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CONTROL of SMOOTH CORDGRASS (SPARTINA

 ALTERNIFLORA) on WILLAPA NATIONAL WILDLIFE

REFUGE

ENVIRONMENTAL ASSESSMENT

WILLAPA BAY

PACIFIC COUNTY

 WASHINGTON

PREPARED BY

DEPARTMENT OF THE INTERIOR

U.S. FISH AND WILDLIFE SERVICE

WILLAPA NATIONAL WILDLIFE REFUGE

HC 01 Box 910

ILWACO, WA 98624

May 1997

TABLE OF CONTENTS
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1.0 INTRODUCTION: PURPOSE AND NEED FOR ACTION................................................1

1.1 PROPOSAL .............................................................................................................1

1.2 PURPOSE AND NEED ...........................................................................................3

1.3 RELATIONSHIP TO OTHER ENVIRONMENTAL ASSESSMENTS/IMPACT

STATEMENTS...................................................................................................8

1.4 SCOPING AND SIGNIFICANT ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

1.4.1 Physical Resources................................................................................... 11

1.4.2 Biological Resources................................................................................ 12

1.4.3 Social Resources...................................................................................... 13

1.4.4 Economic Resources................................................................................ 13

1.5 PERMITS AND CONSULTATION....................................................................... 14

1.6 SUBSEQUENT CHAPTERS OF THIS EA............................................................ 14

2.0 ALTERNATIVES

2.1 INTRODUCTION.................................................................................................. 15

2.2 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED

STUDY ............................................................................................................. 15

2.2.1 Physical/Mechanical ................................................................................. 15

2.2.2 Chemical .................................................................................................. 18

2.2.3 Biological................................................................................................. 18

2.3 ALTERNATIVES INCLUDING NO ACTION AND THE PROPOSED ACTION 18

2.3.1 No Action ................................................................................................ 20

2.3.2 Integrated Pest Management (Proposed Action)....................................... 21

2.3.3 Physical/Mechanical Control..................................................................... 25

2.3.4 Chemical Means Only............................................................................... 27

2.4 SUMMARY COMPARISON OF ENVIRONMENTAL CONSEQUENCES.......... 29

3.0 AFFECTED ENVIRONMENT.......................................................................................... 34

3.1 INTRODUCTION.................................................................................................. 34

3.2 PHYSICAL ENVIRONMENT............................................................................... 34

3.2.1 Location................................................................................................... 34

3.2.2 Soils and Topography............................................................................... 35

3.2.3 Hydrology................................................................................................ 36

3.2.4 Water Quality........................................................................................... 36

3.2.5 Tides........................................................................................................ 37

3.2.6 Estuarine Functions.................................................................................. 37

3.2.7 Wetlands.................................................................................................. 38

3.2.8 Research Natural Areas............................................................................ 38

3.2.9 Climate..................................................................................................... 38

3.2.10 Air Quality .............................................................................................. 39

3.2.11 Visual Resources..................................................................................... 39

3.2.12 Ambient Sound........................................................................................ 39

3.2.13 Infrastructure .......................................................................................... 40

3.3 BIOLOGICAL ENVIRONMENT .......................................................................... 40

3.3.1 Vegetation ............................................................................................... 40

3.3.1.1 Seagrass (Zostra spp.) Community.............................................. 40
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3.3.1.2 Native Saltmarsh Vegetation....................................................... 41

3.3.1.3 Exotic Spartina Marsh................................................................ 41

3.3.2 Wildlife .................................................................................................... 44

3.3.2.1 Aquatic Migratory Birds............................................................. 44

3.3.2.2 Mammals.................................................................................... 45

3.3.2.3 Threatened and Endangered Species ........................................... 45

3.3.2.4 Other Species of Special Concern ............................................... 46

3.3.3 Fish .......................................................................................................... 47

3.3.4 Micro-Organisms and Other Marine Invertebrates .................................... 48

3.3.5 Biodiversity.............................................................................................. 49

3.4 SOCIAL ENVIRONMENT.................................................................................... 49

3.4.1 Cultural.................................................................................................... 49

3.4.2 Social....................................................................................................... 50

3.4.2.1 Human Health............................................................................. 50

3.4.2.2 Concerns .................................................................................... 51

3.4.2.3 Recreation .................................................................................. 51

3.5 ECONOMIC ENVIRONMENT............................................................................. 52

3.5.1 Tourism ................................................................................................... 53

3.5.2 Mariculture and Fisheries.......................................................................... 53

4.0 ENVIRONMENTAL CONSEQUENCES.......................................................................... 54

4.1 INTRODUCTION.................................................................................................. 54

4.2 EFFECTS OF NO ACTION ALTERNATIVE ....................................................... 54

4.2.1 Physical Environment ............................................................................... 54

4.2.1.1 Soils and Topography ................................................................. 54

4.2.1.2 Hydrology .................................................................................. 55

4.2.1.3 Water Quality ............................................................................. 55

4.2.1.4 Ambient Sound........................................................................... 55

4.2.1.5 Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .55

4.2.2 Biological Environment............................................................................ 56

4.2.2.1 Vegetation .................................................................................. 56

4.2.2.2 Spartina...................................................................................... 56

4.2.2.3 Wildlife....................................................................................... 57

4.2.2.4 Fish............................................................................................. 58

4.2.2.5 Microbes and Marine Invertebrates............................................. 59

4.2.2.6 Biodiversity ................................................................................ 60

4.2.3 Social Environment .................................................................................. 60

4.2.3.1 Human Health............................................................................. 60

4.2.3.2 Concerns .................................................................................... 60

4.2.3.3 Recreation .................................................................................. 60

4.2.4 Economic Environment ............................................................................ 61

4.2.4.1 Tourism...................................................................................... 61

4.2.4.2 Mariculture and Fisheries............................................................ 61

4.3 EFFECTS OF INTEGRATED PEST MANAGEMENT ALTERNATIVE

(IPM)(PROPOSED ACTION)........................................................................... 62

4.3.1 Physical Environment ............................................................................... 62

4.3.1.1 Soils and Topography ................................................................. 62
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4.3.1.2 Hydrology .................................................................................. 65

4.3.1.3 Water Quality ............................................................................. 65

4.3.1.4 Ambient Sound........................................................................... 67

4.3.1.5 Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .67

4.3.2 Biological Environment............................................................................ 68

4.3.2.1 Vegetation .................................................................................. 68

4.3.2.2 Spartina...................................................................................... 69

4.3.2.3 Wildlife....................................................................................... 70

4.3.2.4 Fish............................................................................................. 72

4.3.2.5 Microbes and Marine Invertebrates............................................. 74

4.3.2.6 Biodiversity ................................................................................ 76

4.3.3 Social Environment .................................................................................. 76

4.3.3.1 Human Health............................................................................. 76

4.3.3.2 Concerns .................................................................................... 77

4.3.3.3 Recreation .................................................................................. 78

4.3.4. Economic Environment ............................................................................ 79

4.3.4.1 Tourism...................................................................................... 79

4.3.4.2 Mariculture and Fisheries............................................................ 79

4.4 EFFECTS OF PHYSICAL/MECHANICAL MEANS ONLY ALTERNATIVE . .

.794.4.1 Physical Environment .......................................................................... 79

4.4.1.1 Soils and Topography ................................................................. 80

4.4.1.2 Hydrology .................................................................................. 80

4.4.1.3 Water Quality ............................................................................. 80

4.4.1.4 Ambient Sound........................................................................... 81

4.4.1.5 Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .81

4.4.2 Biological Environment............................................................................ 81

4.4.2.1 Vegetation .................................................................................. 81

4.4.2.2 Spartina...................................................................................... 82

4.4.2.3 Wildlife....................................................................................... 82

4.4.2.4 Fish............................................................................................. 83

4.4.2.5 Microbes and Marine Invertebrates............................................. 83

4.4.2.6 Biodiversity ................................................................................ 84

4.4.3 Social Environment .................................................................................. 84

4.4.3.1 Human Health............................................................................. 84

4.4.3.2 Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .84

4.4.3.3 Recreation .................................................................................. 84

4.4.4 Economic Environment ............................................................................ 85

4.4.4.1 Tourism...................................................................................... 85

4.4.4.2 Mariculture and Fisheries............................................................ 85

4.5 EFFECTS OF CHEMICAL MEANS ONLY ALTERNATIVE .............................. 85

4.5.1 Physical Environment ............................................................................... 85

4.5.1.1 Soils and Topography ................................................................. 85

4.5.1.2 Hydrology .................................................................................. 88

4.5.1.3 Water Quality ............................................................................. 88

4.5.1.4 Ambient Sound........................................................................... 90

4.5.1.5 Air Quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .90
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4.5.2 Biological Environment............................................................................ 90

4.5.2.1 Vegetation .................................................................................. 90

4.5.2.2 Spartina...................................................................................... 91

4.5.2.3 Wildlife....................................................................................... 92

4.5.2.4 Fish............................................................................................. 94

4.5.2.5 Microbes and Marine Invertebrates............................................. 95

4.5.2.6 Biodiversity ................................................................................ 97

4.5.3 Social Environment .................................................................................. 97

4.5.3.1 Human Health............................................................................. 97

4.5.3.2 Concerns .................................................................................... 98

4.5.3.3 Recreation .................................................................................. 98

4.5.4 Economic Environment ............................................................................ 98

4.5.4.1 Tourism...................................................................................... 98

4.5.4.2 Mariculture and Fisheries............................................................ 98

4.6 CUMULATIVE EFFECTS .................................................................................... 99

4.6.1 No Action ................................................................................................ 99

4.6.2 All Action Alternatives............................................................................. 99

4.7 UNAVOIDABLE ADVERSE EFFECTS ............................................................. 100

4.7.1 No Action .............................................................................................. 100

4.7.2 All Action Alternatives........................................................................... 100

4.8 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENT OF RESOURCES ... 100

5.0 CREDITS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .101

6.0 LISTS OF AGENCIES AND PERSONS RECEIVING NOTICE OF AVAILABILITY. .103

GLOSSARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .107

REFERENCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .111

APPENDIX
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TABLES

1 Estimated Acreage of Spartina on Refuge Tidelands . . . . . . . . . . . . . . . . . . . . . . . . . . .21

2A. Alternative Consequences Matrix - Physical Resources. . . . . . . . . . . . . . . . . . . . . . . . . .30

2B. Alternative Consequences Matrix - Biological Resources . . . . . . . . . . . . . . . . . . . . . . . .31

2C. Alternative Consequences Matrix - Social Environment. . . . . . . . . . . . . . . . . . . . . . . . . .32

2D. Alternative Consequences Matrix - Economic Environment. . . . . . . . . . . . . . . . . . . . . . .33

3. Average Annual Number of Waterfowl Use Days 1988-1992 . . . . . . . . . . . . . . . . . . . . .45

4. Species and Numbers of Fish Caught in Southern Portion

of Willapa Bay, March 1990 through February 1991 . . . . . . . . . . . . . . . . . . . . . . . . . . .48

FIGURES

1. Project Area Location Map - Willapa National Wildlife Refuge . . . . . . . . . . . . . . . . . . . 2

2. Refuge Tidelands of the Southern Units. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3. Refuge Tidelands Associated with Long Island . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
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References in this Environmental Assessment (EA) to trademarked products are included for

information purposes only and do not imply endorsement by the U.S. Fish and Wildlife Service.

In April 1996, the Service prepared the Interim Environmental Assessment for Control of

Smooth Cordgrass (Spartina alterniflora) on Willapa National Wildlife Refuge in 1996. 

This document is a more comprehensive EA that addresses Spartina control beyond 1996.
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1.0 INTRODUCTION: PURPOSE AND NEED FOR ACTION

1.1 PROPOSAL

The Fish and Wildlife Service, Department of the Interior, proposes to implement a longterm integrated pest management (IPM) program to control and reverse the invasion of

the non-native grass, Spartina alterniflora (Spartina) on Willapa National Wildlife Refuge

and the surrounding tidelands of Willapa Bay. Off-refuge control would be conducted

under cooperative agreements. Lands considered for treatment in this document include

those within the Willapa Bay Watershed on which any Spartina species is impacting

migratory bird habitat (Figure 1). This currently is confined to tidally influenced wetlands

on Willapa Bay, but could potentially extend up tributaries of the bay. A sudden increase

in the spread of Spartina over Willapa Bay in recent years has made it necessary to

develop long-term plans to restore and maintain valuable and limited tideland habitat that

is being converted by this non-native grass.

The integrated pest management program proposed for Spartina management by the

Refuge includes the use of all methods approved by State and Federal regulations. These

methods currently are limited to physical and chemical means and/or combinations thereof,

but may expand to new methods such as biological control in the future. Methods would

be chosen and applied on a site-specific basis. The intent would be to conduct control

operations in the safest and most efficient, effective, and environmentally sound manner.

Specific elements of the proposed IPM approach that are currently approved by State and

Federal regulation are:

- Hand pulling of individual plants (seedlings) with upland disposal,

- Pushing seedlings deep into the mud,

- Repeated mowing of small to large clones using hand-held brushcutters or

larger, self-propelled mowers,

- Hand spraying and wiping with Rodeo® (glyphosate) herbicide and an

approved surfactant,

- Aerial application of Rodeo® (glyphosate) herbicide and an approved surfactant, and

- Mowing followed by herbicide application.

Generally, the refuge mudflats are very soft and easily damaged by foot, tracked, and

wheeled traffic. Therefore, access for ground operations would rely on airboats,

hovercraft, boats, and/or walking with special floatation footwear where necessary. Selfpropelled tracked or wheeled equipment may be used on the refuge to treat Spartina

meadows because the dense root mass can support higher ground pressure equipment.

However, such equipment is commonly used on firmer substrates for Spartina control and

shellfish management activities on other tidelands of the bay and may be used in

cooperative control efforts.

Integrated pest management is an adaptive process. An important component of the
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program would be to develop more effective treatment methods while maintaining or

improving safety, and reducing costs and time for control. As new control techniques are

developed in the future, they would be evaluated for impacts to non-target organisms and

efficacy, and then if determined to be safe, incorporated into the IPM program. Such

techniques that may become part of the IPM program in the future under this alternative

include:

- Use of biological control techniques such as introduction of insects, other

invertebrates, or pathogens that affect Spartina survival, growth, or reproduction,

- Mowing with waterborne equipment, and

- Use of other herbicides and/or surfactants once approved by the Environmental

Protection Agency and Department of Ecology for use in the estuary.

- Use of machinery that removes Spartina, including its roots from the substrate.

Generally, Spartina control efforts would be prioritized, by tideland ownership, as follows:

1. Independent and cooperative control on fee title Federal lands associated

with the Lewis, Porters Point, Riekkola, and Long Island Units (Figures 1

and 2).

2. Cooperative control on State-owned tidelands around Long Island,

commonly known as use deed lands, on which the Service has certain

management responsibilities (Figure 3).

3. Cooperative control on private and State-owned tidelands immediately

adjacent to lands described above.

4. Cooperative control on other tidelands in Willapa Bay.

The strategy for controlling Spartina on a particular treatment area would begin by

targeting plants furthest out in the tidelands and clones that are expected to be major seed

producers. Then, effort would proceed landward toward larger, more-established clones

and meadows. The initial objective would be to halt the rapid spread of Spartina into new

areas. The ultimate goal would be to eradicate Spartina from each treatment area.

1.2 PURPOSE AND NEED

Spartina is a perennial, deep-rooted saltmarsh species native to the Atlantic and Gulf

coasts of North America. It was introduced to the West Coast during the 1890s as a

result of its use as packing material for oyster shipments from the East Coast (Frenkel and

Kunze 1984). On the West Coast, Spartina ranges from British Columbia to northern

California, but the infestation is increasing most rapidly in Washington, particularly

Willapa Bay (Frenkel and Kunze 1984). In 1991, there were approximately 2,500 acres of

Spartina in Willapa Bay, and the infestation is expected to occupy over 30,000 acres

within 45 years (Sayce 1988, Harrington and Harrington 1993).

Spartina is spreading rapidly over tidelands of the Refuge and Willapa Bay, and it is

degrading habitats that support a diverse community of estuarine organisms including

aquatic migratory birds and anadromous fish, and the invertebrate and plant communities

that support them. Widespread colonization by Spartina induces major modifications of

physical, hydrological, chemical, and biological estuarine functions. Spartina displaces
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eelgrass (Zostera spp.) on mudflats and native vegetation in saltmarshes. Benthic

invertebrate species composition in the intertidal zone changes substantially as Spartina

occupies the tidelands (Atkinson 1992, Norman and Patton 1995, Ratchford 1995,

Zipperer 1996b). In New Zealand, Spartina has altered the natural flows of rivers and

tidal channels by trapping sediment, raising flood plains, and restricting waterways (Asher

1990). As Spartina becomes dominant in the tideland, mudflats are raised and channels

are deepened. This in turn eliminates the gently sloping bare intertidal zone that lies

between the saltmarsh and the tidal channels (Aberle 1993).

The Spartina invasion in Willapa Bay is the largest in Washington. The magnitude of this

invasion has fostered a considerable amount of study into the ecological implications of

associated changes to mudflats, eelgrass beds and saltmarshes, fish and wildlife uses of

these habitats, and into effective ways to control it. While research continues, there is

evidence at this point in time to indicate that:

1.) No action would allow continued habitat degradation for shorebirds, brant, and

other waterbirds;

2.) No action would have greater, irreversible effects on the ecosystem than

reasonably applied control measures;

3.) Spartina is spreading at an ever-increasing rate; and
34

4.) Delays in initiating control measures result in geometric increases in impacts and

control costs.

The invasion of Spartina in tidal mudflats and salt marshes has been recognized as a

serious threat to migratory bird use in the bay for over a decade (U.S. Fish and Wildlife

Service 1985). The rapid increase in the rate of spread during this period may be related

to El Niño events, adaptation of the grass to this climate, or a combination of both factors.

 Regardless, the geologic youth of Willapa Bay with its characteristically large expanses of

tidally-exposed mudflats, provides fertile ground for the expansion of Spartina.

Spartina may colonize several substrates (sand, silt, clay, loose cobble, or gravel) where

salinity ranges from 1-35 parts per thousand (Kunze and Cornelius 1982, Landin 1991). 

In Willapa Bay, Spartina is found in all but the lowest intertidal zone. Spartina

propagates by seeds and rhizomes that spread from a vigorous root system (Landin 1990).

 As rhizomes intermingle, clonal circular patches ultimately grow together to form dense

monotypic meadows that entrap sediments, physically raising the elevation of the

tidelands. Sayce (1988) measured up to 0.8 inches of sediment deposition per meter of

clone diameter in a single year. 

The intertidal mudflats displaced by Spartina are particularly valuable habitat for

migratory birds, juvenile fishes, eelgrass, and clams (Proctor et al. 1980). Such areas on

the Refuge have annually provided important feeding habitat for over 20,000 migrating

ducks, tens of thousands of shorebirds, and 3,000 migrating geese at a time. The Refuge

tidelands that are vulnerable to Spartina invasion are essential to sustaining the estimated

2.2 million duck, 400,000 Canada goose, 200,000 brant, and over 2 million shorebird usedays associated with the southern half of Willapa Bay. At the current rate of invasion, the

Refuge mudflats are expected to be eliminated by Spartina within ten years.

The Refuge was established by Executive Order No. 7541 in 1937 as a migratory bird

refuge. Refuge purposes established though the Executive Order and legislation are:

"...as a refuge and breeding ground for migratory birds and other wildlife:..."

Executive Order 7541, dated January 22, 1937

"...for use as an inviolate sanctuary, or for any other management purpose, for

migratory birds." 16 U.S.C. 715d (Migratory Bird Conservation Act)

"...suitable for-- (1) incidental fish and wildlife-oriented recreation development,

(2) the protection of natural resources, (3) the conservation of endangered

species..." 16 U.S.C. 460k-l (Refuge Recreation Act)

"...the conservation of the wetlands of the Nation in order to maintain the public

benefits they provide and to help fulfill international obligations contained in

various migratory bird treaties and conventions..." 16 U.S.C. 390(b), 100 Stat.

3583 (Emergency Wetlands Resources Act of 1986)
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Refuge goals are:

(1) To protect and restore tideland habitat and associated migratory aquatic bird

species representative of the native biological diversity of Willapa Bay.

(2) To preserve and protect unique ecosystems associated with Willapa Bay.

(3) To manage for the conservation and recovery of threatened and endangered animal

species in their natural ecosystems.

(4) To provide opportunities for wildlife/wildlands-dependent recreation, education,

and research.

The continued spread of Spartina does not contribute to the purposes or the goals of the

refuge. The purpose of the proposed action is to restore and retain valuable tideland

habitats for migratory birds, and other fish and wildlife species while stopping the loss of

public use values.

The Lewis, Porter Point, and Riekkola units (collectively known as the southern units and

shown in Figure 2) support important habitat for meeting Refuge objectives. In these

three units the Service has fee-simple title to over 2,900 acres of tidelands supporting

saltmarsh and mudflat habitat. Other refuge-associated tidelands include about 1,600

acres of State-owned Use Deed Lands and 200 acres of fee-simple tidelands adjacent to

Long Island (Figure 3). Waterbird habitat value is being rapidly lost in both areas by

Spartina invasions. The proposed action supports Refuge objectives by protecting and

restoring aquatic bird habitat on these areas through independent and cooperative action,

and by controlling Spartina expansion from other tidelands of the bay through cooperative

efforts.

1.3 RELATIONSHIPS TO OTHER ENVIRONMENTAL ASSESSMENTS/IMPACT

STATEMENTS

Controlling the spread of the introduced Spartina has also become an issue with local and

State governments, tribal and private land managers, and users. The Washington

departments of Agriculture, Ecology, Fisheries, Natural Resources, and Wildlife; and the

Washington State Noxious Weed Board prepared the Noxious Emergent Plant

Management Environmental Impact Statement (State's EIS), which addressed this issue in

coastal bays and estuaries. The proposed action described in this document was IPM

which focuses on the coordinated use of multiple biological, mechanical/physical, and

chemical treatment methods to control, contain, reduce, and/or eradicate noxious plant

species. The final State EIS was released in November 1993. Copies of this EIS are

available at local libraries, the Pacific County Noxious Weed Control Board Office, the

Washington Department of Fish and Wildlife Shellfish Laboratory at Nahcotta, the

Washington State University Cooperative Extension Cranberry Research Station at Long

Beach, and Willapa National Wildlife Refuge Headquarters.

The State's EIS also evaluated No Action and exclusive use of mechanical, physical,

biological or chemical methods for controlling emergent noxious weeds throughout the

State.
36

In 1994, the Service produced a management plan and EA proposing IPM for control of

Spartina on Refuge tidelands. The preferred alternative included physical measures as

well as hand and helicopter application of Rodeo® (glyphosate) with an approved

surfactant. The Service also joined Pacific County and the Washington Department of

Natural Resources and Department of Fisheries (now part of the Department of Fish and

Wildlife) in applying for Shoreline Management Substantial Development permits and

Short-term Modifications to State Water Quality Standards in order to use IPM

procedures to control Spartina in Willapa Bay. Permits were granted but were

subsequently appealed. The appeals were aimed at preventing the proposed use of

herbicides in Willapa Bay. In late 1994, the Service withdrew its permit applications and

decided to develop separate NEPA documents addressing interim and long-term Spartina

management programs.

