effect of human activities in a landscape. 

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 Rate - In exposure assessment, dose per time unit (e.g. mg/day); also called dosage. 

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. 

Emergent Vegetation - Plants growing out of or standing in water, in contrast to “submerged aquatic vegetation 

(SAV),” which grows entirely underneath the waters’ surface. 

Endangered Species - Any species listed in the Federal Register as being in danger of extinction throughout all, 

or a significant portion, of its range. 

Endangered Species Act (ESA) - A law passed in 1973 to conserve species of wildlife and plants, determined 

by the Director of the U.S. Fish and Wildlife Service or the NOAA Fisheries to be endangered or threatened with 

extinction in all or a significant portion of its range. Among other measures, ESA requires all federal agencies to 

conserve these species and consult with the Fish and Wildlife Service or NOAA Fisheries on federal actions that 

may affect these species or their designated critical habitat. 

Endemic - A species or other taxonomic group that is restricted to a particular geographic region due to factors 

such as isolation or response to soil or climatic conditions. (Compare to “Indigenous” and “Native.”) 

Environmental justice - Executive Order 12898 of February 11, 1994 requires federal agencies, to the greatest 

extent practicable and permitted by law, to make achieving environmental justice part of its mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental 

effects of its programs, policies, and activities on minority populations and low-income populations in the United 

States and its territories and possessions, the District of Columbia, the Commonwealth of Puerto Rico, and the 

commonwealth of the Mariana Islands. 

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.) 

Extirpate - To destroy completely; wipe out. 

Extrapolation - The use of a model to make estimates of values of a variable in an 

unobserved interval from values within an already observed interval. 

Fauna - The animals of a specified region or time. 

Federally listed species - Formally listed as a threatened or endangered species under the Endangered Species 

Act. Designations are made by the Fish and Wildlife Service or the National Marine Fisheries Service. 

Federal Insecticide and Rodenticide Act (FIFRA) Pesticide Ingredient - An ingredient of a pesticide that 
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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, which could improve the success of desirable 

species; may be limited, depending on species/soil characteristics. 

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. 

Foaming - Hot foam is a mechanical method that is effective on seedlings and annuals and can be applied under 

certain weather conditions, including wind and light rain. 

Food chain - A hierarchical sequence of organisms, each of which feeds on the next, lower member of the 

sequence. 

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. 

Grazing animals - Treatment method which requires matching the invasive species with the appropriate grazer 

for best success. 

Groundwater Loading Effects of Agricultural Management Systems (GLEAMS) – A model which displays 

herbicide concentrations in streams under a variety of conditions. 

Groundwater - The supply of fresh water found beneath the Earth's surface, usually in aquifers, which often 

supply wells and springs. 

Habitat - The place where a population (e.g., human, animal, plant, microorganism) lives and its surroundings, 

both living and non-living. 

Halftime or 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. 

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. 

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 - 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) 
Final Environmental Impact Statement 

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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 - Commitment of a given area of land or a resource to one or more specific uses (e.g. 

wilderness). In the Northwest Forest Plan, one of the seven allocations of Congressionally Withdrawn Areas, 

Late-Successional Reserves, Adaptive Management Areas, Managed Late-Successional Areas, Administratively 

Withdrawn Areas, Riparian Reserves, or Matrix. 

Landscape - An area composed of interacting ecosystems that are repeated because of geology, land form, soils, 

climate, biota, and human influences throughout the area. Landscapes are generally of a size, shape, and pattern 

which is determined by interacting ecosystems. 

Landscape Character - Particular attributes, qualities, and traits of a landscape that give it an image and make it 

identifiable or unique. 

Landscape Setting - The context and environment in which a landscape is set; a landscape backdrop. It is the 

combination of land use, landform, and vegetation patterns that distinguish an area in appearance and character 

from other areas. 

Leachate - Water that collects chemicals as it trickles through soil or other porous media containing the 

chemicals. 

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. handpulling, 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, 
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weed whipping, hot foam.) 

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. 

Mitigation measures - Modifications of actions taken to: 

(1) avoid impacts by not taking a certain action or parts of an action; 

(2) minimize impacts by limiting the degree or magnitude of the action and its implementation; 

(3) rectify impacts by repairing, rehabilitating, or restoring the affected environment; 

(4) reduce or eliminate impacts over time by preservation and maintenance operations during the life of 

the action; or, 

(5) compensate for impacts by replacing or providing substitute resources or environments.

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. 

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% 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 
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native in that it maintains itself without further human intervention and has invaded native populations. 

Non-local native - This term has two meanings: (1) a population of a native plant species which does not occur 

naturally in the local ecosystem and/or (2) plant material of a native species that does not originate from 

genetically local sources. 

Non-target species - Any plant or animal that is not the intended organism to be controlled by a pesticide 

treatment. 

No-Observed-Adverse-Effect level (NOAEL) - Exposure level at which there are no statistically or biological 

significant differences in the frequency or severity of any adverse effect in the exposed or control populations. 

No-Observed-Effect-Level (NOEL) - Exposure level at which there are no statistically or biological significant 

differences in the frequency or severity of any effect in the exposed or control populations. 