In early 1996, the Service prepared the Interim Environmental Assessment for Control of

Smooth Cordgrass (Spartina alterniflora) on Willapa National Wildlife Refuge in 1996

(Interim EA). The interim EA addressed control on refuge-owned tideland, and was

limited to a single season. However, much of the information presented in that document

applies to this more comprehensive EA. Consequently, this EA builds upon text taken

from the Interim EA.

This EA differs from the Interim EA in the following ways:

- Geographic area

This EA discusses measures proposed to be used by the Service for direct control

of Spartina on the Refuge and for cooperative efforts with others on control

projects on public and private lands throughout Willapa Bay and its tributaries. 

The Interim EA was limited to Spartina control on the southern units and State

lands adjacent to the Refuge. Cooperative efforts will involve sharing personnel,

equipment, and materials to facilitate control work on areas of mutual interest on

the bay. Partners may include private, tribal, State, and County interests. The

Service has reviewed the State's EIS, and has found that it adequately addresses

alternatives, environmental effects, and other National Environmental Policy Act

(NEPA)-relevant issues. For Service assistance with proposed cooperative efforts

in implementing State plans on lands off-refuge, the Service adopts and

incorporates the State's EIS by reference.

- Time period

This EA addresses Spartina control beginning in 1997 and continuing into the

future as needed. The Interim EA addressed a rapid expansion of Spartina on the

Refuge that required immediate action in 1996.

- Control techniques

This EA addresses a broader range of techniques, including aerial herbicide

application, use of larger machinery, and biological control. The Interim EA

focused primarily of the control of newly established clones using hand-held brush

cutters and ground-based herbicide application.
37

1.4 SCOPING AND SIGNIFICANT ISSUES

Control of Spartina is a baywide concern. The spread of this grass and control measures

are of interest to everyone concerned about the present and future ecology and

productivity of Willapa Bay. It is of special concern to those managing tidal flats of

Willapa Bay as waterbird habitat or for shellfish production.

In 1995, The Washington State Legislature passed legislation to address the lack of

progress being made by agencies responsible for controlling Spartina in the State. The

legislation recognized the threat of Spartina, and simplified the permit process for

agencies and private individuals attempting to implement control.

The Willapa Bay Water Resources Coordinating Council has maintained that the threat

posed by Spartina is of "devastating proportion". It has further stated in a letter to the

Washington State Department of Agriculture (March 12, 1996), "In passing emergency

legislation the Washington Legislature unambiguously recognized the enormous threat

Spartina poses to the State's marine resources, its communities and its economy. In no

small part the legislature was responding very forcefully to widespread frustration with the

unsatisfactory slow response to this threat by the responsible agencies".

The Willapa Alliance is an independent, nonprofit organization dedicated to developing

and implementing strategies for sustainable, conservation-based economic development in

the Willapa ecosystem. It is composed of local residents, landowners, and a representative

for the Shoalwater Bay Indian Tribe. Willapa Alliance Resolution number 95-1 is entitled,

"A resolution declaring the uncontrolled spread of Spartina in Willapa Bay, Washington

State, and British Columbia an ecological and economic disaster and supporting the

immediate implementation of Spartina management control and eradication programs as

described by the IPM strategy based upon the findings of the EIS plan to control and

eradicate Spartina". The resolution requests that the State, Federal, and local agencies do

everything in their means to support the intent of this resolution.

Pacific County, through a task force committee, prepared the Spartina Management

Program: Integrated Weed Management for Private and Public Lands in Willapa Bay,

Pacific County, Washington in February 1994 (Updated February 1996). The committee

consisted of interested public, conservation groups, tribal, and county, State, and Federal

agency representatives. This document serves as a plan for management of Spartina for all

tideland owners in Willapa Bay. The objectives of the program in the short term is contain

and control Spartina by stopping both seed set and vegetative spread. In the long term,

eradication is considered. The plan built on information and proposed actions covered in

the State EIS.

The scope of this EA is based on that of the State EIS, and issues that have been raised by

the Pacific County Spartina Task Force, public involvement associated with the Interim

EA, and various public meetings dealing with permit applications, water quality, and the

need to initiate aggressive control of Spartina. 
38

Formal scoping meetings for this EA were conducted on January 6, 1997 at the Raymond

Community Center in Raymond, Washington and on January 7, 1997 at the Peninsula

Church Center in Seaview, Washington. A record of comments recorded at these

meetings is available at the Willapa NWR office.

Issues and alternatives discussed in this document are those that have been brought

forward by both local and regional interests through several years of interagency and

public involvement, and the formal scoping meetings conducted in January of 1997. They

are briefly discussed below in terms of the potential effects of activities associated with

both action and no action alternatives on the physical, biological, social, and economic

resources of the bay.

1.4.1 Physical Resources

Impacts on Sediment Erosion and Deposition

Natural processes of substrate erosion and deposition within the bay would be affected by

action and no action alternatives. If Spartina is left to expand unchecked, it will entrap

sediment rapidly and raise the tidelands, eventually eliminating much of the topographic

relief that is so essential to maintaining the existing diversity of the bay. Offsite, land use

practices that increase erosion also contribute to sediment accumulation in the bay. 

Action alternatives that result in effective control of Spartina would release, through

erosion, some of the sediment that has been trapped over the years. 

Changes in Bay Hydrology

Water movement through the estuary is affected by the topography of the tidelands. As

stated previously, Spartina changes the topographic relief of these tidelands. The tall

dense growth habit of Spartina also impedes water movement. These influences

altogether are expected to slow runoff and water exchange with the ocean over time if

Spartina is not controlled.

Impact on Water Quality

Water quality has been identified as a critical issue in addressing the Spartina problem in

Willapa Bay. The Ad Hoc Coalition for Willapa Bay and Friends of the Earth have

vigorously opposed the application of any herbicide in Willapa Bay. These groups and the

Shoalwater Indian Tribe appealed the Shoreline and Short-term Water Quality permits in

1994, in part, based on their concerns regarding potential water quality impacts of

herbicide use. Concerns have been expressed that treatment of Spartina with herbicide

will disrupt healthy biological processes within the bay and possibly affect human health.

Due to Spartina's capacity to trap sediments that would otherwise move out of the bay,

concern has been expressed that contaminants from roadways, communities, and other

upland sources may be contained within these sediments and would therefore be released

if Spartina were effectively controlled.

Impact on Air Quality

Concern about aerial drift of chemicals used to control Spartina has been expressed. 

These concerns are primarily focussed on potential impacts to human health, but potential
39

effects on gardens and ornamental vegetation have also been mentioned.

1.4.2 Biological Resources

Impacts to Vegetation

The native vegetation of the bay is being displaced by Spartina at a very rapid rate. 

Without control, it is expected that all of the mudflat vegetation (mainly eelgrass), and

much of the saltmarsh vegetation will be displaced and converted to monotypic Spartina

meadows. Control measures for Spartina would unintentionally impact some nontarget

vegetation.

Impacts to Wildlife

Wildlife, particularly migratory aquatic birds, depend on the mix of habitats within the

intertidal area of the bay to provide feeding and resting areas. This is of particular

importance during migration. The Refuge was established specifically to protect the

resources that support migratory birds. It is expected that if Spartina is not controlled,

most of the high-quality migratory bird feeding habitat will be lost. The potential for

various alternatives to affect wildlife resources, including threatened and endangered

species, will also be addressed in this document.

Impacts to Fish

As with wildlife species, Spartina is changing habitat for fish species. Ultimately, Spartina

will convert usable intertidal habitat to high meadow, available to fish only during the

highest tides. Furthermore, Willapa's fish resources have adapted to the diverse intertidal

zones, and the flora and fauna associated with them. There is concern that the more

biologically simple Spartina meadows would negatively impact fish. There are also

concerns that action alternatives could negatively impact fish. The primary concern here is

that chemicals used to kill Spartina might impact or compromise fish health.

Impacts to Invertebrates

Related to all other biological issues are the concerns about potential impacts of

uncontrolled Spartina growth, as well as the action alternatives, on invertebrates on the

tidelands. The vast array of worms, arthropods and mollusks found on the tidelands is a

key component of the estuary's food web which supports the fish and wildlife resources

that are directly valued by people. Concerns include, again, the reduction in biodiversity

(numbers of invertebrate species) associated with Spartina domination and the potential

for impacts to invertebrates from the action alternatives.

1.4.3 Social Resources

Impacts to Public Use

An issue that has arisen concerning Spartina is centered around its effect on public access

and recreation on the bay. Spartina's rapid take-over of the upper mudflat in many areas

has made boat access to and from the shore difficult except during the highest tides. Some

have expressed concern that bird watching opportunities have been limited in areas where

broad meadows have developed along shorelines. Recreational boating, shellfish

gathering, and hunting have also been affected by the expansion of Spartina on the Refuge

and on the bay in general. To be addressed also, is the anticipated impacts of control
40

alternatives on these human activities.

Impacts to Human Health

There are concerns that the use of chemicals to control Spartina could affect human

health. Specifically, the concern is that these chemicals or their byproducts would persist

or bioaccumulate in the food web and find their way into finfish, shellfish, or wildlife used

for human food. A concern has also been raised about the potential for offsite effects on

chemically sensitive people due to airborne drift of sprayed chemicals. The fate,

persistence, and potential for impacts on human health will be addressed.

1.4.4 Economic Resources

Economic Impacts Associated with Reduced Tourism

Although the refuge purpose is not intentionally linked to regional or local economics, the

refuge is none-the-less connected to economic issues though its influence on tourism.

Uncontrolled Spartina growth is expected eventually to impact tourism locally by limiting

or eliminating some of the recreational opportunities mentioned previously. This, in turn,

could reduce tourist dollars spent at local businesses.

Threats to Shellfish and Other Resource Industries

Land management practices on the Refuge can have direct or indirect off-refuge economic

consequences. Such is the case with management of Spartina on refuge lands. If the

refuge supports large acreages of Spartina, the seeds produced would increase the cost of

controlling Spartina on adjacent private and State tidelands. On many of these private and

State lands, development and/or harvest of natural resources for economic gain is the

primary objective. The commercial shellfish industry has identified Spartina as a threat

due to its ability to interfere with water flows and capture sediments.

Impacts to Tideland Property Values

Tideland real estate values in Willapa Bay are primarily a function of the land's capacity to

grow shellfish, usually oysters. Spartina reduces the economic value of the land as it

diminishes or eliminates that capacity. On marginal oyster grounds where Spartina is

established, the cost of controlling the grass can easily exceed the value of the land. In

addition, there is the concern that as control of Spartina is made mandatory by noxious

weed control laws on more lands, some tideland owners may be forced to choose between

expensive control efforts or relinquishing their title to the county.

Control Costs

Effective action alternatives are expensive. Effective control efforts will initially require

large commitments of funds by the Service. It is expected that costs will decline as

techniques become more efficient and seed sources are reduced. Labor represents a

substantial part of Spartina control costs. In 1996, at least 12 seasonal workers were

hired on Willapa Bay specifically for control activities. Such jobs contribute to local

economies.

1.5 PERMITS AND CONSULTATION

Coverage under the Washington State Department of Agriculture (WSDA) water quality
41

permit is required before any chemical control on Spartina can take place in Washington

State. Due to the legislation passed in 1995, WSDA now negotiates and acquires a water

quality permit for Willapa Bay annually from the Washington State Department of

Ecology (WDOE). The permit specifies which months chemical treatment is allowed and

which chemicals are permitted, along with restrictions on wind speed, drying time, and retreatment intervals.

Staff members of Willapa NWR responsible for herbicide application to Spartina hold

valid pesticide licenses, have taken and passed the WSDA aquatic pest control exam,

apply to WSDA and agree to permit terms in order to obtain coverage under the WSDA

water quality permit.

The refuge will initiate an internal Section 7 Consultation under the Federal Endangered

Species Act (16 U.S.C. 1531-1544) to address potential effects of control efforts, both

positive and negative (if any) on threatened and endangered species.

The proposal described in this EA no longer requires a Shoreline Management Substantial

Development Permit due to amendments of RCW 90.58.030 and 1987 c 474 s 1 in 1995

Washington State Legislation.

1.6 SUBSEQUENT CHAPTERS OF THIS EA

Chapter 2 of this EA identifies a number of alternatives for addressing the Spartina

problem, including no action, alternatives not considered further, and the proposed action.

 Chapter 3 describes the affected environment, and Chapter 4 assesses the environmental

consequences of the alternatives.
42

2.0 ALTERNATIVES

2.1 INTRODUCTION

Since 1985, many approaches to Spartina control have been discussed among agencies

and interest groups. The individual ideas range from simple to complex, and from

inexpensive to extremely costly. They also run from potentially effective to likely

ineffective and from extremely disrupting to the existing environment to low probability

for negative impact.

Although many techniques for Spartina management have been suggested, expanding

knowledge of Spartina and the existing environment has helped to focus management

efforts. For this reason, a number of alternatives have been considered but eliminated

from detailed analysis in this document. These will be discussed briefly along with the

rationale for elimination. This chapter will describe in detail and compare the following

four alternatives: No Action, Long-term Integrated Pest Management (the proposed

action), Physical/Mechanical Control, and Chemical Control. Further analysis of

consequences is found in Chapter 4.

2.2 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED

STUDY

2.2.1 Physical/Mechanical

All actions that depend on the movement of heavy equipment on tidelands are complicated

by the deep, very soft, silt substrate of the south end of Willapa Bay. In addition to this,

complicated machinery with many moving parts requires extraordinary amounts of

maintenance and cleaning to keep it operating for a reasonable amount of time in the

corrosive environment of the estuary. These factors and the disruption of physical and

biological resources tend to limit the number of physical/mechanical control options that

can be practically implemented on a sustained basis for effective Spartina management.

Commercial Harvesting

Repeated harvesting of stem material for commercial use could have effects analogous to

repeated mowing, but repetitions would have to be frequent and prolonged enough to

cause death of the plants. We are not aware of adequate demand for cordgrass fiber to

sustain a commercial harvesting operation in Willapa Bay sufficient to control the spread

of the grass. However, if sufficient demand did exist, it is reasonable to assume that

commercial harvest would require a stable or expanding source of Spartina and the

establishment of pulp processing facilities on Willapa Bay. This would be counter to

efforts to reduce infested acreage and would effectively constitute a conversion of tideland

use from conservation/aquaculture to industrial agriculture. Small, hand operations would

have some capability to reduce the rate of vegetative spread of clones or prevent seed

production, but only on small areas.

Tramping/crushing

This method destroys the above-ground portion, but does not directly affect the roots. 
43

Thus, like mowing, repeated actions in a growing season would be required to kill

Spartina clones. We are aware of no machine that is currently available for large-scale

crushing operations. The difficulty of transporting and operating such a machine in the

tideland environment must be overcome before such a technique can be realistically

evaluated. Potential exists for serious environmental impacts which may include

temporary increases in sedimentation and erosion, local decreases in water quality, and

disruption of infauna and epifauna, important prey items of aquatic migratory birds,

anadromous fish, and other native fish and wildlife.

Excavation/dredging

Conventional dredging equipment would be used to remove sediment and Spartina to at

least the depth to which the root mass extends. All plant parts must be removed and

disposed of at an upland site to avoid resprouting. This alternative is not considered

further at this time primarily due to its extreme cost. However, there is also a high likelihood of cutting or breaking plant parts, especially roots, with subsequent dispersal of

propagules to other parts of the bay or even outside the bay via currents. Impacts to soils,

water quality, hydrology, animals, and other plants are expected to be substantial. 

Disposal of dredge spoils would be a problem of at least the same proportions as the

excavation alone.

Scraping

Scraping would require the development of heavy equipment that could scrape Spartina,

including roots, into masses that could subsequently be removed from the tidelands.

Scraping has the same problems as excavation and dredging. 

Plowing/rotovating

Plowing and rotovating involves the mechanical disruption of Spartina, its root system,

and the supporting substrate. This is effective on some upland weeds because it results in

the desiccation of roots. It is not expected to be effective in killing Spartina because no

drying would occur in the tidal environment. It is expected that such efforts would

actually spread the species through propagules created by cutting up the plants. 

Equipment is not currently available that would efficiently operate on the very soft

substrates.

Dewatering/draining

This would require large earthen dikes and other water-control structures such as

tidegates and pumps to prevent the inundations required by Spartina. Such a large-scale

construction effort would result in immense environmental damage including impacts to

soils, water quality, hydrology, animals, and other plants.

Flooding/inundating

This entails covering plants with water deep enough to prevent photosynthesis and cause

plant mortality. It would require structures even larger than those needed to dewater

areas, but with the opposite intent. Again, immense environmental damage is anticipated

including impacts to soils, water quality, hydrology, animals, and other plants.
44

Burning

Spartina in Willapa Bay will not carry flame without the application of additional fuel. 

Burning with broadcast application of fuel such as gasoline and or diesel oil would

generate water-, soil-, and/or air-quality degradation. Impacts of pollutants on

invertebrates, fish, and other organisms could be high. Multiple treatments would be

required.

Steam

Steam has been used with some success to control Spartina anglica in New Zealand

(Shaw 1997). This is apparently more effective than mowing on that species since it kills

the stem and upper root tissues of the plant. However, it is expected to have limited

application on Spartina alterniflora because of the much greater above-ground biomass

involved. It is anticipated that costs, delivery problems, and impacts to invertebrates

would be high. Although it appears that this method would have little use in controlling

Spartina on Willapa Bay, future testing at least on a small scale seems warranted.

Covering

Long-term covering of clones with sheets of shade or geotextile cloth causes death by

preventing photosynthesis. Material must be securely held in place to withstand tidal and

wind actions. Refuge studies have shown that this method is labor intensive and requires

covering well-beyond the edges of clones to prevent Spartina from growing up from roots

extending beyond the edge of the visible shoots (U.S. Fish and Wildlife Service 1990). 

Covering may be torn or lifted off by wind and wave action. Covers also become covered

with sediment, which is then released when covers are removed. Generally, it was found

to be impractical where treatment of more than a few small clones was required, and it

generates substantial site disturbance during cover placement and removal.

Laser beams

Carbon dioxide lasers have been used to kill seed heads on certain plant species. This

method has not been tried on Spartina for effectiveness. Laser operations are hazardous. 

Safe, portable laser units have not been developed. Such technology has potential for

limited control of seed production if development continues and succeeds.

Freezing roots

This requires an elaborate system to circulate extremely cold liquid through the root mass.

 No such system has been developed on a large enough scale. If a large but portable

system is developed, it might assist in small-scale, local control.

2.2.2 Chemical

Highly selective herbicides

We are not aware that a species-, genus-, or even family-specific herbicide for Spartina

spp. is currently available.

Smothering with diesel, other oil, or fluid

Application of diesel or other toxic substances in the aquatic and marine environments to

control Spartina has significant environmental impacts and is illegal.
45

2.2.3 Biological

Grazing

Grazing by wild or domestic herbivores would have varying effects depending on the

season, duration, intensity, and types of animals used. Use of cattle or other large

herbivores is not practical because of the extremely soft substrate in the many parts of the

bay. If it was feasible, the environmental impacts of such large-scale grazing in the

intertidal zone would be significant. Grazing animals could contribute to the spread of

Spartina through dispersal of seeds and propagules.

Bioengineering

Bioengineering would involve artificial genetic manipulation of organisms to specifically

retard Spartina growth or reproduction. This method is hypothetically possible and may

become feasible in the future.

Succession/competition

Natural succession may cause limited displacement of Spartina by other marsh vegetation

as the invading grass modifies its environment. This is a result of the physical and

hydrological alterations created by Spartina clones and meadows. Unfortunately,

succession occurs only after the mudflats have converted to higher elevation vegetated

marshes. Spartina remains dominant with small patches of desirable plants intermixed. 

Thus, the habitat values of affected open mudflats and high vegetated marshes are still

lost. Spartina would continue to thrive in the lower intertidal zone and along channels.

2.3 ALTERNATIVES INCLUDING NO ACTION AND THE PROPOSED ACTION

Costs of action alternatives

Approximately $75,000 was spent on Spartina control on the Refuge in 1996. It is

impossible to predict with any precision the future costs to the Service of Spartina control

under any of the action alternatives. The rate of Spartina spread and efficacy of evolving

control techniques are not static or predictable and will greatly influence future costs. 

Generally speaking, the more funding applied to Spartina control now, the lower that

control and/or maintenance costs are likely to be in the future.

We estimate, that for the foreseeable future, the Refuge will spend from $50,000 to

$200,000 annually to address Spartina management on fee title and use deed lands. 

However, efforts to expand funding beyond this would be aggressively pursued. Because

of the large acreage of Spartina dominated land in the bay, any of the three action

alternatives could effectively utilize even larger amounts of funding, particularly in the first

few years of eliminating existing clones and meadows. Since expenditures for control are

primarily dependent on available funding, the annual costs for each action alternative

would be identical. In the descriptions that follow, relative control efficacy of each action

alternative is described, thus providing some comparison of cost effectiveness. Of course,

the No Action Alternative would have no control costs and would result in no Spartina

control.
46

Activities common to action alternatives

All action alternatives would include certain basic management requirements, monitoring,

and mitigation as is the case with many activities on a national wildlife refuge. Operations

on the tidelands would involve standard precautions and methods associated with

deployment of equipment, people, and supplies to areas with extremely poor access. The

following are specific protocols that would be a part of all action alternatives:

- Transport vessels and vehicles would not be serviced or fueled in the field except

under emergency circumstances.

- Hand-operated, gasoline-powered equipment would be fueled in the field using

precautions that would contain or avoid spills. This would involve fueling on

board a vessel and use of petroleum absorbent cloth.

- Fuel or chemical mixing would be accomplished prior to entering tidelands.

- Safety equipment appropriate to the risks involved would be available on vessels,

vehicles, and on individuals. This would include such items as personal protective

equipment, spill-response materials, radios, first aid kits, tools, fire extinguishers,

location devices, and personal floatation devices.

- Personnel would be trained in the operation of vessels, vehicles, and equipment to

ensure that such equipment would be used safely, effectively, and with minimal

disturbance to soils, nontarget vegetation, wildlife, control personnel, and the

public. Only employees with Washington State Aquatic Applicator's Licences or

workers under their direct supervision would prepare or apply chemicals. Control

programs involving chemical application would be in compliance with the USFWS

Manual (242 FW 7).

- Operations on the particularly soft mud of Refuge tidelands have evolved toward

dependence on hovercraft and airboat technology for moving people and

equipment at low tide. This technology has been found to be not only efficient, but

also the lowest impact means to move about in this most difficult environment. To

minimize impacts to nontarget vegetation, epibenthic invertebrates, and soils,

priority would be given to the use of these vehicles to transport personnel,

equipment, and supplies when tidelands are exposed. When practical, small power

boats would be used to access work sites prior to low tide or via flooded channels.

 In general, the use of wheeled or crawler-type equipment and walking on the

tidelands would be avoided to the extent possible.