Not Likely to Adversely Affect (NLAA) - Determinations are applied to those species that had very little habitat 

on National Forests in Region Six, were not in habitats susceptible to invasive plants, or were known to tolerate 

herbicide treatments without effects. 

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. ORV’s 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 - A plant species having a life span of more than two years. 

Periphyton - Microscopic plants and animals that are firmly attached to solid surfaces under water such as rocks, 

logs, pilings and other structures. 

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 pesticide mixers, loaders and 

applicators and re-entry workers, hazmat emergency responders, workers cleaning up Superfund sites, et. al., 

which is 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. 

Pesticide tolerance - The amount of pesticide residue allowed by law to remain in or on a harvested crop. 

pH - The negative log of the hydrogen ion concentration. A high pH (greater than seven) is alkaline or basic and 

a low pH (less than seven) is acidic. 

Population - A group of individuals of the same species in an area. 

Population at Risk - A population subgroup that is more likely to be exposed to a chemical, or is more sensitive 

to the chemical, than is the general population. 

Porosity - Degree to which soil, gravel, sediment, or rock is permeated with pores or cavities through which 

water or air can move. 

Potable Water - Water that is considered safe for drinking and cooking. 

Project Design Features/Features (PDC, PDF) - A set of implementation Design Features/features applied to 

projects 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. 
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Potential Vegetation Type (PVT) - The term Potential Vegetation Type is used to represent the combination of 

species that could occupy the site in the absence of disturbance. 

Protozoa - Single-celled, microorganisms without cell walls containing visibly evident nuclei and organelles. 

Most protozoa are free-living although many are parasitic. 

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. 

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 Reserves - Areas along live and intermittent streams, wetlands, ponds, lakes, and unstable and 

potentially unstable areas where riparian-dependent resources receive primary emphasis. Riparian Reserves are 

important to the terrestrial ecosystem as well, serving as dispersal habitat for certain terrestrial species. 

Risk Assessment - An analytic process that is firmly based on scientific considerations, but also requires 

judgments to be made when the available information is incomplete. These judgments inevitably draw on both 

scientific and policy considerations. 

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. 

Saturated zone - A subsurface area in which all pores and cracks are filled with water under pressure equal to or 

greater than that of the atmosphere. 

Scenery Management - The art and science of arranging, planning, and designing landscape attributes relative 

to the appearance of places and expanses in outdoor settings. 

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 Integrity - State of naturalness or, conversely, the state of disturbance created by human activities or 

alteration. Integrity is stated in degrees of deviation from the existing landscape character in a national forest. 

Scenic Quality - The essential attributes of landscape that when viewed by people, elicit psychological and 

physiological benefits to individuals and to society in general. 

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 - Species identified by the Regional Forester for which population variability is a concern, as 
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evidenced by significant current or predicted downward trend in population numbers or density; or significant 

current or predicted downward trends in habitat capability that would reduce a species existing distribution. 

Sensitivity Level - A particular degree or measure of viewer interest in the scenic qualities of the landscape. 

Species of Local Interest (SOLI) - Threatened, endangered and proposed species; Regional Forester’s Sensitive 

species, management indicator species, and other rare or endemic species of concern. 

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. 

Submerged Aquatic Vegetation (SAV) - Vegetation that lives at or below the water surface; an important 

habitat for young fish and other aquatic organisms. In contrast to “emergent vegetation,” which is growing out of 

or standing in water. 

Substrate - With reference to enzymes, the chemical that the enzyme acts upon. 

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. 

Survey and Manage - Mitigation measure adopted as a set of standards and guidelines within the Northwest 

Forest Plan Record of Decision and replaced with standards and guidelines in 2001 (Record of Decision) 

intended to mitigate impacts of land management efforts on those species that are closely associated with LateSuccessional or old-growth forests whose long-term persistence is a concern. This mitigation measure applies to 

all land allocations and requires land managers to take certain actions relative to species of plants and animals, 

particularly some amphibians, bryophytes, lichens, mollusks, vascular plants, fungi, and arthropods, which are 

rare or about which little is known. These actions include: (1) manage known sites; (2) survey prior to habitatdisturbing activities; and, (3) conduct extensive and general regional (strategic) surveys. 

Synergistic effect - Situation in which the combined effects of exposure to two chemicals simultaneously is 

much greater than the sum of the effect of exposure to each chemical given alone. 

Take - "The term 'take' means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to 

attempt to engage in any such conduct." (Title 16, Chapter 35, Section 1532, Endangered Species Act of 1973) 

Threatened species - Plant or animal species likely to become endangered throughout all, or a significant 

portion of, its range within the foreseeable future. A plant or animal identified and defined in accordance with the 

1973 Endangered Species Act and published in the Federal Register. 

Threshold - 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. 
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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 Area - An infested area where weeds have been treated or retreated by an acceptable method for the 

specific objective of controlling their spread or reducing their density. 

U.S. Fish and Wildlife Service (US FWS) - The federal agency that is the listing authority for species other than 

marine mammals and anadromous fish under the ESA. 

U.S. Forest Service (USDA FS or USFS) - The federal agency responsible for management of the nation’s 

National Forest lands. 

Variety Class - A particular level of visual variety or diversity of landscape character.

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 Absorption Capability - A classification system used to denote relative ability of a landscape to accept 

human alterations without loss of character of scenic quality. 

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.