- A Spartina management and monitoring plan would be developed, then reviewed

and updated as needed. The plan would identify proposed treatment areas,

methods, cooperative efforts, and monitoring activities.

- Information gained from operations would be shared with others engaged in

Spartina management on Willapa Bay and elsewhere, such as Puget Sound.
47

Priorities common to all action alternatives

- Areas selected for treatment would be prioritized as follows.

1. Fee title federal lands associated with the Lewis, Porters Point, Riekkola,

and Long Island units (Figures 2 and 3).

2. State-owned tidelands around Long Island, commonly known as use deed

lands, on which the Service holds certain management responsibilities

(Figure 3).

3. State-owned tidelands immediately adjacent to lands described above.

4. Cooperative control on other tidelands or wetlands within the Willapa Bay

watershed.

- Treatment of Spartina on the Refuge would be prioritized as follows.

1. Early flowering clones which are most likely to produce viable seed.

2. Scattered outlier clones and seedlings.

3. Coalescing clones

4. Meadows

2.3.1 No Action

Under this alternative, Spartina would not be controlled on Refuge-owned tideland and

the Service would not provide assistance with Spartina control on other tidelands within

Willapa Bay.

Table 1 shows the estimated acreage of Spartina invasion on refuge lands. If no action is

taken to control Spartina on the Refuge, it is projected (based on the expansion of

Spartina in recent years) that all remaining mudflat area on the Southern Units will be

dominated by the invading grass within the next 10 years. On Refuge tidelands associated

with Long Island, Spartina has already dominated about 1,200 acres or 67% of the area. 

Nearly all of the remaining mudflat habitat on these tidelands will likely be dominated by

Spartina within the next five years if no action is taken.

Table 1

Estimated Acreage of Spartina on Refuge Tidelands

(October, 1996)

Degree of Spartina Invasion Three Southern Refuge

Units

(2900 acres)

Tidelands Associated with

Long Island (1800 acres)

Spartina Meadows 300 (10%) 1,000 (56%)

Coalescing Clones 140 ( 5%) 200 (11%)

Scattered Clones and

Seedlings 1,550* (53%) 260 (14%)
48

Unaffected (1996) 910 (32%) 340 (19%)

* Approximately 90% of the spartina on this area was controlled in 1996.

At the end of the 1996 growing season it was estimated that there were approximately

5,000 acres of Spartina on about 15,000 acres of tidelands throughout Willapa Bay

(Moore 1997). The no action alternative would not only fail to contribute to Spartina

control off refuge, it would also interfere with the off-refuge efforts by allowing a major

seed source to thrive on the Refuge.

2.3.2 Integrated Pest Management (Proposed Action)

Integrated Pest Management (IPM) is a dynamic approach to pest management which

utilizes a full knowledge of a pest problem through an understanding of the ecology of the

pest and related organisms. Programs are carefully designed under IPM using a

combination of compatible techniques to limit damage caused by the pest to a tolerable

level (U.S. Fish and Wildlife Service 1982). In many cases, IPM will utilize combinations

of physical/mechanical, cultural, biological, and chemical control techniques to meet

objectives. At this time, biological and cultural techniques are not available for Spartina

control. However, biological control agents are being studied and will likely become

available for use in the future.

Integrated pest management incorporates a broad range of techniques and therefore

expands opportunities to do effective control work beyond those of individual control

methods. Clone elevation, stage of plant development, tidal conditions, and weather all

can influence the efficacy of any individual control technique. Chemical methods, while

more effective under ideal circumstances, are most limited by adverse situations. 

Consequently, crews using IPM can quickly adapt to conditions found in the field to

obtain safe, economical results.

Although IPM would retain some of the impacts of chemical, biological, and

physical/mechanical methods, it is expected that overall impacts would be reduced by

improved efficacy and less reliance on a single control method. To illustrate this, consider

a 30- to 50-foot diameter clone that has grown to full height on a low mudflat. It is likely

that it would take at least four mowings, with the associated physical impacts (trampling

of nontarget species and sediment disturbance) to kill such a clone. Likewise, total

reliance on chemical control techniques would likely require the application of large

amounts of spray mix perhaps in multiple treatments to kill such a mature clone. Using

knowledge gained from 1996 control work and 1995/1996 monitoring (Major and Grue

1997) it was revealed that such a clone can be killed with one mowing followed in 30 to

60 days with an application of glyphosate on the short, soft regrowth. In such a case, the

clone would be killed more economically with less spray than when chemicals alone are

used and with fewer visits and on site disturbance than when mowing only is used.

The adaptive nature of IPM would permit the program to evolve as more is learned about

efficacy and nontarget effects. Consequently, a precise description of actual control work

that would be conducted several years in the future is not possible. However, the state of
49

existing programs being conducted on Willapa Bay and in Puget Sound have provided a

general picture of the long-term Spartina control program being proposed by the Service

on Willapa Bay.

Under IPM, control methods would vary throughout the year to take best advantage of

Spartina growth, weather conditions, and other factors. The following are descriptions

IPM proposed by season.

Early Growing Season

Current water quality permit standards allow application of glyphosate and approved

surfactants starting June 1. 

- If Spartina is actively photosynthesizing and is approximately two feet tall or less

after this date, herbicide application alone has been found to be effective. Aerial

application by helicopter or fixed-wing aircraft would be used on meadows and

areas of coalescing clones. 

- Spot herbicide application using spray equipment mounted on airboats, hovercraft,

and pack frames would be used to treat isolated, scattered clones. Clones that

were not completely killed in the previous season would likely be re-treated in the

early part of the growing season. Approved marker dye might be used to avoid

missing or overlapping parts of clones being treated with herbicide.

- Mowing of clones and meadows as described under the Physical/Mechanical

Alternative (see section 2.3.3) would begin where shoots generally exceed two feet

in height.

- Seedlings would be treated by crews on mud walking equipment who would pull

or push them into the mud as described under the Physical/Mechanical Alternative.

Mid Growing Season

- In late June, a search for flowering clones would be conducted and such clones

would be either sprayed or mowed immediately, or marked for later treatment. 

The intent would be to identify clones that are inclined to produce viable seed and

apply special emphasis on stopping their development. 

- Initial and repeated mowing of clones and meadows would continue to either

directly kill the clones or prepare them for subsequent spray.

- Herbicide application would generally be on clones and meadows that were

mowed 30 to 60 days earlier in the season. 

- Some spraying of unmowed Spartina would occur where prolonged adsorption

opportunities existed or if more effective approved chemical became available.

- Pushing and pulling seedlings would continue through this period.

- Flaming of flowers or seed heads using propane torches or similar tools would be

used to stop seed production during this time of the year. 

Late Growing Season

- Spray operation would generally stop during the month of September, although

new developments in chemical methods might extend herbicide application to later

dates.
50

- Mechanical/physical methods would continue through late season when funding

permitted since there is some evidence that this weakens the next season’s early

growth.

Winter

- On-going studies are indicating that winter mowing of Spartina stubble and winter

shoots to the mudline may kill clones or substantially retard the next season’s

growth. It is thought that winter mowing may work to smother the roots under

some circumstances. Even though the season of maximum dormancy in which this

may be used is short and weather conditions further limit safe work on the bay

during this time of year, this technique might be used to complement efforts

conducted during the growing season.

All Seasons

- Mechanical methods that would remove Spartina along with its root mass could

theoretically be used year around. A vibrating fork devise has been tested with

some success that is capable of removing Spartina along with its root mass.

At such time that new physical/mechanical, cultural, biological, chemical, or other control

techniques are tested and approved for use on the bay, they would be incorporated into

the IPM program. As has been the case with chemicals currently approved for use in

Willapa Bay, the Service would incorporate new herbicides and adjuvants into its IPM

program if they proved effective and were approved under the State Water Quality Permit

and a U.S. Fish and Wildlife Service Pesticide Use Proposal. Procedures and timing for

applying biological control agents would depend on the organisms used. Details about

such future developments under IPM, of course, cannot be addressed until specific

chemicals or agents are identified or tested.

Further discussions of specific mechanical and chemical application techniques are found

in 2.3.3 and 2.3.4. 

On the Southern Units of the Refuge, implementation of the IPM Alternative at expected

funding levels over the next 5 years would be expected to stop most of the seed

production and maintain approximately 2,300 acres of mudflat free of scattered small

clones and seedlings. Within about 10 years, IPM would likely permit the conversion of

about half of the existing Spartina meadow and coalescing clone acreage to native

saltmarsh vegetation, while the other half would likely revert to mudflat. Once meadows

were controlled, it is reasonable to expect that Spartina control work on this area could be

reduced to spot treatment of reinvading clones, requiring only a few staff weeks per year.

Due to the greater degree of Spartina dominance on Use Deed tidelands around Long

Island, elimination of the meadows could take about 10 years to complete using IPM. 

However, due to the amount of sediment accreted and the tendency of native saltmarsh to

stabilize such elevated sediments, little of the former Spartina meadow would likely revert

to mudflat. Seed production could likely be stopped within 5 years. Variables that could

reduce the number of years needed to achieve control on these lands include increased
51

funding allocations, increased assistance from DNR, and advances in IPM techniques.

Cooperative work off refuge using IPM and its success at controlling Spartina cannot be

precisely quantified, because specific agreements with public and private landowners have

yet to be developed. However, IPM would be expected to provide the greatest amount of

flexibility for accommodating landowners’ management objectives, control capability, and

personal preferences.

2.3.3 Physical/Mechanical Control

Physical and mechanical methods of controlling Spartina are those that physically

manipulate the grass itself, or some aspect of the habitat on which the grass depends. 

Such manipulation may or may not involve the use of power tools or machinery. The

physical/mechanical alternative addressed in this EA includes the use of hand pulling or

pushing of seedlings, mowing, removal of whole clones/meadows from the substrate using

machinery, and torching of flower and seed heads. These various techniques would be

applied individually or in combination, on a site-specific basis, as appropriate.

Hand pulling

This entails removal of seedlings that have sprouted from the previous year's seed set. 

This method has proven to be effective at retarding the first stage of Spartina invasion on

mudflats (Wilson and Lebovitz 1996).

The technique typically involves approaching each seedling by hovercraft, airboat, or on

foot, using a mud-walking device attached to boots. The seedling is pulled up by hand

with its roots attached if a rhizome has not developed. If a rhizome has developed, some

digging by hand or with a hand tool such as a trowel or garden fork may be necessary. 

Plants must be removed from the intertidal zone and disposed in a way that will prevent

them from getting back to tidelands. Drying, burning, or burying at an upland site would

be sufficient to avoid reintroducing the seedling to the bay.

Care must be taken to minimize propagules that are broken or cut off below ground as

they may resprout. Propagules must be properly disposed of to prevent dispersal by tides.

 Repeated treatments throughout the growing season are required because of resprouting

and late germination of seeds. This technique is limited to seedlings, and is most effective

early in the growing season before rhizomes become well-developed. It is not practical for

established clones due to the amount of hard labor involved in digging up and removing

the large root masses.

Pushing Seedlings into the Mud

This newly-developed technique shows promise as a substitute for pulling seedlings (Milne

1995). It is based on the idea that a seedling will die if it is pushed at least 18 inches

below the surface of the mud. The procedure is accomplished by using a rod of

approximately 1.5 to 2 inches in diameter to shove a seedling down into the soft mud

beyond the plant's ability to send a shoot back to the surface. The main advantage of this

technique is that removal of the seedlings from the tidelands is not necessary. Less time

and movement at the seedling site is needed, and no side trips to unload seedlings would
52

be required. These advantages would reduce physical effort and further reduce impacts

associated with trampling. It is expected that the technique can be modified to be

performed from a hovercraft or airboat, thereby reducing or even eliminating impacts

associated with walking on the mudflats.

As with hand pulling, the pushing technique is reasonably applied only to seedlings. Once

the clone is well-established in its second season, too much effort and disturbance would

be required to push so much plant material down to the necessary depth. Furthermore,

there would be a high probability of leaving viable rhizome fragments near the surface to

permit resprouting.

Mechanical cutting or mowing

Studies have demonstrated that Spartina is stressed by repeated mowing (U.S. Fish and

Wildlife Service 1991, Atkinson 1992) and that clones can be killed in some situations

where the mowings are consistently repeated. A number of variables are suspected to

influence the vulnerability of Spartina to mowing. How these variables appear to work is

demonstrated qualitatively as follows.

Less Effective More Effective

Few treatments Many treatments

Inconsistent Regular repetitions

Mud substrate Sand or gravel

Large clones Small clones

Genetic resistance Genetically vulnerable

To date, several types of mowing devices have been used to cut Spartina in Willapa Bay. 

The device that has been most commonly employed on the soft, irregular surfaces found

on the Southern Units of the Refuge has been a gasoline-powered, hand-held, brush

cutter. The need for larger, self-propelled mowers/harvesters has been identified, and

such machines are expected to be tested on Willapa Bay in 1997. Such devices would be

used at locations where they would not get bogged down and excessively disturb

sediment. Generally, large mowers would be used to mow meadows and large clones. 

The dense root mass of established meadows is expected to support larger tracked and

wheeled equipment.

The most commonly employed technique would involve mowing all stems within a

selected clone as close to the ground as possible without cutting into and lifting the roots.

 As regrowth occurs, this is repeated until the root system dies and resprouting ceases. 

Care must be taken not to cut and lift roots and rhizomes that may resprout on site or be

dispersed by tidal currents. Mowed material is allowed to float away on subsequent high

tides.

A modification of this technique would be used on larger clones located in relatively high

areas that are sheltered from wind and wave action. In such areas, the outer margin of the

clone would be left standing to prevent the mowed material from floating away. This

technique has been shown to have the added effect of shading some of the regrowth with
53

the trapped cuttings.

Mowing alone has limited application as a means of controlling Spartina. It is not

practical on large clones and meadows or as the sole method in large-scale operations due

to its high cost. In earlier studies on the Refuge (Atkinson 1992), large clones (averaging

150' diameter) in mud had to be mowed 10 times over two growing seasons to be killed. 

It was estimated from this study that the cost of mowing such large clones to death might

exceed $1,000 per acre. 

Another limitation of mowing alone is the problem of diminishing returns from repeated

mowing effort (Atkinson 1992). Resprouting vigor was reduced substantially when large

clones were mowed the first two or three times. Subsequent mowings retard regrowth to

a lesser degree. In the end, it was necessary to hand pull remaining shoots sprouting from

particularly tenacious roots.

A value of mowing is that it can be employed effectively to stop a season's seed

production. To do this, it is essential that mowing be done late enough in the growing

season that the clones are unable to recover and flower, but early enough that viable seed

has not already been produced. This limits such a strategy to the months of July and

August.

Torching

Like mowing, clean burning of Spartina stems with a flaming weed torch would leave root

systems intact. Thus repeated treatments are necessary to kill the plants. This method

may be practical for preventing seed production by flaming flower or seed heads.

Implementation of the Physical/Mechanical Control Alternative would be expected to

substantially increase the number of years it would take to gain control of Spartina on the

Refuge. This is due to the higher cost of killing meadows and large clones, and the delays

in retarding seed production from some areas. It is possible that at current funding levels,

control would never be accomplished on the Refuge using this alternative. With existing

mowing equipment, the refuge would have very little capacity to cooperate in off-refuge

Spartina control projects. 

2.3.4 Chemical Means Only

This alternative would rely exclusively on ground or aerial application of chemicals to

control Spartina. Only herbicides and adjuvants (e.g., surfactants and dyes) approved by

the U.S. Environmental Protection Agency (USEPA), Washington State Department of

Ecology (DOE) through its Water Quality Modifications Permit, and U.S. Fish and

Wildlife Service (USFWS) through a pesticide use proposal would be applied to Spartina.

 Currently, only Rodeo® and one of three nonionic surfactants (R-11® Spreader Activator,

X-77® Spreader, or LI-700®) may be applied to Spartina in Washington state. For general

information on Rodeo® and these nonionic surfactants see the Appendix. Herbicides and

adjuvants would be applied to Spartina consistent with the pesticide label, and restrictions

imposed by USEPA, DOE, and USFWS.
54

For ground applications, a herbicide tank mix would be applied to Spartina using a backpack sprayer or portable spray device that would be mounted in a conventional boat,

airboat, hovercraft, or where substrates permit, an all-terrain vehicle. Ground

applications would involve spraying foliage on a spray-to-wet basis. Rodeo® and a

nonionic surfactant (adjuvant) would be applied by ground equipment at rates equal to or

less than the maximum rates permitted for Spartina control by USEPA and DOE, which

currently are 5% and 2% solutions (volume of chemical to volume of spray solution),

respectively. Off-site movement (drift) of chemicals by air currents and tidal washing

would be minimized by timing treatments to coincide with favorable environmental

conditions. Such conditions would include the following: wind velocity less than 8

km/hour (5 mph), no rain events 6 hours before or during spraying, no visible moisture on

plants during application, and at least 5 to 6 hours exposure time between application and

subsequent high tide to allow for cuticle penetration of the herbicide. With hand-held

equipment used for ground applications, spraying would be directed inward and

downward onto Spartina to avoid over spray on non-target areas.

Herbicides and adjuvants would be wiped onto Spartina using hand-held or self-propelled

applicators. Wiping would involve covering foliage until it has a wet appearance. 

Rodeo® and a nonionic surfactant (adjuvant) would be applied by wipers at rates equal to

or less than the maximum rates permitted for Spartina control by USEPA and DOE,

which currently are 33% and 5% solutions, respectively. Wiping with hand-held

applicators is normally impractical for clones larger than a few feet in diameter. Wiping

devices mounted on all-terrain vehicles have been developed and used with some success

on meadows (Sheldon 1996). Although such machinery has not been tested on the refuge

yet, it could become a component of this alternative as technology develops.

For aerial applications, the primary means of applying a herbicide tank mix to Spartina

would involve a helicopter equipped with a boom. Rodeo® and a nonionic surfactant

(adjuvant) would be applied at rates equal to or less than the maximum rates permitted for

Spartina control by USEPA and DOE, which currently are 8.8 liters/ha (3.75 quarts/acre)

and a 2% solution, respectively. The same environmental conditions described for ground

applications would be needed to minimize drift. Aerial application would be used on

meadows or very large clones and would be conducted so that the herbicide tank mix

would not be directed outward beyond the edge of the Spartina stand and, would

consequently, minimize over spraying of non-target areas.

Because efficacy associated with ground and aerial applications is dependent upon, among

other factors, exposure time (period between treatment and tidal inundation), efforts

would be made to maximize time available for uptake of applied herbicide tank mixes by

Spartina. For example, the exposure time could be maximized by applying herbicide tank

mixes when a low high tide is rising, where Spartina in the upper regions of the intertidal

zone is not completely inundated. During the late summer with mid-morning low high

tides, treated Spartina could be exposed for about 12 hours before the tide washed treated

portions of the plant. 

Although limiting Spartina control to chemical means only would likely be reasonably
55

effective with little risk of harming non-target species, it has limitations in treating clones

in the lower intertidal areas where tidal inundation would usually wash the chemical off of

the plants in less than 5 to 6 hours. Another limitation to this alternative is that requisite

tidal and weather conditions restrict the amount of time available for control work. 

Finally, compared to use of multiple techniques, this alternative would require the use of

more chemical to achieve equivalent Spartina control because it does not benefit from the

assistance of mechanical methods and would have to be used in situations that are not

particularly suited to high chemical efficacy.

Implementation of the Chemical Means Only Alternative would be expected to somewhat

increase the number of years it would take to gain control of Spartina on the Refuge. 

This is expected primarily due to limited opportunities to apply chemicals effectively and

safely, and due to the difficulties in killing mature Spartina with the chemicals that are

currently available for use in the bay. However, it is possible that at current funding

levels, control could be accomplished on the Refuge using this alternative, but it would

likely take over 10 years.

2.4 SUMMARY COMPARISON OF ENVIRONMENTAL CONSEQUENCES

Tables 2A through 2D provide a summary comparison of the consequences under each of

the evaluated alternatives.

TABLE 2A. Alternative Consequences Matrix - Physical Resources.

Physical

Issues

No Action

Alternative

IPM

Alternative

Physical/Mechanical

Only

Alternative

Chemical Only

Alternative

Soils and

Topography

Spartina-facilitated

sediment buildup

would continue to raise

mudflats in most areas

of the bay.

Spartina-facilitated

sediment buildup in

scattered clones and

meadows would be

slowed or halted in the

shortest amount of time. 

Low concentrations of

chemicals would bind to

soil and then break down.

Spartina-facilitated sediment

buildup in scattered clones

would be slowed or halted,

but some meadows would

continue to capture sediment

for many years in most areas

of the bay.

Spartina-facilitated sediment

buildup in scattered clones

and meadows would be

slowed or halted in most

areas of the bay, but over a

longer period of time than

with IPM. Chemicals would

bind to soil and then break

down.

Hydrology

Alteration of natural

flow patterns would

continue unchecked.

Alteration of natural flow

patterns would be slowed

over the next few years

and reversed in the longrun.

Alteration of natural flow

patterns would likely be

slowed over the next few

years. Changes in water

movement due to Spartina

would continue in areas

where control could not be

accomplished.

Alteration of natural flow

patterns would be slowed

over the next decade, and

possibly reversed eventually.

Water

Quality

Potential for

temperatures to

increase and changes in

 salinity and oxygen

levels.

Potential for short-term

herbicide contamination. 

Greatest potential for

reducing temperature

increases and changes in

salinity and oxygen levels

caused by Spartina.

Greatest localized increases

in suspended sediments.

Reduces potential for

temperature increases and

changes in salinity and

oxygen levels, but to a lesser

degree than other action

alternatives.

Potential for herbicide

contamination. Reduces

potential for temperature

increases and changes in

salinity and oxygen levels.
56

Ambient

Sound

No changes. Short term increased

ambient noise levels

associated with use of

aircraft, airboats, weed

cutters, etc.

A higher reliance on large

machinery that could work

night and day would likely

result in more noise than

other alternatives.

Even with use of aircraft, this

alternative would generate

less total noise than other

action alternatives mainly

because of reduced work

opportunity. Ground-based

chemical application

machinery tends to generate

less noise than mechanical

methods.

Air Quality No changes Of action alternatives,

least potential for air

pollution from

combustion of fossil fuels

due to higher efficiency. 

Less potential for

herbicide drift than

Chemical Only

Alternative.

Of action alternatives,

highest potential for

pollution from combustion of

fossil fuels. 

Of action alternatives, there

would be a higher potential

for herbicide spray drift due

to total reliance on chemical

control. Pollution from

burning fossil fuels may be

comparable to that of the

Physical/Mechanical

Alternative.
57

TABLE 2B. Alternative Consequences Matrix - Biological Resources.

Biological

Issues

No Action

Alternative

IPM

Alternative

Physical/Mechanical

Only

Alternative

Chemical Only

Alternative

Vegetation

The displacement of

eelgrass and

macroalgae beds would

continue. Within 10

years, nearly all of this

habitat on the Refuge

may be lost, and onehalf of the Refuge’s

native saltmarsh

habitat may be lost. 

Spartina seed dispersal

from the Refuge would

promote loss of similar

habitats off-refuge.

The greatest acreage of

native plant habitat would

be preserved and

eventually restored. All

existing mudflat habitat

supporting macroalgae

and eelgrass on the

Refuge would be

maintained. Some

Spartina dominated areas

would be converted to

mudflat and some would

convert to native

saltmarsh. Existing native

saltmarsh would be

preserved. Impacts to offrefuge vegetation due to

Spartina spread would be

minimized.

Of the action alternatives,

this would preserve the

smallest acreage of native

plant habitat. About 1,800

acres of mudflat supporting

eelgrass and macroalgae on

the southern units would be

maintained. Some Spartina

meadow would likely remain

and expand on Long Island

tidelands. Less efficiency at

controlling Spartina on

Refuge tidelands would have

more impacts to off-refuge

vegetation.

About 2,000 acres of

mudflat supporting eelgrass

and macroalgae on the

southern units would be

maintained. Most of the

existing mudflat habitat

would be maintained on

Long Island tidelands. Most

of the existing Spartina

meadow on the Refuge

would convert to native

saltmarsh. Seed production

would likely be stopped over

time, reducing off-refuge

impacts.

Spartina

Spartina would

continue to spread. 

Spartina dominated

acreage on the Refuge

is likely to increase to

over 4,000 acres within

10 years. Spartina seed

dispersal from the

Refuge would interfere

with control efforts offrefuge.

Spartina would not

increase. Seed production

from Refuge lands could

be stopped within 5 years.

Spartina meadows and

clones would be mostly

eliminated from Refuge

lands within 10 years.

Spartina expansion would be

slowed. Seed production

could be stopped on the

southern units but not on

Long Island without

assistance from DNR. Some

Spartina meadows would

likely remain after 10 years

of control effort.

Seed production from the

refuge would likely be

stopped in about 10 years. 

Meadows would be

eliminated from the southern

units and greatly reduced

around Long Island.

Wildlife

Feeding and resting

habitat for waterfowl,

other waterbirds, and

eagles would be

degraded. Most habitat

for shorebirds on the

Refuge would be

eliminated within 10

years. Spartina

dispersal from the

Refuge would

contribute to habitat

loss off-refuge.

Existing mudflat and

native saltmarsh habitat

on the refuge would be

maintained. Former areas

of this habitat, now

occupied by Spartina

would revert mostly to

native saltmarsh. Wildlife

use of the Refuge would

be sustained.

Some existing mudflat

habitat would continue to be

lost to Spartina. Nearly all

Spartina meadow killed by

this alternative would

convert to native saltmarsh. 

Of the action alternatives,

this would preserve the least

mudflat habitat for migratory

bird use.

Most of the existing mudflat

and native saltmarsh habitat

on the Refuge would be

maintained. Former areas of

this habitat, now occupied by

Spartina would revert

mostly to native saltmarsh. 

Wildlife use of the Refuge

would be sustained.

Fish

Feeding habitat would

continue to be

degraded and lost. 

Prey populations

would be altered.

More habitat would be

protected for existing fish

populations than in other

alternatives.

Some habitat would become

unusable for fish due to this

alternative’s likely inability

to fully control Spartina.

Most of the habitat would be

protected for existing fish

populations.

Invertebrate

s

Species composition

would change in areas

occupied by Spartina. 

Potential for trampling of

invertebrates at work

sites. More habitat for the

existing invertebrate

community would be

protected than with other

alternatives.

Potential for trampling of

invertebrates at work sites. 

Where Spartina is not

controlled, species

composition would change.

This would have the least

potential of the action

alternatives for trampling of

invertebrates at work sites. 

Most of the habitat for the

existing invertebrate

community would be

protected.
58

TABLE 2C. Alternative Consequences Matrix - Social Environment.

Social

Issues

No Action

Alternative

IPM

Alternative

Physical/Mechanical

Only

Alternative

Chemical Only

Alternative

Human

Health

Possible increases in

mosquito problems,

mosquito control

programs, and pollen

allergies.

Health problems

associated with Spartina

pollen production and

mosquitos that breed in

Spartina meadows would

be reduced by Spartina

control on the refuge

within 10 years. This

alternative provides the

greatest opportunity for

the Refuge to reduce such

impacts off-refuge.

There could be some

reduction in pollen

production and in mosquito

habitat However, this

alternative’s inability to fully

control Spartina would

allow these problems to

persist to a degree. Greater

risk of injury to control

workers.

Health problems associated

with Spartina pollen

production and mosquitos

that breed in Spartina

meadows would be reduced

by this alternative on the

refuge within 10 years, but to

a slightly lesser extent than

IPM.

Concerns

Concerns with

chemical use

associated with

Spartina control on the

Refuge would be

eliminated. Concern

over loss of bay

resources would not be

addressed. Chemical

concerns associated

with mosquito control

might increase.

Concerns about chemical

use would be reduced to

the degree that control

would not depend

exclusively on chemical

methods. Spartina spread

would be stopped on the

Refuge, reducing concerns

over the loss of Bay

resources. 

The absence of chemical use

would remove concerns

about chemical risk.

Spartina spread would be

slowed, but not as much as

with IPM or chemical only.

Concerns about chemical

risk would be greatest under

this alternative. Concerns

about Spartina spread would

be reduced.

Recreation

In the short term, no

noise or disturbance to

recreational users. In

the long term, loss of

resources and access

would reduce

recreational

opportunities.

Noise from airboats,

hovercraft, and aircraft. 

Disturbance of waterbirds

would reduce bird

observations. In the long

term, would be beneficial

to recreational uses.

Due to reduced control, some

recreational opportunities

would decline. Noise

disturbance to recreational

users would likely be greater

than with other alternatives.

Noise would be generated by

airboats, hovercraft, and

aircraft, but over shorter

periods of time. Disturbance

of waterbirds would reduce

bird observations. In the

long term, would be

beneficial to recreational

uses.

TABLE 2D. Alternative Consequences Matrix - Economic Environment.

No Action

Alternative

IPM

Alternative

Physical/Mechanical

Only

Chemical Only

Alternative
59

Issues Alternative

Tourism No effect in short term.

In long term, reduced

visitation and tourist

dollars.

No effect in short term. In

long term, would be

beneficial to tourism by

maintaining attractive

features of the bay.

No effect in short term. In

long term, recreational

opportunities and tourism

would decrease somewhat

due to declines in wildlife

and fish, native plants, and

open water.

No effect in short term. In

long term, would be

beneficial to tourism by

maintaining attractive

features of the bay.

Mariculture

& Fisheries

Growing seed source

on the Refuge would

increase Spartina

control costs on

adjacent private and

State tidelands. Owners

forced to choose

between expensive

control or relinquishing

their title. In longterm, changes in

habitat and likely

reduced production of

fish and shellfish.

Reducing and eventually

eliminating seed

production from the

Refuge would

substantially slow

Spartina invasion of

commercial beds and

important fish- rearing

habitat.

Seed production would not

likely be fully controlled on

the Refuge. Some spread of

seeds to off-refuge habitats

would continue. 

Opportunity for cooperative

control efforts on adjacent

lands would be unlikely. 

The major reduction in seed

production from refuge lands

would substantially slow the

invasion of Spartina into

commercial shellfish beds

and important fish rearing

habitat.

 
60

3.0 AFFECTED ENVIRONMENT

3.1 INTRODUCTION

This chapter describes the existing environment, that is, the baseline condition in Willapa

Bay. It emphasizes the environmental resources and components that would be affected

by the alternatives or that would affect the alternatives, if implemented. The chapter is

divided into four additional subheadings concerning the physical, biological,

cultural/social, and economic environments. It does not address effects. They are covered

in Chapter 4, Environmental Consequences.

3.2 PHYSICAL ENVIRONMENT

3.2.1 Location

The proposed project area is the 85,000 acre Willapa Bay (formerly Shoalwater Bay) in

extreme southwestern Washington. The bay is separated from the Pacific Ocean by the

Long Beach Peninsula. The bay forms an estuary between the ocean to the west of the

barrier peninsula and the watersheds of several rivers to the east. The bay’s generally

shallow water depth, twice daily low tides, and often deep muddy substrate have allowed

very limited heavy shipping and industry, resulting in a relative clean and productive

environment. Recent concerns have risen about the effects of rapidly expanding

residential development as well as past land management practices in the watershed.

Willapa Refuge includes four separate areas in Willapa Bay: the Southern (consisting of

Lewis, Porter Point, and Riekkola units); Long Island; Leadbetter Point; and Cape

Shoalwater units (Fig. 1). Most of the Cape Shoalwater uplands have been lost to shore

erosion. The Leadbetter Point Unit is contiguous with Leadbetter State Park. An area

sometimes considered with Refuge lands is the Presidential Proclamation Boundary. This

area, which surrounds Long Island, was closed to waterfowl hunting by President

Roosevelt in 1940. Some topographic maps mistakenly label this area as the Willapa

National Wildlife Refuge.

Spartina grows on tidal flats and stream channels in the Willapa Bay estuary. Spartina

invasions identified for potential control actions addressed in this EA are located at

various locations within the bay. Considered for control are the following categories of

lands:

1. Refuge-owned tidelands;

2. State-owned, Refuge-managed tidelands (use-deed lands); and

3. Other State or private tidelands that may affect Refuge lands.
61

First priority for control will be given to Refuge lands. Of particular concern for Refuge

management are Spartina plants growing within the Porter Point, Riekkola, and Lewis

units, and adjacent to Long Island. Cooperative activities on other public and private

tidelands may occur throughout the estuary.

3.2.2 Soils and Topography

Willapa Bay is a bar-built estuary influenced by geological changes in sea and land levels. 

It is geologically young, isostatically rebounding, and rapidly accreting sediments (Day, et

al 1989). Near-shore subsidence events (underwater earthquakes) are thought to

periodically change the relative level of land to water along the Pacific Northwest coast.

Like other Northwest estuaries, Willapa Bay is dominated by mudflats rather than

saltmarshes. The physical structure is shaped by dynamic natural forces including large

tidal ranges, strong currents, and heavy runoff (Day et al., 1989).

The bay has extensive, gradually-sloping, intertidal flats with small, shallow channels

connecting to larger, deeper ones which expedite the cyclic flows of tides. The flats in the

southern end of the bay have a fine silty substrate accumulated from upland sediments of

rivers and streams flowing into the bay. The upper layer of fine sediments may be

regularly resuspended by strong currents, wave action, rainfall on exposed mudflats,

biological activity on or below the surface (such as that associated with burrowing

shrimp), or human activities (such as boating, aquaculture, or dredging). The nutrientrich, silty substrates may favor Spartina colonization, which then enhances sedimentation

as currents are slowed by the vegetation. Further north in the bay where currents are

stronger, bare tidal flats collect less silty material and tend to have coarser, sandier

bottoms.

While it is clear that logging, road construction, and other forms of development have

been introducing sediment into the bay for many decades, we are aware of no studies

supporting the hypothesis that the spread of Spartina in the bay is a biological response to

sediment influx. Spartina’s ability to invade all substrates (except solid rock) on the bay in

the absence of control strongly indicates that the rapid expansion of this grass would

continue with or without changes in sediment loading.

Spartina stems and rhizomes trap and accumulate fine sediments from tidal and river flow

and upland runoff (Washington State 1993). Zipperer (1996) found that, relative to

mudflats, Spartina patches in Willapa Bay were characterized by finer grain sizes, more

total sediment deposition, and were at higher elevations. Fraser-Quick (1992) noted that

Spartina can capture sediment at the rate of between 1.2 and 2.0 inches annually. This

results in raised elevations of several inches in 15 to 20 feet diameter clumps of Spartina

(Williamson 1995). Drainage channels cut deeper as flows become more concentrated. 

This combined with the raised elevation of Spartina vegetation causes steeper channel

walls.
62

3.2.3 Hydrology

The rivers and tributaries that enter Willapa Bay drain an area of more than 900 square

miles (Shotwell 1977). The main drainages in the watershed are the Bear, Naselle,

Nemah, Palix, Willapa, and North rivers. The mouth of Willapa Bay lies between

Leadbetter Point and North Cove at the bay’s northwest corner (Fig. 1).

Historically, tidal currents have flowed in and out of the bay through various channels in

the bay’s mouth. Much of the flow has been directed through the north channel toward

North Cove resulting in extensive erosion over the last 100 years (WDOE 1996). In

response to the threat of further erosion, Pacific County and the State of Washington are

proposing emergency dredging of a middle channel to redirect tidal currents away from

Cape Shoalwater/North Cove. Concurrently the Washington Department of Ecology and

U.S. Geological Survey initiated a five-year study to identify the causes of coastal erosion

in Southwest Washington, including the Cape Shoalwater/North Cove area (WDOE

1995). The dynamic circulation forces also enhance the colonization and spread of

characteristically invasive species like Spartina by distributing propagules throughout the

area (Zipperer 1996b).

Runoff patterns of Pacific Northwest coastal rivers exhibit peak flows in the winter

associated with increased precipitation (Proctor 1980). Heavy winter runoff combined

with storm surges and seasonally high tides produce flooding in adjacent low-lying areas. 

Restricted flows resulting from raised elevations or intertidal vegetation can cause water

to back up, thus, exacerbating flooding.

3.2.4 Water Quality

Willapa Bay is commonly perceived as one of the least spoiled and most productive

estuaries remaining in the contiguous 48 states. Adjectives such as ‘pristine’ and

‘unspoiled’ are often used as descriptors of the bay and its waters. Water is the principle

erosion agent along the Pacific Northwest coast (Proctor 1980). Runoff from upland

sites in the watershed combine with the inflow of marine waters, including that from the

Columbia River, to produce a rich soup of soil particles, salts, nutrients, pollutants, and

organisms. Without mixing agents, the freshwater runoff would tend to remain primarily

on the surface above the denser saltwater. But winds and tides combine to mix the

waters. In brackish, tidally influenced estuaries of western Washington, salinities range

from 20 to 30 ppth at the mouth to 0 ppth at the limit of saltwater intrusion (average

salinity is 32 ppth in the Pacific Ocean) (State of Washington 1993).
63

Where Spartina dominates, the water column may be affected in several ways. With

restricted flows, surface water temperatures may increase. Salinity may increase or

decrease depending on the effects on evaporation and mixing rates. Levels of dissolved

oxygen may decrease due to decomposition of Spartina litter after seasonal die back. 

Water quality may be improved because the Spartina traps suspended sediments or filters

pollutants. 

Beginning in the spring of 1997, the Washington Department of Ecology is conducting an

EPA-funded project to study water quality parameters in Willapa Bay. Water

temperature, dissolved oxygen, nutrients, chlorophyll, pH, light transmission, and turbidity

as measured by Secchi disk depth will be determined at six locations (Newton 1997).

3.2.5 Tides

On the West Coast of North America, there are two high tides and two low tides in each

daily cycle. The two sets of tides are of differing heights, producing a higher and lower

high tide as well as a higher and lower low tide each cycle (mixed diurnal) (Shotwell

1977). The mean diurnal tide [between mean higher high water (MHHW) and mean lower

low water (MLLW)] for Willapa Bay ranges from about 8.1 feet at the entrance to about

10.2 feet near Nahcotta (NOAA 1977).

At high tide, Willapa Bay is a wide expanse of open, albeit shallow, water; whereas, more

than 50% of the bay’s mud flats may be exposed at low tide (Hedgepeth and Obrebski

1981). All of the proposed project area is tidally influenced to some degree. The highest

elevations may be covered only during the higher annual tides whereas the lowest portions

are exposed only during the lower annual tides.

The tidal cycles greatly affect mobility and uses in the bay, including Spartina control

efforts. Although most of the proposed control actions would occur on mudflats exposed

between MHHW and MLLW, some actions would be conducted for Spartina occurring

more than a foot above or below these elevations. The large range of and strong currents

associated with the tides increase the potential colonization and spread of Spartina within

and outside the bay.

3.2.6 Estuarine Functions
64

As an estuary, Willapa Bay is a semi-enclosed coastal body of water with free connection

to the open sea and within which sea water is measurably diluted with freshwater derived

from upland drainage (Pritchard 1967). Estuaries provide an interface between riverine

freshwater and marine saltwater ecosystems. The intermix of fresh and salt water, a

complex drainage structure, ever-changing tidal currents, and varying runoff levels combine to create a dynamic system with shifting circulation, stratification, mixing, and flushing patterns (Day et al. 1989). Sediments, nutrients, and biota flow among the terrestrial,

riverine, and marine environments via the estuary (Simenstad 1983). Within the Willapa

Bay estuary, a dynamic system of biological, chemical, and physical forces interact to

produce an environment which is biologically productive and economically valuable to

humans (Shotwell 1977). Since estuarine functions would be affected differentially by the

separate alternatives discussed in this document, functions are tracked through the

individual resources that contribute to or are a product of the functions.

Spartina dynamically alters West Coast estuarine functions. Calloway and Josselyn (1992)

noted Spartina “may affect sedimentation rates and patterns, available detritus, benthic

algae production, wrack deposition and distribution, habitat structure for native wetland

animals, benthic invertebrate populations, and shorebird and wading bird foraging areas.” 

In its native East Coast environment, S. alterniflora is used in salt marsh creation because

of its ability to rapidly convert disturbed or newly created tidal flats to vegetated marsh

and its importance as a native primary producer and detritus source. In its endemic

distribution, Spartina is naturally the dominant vegetation of the lower intertidal area and

the foundation of estuarine food webs. On the West Coast, Spartina is viewed as an

aggressive exotic that alters estuarine structure and function, excludes native salt marsh

and mudflat vegetation and eliminates native habitat for shorebirds, waterfowl, and certain

shellfish and finfish (Sayce 1988, Mumford et al. 1990, Simenstad and Thom 1995).

Alterations in sediment grain size, marsh elevation, and tidal configuration may occur as

Spartina patches grow larger or expand into new areas (Thompson 1991, Simenstad and

Thom 1995). Zipperer (1996b) found that, relative to mudflats, Spartina patches in

Willapa Bay were characterized by finer grain sizes, more total sediment deposition, and

greater amounts of below- and above-ground structure. She also found that Spartina

patches were at higher elevations and exhibited dampened temperature fluctuations

throughout the year.

3.2.7 Wetlands

The entire project area is tidal wetlands with either mudflats (with or without eelgrass),

native saltmarsh, or Spartina marsh.

3.2.8 Research Natural Areas

Three Research Natural Areas (RNAs) occur on Refuge uplands. The Diamond Point

RNA on Long Island is forested upland habitat immediately adjacent to large expanses of

Spartina targeted for control. The Cedar Grove RNA on Long Island is also forested

upland but is not adjacent to any shoreline or Spartina. The Leadbetter Point RNA, a dune

complex encompassing the entire Leadbetter Point Unit, has Spartina concentrations on

the tidal flats to its eastern (bay) side.
65

3.2.9 Climate
103

The climate of the Pacific Northwest coastal region is marine influenced (Proctor et al.

1980). It is characterized as a mid-latitude, West-Coast, marine type with very wet

winters and dry summers. It has high rainfall and a moderate temperature range (Phillips

1984). Snow is unusual. Rainfall is highest in December and January, and lowest in July.

 Annual precipitation ranges from about 60 to 80 inches near the coast on the west side of

the bay to 100 to 120 inches in the Willapa Hills to the east (Proctor et al 1980). 

Predominate winds are on-shore from the open ocean. Strong southerly winds usually

accompany winter storms. Some meteorologists think that the region has entered into a

20-year wet cycle with above-average precipitation rates over the past two years.

3.2.10 Air Quality

There are no major industrial sources of air pollution around the Willapa Bay estuary. The

predominant onshore winds and winter storms assure an almost constant replenishment of

 clean, fresh air from the Pacific Ocean. Temperature inversions that might trap smoke or

other pollutants are rare. Airborne pollen from Spartina is increasing during the plants’

flowering season, especially downwind of large clones and meadows.

3.2.11 Visual Resources

From land, the proposed project area is visible from vantage points along Highway 101, all

Refuge units, Leadbetter State Park, and bay-front property. The area may also be seen

from water or air.

The proposed control sites range from mostly open mudflats, which grow a summer cover

of eelgrass and algae, to extensive Spartina marshes. Small clones and individual plants

may grow far out onto these mudflats while a fringe of saltmarsh vegetation may grow

along the higher flats above Spartina clones and meadows. On the Refuge, massive

Spartina meadows visually dominate the intertidal flats along the northeastern shoreline of

Long Island, on the east side of Long Island Slough immediately north of Refuge

headquarters, and north of the native saltmarsh to the west of Porter’s Point. Of these

major Spartina meadows, those along the northeastern shore of Long Island dominate the

intertidal flats from subtidal channel to upland vegetation.

The mud appears grayish brown but turns greenish from algae and eelgrass in summer. 

The saltmarsh and Spartina plants are green in the summer, turning reddish and then

brown in the fall. Native saltmarsh plants are usually beaten down in-place during winter,

whereas Spartina breaks off and washes away leaving a stubble appearance on the mud. 

The dead Spartina stems are seen after they wash up on bay shores and ocean beaches,

especially along Long Beach Peninsula. Sometimes large floating mats of dead Spartina

are carried onto high intertidal saltmarsh vegetation by the highest tides. The brown mats

remain until the tidal cycles return to tides high enough to refloat them.

3.2.12 Ambient Sound

Most proposed project sites on- and off-Refuge are relatively isolated and inaccessible

with few unnatural sound sources nearby. A few are closer to development and humangenerated noises. Engines in oyster dredges, boats, vehicles, and planes are primary noise

sources. Surf crashing onto the ocean beach is the source of a constant background noise
104

that varies in intensity with wind and surf conditions.

3.2.13 Infrastructure

There are no roads, trails, or other access structures to proposed project sites. Most of

the intertidal lands in the south end of the bay are soft, silty mud. Primary access to

project sites on the Refuge will be via airboat or hovercraft from the boat ramp at Refuge

headquarters on U.S. Route 101 or the dike road in the Refuge’s southern units. 

Additional potential access points include Leadbetter Point State Park, Palix River, North

River, and Bay Center. Other sites may be identified in the north end of the bay as control

efforts expand.

Upland routes associated with the Refuge include a single-lane dirt road atop the dike in

the southern units, abandoned logging roads (becoming trails) in the Long Island Unit, and

a hiking trail system at the Leadbetter Point Unit. Sandridge Road, including a portion of

State Route 103, and Stackpole Road traverse the bay side of the Long Beach Peninsula

and provide access to the Leadbetter Point Unit. U.S. Route 101 stretches along portions

of the east side and south end of the bay, while State Route 105 runs along the north end.

3.3 BIOLOGICAL ENVIRONMENT

3.3.1 Vegetation

3.3.1.1 Seagrass (Zostra spp.) Community

One of the largest seagrass (eelgrass) meadows in the Pacific Northwest occurs in the

protected estuarine waters of Willapa Bay (Phillips 1984). Hedgpeth and Obrebski (1981)

described an eelgrass community as “a whole system of growth, catchment of detritus,

support of microbial associations, source of oxygen by day and deprivation by night, the

mainstay of small crustacea, and modifier of current and sedimentation patterns and

nutrient regimes.” Wyllie-Echeverria and Hershman (1994) listed six major functions of

seagrasses from Wood et al. (1969): (1) stabilize bottom sediments; (2) slow and retard

current, prompt sedimentation, and inhibit resuspension of organic and inorganic matter;

(3) provide shelter and substrate (for other organisms); (4) provide grazing and detrital

food pathways; (5) support high productivity; and (6) cycle nutrients internally.

Refuge mudflats, totaling more than 2,700 acres, support beds of native eelgrass (Zostra

marina), and introduced Japanese seagrass (Z. japonica), (referred to collectively as

seagrasses in this document). In Willapa Bay, Z. marina occurs in the lower intertidal and

subtidal; whereas, Z. japonica is abundant on the middle to lower intertidal mudflats. The

presence of seagrasses is critical in the foodweb (Wylie-Escheverria and Hershman 1994).

 Many waterfowl species depend on the seagrasses and small invertebrates associated with

them for food. Baldwin and Lovvorn (1994) found that in Boundary Bay, British

Columbia, eelgrass comprised the largest single portion of the diet for black brant (Branta

bernicula nigricans) geese; and American wigeon (Anus americana), northern pintail (A.

acuta acuta), and mallard (A. platyrhynchos platyrhynchos) ducks. They also found the

greatest amount and variety of most invertebrate foods of waterfowl in the eelgrass zones.
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3.3.1.2 Native Saltmarsh Vegetation

Native saltmarsh vegetation in the upper tidal flats includes pickleweed (Salicornia

virginica), jaumea (Jaumea carnosa), saltgrass (Distichulis spicata), seaside arrowgrass

(Triglochin maritimum), tufted hairgrass (Deschampsia caespitosa), and saltmarsh

bulrush (Scirpus maritimus) (Sayce 1993, Zipperer 1996b). There are about 500 acres of

native saltmarsh on the Refuge.

Investigations by the Wetland Ecosystem Team, University of Washington were initiated

on the Refuge under Special Use Permit in 1994. These studies are investigating the

effects of Spartina upon littoral mudflat community function and the ecological effects of

native species and Spartina on marsh progradation. Some preliminary results of this work

are discussed throughout this EA under various citations. Final publications for these

studies are expected in 1997 or 1998.

3.3.1.3 Exotic Spartina Marsh

Spartina or cordgrass was introduced to the West Coast during the 1890's resulting from

its use as packing material for oyster shipments from the East Coast (Frenkle and Kunze

1984). Although Spartina clones were seen in Willapa Bay in 1911 (Scheffer 1945) and a

Refuge Manager noted it in an Annual Report in 1942 (USFWS 1942), recent climatic

events have apparently spurred its spread. In the mid-1970's, the growth and expansion of

Spartina gained the attention of many public and private land owners and natural resource

managers. In 1987, the Refuge funded research to inventory and investigate the

reproductive ecology of Spartina (Mumford et al., 1990).

Several theories have been generated about the rapid growth and expansion of Spartina in

Willapa Bay in recent decades. A popular one is that warmer ocean temperatures

associated with a series of El Niño events in recent years have favored the growth and

spread of the plant in the Pacific Northwest. Typical of Pacific Northwest estuaries, the

geologically young Willapa Bay with its relatively high tidal range has characteristically

large expanses of mudflats which are susceptible to Spartina invasion.

In favorable alien environments, plant species tend to be more vigorous and taller,

producing more seeds than in their native distribution (Crawley 1987 in Blossey and

Notzold 1995). S. alterniflora in Willapa Bay represents the largest Spartina infestation

in the state of Washington (Washington State 1993). The rate of spread of Spartina is

geometric, that is, the quantity of growth each year increases based on the increased

amount of Spartina from the previous year. In 1945, 4.5 acres of Spartina were present,

432 acres in 1982, 2,400 acres in 1990 (Marks 1995), and 4,700 acres in 1996. Stiller and

Denton (1995) noted that at current expansion rates Spartina threatens to occupy most of

the intertidal habitat in Willapa Bay within 40 years. Some of the largest acreages of

Spartina meadows in the bay occur on Refuge fee-simple title lands (300 acres) or

Refuge-associated use deed lands around Long Island (1,000 acres). Small Spartina

clones and individual plants may invade native saltmarsh vegetation and small patches of

native vegetation may survive in nearly monotypic Spartina meadows.

Each fall the above-ground Spartina stems die back and break off to float as wrack. 
106

Sometimes large floating mats of dead Spartina form that may be carried onto high

intertidal saltmarsh vegetation by the highest tides. They remain there, smothering

underlying vegetation until the tidal cycle returns to high enough tides to refloat them. 

The Spartina rhizomes sprout new stems which grow in the spring.

Spartina acts as a pioneer species in sheltered tidal coastal and estuarine environments. 

Calloway and Josselyn (1992) found that Spartina in San Francisco Bay had a much better

chance of becoming established in new areas than native plants, and once established, it

spread more rapidly than native plants. Spartina sexually reproduces via yearly seeding

and native patches can spread vegetatively an average of 1.5 feet/year via rhizome or tiller

expansion (Sayce 1986, Mumford et al 1990, Zipperer 1996b). Seeds are the primary

source of new plants and colonies; but plants also grow from pieces of root or rhizomes. 

Plants spread laterally from underground roots (rhizomes) or by above-ground shoots

(tillers) to form clonal colonies. Lateral growth of individual clones has been measured at

up to 1.6 feet per year in Willapa Bay and 3.6 to 5.6 feet per year in Padilla Bay (WDOA

1992). As individual colonies spread, the circular clones ultimately grow together to

form dense monotypic meadows (Mumford et al 1990).

Spartina can occupy a broad range of intertidal substrates from soft silty muds to coarse

sand and cobbles, and it tolerates a wide range of salinity from ocean concentrations to

almost pure freshwater (Aberle 1993). Mumford (1990) found that Spartina grows within

3 feet of MLLW, is tolerant of a wide range of pH and salinity, and withstands prolonged

tidal inundations. Bertness and Ellison (1987) found that, unlike other native high-marsh

perennials in saltmarshes of New England, S. alterniflora is capable of vigorous growth

across the entire marsh zonation. In Willapa Bay, Spartina occurs on intertidal and

subtidal mudflats - from the sides of tidal drainage channels up into the high vegetated

marshes of the upper intertidal, sometimes to upland vegetation. Early establishment

usually occurs just below the saltmarsh with further spread occurring both far out onto the

mudflats and up into the saltmarsh (Hidy 1995).

In New England saltmarshes, Bertness and Ellison (1987) reported that S. alterniflora and

saltgrass occupy recently disturbed areas because of differential mortality and reoccupancy strategies. In short-term disturbance events, such as covering by dead plant

material (wrack), these species are more tolerant of burial than other saltmarsh plants. 

Longer lasting disturbances kill all underlying vegetation, leaving discrete bare spots. S.

alterniflora recruits into these patches by seed, while saltgrass recolonizes with vegetative

runners. The relative abundance of these species in recently created bare patches greatly

exceeds their relative abundance in surrounding vegetation.

Possible benefits that have been advanced for Spartina include its ability to filter

pollutants, control erosion, and as a link in the food-chain. The specific capabilities of a

Spartina marsh to filter pollutants from the water column compared to native West Coast

saltmarsh vegetation are not documented. Perhaps, where Spartina accretes sediments, it

slows the water column sufficiently so that denser particles and pollutants settle out of the

water. Once established on high-energy, shallow flats, thick growths of Spartina may help

dissipate waves enough to reduce deterioration of adjacent shorelines prone to wave
107

erosion. It will neither retard shoreline erosion associated with a deep undermining

current such as that causing erosion at Cape Shoalwater, nor will it affect shoreline

erosion caused by the collapse of steep banks due to saturated soils. When available to

dabbling ducks, Spartina seed may contribute to waterfowl diets in Willapa Bay. But seed

concentrations are mostly available only during tides high enough to allow access of the

birds over the tall Spartina meadows. No grazers, whether macro- or microscopic, are

known for Spartina in Pacific Northwest estuaries.

Simenstad and Thom (1995) considered Spartina as an exotic of questionable benefit to

West Coast estuaries. They noted that, while mud and sandflat community food webs

(based on benthic microalgae) will decline with continued Spartina expansion, they will be

replaced by webs driven by the extensive supply of Spartina detritus. Food webs based on

seagrass communities (Z. japonica) are lost by Spartina displacement. Ongoing and

future research in Willapa Bay may eventually enable us to evaluate and predict more

accurately the larger ecosystem consequences and effects on micro and macro

communities (whether beneficial or not).

In addition to extensive colonization within Willapa Bay, S. alterniflora also appears in 

Gray’s Harbor, Copalis River estuary, Puget Sound, Sequim Bay, and the Strait of Juan de

Fuca. Its cogener, S. patens, and the English species complex, S. angelica/townsendii, are

also reported in Puget Sound (Mumford et al. 1990, Rigs and Bulthuis 1994, Simenstad

and Thom 1995, Zipperer 1996b). It is not known how all populations of Spartina in

Washington originated, but it is speculated that the Grays Harbor one derived from

Willapa Bay. None are as old or extensive as that in Willapa Bay. Besides Washington,

Spartina occurs as an exotic species in Oregon, California, Great Britain, France, The

Netherlands, New Zealand, and China (Aberle 1993).

3.3.2 Wildlife

Willapa Bay has diverse wildlife resources. About 233 species of birds, 51 species of

mammals, and 17 species of amphibians and reptiles (resident or migratory) are known to

use Refuge lands and associated waters (US Fish and Wildlife Service 1991). 

3.3.2.1 Aquatic Migratory Birds

The Refuge was established for the protection of habitat for wintering and migrating

aquatic birds including ducks, geese, brant, swans, shorebirds, and wading birds. The use

of the Willapa Bay estuary by waterbirds (here referring to loons, grebes, cormorants,

herons, bitterns, ducks, geese, brant, plovers, sandpipers, dunlin, and other shorebirds) is

of special significance. Willapa Bay is one of ten major wintering and resting areas for

waterfowl and shorebirds of the Pacific Flyway. It is one of three sites in Washington that

gets more than 100,000 shorebirds at a time (Page et al., 1992). As a major flyway

stopover point and staging area, Willapa Bay is of critical importance for fuel

replenishment for migrating aquatic birds, some of which may travel 10,000 miles one way

in their annual flights.

The numbers of waterfowl and shorebirds are lowest in summer, and highest in spring and

fall, but remain relatively high throughout winter. As many as 135,000 shorebirds may be
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present at one time during spring migration (Page et al., 1992).

These birds depend on the abundance of mudflat invertebrates, seagrasses, native

saltmarsh plants, and associated invertebrates for food. The birds tend to feed mostly in

the high intertidal mudflats, which are the first areas available as the tides recede and the

last ones covered by incoming tides. Since Spartina usually establishes first in the high

intertidal and then spreads into lower and higher zones, this important zone is the first lost

to most waterbird species by dense Spartina vegetation.

Spartina is beneficial to wildlife in its native East Coast environment, but is considered

detrimental in Willapa Bay and other estuaries of the Pacific Northwest, where it is not

native. This concern draws from the fact that wildlife on either coast has evolved to best

use the natural conditions of the native environment. Major changes in an environment

can produce profound effects on the wildlife. Spartina can impose particularly dramatic,

large-scale changes because it colonizes the broad, open mud and sandflats characteristic

of the region’s geologically young estuaries. The estuary’s food-webs are based on the

eelgrass and algal communities of those flats. Besides the structural changes, which

impede the movement of much of the currently abundant wildlife, Spartina also changes

the very basis of the food webs that the native wildlife depends on.

Waterbirds speed up nutrient turnover in estuaries through digestion of plant matter and

defecation. Baldwin and Lovvorn (1994) found that waterfowl, especially brant,

accelerated nutrient regeneration through the excretion of large quantities of feces derived

from eelgrass that would otherwise decompose very slowly. Erwin (1996) also

recognized the importance of waterbirds and associated raptors as top-level consumers,

and critical links in nutrient flux in shallow-water estuaries.

Ducks using Willapa Bay are mostly widgeon; northern pintail; teals (Anus crecca

carolinensis, A. discors, A. cyanoptera); and mallards. Average annual duck use on the

Refuge is estimated to be 2.2 million use-days. Canada geese (Branta canadensis) around

the bay are mainly lesser (B. c. parvipes), tavenor (B. c. taverneri), cackler (B. c. minima),

and dusky (B. c. occidentalis) subspecies with fewer numbers of western (B. c. moffitti),

Vancouver (B. c. fulva), and Aleutian (B. c. leucoparia) subspecies. There are an

estimated 400,000 goose use-days per year on the Refuge. Black brant use is estimated at

about 200,000 use-days within the Presidential Proclamation Boundary and 800,000 usedays baywide annually.

Table 3 shows average waterfowl use at Willapa Bay from 1988-1992. Entries reflect use

on or immediately adjacent to Refuge lands and within the Proclamation Boundary (U.S.

Fish & Wildlife Service 1992).

TABLE 3. Average Annual Number of Waterfowl Use Days 1988-1992.

Swans Geese Brant Ducks TOTAL

Average 916 376,700 213,100 2,106,220 2,697,220

Source: U.S. Fish and Wildlife Service, Annual Narrative Report 1992.
109

3.3.2.2 Mammals

Few mammals use the proposed project sites. River otter (Lutra canadensis) may venture

into channels on the mudflats in search of fish. Small mammals such as shrews, mice, or

voles live in native saltmarsh vegetation and may be present in Spartina clones or

meadows in the high intertidal area above regular tidal inundation. Harbor seals use

channels for swimming and feeding, and haul out on sandy bars or islands throughout the

bay to rest. Other marine mammals generally use the deeper, more saline waters of the

northern end of the bay.

3.3.2.3 Threatened and Endangered Species

The following federally listed threatened (T) or endangered (E) Species may occur in

Willapa Bay and adjacent uplands: bald eagle (Haliaeetus leucocephalus), T; western

snowy plover (Charadrius alexandrinus nivosus), T; marbled murrelet (Brachyramphus

marmoratus marmoratus), T; Aleutian Canada goose, T; peregrine falcon (Falco

peregrinus), E; brown pelican (Pelecanus occidentalis), E; and Oregon silverspot

butterfly (Speyeria zerene hippolyta), T (USFWS 1995 & 1996a & b). The latter species

was last seen on the Long beach Peninsula in 1990 (WDW 1993). Stellar sea-lion

(Eumetopias jubatus), T; green sea turtle (Chelonia mydas), E; loggerhead sea turtle

(Caretta caretta), (T); and leatherback sea turtle (Demochelys corlacea), E (USFWS

1995 & 1996a & b) are considered rare visitors to Willapa Bay. If present, they would

use only the deepest, most saline waters at the north end of the bay.

During the spring, 1997, aerial survey, eight active bald eagle nests with incubating adults

were observed around Willapa Bay (Anderson, personal communication, 1997). Two nest

sites located on Long Island, near the largest Spartina meadows, were not active this year.

 Some of the active nests were up to one mile from water. Some were even further from

existing Spartina. Leadbetter Point has one of two nesting colonies of snowy plovers in

Washington. Small groups of plovers nest on the beach west of the mouth of the bay and

on a small island off Leadbetter Point. Federally proposed Critical Habitat for the plovers

occurs on the ocean beach at Leadbetter Point.

One Threatened plant, water howellia (Howellia aquatilis) may occur in freshwater

wetlands, ponds, or lakes in the vicinity of Willapa Bay.

3.3.2.4 Other Species of Special Concern

The Washington, D.C., office of Migratory Bird Management in the U.S. Fish and Wildlife

Service prepared a 1995 list of Migratory Nongame Birds of Management Concern in the

United States. The Western Washington Office (Olympia) of the U.S. Fish and Wildlife

Service identified Species of Concern occurring in the western portion of Washington

State in 1996. Species of Concern are those species whose conservation standing is of

concern to the Service, but for which status information is still needed. Of those Species

of Concern that occur at Willapa Bay, the northern goshawk (Accipiter gentilis), olivesided flycatcher (Contopus borealis), long-eared myotis bat (Myotis evotis), and longlegged myotis bat (Myotis volans) do not commonly use the intertidal habitat.
110

The State of Washington has its own Threatened and Endangered (T & E) Program and

associated lists of species. In addition to State-listed species duplicated in the Federal lists

above, the State has named candidate species for consideration for State T & E status. 

The following candidate species, which occur in Willapa Bay and adjacent lands, merit

special consideration: Pacific harbor porpoise (Phocoena phocoena), common loon

(Gavia immer), Brandt’s cormorant (Phalacrocorax penicillatus), pileated woodpecker

(Dryocopus pileatus), and western bluebird (Sialia mexicana) (WDFW 1994).

The Newcomb’s littorine snail (Algamorda subrotundata) is on the State candidate

species list and is considered a Species of Concern by the Service’s Western Washington

office. The snail is reported from Neah Bay, Washington to Humboldt Bay, California and

occurs in Willapa Bay. Over its range, habitat loss and pollution are thought to be the

greatest threats. The greatest known area and most secure habitat for this species appears

to be in Washington State. The snail is associated specifically with saltmarshes that have

pickleweed or Salicornia (WDFW 1995, USFWS 1996). So the snail is expected to be

present in the pickleweed zone of the high intertidal marshes, such as occurs in the south

end of Willapa Bay. Its pickleweed habitat is reduced by the invasion of Spartina into the

high intertidal.

While not listed, the Olympia oyster (Ostrea lurida) is native to the Pacific Northwest and

occurs in marine waters from Baja California, Mexico to Sitka, Alaska. Once common in

Washington, the Olympia oyster now has a restricted and very patchy distribution in

Willapa Bay, Gray’s Harbor, and southern Puget Sound, where it is locally abundant due

to mariculture activities. Olympia oysters are susceptible to significant population declines

due to their inclination to settle in discrete aggregations or reefs which are vulnerable to

disturbance, over-harvest and pollution (USFWS 1989, Dumbald 1997). Throughout

their range, habitat available to the native oyster, besides being naturally limited, has been

affected by human activities. Commercially, the Pacific or Japanese oyster (Crassotrea

gigas) is favored by mariculturalists because of its larger size, better marketability, and

ease of production (USFWS 1988). Both species are filter feeders, and rely on

zooplankton and phytoplankton. The gill openings are larger in Olympia oysters than

Pacific oysters and allow for selection of larger food items but do not allow the Olympia

oyster to consume very small plankton. Olympia oysters usually inhabit low intertidal flats

or small tidal channels where they avoid freezing or drying, conditions to which they are

sensitive if exposed for extended periods (USFWS 1989, Dumbald 1997). Their habitat is

threatened by Spartina as it spreads into lower intertidal zones.

Not listed, but of concern due to potential disturbance during nesting, great blue herons

(Ardea herodias), that regularly feed in the bay’s intertidal habitat, have historically used a

rookery located near Paradise Point on Long Island, adjacent to a large, dense meadow of

Spartina. This heronry has not been active in recent breeding seasons (1994-97)

(Williamson 1997). Willapa Bay is one of two major overwintering and migratory rest

areas for black brant in Washington. It is also a major migratory stopover or

overwintering area for tens to hundreds of thousands of waterfowl and shorebirds, several

of which have special management considerations. While the latter two groups are

susceptible to disturbances on the flats, conflicts will be avoided since control activities
111

will take place in summer, while peak numbers occur from fall through spring.

3.3.3 Fish

No comprehensive fish list is available for Willapa Bay. During a research project within

the southern units of the Refuge, Allard (1991) reported catches representing 12 different

species (Table 4 ) throughout one year of effort.
112

TABLE 4. Species and Numbers of Fish Caught in Southern Portion of Willapa

 Bay, March 1990 through February 1991.

SPECIES NUMBER

Shiner Surfperch (Cymatogaster aggregata) 1,564

Staghorn Sculpin (Leptocottus armatus) 434

Surf Smelt (Hypomesus pretiosus pretiosus) 394

Threespine Stickleback (Gasterosteus aculeatus) 372

Chum Salmon (Oncorhychus keta) 56

Northern Anchovy (Engraulis mordax) 6

Chinook Salmon (O. tshawytscha) 5

Starry Flounder (Platichthys stellatus) 5

Walleye Surfperch (Hyperprosopon argentem) 2

Pacific Herring (Clupea harengus) 1

Bay Pipefish (Syngnathus californiensis) 2

Saddleback Gunnel (Pholis ornata) 1

TOTAL 2,842

Source: Allard 1991 

3.3.4 Micro-Organisms and Other Marine Invertebrates

An important part of the biological environment of the bay is the plankton - the bacteria,

and tiny plants and animals living in the water and mud. They combine and convert the

many nutrients of the estuarine waters into living matter and more nutrients. Because they

are so fundamental an aspect of the overall environment, they are considered an inherent

part of the water column itself (Shotwell 1977).

Hedgpeth and Obrebski (1977) consider Willapa Bay as perhaps the most productive bay

on the U.S. Pacific Coast. It provides an optimum environment for many estuarine

species. Rivers and streams bring minerals and nutrients in terrestrial runoff. Plant matter

from saltmarsh plants and eelgrass community is broken up and transported throughout

the bay by waves and tidal actions. Invertebrates, waterfowl, fish, and plankton further

decompose some of the detritus and deposit recycled nutrients. The resulting rich soup of

nutrients is food to various filter-feeding and scavenging invertebrates including plankton,

clams, oysters, shrimp, and crab.

Zipperer (1996b) found that invertebrate species composition and total numbers are

different in Spartina patches and open mudflats in Willapa Bay. Adjacent mudflats have

higher total invertebrate densities and lower taxa richness late in the season (August) but
113

lower total densities and similar taxa richness to Spartina early in the season (April). The

benthic invertebrate assemblage of the mudflats are characterized by a dominance of

crustaceans, polycheates, and mollusks (important shorebird foods), while characteristic

assemblages in Spartina patches were polychaetes, oliochaetes, and dipteran larvae (not as

important an assembly of foods).

3.3.5 Biodiversity

In simplest terms, biodiversity is the variety of life and its processes. Murphy (1988) used

Wilcox’ description of biodiversity: “the variety of life forms, the ecological roles they

perform, and the genetic diversity they contain.” It is highest when there are many wellrepresented species in a place. It is lowest in places with little variety of well-represented

species, or where one or a few species dominate. Biodiversity supports the stability,

integrity, and resilience of ecological systems. In this document, biodiversity is applied at

the species and community level. Willapa Bay tidelands provide crucial habitat for diverse

communities of birds, fish, and invertebrates. But the bay’s insular nature and relatively

low plant diversity also make it vulnerable to exotic species invasions.

3.4 SOCIAL ENVIRONMENT

3.4.1 Cultural

The proposed project area is entirely uninhabited tidal flats of Willapa Bay. Swan (1982)

relates several areas that were inhabited, considered sacred places, or were meaningful in

the lore of the Native Americans of Shoalwater Bay in the mid-1800s. No known

historical or archeological sites occur in Refuge-owned lands proposed for Spartina

control. Abramowitz (1980) inventoried portions of the southern units, south of the dike

that separates intertidal flats from the freshwater wetlands. No evidence of any cultural

resources was found during the inventory and he noted none had been found previously. 

No further inventories have been done in the area.

Abramowitz surmised that better locations for camps or villages of Shoalwater Chinooks

existed further up the Bear River or elsewhere in the south end of the bay. Bear River and

Tarlatt Slough were identified as the northern termini for portage routes between the

Columbia River and points north for trading purposes by Chinook Indians.

Cook and Jordan (1994) noted that 489 residents of Pacific County were identified as

“American Indians” in the 1990 census. Approximately 180 members of the Shoalwater

Tribe live on approximately 1,000 acres near the base of the Tokeland Peninsula at the

north end of the bay.

There are claims by Native Americans that much of the land along the lower Columbia

River and on Willapa Bay was never legally transferred to the United States (Chinook

Tribal Council 1996). The Refuge was established by Executive Order in 1937. Refuge

purposes have been established by Executive Order and legislation and are summarized in

part 1.2 of this EA. In the absence of contrary legal direction, the Service is obligated to

abide by such Executive Orders and Federal Statutes.
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3.4.2 Social

The proposed project site lies entirely in Pacific County, Washington. The population of

this mostly rural county in 1993 was 19,800 (Cook and Jordan 1994). Communities on

Willapa Bay include Oysterville, Nahcotta, Bay Center, South Bend, Raymond, and

Tokeland. Other nearby communities on the Long Beach Peninsula are Ocean Park, Long

Beach, Seaview, and Ilwaco. South Bend is the county seat.

The population of Pacific County is aging. The average age of its citizens is the highest of

any county in the State. Between 1990 and 1993 the county had more deaths than births.

 There was a substantial increase in residents over the age of 59 as a result of retirement

and near-retirement migration in addition to aging of younger residents (Cook and Jordan

1994).

3.4.2.1 Human Health

Compared to the State as a whole, Pacific County has statistically higher, age-adjusted

lung cancer deaths and heart disease rates. It has lower rates of breast cancer and higher

rates of teen pregnancy (Spoor 1997). These and other such statistics will be presented in

a document on Pacific County health status which is scheduled to be available in the

summer of 1997. The document will consider data from the early 1980s through 1995.

There is no indication of local environmental causes for Pacific County's differences in

health statistics (Spoor 1997, Harrison 1997). 

In the early 1990s, the Shoalwater Bay Tribe experienced an extremely high level of prenatal complications and infant mortality. In response, the tribe called for improved access

to health care and a major effort to evaluate the potential social and environmental causes

of their health problems. A health care facility was completed and opened in 1995. Also

in 1995, a limited assessment of some potential pollution sources in the vicinity of the

reservation was carried out by the EPA's Regional Laboratory in cooperation with its

Washington Operations Office. The limited assessment involved a relatively small number

of samples collected and analyzed at one point in time. Sampled during the assessment

were: 1) an abandoned dump site one mile west of the reservation; 2) drainage from

nearby agricultural runoff; 3) adjacent tideflats (tested for carbaryl, glyphosate, septic

system effluents, and other organic or inorganic contaminants); and 4) drinking water. 

While the study found several pesticides exceeding federal and state water quality

standards in drainage from cranberry bogs, sediment samples from the tideflats were

relatively clean. The study did not reveal a link between infant mortality and

environmental conditions (USEPA 1997). Glyphosate was not detected in sediment

samples collected for the EPA Limited Environmental Assessment; however, little

chemical control of Spartina had been attempted in Willapa Bay prior to sample collection

for this study. 

Public agencies that can be contacted concerning environmental contamination in Pacific

County are Pacific County Department of Community Development and Pacific County

Department of Public Health. In addition, agencies that can be contacted concerning

environmental contamination associated with applications of agricultural chemicals on

Willapa Bay are the Washington State Department of Agriculture, Pesticide Management
115

Division and the Washington State Department of Ecology, Office of Water Quality, both

in Olympia. Willapa NWR Headquarters office can be contacted by phone for information

on scheduled applications of herbicides on the Refuge.

While saltmarsh mosquitos were undoubtably a part of the Willapa Bay's insect community

prior to Spartina's introduction, older Spartina meadows provide habitat that may favor

mosquito larval development (pools with poor tidal circulation and an absence of

predatory fish). Major programs for the control of saltmarsh mosquitos on Spartinadominated east coast saltmarshes have been in place for decades (Wolfe 1996). Such

programs have involved the use of chemicals and environmentally disrupting ditching

systems. There is currently no saltmarsh mosquito control program on Willapa Bay.

Spartina is a wind-pollinated grass that is expanding over mudflats on which no windpollinated species formerly existed. Therefore, it is expected that Spartina is contributing

additional pollen to the atmosphere from late July through September. As with many

grasses, there would likely be people that are allergic to Spartina pollen.

3.4.2.2 Concerns

Some members of the local community, and society as a whole, perceive the use of 

chemicals, such as herbicides, to be an unreasonable threat to human health and/or the

natural environment. They strongly object to the use of any herbicide to control Spartina

in Willapa Bay. People with chemically sensitivities are concerned about potential effects

should airborne sprays drift inland onto the peninsula.

Some landowners are concerned about the effort needed for control and the costs of

control on their property.

3.4.2.3 Recreation

Recreational uses of the bay include motor-boating, kayaking, canoeing, sailing, hunting,

fishing, clamming, wildlife viewing, and camping. The Refuge allows camping on Long

Island, a popular kayaking destination, which has five primitive campgrounds and hiking

trails. Because of shallow water depths, large tidal ranges, swift currents, frequent high

winds, and changeable weather patterns in the bay, all forms of boating are limited both

spatially and temporally. Most boating occurs at higher tidal stages. Within the bay,

recreational clamming is limited to public lands with firm sandy substrates, primarily along

the west shore of Long Island.

Waterfowl hunting and wildlife viewing are primarily land-based and occur along the dike

and saltmarsh areas in the Refuge’s southern units and tidal flats adjacent to the

Leadbetter Point Unit. Since 1991, an average of about 250 hunters has used these areas

annually. There is also goose hunting at blinds in upland fields of the Reikkola Unit. The

Riekkola Unit goose hunt has averaged about 120 participants annually since 1991. Long

Island supports an archery hunt for deer, elk, black bear and grouse. The average annual

use for Long Island since 1991 is about 185 hunters. No quantitative information is

available for other baywide recreational uses associated specifically with tidelands.
116

3.5 ECONOMIC ENVIRONMENT

Tourism, logging, lumber manufacturing, oyster harvesting, seafood canning, crabbing,

commercial and sport fishing, dairy farming, stock raising, and cranberry growing have

been the historical bases for the economy of Pacific County (Pacific County n.d.). 

Cook and Jordan (1994) stated that the County’s economy was more dependent on

employment in forestry, fisheries, manufacturing, and personal services than the state as a

whole in 1990. Employment in distributive, social, and particularly producer services was

under-represented in Pacific County by comparison. The median income per household in

Pacific County was $20,029 in 1989. This was a drop of 15.2 % from 1979 as measured

in 1989 dollars.

A few residents in Nahcotta have experimented with production of paper from Spartina. 

Initial results indicate that Spartina paper may be a quality product as a specialty paper

(Washington State 1993). Spartina paper has remained in a low-volume niche market and

is used primarily in novelty cards or specialty objects. Spartina paper products may be

suitable for use in crafts and as packing material, flooring, or room dividers.

In Washington, Spartina is listed as a “class B” noxious weed with mandatory control in

designated areas, including private property. In Pacific County, five management units at

the north end of Willapa Bay are mandated for control by the County Weed Board. In all

other areas, control of Spartina is optional. Control is expensive, while the presence of 

Spartina may lower economic return and property value. The Washington Department of

Agriculture has a 50/50 cost-sharing program with private landowners, while the Farm

Services Agency offers a 75/25 Federal/private cost-share program for Spartina control

efforts.

3.5.1 Tourism

The tourism industry is growing both worldwide and within the Pacific Northwest. 

Tourism is the second largest industry in the world. Since 1988, all tourism has grown at

a 4% annual rate while ecotourism has expanded at a 30% annual rate (Peterson 1996). 

Tourism is also growing rapidly in importance to the local economy, especially on the

Long Beach Peninsula. Personal services in tourism-related businesses, and especially

eating and drinking places, had the largest percentage of growth in employment between

1980 and 1990 (Cook and Jordan 1994). No information is available on the how much

money the tourism industry contributes to the local economy.

A fast growing segment of tourism is travel with nature as a principal objective, sometimes

known as nature-based tourism (Peterson 1996). A tour boat company operating from

Nahcotta offers tours around Long Island in Willapa Bay. A second tour operation has

been proposed for the bay, but its status is uncertain at this time.

The Long Beach Peninsula Visitors Center in Seaview had about 500 (winter) to 5,000

(summer) visitor log entries annually from 1989 to 1995. Visitors are drawn to the

Peninsula primarily for recreational activities associated with the ocean beaches and
117

secondarily for those associated with Willapa Bay.

There are two museums, 10 historic sites, and 20 parks or other recreational facilities in

Pacific County, including Willapa NWR; Fort Canby, Fort Columbia and Leadbetter State

Parks; and Bush Pioneer and Bruceport County parks (State of Washington n.d.).

3.5.2 Mariculture and Fisheries

Many of the private tidal flats in the bay are managed as oyster mariculture sites. Pacific

and neighboring Grays Harbor counties are home for two-thirds of the oyster industry in

Washington (Conway 1991). Washington Department of Fish and Wildlife (Hoines 1996)

reported a five-year average of 462,000 gallons of Pacific oysters harvested in Pacific

County. In Pacific County, the oyster growing and processing industry employed 480

workers with a total labor income of $6.3 million, accounting for one out of every twelve

jobs in 1990 (Conway 1991). Companies processing fish, shrimp, and crab, but not

oysters, employed another 260 to 330 individuals in the County in 1990 (State of

Washington n.d.).

The stability of the oyster mariculture industry in Willapa Bay is threatened by two types

of burrowing shrimp, the ghost and mud shrimp. The shrimp affect oyster production by

smothering of “seed” and adults, competition for food resulting in reduction in growth

rates and/or condition, and operational difficulties at harvesting. Since testing by State

and Federal agencies in the early 1960s, carbaryl (Sevin ®) has been used to control ghost

shrimp in the bay.
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4.0 ENVIRONMENTAL CONSEQUENCES

4.1 INTRODUCTION

This chapter forms the scientific and analytical basis for comparisons of the alternatives

considered in this document. It is organized by alternative. It discusses the alternatives in

the same order as Chapter Two and the resources and issues in the same order as Chapter

Three. It addresses direct and indirect effects of each alternative.

4.2 EFFECTS OF NO ACTION ALTERNATIVE

4.2.1 Physical Environment

Continued transformation of open tidal flats to raised Spartina marsh would change the

physical structure of the environment and alter estuarine functions in ways not yet fully

understood. It is predictable that changes in vegetative structure and topographic relief

would affect tidal and stream flow velocities and current patterns, sedimentation rates and

patterns, fresh and salt water mixing patterns, water quality and chemistry, temperatures,

and salinity levels in the proposed project area.

4.2.1.1 Soils and Topography

Sediment buildup and changes in substrate composition and topography would continue

over an ever-increasing portion of Refuge lands. Mudflats would continue to be raised

and thus converted to high intertidal marshes. Instead of gradually sloping flats, the surface level within Spartina marshes would be raised, creating sharp dropoffs along drainage

channels sides. Channels would cut deeper with more concentrated currents and increased

flows.

Spartina stems and rhizomes would continue to trap and accumulate sediments from tidal

flows and terrestrial runoff until an equilibrium is achieved. Sediments in Spartina

marshes would consist of a higher proportion of softer, finer-grained particles such as silts

and clays than open mudflats (State of Washington 1993, Zipperer 1996b). Thus, the

proposed project area would continue to have a very soft, silty substrate. With the

entrapment of sediments in Spartina marshes, there could be a concurrent reduction in

sediment input in open areas of the bay.

It has been suggested that Spartina's ability to accelerate sediment deposition may help to

bury, and thereby isolate, radioactive material transported to Willapa Bay in the 1950s and

1960s from the Hanford Nuclear Site via the Columbia River plume. Normal sediment

deposition and radioactive decay processes (some materials have very short half-lives)

have already promoted attenuation of the effects of radioactive materials (Young 1997). 

A recent report on radioactivity in Columbia River sediments done by the Washington

State Department of Health concluded that the human-caused radionuclide concentrations

found in Columbia River sediments do not pose a significant human health risk

(Washington State Department of Ecology 1995). Given this, it appears unlikely that

Spartina-induced sedimentation would contribute substantially to improving human health

in this regard.

4.2.1.2 Hydrology
119

Tidal and runoff flow velocities and patterns across Refuge tidelands would be affected as

currents are reduced or diverted by dense Spartina vegetation, increased sedimentation,

and stabilized sediments. As more sediments deposit in larger areas of Spartina,

transformation of the mudflats' configuration would continue. Natural flow patterns

would be altered as tidal flats build up and deep, steep-sided, tidal channels form. With

the restricted runoff along drainage channels, the frequency of and potential for flooding in

low-lying areas landward of Spartina meadows might increase, especially at high tides

during major storm events. As Spartina becomes more widespread and denser over time,

flood-control dikes would possibly be exposed to higher, storm-tide levels for longer

durations, which could lead to erosion of the dikes.

Emergency dredging at the entrance of Willapa Bay is proposed to stabilize erosion

occurring at North Cove. It is not known exactly what effects this alteration of tidal

currents and flow patterns in the bay would have on dispersal of Spartina propagules. But

with ever-increasing seed production in the absence of Spartina control and altered flow

patterns with the dredging, the potential for establishment of Spartina in new areas both

within and outside the bay could increase.

4.2.1.3 Water Quality

Few studies have evaluated the effects of Spartina vegetation on water quality. The State

EIS expressed the following ideas: Surface water temperatures would increase in shallow

areas with restricted flow. Salinity could increase or decrease locally depending on the

effects on rates of evaporation and mixing of fresh and salt water. Levels of dissolved

oxygen might decrease locally due to decomposition of Spartina litter after seasonal die

back while water quality might improve in some areas because of the cordgrass trapping

suspended sediments or filtering pollutants. 

Beginning in the spring of 1997, the Washington Department of Ecology is conducting an

EPA-funded project to study water quality parameters in Willapa Bay. Water

temperature, dissolved oxygen, nutrients, chlorophyll, pH, light transmission, and

turbidity, as measured by Secchi disk depth, will be measured at six locations (Newton

1997).

4.2.1.4 Ambient Sound

There would be no changes in ambient sound levels with the No Action Alternative.

4.2.1.5 Air Quality

Since fossil fuels would not be burned and chemicals would not be applied to control

Spartina, air pollution from these sources would not occur. However, unchecked

Spartina expansion would result in higher pollen counts in late summer (also see 4.2.3.1.).

4.2.2 Biological Environment

The continued conversion of intertidal mudflat communities and saltmarsh vegetation in

the project area to Spartina marsh would result in the loss of open mudflats, eelgrass and

macroalgae beds, and native saltmarsh vegetation. This, in turn, would affect the numbers

and species composition of birds, fish, and invertebrates that live, feed, or otherwise use
120

the mudflats. Increasing amounts of airborne pollen during Spartina flowering season

would continue.

4.2.2.1 Vegetation

Seagrass and macroalgae beds on mudflats in the project area would be displaced by

Spartina. At higher elevations in the estuary, native saltmarsh vegetation would

sometimes be replaced as Spartina meadows invade native marshes. As the level of the

bay’s bottom rises due to accretion of sediments, some native plant species may be reestablished within the Spartina meadows at higher elevations.

With no Spartina control, all native saltmarsh and mudflat vegetation is at some risk of

Spartina intrusion and replacement. With the No Action alternative, Spartina is expected

to dominate all intertidal mudlats and displace about half of the existing native saltmarsh

vegetation in the Refuge’s southern units within 10 years. Where it is already strongly

established around Long Island, Spartina would complete its dominance of all intertidal

mudflats and convert about half of the existing native saltmarsh in 5 years. Lack of

control for Spartina seed production on Refuge lands would contribute to its continued

spread and interfere with control efforts on other lands throughout the bay.

Although no figures are available on the acreage of seagrass and macroalgae beds in the

project area, most of the intertidal flats currently without native saltmarsh or Spartina

support some level of seagrass and macroalgae growth which are vulnerable to Spartina

invasion.

4.2.2.2 Spartina

No control of Spartina would allow its continued vigorous spread and establishment

throughout the project area. Larger clones and meadows would grow and dominate areas

that currently have only seedlings and small, scattered clones. Spartina-dominated

acreage on Refuge land would likely increase to 4,000 acres within the next 10 years. 

Seed production would occur on meadows and larger clones. More seed production

would foster Spartina spread onto flats on and off the Refuge. Spartina would displace

native marsh plants and seagrasses and macroalgae beds as described above. 

The incidence of viable seeds and propagules transported out of Willapa Bay and

establishing new Spartina colonies in other coastal tidelands would be expected to

increase. In recent years new seedlings have been found in Grays Harbor. It is presumed

that viable seed is transported out of Willapa Bay attached to spikes in floating mats of

Spartina. The northward, nearshore ocean current, tidal flows within estuaries, and the

ability of these Spartina mats to float for many weeks potentially exposes much of the

coast of Washington and British Columbia to Willapa's Spartina (Sayce 1997).

Some particles, including pollutants may settle out of the water column into sediments

accreted by Spartina. Some shorelines with high-energy, shallow flats supporting large

Spartina clones or meadows may be less erosion prone due to dissipation of wave energy

by the plants. The basis for the food webs in Willapa Bay will be changed from seagrass

and benthic microalgae to Spartina detritus.
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4.2.2.3 Wildlife

No Action would contribute to further decline or loss of habitat value for migratory

waterfowl and other waterbirds on tideflats on and off the Refuge. Physical displacement

or degradation of habitat for several species of waterfowl, shorebirds, and other

waterbirds would occur. Most of the foraging habitat for shorebirds on the Refuge would

be eliminated within 10 years. Black brant, Canada geese, and American wigeon, northern

pintail, and mallard ducks would be especially impacted by the loss of eelgrass

communities. Open-water feeding birds, such as loons, grebes, and diving ducks, would

be precluded from using areas of Spartina marsh except when extreme high tidal

conditions allowed them to swim over the tops of the plants.

Shorebirds that feed on open mudflats, such as the large flocks of sanderlings (Calidris

alba), western (C. mauri) and least (C. minutilla) sandpipers, and dunlins (C. alpina)

would avoid dense Spartina marshes. Goss-Custard and Moser (1988) found that during

the decline in numbers of dunlin in the British Isles, the greatest declines occurred in

estuaries where cordgrass (S. anglica) had spread most over the intertidal mudflats on

which the birds fed. In estuaries where the extent of Spartina had not changed, the

numbers of dunlin did not show a statistically significant decline, with the exception of a

few small outlying estuaries. At Dyfi estuary, on the coast of Wales, Davis and Moss

(1982) noted a “close temporal correlation between the expansion of Spartina (anglica)

and a steep decline in numbers of certain waders.... There seems to be no other obvious

reason for the decline in wader numbers, which is much greater than any national or

regional trend.” Millard and Evans (1982) stated that dunlin and other flocking species at

Lindisfarne, Northumberland, England are likely to prefer feeding on the open mud, if

food is available there, than among Spartina (anglica) clumps. Avoidance of the Spartina

zone may be connected with flocking behavior which acts as an anti-predator device and

permits individuals within the flock to feed more efficiently. They also found that the

shorebird most commonly found in dense Spartina was the redshank (Tringa totanus). 

But no more than 15% of the local population of that species occurred in the Spartina

habitat at one time. They added that the high density of Spartina stems likely prevents

birds from landing easily and restricts their movement on the ground. Most individual

birds within Spartina were feeding on the few small patches of open mud within the

Spartina. It is not known what other environmental factors, if any, may have affected

these populations.

Populations of invertebrate prey species for shorebirds would also be altered in Spartinainfested areas. Zipperer (1996b) found benthic invertebrate assemblages dominated more

by prey species favored by shorebirds on mudflats (crustaceans, polycheates, and

mollusks) than in Spartina patches (dipteran larvae, oliocheates, and polycheates) at

Willapa Bay.

No studies have been conducted to determine use of West Coast Spartina areas by wading

birds such as herons and bitterns. Sayce (1994) observed both groups of birds feeding in

Spartina stands in Willapa Bay. Great blue herons would feed in shallow water along the

edges of Spartina marshes when tide levels permitted. However, this habitat would be
122

lost over time as the channel depth increased and channel banks became steeper. They

may also use non-vegetated tidal pools within patchy Spartina vegetation. More secretive

waders such as American bitterns (Botaurus lentiginosus) and green herons (B. striatus)

might utilize the cover of Spartina to feed, if the right prey species were available.

Threatened bald eagles would continue to lose feeding habitat.

The Newcomb’s littorine snail, a Federally recognized Species of Concern and State

Candidate Species, which is thought to live on pickleweed plants in the native saltmarsh in

Willapa Bay (WDFW 1995, USFWS 1996), could lose habitat as Spartina crowds out

native vegetation.

4.2.2.4 Fish

Replacement of intertidal mudflats, eelgrass beds, and native saltmarsh vegetation with

Spartina marsh would likely have mixed effects on fish use within the project area

depending on the species and life stage. Loss of mudflat, eelgrass, and macroalgae habitat

would negatively impact those fish species that depend on these areas for feeding,

spawning, or rearing habitats. In addition, prey populations and composition, particularly

of benthic fauna and their consumers, would likely differ greatly between the native

environment and that of the exotic Spartina marsh (Zipperer 1996b). The ultimate effect

of such changes in food-web dynamics on fish populations is not fully known (Washington

State 1993).

Small to medium clones or the edges of large clones and meadows of Spartina would

provide cover or feeding habitat for some fish species and particular life stages of other

species. For example, salmon smolts may use the cover of these areas during their

transitional stage in the estuarine environment. However, feeding by juvenile salmon

might be limited in Spartina because favored prey species (such as bottom-dwelling, filterfeeding invertebrates) may not survive in the fine, soft sediments trapped by Spartina

(State of Washington 1993). A study of outmigrating juvenile chum salmon in Hood

Canal determined that eelgrass and its associated algae are the basis of the food web for

this species in the estuary (Simenstad and Wissmar 1985 in Thom 1987 cited in

Washington State 1993). Returning adult salmon would not be able to use tidal flats

covered by dense Spartina marsh and would be limited to the deeper channels that remain

clear of Spartina.

As Spartina clones grow into large dense meadows, the temporary value of the smaller,

isolated clones would be permanently lost. Only small fish would be able to penetrate

deep into the marsh and would probably do so only if sufficient amounts of food were

available. The University of Washington and the Washington Department of Fish and

Wildlife are continuing research into the use of Spartina clones of various sizes by fish in

Willapa Bay. The studies will allow better specification and quantification of anticipated

effects on fish. Early results show that fish use is limited to the edge of smaller clones

(Fresh et al 1996).

With the No Action alternative, the incremental growth of Spartina in large clones and
123

meadows would cause a corresponding loss of fish habitat for some species due to the

expansion. Use by those fish would be expected to decrease accordingly throughout the

project area. Ultimately all tidal habitat on the project area except for deeply incised, open

channels and their Spartina marsh edges would be lost for those species that depend on

open water, eelgrass, algae, or mudflat communities to meet one or more of their life

requirements.

4.2.2.5 Microbes and Marine Invertebrates

The dense root mat and thick layer of soft, fine sediments associated with Spartina

marshes would preclude colonization by and the survival of many shellfish and other

invertebrates that commonly occur in tidal mudflats, or seagrass and macroalgae beds

(Washington State 1993). Thus, populations of some species would decline in areas with

extensive Spartina infestations. A preliminary investigation to assess the impacts of S.

alterniflora to benthic invertebrates in Willapa Bay showed, in some cases, decreases in

numbers or absence of species in areas colonized by expanding Spartina clones compared

to adjacent “bare” flats (Atkinson 1992). Zipperer (1996b) found that benthic invertebrate

species in Spartina patches were characterized by dipteran (fly) larvae, polycheates, and

oliocheates, while mudflats had a dominance of crustaceans, polycheates, and mollusks at

Willapa Bay.

An increase in the number of salt water mosquitos and flies (diptera) would result from

topographic changes associated with sediment accretion (State of Washington 1993,

Zipperer 1996b).

4.2.2.6 Biodiversity

It is expected that, with the development of large, monotypic stands of non-native

Spartina, the diversity of plants, invertebrates, birds, and fish would decrease over much

of the bay’s affected tidal flats. This loss of diversity in the bay due to Spartina spread is

not quantified.

4.2.3 Social Environment

Implementation of the No Action alternative in the proposed project area would affect

adjacent property owners, wildlife viewers, hunters, and other recreationists on Refuge

lands through adverse changes in access or wildlife habitat by the rapid spread of Spartina.

4.2.3.1 Human Health

The growth of Spartina would be expected to result in increases in saltwater mosquitos

(Washington State 1993), flies (Zipperer 1996b), and airborne pollen. Discomfort from

mosquito bites would be more common in the vicinity of Spartina marshes. People who

use the mudflats with Spartina marshes would be subject to more mosquito bites with a

possible increase in exposure to vector-borne disease. Large-scale mosquito control

efforts, like those at many East Coast communities adjacent to Spartina marshes, may

become necessary. Local mosquito-related nuisance complaints could precipitate the

creation of mosquito control districts (as on the East Coast) to conduct control efforts on

the bay, possibly including the use of larvicides. Larvicide use would generate concerns

about potential impacts on water and air quality, human health, and fish, wildlife and their
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habitats. Pollen-related allergic reactions in people around the bay and particularly on the

predominately downwind east side would be expected to increase.

4.2.3.2 Concerns

Concerns about the use of chemicals to control Spartina on the Refuge would be

alleviated. Concerns about the spread of Spartina would not be addressed. An increasing

concern about mosquito control including the use of larvicide might develop.

4.2.3.3 Recreation

Although there have been no studies of changes in recreational uses due to Spartina,

recreational opportunities in the bay would be reduced by increased Spartina growth on

the mudflats. It is reasonable to assume that reduced access to open water and mudflats,

loss of navigation routes, loss of wildlife habitat, alterations to estuarine functions, and

visual barriers would result from continued Spartina growth (Washington State 1993). 

Such changes would eventually result in substantial negative impacts to recreational

activities including sport fishing, waterfowl hunting, wildlife viewing, recreational shellfish

harvesting, and boating on tidelands and associated waters. It is not known how many of

the approximately 14,000 annual Refuge visitors (US Fish & Wildlife Service unpubl.

data) would be affected.

4.2.4 Economic Environment

Even though the Refuge’s purpose is not intentionally linked to the regional or local

economy, the Refuge is none-the-less connected to economic issues through its influence

on tourism and the bay’s environment. Economic uses based on an open-water,

unrestricted mudflat environment would decline.

If an economy based on use of Spartina such as paper making along with an

environmentally safe harvest method was developed, it might be used to manage a portion

of the Spartina in the bay and reduce some of the environmental impacts associated with

the plant’s spread.

4.2.4.1 Tourism

Uncontrolled Spartina growth would eventually impact tourist activities by limiting or

eliminating the recreational opportunities mentioned previously. Nature-based tourism in

the bay would be impacted as recreational opportunities are reduced. Many out-door

activities might be negatively affected by an increase in saltmarsh mosquitos. This, in turn,

could reduce visitation and tourist dollars spent at local businesses on the Long Beach

Peninsula. It is not known what these costs would ultimately be for the businesses.

4.2.4.2 Mariculture and Fisheries

Although no commercial operations would be directly affected by a lack of Spartina

control on Refuge-owned or managed lands, indirect effects are anticipated. If Refuge

lands support large areas of Spartina, the seeds produced would increase the cost of

controlling Spartina on other tidelands. On many of these lands, oyster mariculture or

other shellfish harvest is the primary use. The growth of Spartina can greatly hinder or
125

prevent shellfish production or harvest. On marginal shellfish grounds, the cost of

controlling Spartina can easily exceed the value of the land (Sheldon 1997). Added to this

is the concern that as control of Spartina is mandated on more areas by the local noxious

weed control board, some tideland owners may be forced to choose between control

efforts (with costs in excess of the value of their land) or relinquishing their titles to the

county or state. Long-term impacts to maricultural economies would depend on the

feasibility of large-scale use of longline, rack, or other suspension methods of oyster

culture compatible with Spartina presence.

Uncontrolled Spartina growth in the bay could affect commercial fisheries through longterm changes in habitat, and production of fish and shellfish, or the harvest thereof. 

However, the importance of the changes or the effects on commercial species cannot be

predicted with existing information.

NOTE: For more discussion of the consequences of the No Action Alternative, see pages

91-100 and the Element C report of the State FEIS on Noxious Emergent Plant

Management, 1993.

4.3 EFFECTS OF INTEGRATED PEST MANAGEMENT ALTERNATIVE (IPM)

 (PROPOSED ACTION)

The Integrated Pest Management (IPM) alternative allows for the selection of one or more

methods to meet site-specific requirements to maximize efficacy and minimize impacts to

non-target biota. Within a site, variation in environmental sensitivity can be addressed

through use of a combination of methods for Spartina control. For example, it is

important to control Spartina clones that have been identified as major producers of viable

seed. While such clones are at a growth stage that would be particularly vulnerable to

herbicide application, location, tidal conditions, or weather may make this technique

ineffective or risky to nontarget organisms. In such cases mechanical methods could be

used exclusively or to preserve options for later effective herbicide treatment.

In general, impacts from two or more methods likely would be the sum of impacts

associated with individual methods (sections 4.4 and 4.5) as well as potential cumulative

impacts, particularly disturbance of surrounding vegetation and mudflats. However,

greater efficacy of combined treatments ultimately would result in less long-term

disturbance than would be associated with repeated applications of individual methods. 

For example, mowing followed by herbicide application appears to be more effective in

controlling small to medium-sized Spartina clones and, therefore, fewer treatments

ultimately would be required to achieve the desired control. Fewer treatments means

reduced impacts to surrounding vegetation or mudflats and/or less herbicide used than

with mechanical or chemical means only.

IPM would provide the greatest baywide control of Spartina through control of seed

production and the Refuge’s ability to work cooperatively with other tideland owners. 

Furthermore, IPM’s potential to incorporate future technological advances in mechanical,

chemical, and biological control techniques has by far the greatest potential for accelerated
126

control.

4.3.1 Physical Environment

4.3.1.1 Soils and Topography

The sediment buildup and changes in substrate composition and topography resulting from

Spartina growth would be slowed or halted in control areas in the shortest amount of

time. This would result in more normal movement and distribution of sediments in the

water column. The existing mudflat topography would be preserved where Spartina

seedlings are removed.

At treated sites, some erosion and transport of sediments might occur. Tidal action, wind,

waves, and currents might cause erosion and redistribution of fine particles in treated

areas. The extent of erosion would depend upon the magnitude of tidal exchanges,

frequency and intensity of storms, and size of the area treated. Because roots of treated

Spartina might take several years to decay and allow erosion, eroded sediment would not

contain measurable quantities of glyphosate or adjuvant. Erosion may be minimized

through colonization by native species.

Control operations might result in temporary increases in sediment load in the water

column due to disturbance of the substrate and erosion of previously accreted sediments

where clones were killed. The weight of people and equipment might cause temporary

localized compaction of substrates.

Glyphosate is not environmentally persistent and would not accumulate within sediment

from ground applications of Rodeo® tank mixes. Kroll (1991) found that glyphosate

concentrations in sediment of tidal marshes treated by hand-held sprayer with Rodeo®

(0.75% solution) and Arborchem Aquatic surfactant (0.5% solution) declined 88% by 56

days post-treatment. For Spartina clones treated by a hand-held sprayer with Rodeo®

(5% solution) and LI-700® (2% solution) in Willapa Bay, average concentrations of

glyphosate in substrates underneath Spartina declined 14% (1.39→ 1.18 ppm DW [dry

weight]; North River) and 29% (2.23→ 1.58 ppm DW; Lewis Unit on the Refuge) to 43%

(3.60→ 2.05 ppm DW; Nemah Beach) and 73% (5.31→ 1.44 ppm DW; Leadbetter Point)

for muddy and sandy substrates between spray day and 30 days post-treatment,

respectively (Major and Grue 1997). After 1 year post-treatment, glyphosate

concentrations from treated clones with the highest concentrations at 30 days after

application ranged from 0.088 to 0.772 ppm DW and 0.134 to 1.84 ppm DW for sandy

(Nemah Beach) and muddy substrates (Lewis Unit on the Refuge), respectively (Major

and Grue 1997). Greater declines in glyphosate concentrations occurred for sandy

substrates because less glyphosate likely was translocated to Spartina rhizomes

incorporated into sediment samples. Application rates were 14 (Leadbetter Point) to 47

liters/ha (Nemah Beach) and 54 (North River) to 63 liters/ha (Lewis Unit on the Refuge)

for clones on sandy and muddy substrates, respectively.

Glyphosate also would not accumulate within sediment from aerial applications of

Rodeo® tank mixes. Paveglio et al. (1996) found that average concentrations of
127

glyphosate in sediment directly exposed to spray significantly declined (51%

[1.16→ 0.563 ppm DW] to 72% [2.82→ 0.799 ppm DW]) 119 days after aerial

application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1 liter/ha) to control

Spartina in Willapa Bay. Average concentrations of glyphosate in sediment

underneath Spartina declined (31% [0.420→ 0.290 ppm DW]) 30 days after aerial

application of Rodeo® (8.8 liters/ha) and X-77® Spreader (1.2 liter/ha) to a

Spartina meadow in Willapa Bay (Major and Grue 1997). For sampling locations

within this treated meadow with the highest concentrations 30 days after

application, glyphosate levels ranged from 0.088 to 0.404 ppm DW at 1 year posttreatment (Major and Grue 1997). Feng et al. (1990) reported a 92 to 96%

decline in glyphosate concentrations 360 days after aerial application of Roundup®

(2.0 kg/ha glyphosate) to a watershed in a Canadian forest.

Alkylphenol polyethoxylates, the principal active ingredient potentially hazardous

to fish and wildlife within X-77® Spreader (nonylphenol polyethoxylates) and R11®

 Spreader Activator (octylphenol polyethoxylates), also would not accumulate

within sediments because they undergo rapid and complete primary degradation

(Naylor 1992). Alkylphenol polyethoxylates degradation occurs through

shortening of the ethoxylate chain by microbial activity (Swisher 1987), which

produces polyethylene glycols that are biodegradable and less toxic than the

precursors (Conway et al. 1983). Extensive biodegradation (>90%) occurred

within 14 days post-treatment for shake-culture tests where nonylphenol

polyethoxylates were placed in flasks with a bacterial-inoculated medium

(Huddleston and Allred 1965, Lashen et al. 1966). In contrast, Paveglio et al.

(1996) found that average concentrations of nonylphenol polyethoxylates in

sediment directly exposed to spray declined 42% (0.181→ 0.105 ppm DW) within

14 days following aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader

(1 liter/ha) to control Spartina (Willapa Bay). Lower temperatures and reduced

microbial activity associated with later sampling periods may have contributed to

the stabilization of nonylphenol concentrations. Unlike shortening of the

ethoxylate chain, ultimate degradation (conversion to carbon dioxide and water) of

alkylphenol polyethoxylates may not be complete (Swisher 1987). Laboratory

studies (Fuka 1978, 1980; Pitter 1979) found 80-90% ultimate biodegradation for

nonylphenol polyethoxylates.

No information is available regarding the degradation of LI-700®; however, it is composed

of a natural lipid (phosphatidylcholine [lecithin]) that is likely subject to biodegradation

Drift of Rodeo® tank mixes to non-target areas associated with ground applications to

Spartina would be minimal under favorable environmental conditions. For sites in Willapa

Bay with Spartina clones treated by a hand-held sprayer with Rodeo® (5% solution) and

LI-700® (2% solution), average concentrations of glyphosate in off-target substrates 0.5 m

from the clone edge immediately after treatment ranged from 1.07 to 5.28 ppm DW

(Major and Grue 1997). The highest concentration of glyphosate (5.28 ppm DW) for

sediments adjacent to hand-treated Spartina clones on spray day occurred at the site

(Lewis Unit on the Refuge) with the highest rate of Rodeo® application (63 liters/ha). 
128

Grue and Major (1997) also found glyphosate in substrate samples 5 m from edges of

hand-sprayed clones, but concentrations were less than 0.087 ppm DW. Glyphosate likely

was detected 5 m from clones because the height of the Spartina resulted in applications

directed up or across clones rather down onto plants.

Drift of Rodeo® tank mixes to non-target areas associated with aerial applications

to Spartina also would be minimal under favorable environmental conditions. 

Grue and Major (1996) found that drift associated with aerial application of

Rodeo® (8.8 liters/ha) and X-77® Spreader (1.2 liter/ha) to a Spartina meadow in

Willapa Bay was minimal. Glyphosate concentrations in sediment 3 and 10 m from

the plot boundary immediately after spray ranged from below the detection limit

(0.020 ppm DW) to 0.114 ppm DW and below the detection limit (4 of 5 samples)

to 0.117 ppm DW, respectively. No visible mortality of non-target vegetation on

mudflats or salt marsh was found immediately adjacent to a Spartina meadow (152

ha) at Kaffee-Lewis Slough as well as a 12-ha meadow at Seal Slough 5 weeks

following aerial application with Rodeo® (8.8 liters/ha) and R-11® Spreader

Activator (0.5% solution) in 1996 (C. Moore, Washington Dept. Agric., pers.

commun.). Feng et al. (1989) found that average off-target distance between the

spray boundary and healthy vegetation associated with aerial application of

Roundup® (2.0 kg/ha glyphosate) was 2 m.

4.3.1.2 Hydrology

Hydrologic patterns in the project area would be directly affected by the removal of

Spartina, especially dense clones and meadows. Removal of Spartina plants would allow

increased flow velocities and unobstructed flow patterns. Over time, redistribution of

sediments from treated clone sites and meadows would likely allow tidal and runoff flows

to return to pre-Spartina velocities and patterns. Because IPM would most effectively

control the Spartina invasion, flow velocities and patterns across treated tidelands would

be expected to return to pre-invasion condition sooner compared with individual control

methods. 

Natural tidal drainage patterns would be preserved in treated areas where early stages of

Spartina growth is halted or prevented. Some changes may still occur because of the

presence of nearby uncontrolled Spartina. The potential for flooding resulting from the

restricted runoff associated with Spartina growth on Refuge tidelands would be avoided

or reduced.

4.3.1.3 Water Quality

Beginning in the spring of 1997, the Washington Department of Ecology is conducting an

EPA-funded project to study water quality parameters in Willapa Bay. Water

temperature, dissolved oxygen, nutrients, chlorophyll, pH, light transmission, and

turbidity, as measured by Secchi disk depth, will be measured at six locations (Newton

1997).

Disturbance to the substrate caused by people and equipment may result in local increases

in suspended sediments as work areas are tidally reflooded. These effects should be minor
129

because only relatively small areas would be involved. Mitigation measures to reduce

trampling effects would include use of an air boat or hovercraft to directly access each

clone or meadow, thus avoiding or minimizing trampling of adjacent mudflats and eelgrass

beds.

The degree of water-quality degradation by chemicals would be dependent upon the

amount of Rodeo® tank mix that reaches the water and its subsequent biodegradation. 

Because Spartina intercepts most of the aerially (Kilbride et al. 1995, Major and Grue

1997) and ground-applied herbicide tank mix (Major and Grue 1997), and overspray or

drift are minimal (Feng et al. 1989, Major and Grue 1997), the primary source for

glyphosate and adjuvant introduction into seawater results from the initial washing of

target vegetation by the first tidal inundation or rainfall that occurs before chemical

incorporation into Spartina tissue.

Dilution, dissipation, and biodegradation quickly diminish waterborne concentrations of

glyphosate and adjuvant. Paveglio et al. (1996) found that concentrations of glyphosate

and nonylphenol polyethoxylates in seawater were below detection limits (0.5 and 2.0 ppb,

respectively) 1 day post-treatment (2 tidal cycles) after aerial application of Rodeo® (4.7

liters/ha) and X-77® Spreader (1.0 liter/ha) to control Spartina in Willapa Bay. Similarly,

Kroll (1991) found seawater concentrations of glyphosate dropped below the detection

limit (5 ppb) by 7 days post-treatment in tidal marshes with Phragmites communis patches

treated by a hand-held sprayer with Rodeo® (0.75% solution) and Arborchem Aquatic

surfactant (0.5% solution). 

Because the sea-substrate microlayer (seawater-sediment interface) provides habitat for a

wide variety of marine biota, concern exists regarding toxicity resulting from exposure to

Rodeo® tank mixes from drift or overspray particularly during low tides. Paveglio et al

(1996) found that average concentrations for glyphosate and nonylphenol polyethoxylates

from the leading edge of the first high tide after treatment were ≤ 25.6 and ≤ 16.0 ppb,

respectively, and they quickly declined (≤ 9.77 and ≤ 0.5 ppb [detection limit] for

glyphosate and nonylphenol polyethoxylates, respectively) as a result of water-column

dilution from the subsequent tidal inundation. Similarly, Sundaram et al. (1980) found

that after aerial application of 0.47 liters/ha nonylphenol (to determine the environmental

fate of nonylphenol associated with applications of the pesticide Metacil) the highest

concentration (9.1 ppb) in a stream 1 hour post-treatment declined to undetectable levels

(<1.0 ppb) within 24 hours post-treatment; they attributed the rapid dissipation to dilution

by water flow. Consequently, hazards to microlayer biota at low tide are unlikely because

glyphosate and alkylphenol polyethoxylates would be present at non-toxic concentrations

(see subsection 4.3.2.5) that are relatively short-lived as a result of water-column dilution.

Water-quality degradation through interaction of Rodeo® tank mixes with other pesticides

used in and adjacent to Willapa Bay would be unlikely. In intertidal areas where Spartina

has been sprayed with Rodeo® tank mixes, dilution, dissipation, and biodegradation

quickly diminished waterborne concentrations of glyphosate and adjuvant (Paveglio et al.

1996). Areas with Spartina are geographically separated from areas where oyster beds
130

with burrowing shrimp are sprayed with Sevin (carbaryl) and cranberries (grown in inland

bogs) are sprayed with a variety of insecticides, herbicides, and fungicides. Moreover,

carbaryl concentrations in water on oyster tracts treated for shrimp were only detectable

for 20 to 30 minutes following the first tidal inundation after treatment (Tufts 1990). The

detectable levels of carbaryl were only found within 68 m (225 feet) of treated tracts

(Tufts 1989). For cranberry crops, water applied to bogs along the Long Beach peninsula

generally drains into freshwater wetlands rather than directly into Willapa Bay (Patterson

1994).

Fuel spills/leakages could result from the use of power tools and vehicles in control

operations. Incomplete fuel combustion during torching could result in pollution. 

Protocols would be established to minimize the risk (section 2.3). 

Although degradation of water quality from Rodeo® tank mixes would likely be minimal,

decomposition of treated Spartina may temporarily reduce dissolved oxygen levels and

release nutrients (nitrogen, phosphorus, and carbon) which may result in algal blooms. 

Conversely, nutrient releases from decaying Spartina may beneficially increase primary

production. The potential negative effects of Spartina on water quality, including

increased surface water temperatures and reduced levels of dissolved oxygen (see

subsection 4.2.1.3), would be ameliorated to the degree that control is successful.

4.3.1.4 Ambient Sound

Operation of airboats, hovercraft, skiffs, and/or helicopters to support control efforts

would increase noise on and around the proposed project site. Higher noise levels would

occur primarily during transport of staff, equipment, and supplies to and from work sites

as well as during aerial herbicide application. The increase would be most noticeable to

those in non-motorized boats in the vicinity of the activity or along transport routes. Work

on refuge-owned and refuge-associated tidelands would temporarily elevate noise levels

around Long Island, along highway 101 from Stanley Peninsula south to Greenhead

Slough, and near Leadbetter Point. On calm days, the sounds would become more

noticeable along the east edge of the Long Beach Peninsula.

4.3.1.5 Air Quality

Of the action alternatives, IPM would likely produce the least amount of air pollution. 

Higher efficiency in the control effort would reduce the hours of equipment operation over

time. The potential for herbicide drift is discussed in 4.3.1.1. Spartina pollen production

would be reduced to the greatest extent under IPM. Torching of flower and/or seed heads

would generate smoke and some pollution from incomplete combustion of torch fuel;

however, this technique has been used only on a very small scale. 

4.3.2 Biological Environment

4.3.2.1 Vegetation

With IPM, about 2,300 acres of mudflats supporting seagrass and macroalgae habitat

would be maintained on the Refuge’s southern units. Nearly all existing mudflat habitat

around Long Island would be maintained. Some Spartina-dominated areas would be

converted to mudflat and some would convert to native saltmarsh. Existing native
131

saltmarsh would be preserved. Impacts to off-refuge vegetation due to Spartina spread

would be minimized.

The movement of people and vehicles across tidelands during control efforts may result in

damage to native vegetation such as saltmarsh plants, eelgrass beds, and macroalgae beds.

 It is expected that negative impacts would be minor and temporary. Damage would be

minimized by using mudwalkers and low-impact vehicles (hovercraft and airboat). Native

plants living in Spartina colonies would be damaged or destroyed by control methods.

Rodeo® tank mixes have had variable effects upon non-target marine plants. Japanese

eelgrass (Z. japonica) growth was adversely affected at 1 of 2 plots aerially treated with

Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0 liter/ha) in Willapa Bay (Fresh et al 1996).

The affected plot had shallower water depth and, therefore, greater eelgrass exposure

during the herbicide application. Rodeo® (10.3 [4.44 quarts/acre] to 0.7 liter/ha [0.3

quarts/acre]) and X-77® Spreader applied by hand-held sprayer to eelgrass (Zostera spp.)

in Padilla Bay did not affect biomass during an 8-week study period (Bulthuis and

Hartman 1994). Rodeo® (4.7 liters/ha) and X-77® Spreader (1% solution) applied by

hand-held sprayer to plots with native salt marsh vegetation had no effect upon density,

cover, and biomass of pickleweed or salt grass up to 1 year post-treatment; however,

cover and biomass of saltbush (Atriplex patula) were reduced at 60 days post-treatment

because exposure time (>8 hours) was longer for this species located higher in the

intertidal zone (Bulthuis and Scott 1993). No adverse effects were found to microalgae

after aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0 liter/ha) to

control Spartina in Willapa Bay (Simenstad et al. 1996). Direct application of Rodeo® to

marine macrophytes would likely result in impacts. However, these impacts may be

reduced or eliminated if non-target macrophytes are covered with seawater. No impacts

to marine microalgae would result from herbicide control of Spartina. 

The 96-hour LC50 value, concentration found to cause mortality in 50% of the individuals

during a laboratory toxicity test, for the marine alga (Skelatonema costatum) is 27 ppb for

nonylphenol (Naylor 1992), which is the nonylphenol polyethoxylate degradation product

with the greatest toxicity to aquatic organisms. This value is 1.7 times higher than the

maximum average concentration of nonylphenol polyethoxylates (16 ppb) from the leading

edge of the first high tide following aerial application of Rodeo® (4.7 liters/ha) and X-77®

Spreader (1.0 liter/ha) from the Paveglio et al. (1996) study. 

Although no biological or cultural techniques are currently available for Spartina control,

possible future techniques include use of microbial pathogens, insect herbivores, and

genetic engineering (State of Washington 1993). A realistic goal of biological control

methods would be to reduce Spartina abundance to a more easily managed level for other

techniques, rather than complete eradication.

Potential risks of using biological control agents include unintended damage to or loss of

native plants or animals and reduced palatability of affected native plants (forbs and

grasses) to animals. Because of these potential risks, biological control methods such as

use of new pathogens, introduced insects, or genetic engineering, typically require several
132

years for research and approval to assess efficacy, effects on target and nontarget

organisms, and other environmental concerns. Then after introduction, several more years

may pass before viability of the target plant is affected (State of Washington 1993).

The beneficial effect of Integrated Pest Management would be to preserve and restore

native plant habitat by stopping the spread of Spartina. Eelgrass would quickly recolonize

areas where Spartina was controlled.

4.3.2.2 Spartina

Spartina would be directly affected by physical/mechanical and/or chemical control actions

of IPM. It would slow or prevent Spartina spread via asexual growth. It would also

reduce or prevent the establishment of seedlings. Spartina seed production would be

mostly stopped in about 5 years on the southern units and around Long Island. It is

estimated that about half of the existing Spartina meadow and coalescing clones would

convert to native salt marsh and the other half would revert to mud flat on the southern

units. Around Long Island, it is anticipated that most existing Spartina meadows would

convert to native saltmarsh in about 10 years. Little meadow would return to mud flat

there. The lowest potential for viable seed movement out of Willapa Bay to other

estuaries would occur under the IPM alternative.

Ground applications with Rodeo® tank mixes would control Spartina within the intertidal

zone. Kilbride et al. (1996) sprayed Spartina clones on the Refuge (Porter Point) by

hand-held equipment and achieved 84% control (reduction in stem densities) 1 year posttreatment. R. Crockett (Monsanto Agric. Co., pers. commun.) found ≥90% declines in

Spartina 1 year after treatment with Rodeo® (0.56 to 2.24 kg glyphosate/ha) and R-11®

Spreader Activator (1% solution) by hand-held boom. Major and Grue (1997) found 80

to 90% and 89 to 93% reductions in stem densities 1 year after treatment of Spartina

clones in Willapa Bay on sites with muddy substrates (North River and Lewis Unit on the

Refuge) associated with spraying Rodeo® (5% solution) and LI-700 (2% solution) by

hand-held equipment alone and in combination with mowing 6 weeks prior to herbicide

application, respectively. Lesser control (6 and 69% reductions for spray alone and

mowing/spraying treatments, respectively) was found for a site (Nemah Beach) identically

treated on sandy substrate (Major and Grue 1997). Differences in efficacy may have been

related to Rodeo® delivery rates, where muddy sites received 54 to 63 liters/ha compared

with 47 liters/ha at the sandy site. Garnett et al. (1992) found a 74 to 89% decrease (1

year after treatment) in stem densities of Spartina anglica sprayed by hand-held boom

with Roundup® (1.80 kg glyphosate/ha) and Pro-Mix surfactant (2% solution). Pritchard

(1995) applied glyphosate (Glyphosate 360 at 40 liters/ha) to plots within a Spartina

meadow (Victoria, Australia) by held-held sprayer and achieved 84% control after 1 posttreatment year.

Aerial applications of Rodeo® tank mixes to Spartina would also result in control. 

Kilbride et al. (1996) found 32% declines in stem densities of Spartina for three 1-ha plots

with clones aerially sprayed in August 1992 with Rodeo® (4.7 liters/ha) and X-77®

Spreader (1 liter/ha) in Willapa Bay. Short exposure time (≤5.5 hours) and low rate of

Rodeo® application (4.7 compared with 8.8 liters/ha [maximum rate by label]) likely
133

prevented cuticular penetration of sufficient amounts of glyphosate to effect better

control. In August 1995, a 2-ha plot within a Spartina meadow in Willapa Bay (KaffeeLewis Slough) was aerially sprayed with Rodeo®

 (8.8 liters/ha) and X-77® Spreader (1.2

liter/ha). Pre- and post-treatment (1 year) data (stem densities) were collected and

indicated no Spartina control (Grue and Major 1997). In addition, the Spartina meadow

(152 ha) in Kaffee-Lewis Slough, which included the 2-ha plot treated in 1995, as well as

a 12-ha meadow in Seal Slough were aerially sprayed in early July 1996 with Rodeo® (8.8

liters/ha) and R-11® Spreader Activator (0.5% solution). Visual (aerial) observations of

the treated meadows 5 weeks after application indicated approximately 65 to 75% brown

down with no seed set (C. Moore, Washington Dept. Agric., pers. commun.). Greater

control likely will be achieved with meadow spraying that occurred during 1996 compared

with the 1992 and 1995 treatments because exposure time was greater. The 1996

application was conducted during a rising low-high tide with 12 hours of exposure before

most of the treated Spartina was inundated; whereas, exposure times for the 1992 and

1995 treatments were about 6 hours.

If any new techniques become available, biological control would most likely reduce

expansion of Spartina by preventing seed set and reducing vegetative spread. Standing

biomass of Spartina in treated areas might also be reduced.

4.3.2.3 Wildlife

Overall, Spartina control would be beneficial to wildlife. Native habitat would be restored

or preserved for aquatic migratory birds that utilize the mudflats and saltmarsh on the

Refuge. Spartina growth would continue on the remainder of the area. Mudflats would

remain for shorebird feeding. Black brant, Canada geese, American wigeon, northern

pintail, and mallards would continue to find food in protected eelgrass communities. In

order to avoid disturbances, aerial control activities would not take place within 1⁄2 mile of

any active bald eagle nest. Loons, grebes, scaup, and other diving birds would have openwater areas.

Human activity and noise from the airboats, hovercraft, and skiffs would temporarily

disturb aquatic migratory birds from the project area during operations at low tides. Most

waterbirds, shorebirds, herons, and raptors, including bald eagles, would be expected to

flee from and/or avoid localities where and when work is in progress. Disturbance would

be minimized by the relatively small scale of control operations. On a typical day, a crew

of two to four people (larger crews may be used at times) would be working on a few

acres. Birds that are displaced from a work site would be able to move to nearby areas

and continue their activities. Birds that use water for resting and feeding would be

expected to return to control sites during high tides. Control activities would occur

during the spring and summer when use of Willapa Bay by brant, geese, ducks, shorebirds,

loons, and many other waterbirds is low to nonexistent. Because of the probable

synergistic effects of IPM and the resultant smaller control effort, any risks of negative

impacts associated with control efforts would be lessened.

Little is known concerning the use of Spartina on the West Coast by marsh and water

birds. It is possible that some species that prefer dense vegetation, such as bitterns, could
134

lose cover and feeding habitat by removal of Spartina.

Because toxic dietary thresholds are not likely to be reached after Rodeo® applications to

control Spartina, no effects upon aquatic migratory birds are expected. Dietary toxicity

tests with mallard ducklings found a LC50 value of 4,640 ppm for glyphosate, which

classifies glyphosate as practically nontoxic (Heydens 1991). This LC50 level would

require an average daily intake of 1,106 mg/kg (Heydens 1991). Female mallards exposed

to dietary concentrations ≤1,000 ppm (equivalent to an average daily intake of 126 mg/kg)

showed no reproductive effects. In addition, the highest average concentration of

glyphosate in Spartina, which might be similar to what could be expected in sprayed

eelgrass (a species consumed by aquatic birds), 1 day after aerial application of Rodeo®

(4.7 liters/ha) and X-77® Spreader (1 liter/ha) in Willapa Bay was 65.6 ppm (Paveglio et

al. 1996). Because this value is 71 times less than the LC50 value for mallard ducklings,

toxic dietary thresholds for aquatic birds would not likely be reached after Rodeo®

applications to control Spartina.

Field studies have not demonstrated direct adverse effects of Rodeo® tank mixes on birds.

 Solberg and Higgins (1993) found nesting success of waterfowl species was not affected

in wetlands sprayed with Rodeo® (2.8 liters/ha) and X-77® Spreader (0.33% solution) to

control cattails (Typha spp.). Roundup® (2.3 liters/ha) applied to an Oregon coastal forest

for conifer release did not affect the bird community although habitat was altered for 2

years post-treatment (Morrison and Meslow 1984). In contrast, Santillo et al. (1989)

found that aerial application of Roundup® to clearcuts in north-central Maine reduced total

numbers of birds, but this was a result of changes in habitat structure rather than mortality

from pesticide exposure.

Several field studies have been conducted to determine the effects of glyphosate on

mammals. Sullivan (1979) found that black-tailed deer (Odocoileus hemionus) did not

alter browsing habits and showed no adverse effects from consuming forage in areas

aerially treated with Roundup®. Anthony and Morrison (1985) found that aerial

application of Roundup® (2.25 liters/ha) in coastal forests of western Oregon increased the

abundance and diversity of small mammal populations. D’Anieri et al. (1987) found that

richness of the small mammal community was not affected after clearcuts in northern

Maine were aerially treated with Roundup® (2.25 liters/ha). 

Acute toxicity based upon a limited number of laboratory studies indicate that X-77®

Spreader, R-11® Spreader Activator, and LI-700® are nontoxic to mammals. For

nonylphenol polyethoxylates, the oral LD50 for rats and mice ranges from 2,000 to 4,000

ppm (Benson and Nimrod 1994). No nonylphenol polyethoxylates were detected in

Spartina 1 day after aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1

liter/ha) in Willapa Bay (Paveglio et al. 1996), and nonylphenol polyethoxlates were found

at an average concentration of 0.181 ppm in sediment on spray day. Because these values

are at least 11,000 times less than the LD50 value for rats and mice, effects on mammals

are not likely after applications of Rodeo® and alkylphenol polyethoxylate-based

surfactants to control Spartina.
135

Through laboratory studies (Mueller and Kim 1978, Soto et al. 1991, Jobling and Sumpter

1993), alkylphenol polyethoxylates have recently been recognized as xenoestrogens

(environmental estrogens) capable of mimicking estrogen and, therefore, affecting

reproductive endocrine function in biota. However, nonylphenol polyethoxylates did not

persist in seawater and sediment after herbicide applications to control Spartina (Paveglio

et al. 1996) and, consequently, estrogenic effects upon wildlife are unlikely.

4.3.2.4 Fish

IPM would be expected to have an overall positive effect on fish. The loss of temporary

cover habitat along the edges of Spartina clones and meadows for salmon smolts and

other small fish would be more than offset by the restoration of eelgrass, algae, and

mudflat habitat and the prevention of the development of large monotypic Spartina

meadows.

The risk of fuel spills and localized temporary increases in suspended (water column)

sediments in work areas would be minimized by protocols which would forbid fueling

outside contained areas such as boats and would use hovercraft or airboats to directly

access Spartina clones. Because of the very low concentrations of glyphosate found in

saltwater after application and the low toxicity of glyphosate and surfactant, acute or

chronic toxicity to fish are not expected to occur. Because of the probable synergistic

effects of IPM and the resulting smaller control effort, any risks of impacts associated with

control efforts would be lessened.

Potential benefits are associated with preservation or restoration of native fish habitat

(intertidal mudflats). The mudflats support a rich and diverse benthic fauna upon which

fish feed and the mudflats are accessible through a substantial part of the tidal cycle. 

Species that depend on open water, eelgrass, algae, or mudflat communities to meet one

or more of their life requirements could utilize areas where Spartina is controlled. The

composition of the benthic fauna and hence the food web of fish in treated areas would

likely revert back to pre-Spartina conditions in some areas over time. In the future,

trapped sediments would be resuspended, lowering the elevation of treated sites so that

they would be inundated (and thus available to fish) during more of the tidal cycle.

A biological opinion written by the Service’s Klamath Basin Ecosystem Restoration Office

(February 2, 1996) entitled “Reinitiation of Formal Consultation on the Use of Pesticides

and Fertilizers on Federal Lease Lands and Acrolein and Herbicide Use on the Klamath

Project Right-of-Way Located on the Klamath Project” stated that laboratory studies

show glyphosate is soluble in water and very toxic to fish. According to Elaine SnyderConn, the contaminant specialist for the Service who co-authored this biological opinion,

the statement was based upon laboratory toxicity tests with freshwater fishes such as

rainbow trout, fathead minnows, and bluegill exposed to Roundup (Mayer and Ellersieck

1986). However, Rodeo is ten times less toxic than Roundup because of the difference in

surfactants present in the two formulations (Mitchell et al. 1987).

A very large margin of safety exists between maximum concentrations of glyphosate

found in seawater in the Paveglio et al. (1996) study and concentrations resulting in acute
136

and subacute impacts to anadromous fishes. The maximum average concentration of

glyphosate (25.6 ppb) found during the first tidal inundation for the Paveglio et al. (1996)

study was 23,000 to 56,000 times less than 96-hour LC50s (Rodeo® and X-77® Spreader)

for chinook and coho salmon (O. kisutch) fingerlings (Mitchell et al. 1987a), and 108

times less than concentrations that did not disrupt seawater adaptation or growth of coho

salmon smolts (Roundup® [Mitchell et al. 1987b]). 

Acute toxicity based upon a limited number of laboratory studies indicate that X-77®

Spreader/R-11® Spreader Activator and LI-700® are moderately and nontoxic to fish,

respectively. LC50s (96- and 48-hour) values for nonylphenol and nonylphenol

polyethoxylates were ≤ 3.0 ppm and range from 0.13 ppm for Atlantic salmon (Salmo

salar; McLeese et al. 1980) to 3.0 ppm for saltwater cod (Gadus morhua; Swedmark

1968) and flounder (Pleuronectes flesus; Swedmark et al. 1971). In general, young fish

have been found to be more sensitive than adults. For example, developmental

abnormalities and increased mortality rates occurred for cod eggs and larvae exposed to

>0.2 ppm (Swedmark et al. 1971). Because maximum mean concentrations of

nonylphenol polyethoxylates in the leading edge of the first high tide after treatment

(worse case) was considerably less (16 ppb [Paveglio et al. 1996]) than these LC50 values,

toxicological effects upon fish are unlikely. 

Estrogenic effects upon fish associated with alkylphenol polyethoxylate-based surfactants

are unlikely. Sheahan and Harries (1992) found nonylphenol concentrations between 20

and 50 ppb induced the production of vitellogenin (protein usually found only in sexually

mature females) in male rainbow trout. Jobling et al. (1996) found induction of

vitellogenin synthesis and reduction in testicular growth for juvenile male rainbow trout

continuously exposed to 3 and 10 ppb nonylphenol and octylphenol, respectively, during 

a 3-week laboratory study. Jobling et al. (1996) also found that the degree of inhibition

for testicular growth associated with nonylphenol and octylphenol depended upon the

timing of exposure as well as sexual maturity, where inhibition was less pronounced for

exposure toward the end the gonad growth phase and no inhibition was found for sexually

mature fish. Although Paveglio et al. (1996) found higher average concentrations of

nonylphenol polyethoxylates (≤16 ppb) in the leading edge of the first tidal inundation

after herbicide application, nonylphenol polyethoxylates were undetectable (≤2.0 ppb) in

seawater during the first high tide after treatment.

4.3.2.5 Microbes and Marine Invertebrates

The presence of people and equipment on the tidelands would have some negative impacts

on invertebrates. Organisms living in or on the mudflats and salt marsh as well as Spartina

seedlings, clones, and meadows could be crushed, burned, or dislodged. When seedlings

are removed, organisms adhering to the seedlings would perish. Impacts would be

minimized by the use of mudwalkers and low-impact vehicles such as hovercraft and

airboats.

The results of field and laboratory studies indicate that Rodeo® tank mixes applied to

Spartina likely would not affect marine invertebrates through seawater exposure. 
137

Simenstad et al. (1996) found no short- (28 days post-treatment) or long-term (119 days

post-treatment) effects to epibenthic invertebrate communities associated with aerial

application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0 liter/ha) to control

Spartina in Willapa Bay. Kubena (1996) conducted 96-hour bioassays with marine

amphipods native to the Atlantic Coast (Leptocheirus plumulosus) and the Pacific

Northwest (Eohaustrorius estuarius) that were placed in various dilutions (0.1 to 10%) of

the herbicide tank mix representing the maximum application rate for aerial control of

Spartina (8.8 liters/ha for Rodeo® [500 ppm glyphosate] and 2% solution for a nonionic

surfactant [25 ppm nonylphenol polyethoxylates {X-77® Spreader}, 40 ppm octylphenol

polyethoxylates {R-11® Spreader Activator}, or 22 ppm phosphatidylcholine {LI-700®}]).

 Amphipod survival was not affected for these 96-hour bioassays up to the highest

concentrations tested (50 ppm glyphosate and 2.5, 4.0, or 2.2 ppm for nonylphenol

polyethoxylates, octylphenol polyethoxylates, and phosphatidylcholine, respectively). In

another series of 96-hour bioassays, amphipod survival was reduced by 30% and 25 to

80% at 248 ppm glyphosate and 11 ppm phosphatidylcholine and 124 ppm glyphosate and

6.2 or 9.9 ppm nonylphenol polyethoxylates or octylphenol polyethoxylates, respectively. 

Bioassays (48-hour) with echinoderm larvae (Dendraster excentricus) indicated that

glyphosate and nonylphenol polyethoxylates, octylphenol polyethoxylates, or

phosphatidylcholine concentrations up to the highest concentrations tested (5 ppm and

0.25, 0.40, or 0.22 ppm, respectively) did not affect survival. Kubena et al. (1996)

conducted a 96-hour bioassay with Pacific oysters (Crassostrea gigas) in which seawater

spiked with Rodeo® and R-11® Spreader Activator was added to 2.8 ml chambers with

seawater from Puget Sound. For this 96-hour bioassay, glyphosate and octylphenol

polyethoxylate concentrations at 250 and 20 ppm, respectively, reduced survival of larval

oysters. The maximum average concentration of glyphosate in seawater (25.6 ppb) found

on sprayed plots during the first high tide after application for the Paveglio et al. (1996)

study was 4,844- and 9,766-fold less than glyphosate concentrations that reduced survival

of amphipods and oysters, respectively, in bioassays.

The results of field and laboratory studies indicate that Rodeo® tank mixes applied to

Spartina likely would not affect marine invertebrates through sediment exposure.

Simenstad et al. (1996) found no short- (28 days post-treatment) or long-term (119 days

post-treatment) effects to benthic invertebrate (infauna and meiofauna) communities

associated with aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0

liter/ha) to control Spartina in Willapa Bay. Kubena (1996) conducted 10-day bioassays

with Leptocheirus plumulosus and Eohaustrorius estuarius in which Refuge (Lewis Unit)

sediment spiked with Rodeo® and R-11® Spreader Activator were added to the 1-liter test

chambers with seawater from Puget Sound. For these 10-day bioassays, glyphosate and

octylphenol polyethoxylates up to the maximum concentrations tested (2,066 and 165

ppm, respectively) did not affect amphipod survival. Kubena et al. (1996) conducted 96-

hour bioassays with Pacific oysters in which Refuge sediment spiked with Rodeo® and

surfactant (X-77® Spreader, R-11® Spreader Activator, or LI-700®) was added to 2.8 ml

chambers with seawater from Puget Sound. For these bioassays, glyphosate and

nonylphenol polyethoxylates, octylphenol polyethoxylates, or phosphatidylcholine

concentrations at 5,122 ppm and 256, 410, or 224 ppm, respectively, reduced survival of

larval oysters. The maximum average concentrations of glyphosate and nonlyphenol
138

polyethoxylates in sediment (2.82 and 0.181 ppm DW, respectively) found on treatment

plots for the Paveglio et al. (1996) study were 1,816- and 1,414-fold less than glyphosate

and nonylphenol polyethoxylate concentrations, respectively, that reduced survival of

oysters in bioassays.

The results of LC50 tests with glyphosate or alkylphenol (nonylphenol and octylphenol)

polyethoxylates also indicate that Rodeo® tank mixes applied to Spartina likely would not

affect marine invertebrates. The maximum average concentration of glyphosate in

seawater found on sprayed plots during the first high tide after application for the Paveglio

et al (1996) study was 25 to 39,000 times less than 96-hour LC50s for fertilized eggs of

Atlantic oysters (Crassostrea virginica), fiddler crabs (Uca pugilator), grass shrimp

(Palaemonetes vulgaris), a marine alga (Skeletonema costatum), mysid shrimp

(Mysidopsis bahia), and sea urchins (Tripneustes esculentus) tested with glyphosate

(Heydens 1991). For alkylphenol polyethoxylates, 96-hour LC50s values of 2.9 to >100

ppm and <5 to >100 ppm were found for marine crustaceans and bivalves, respectively

(Talmage 1993:270), but nonylphenol polyethoxylates were not detected (<2.0 ppb) in

seawater found on sprayed plots during the first high tide after application for the Paveglio

et al. (1996) study. Laboratory studies also indicate that LI-700® is nontoxic to aquatic

invertebrates.

Because nonylphenol polyethoxylates did not persist in seawater or sediment after

herbicide applications to control Spartina (Paveglio et al. 1996), estrogenic effects upon

invertebrates associated with alkylphenol polyethoxylate-based surfactants are unlikely. 

By preserving and restoring mudflats, eelgrass, and macroalgae beds, Spartina control

using IPM would have the greatest potential to benefit shellfish and other invertebrates

associated with these habitats. By reducing seed production in the bay, fewer Spartina

seedlings would be expected to sprout on Refuge and neighboring tidelands, thus

maintaining more mudflat habitat for invertebrates. In areas still dominated by Spartina,

many species of shellfish and other benthic macroinvertebrates would either not survive or

be reduced in numbers (Washington State 1993, Atkinson 1992, Simenstad and Thom

1995).

4.3.2.6 Biodiversity

With careful procedures to avoid application to nontargeted organisms and the

unlikelihood of toxicological effects at maximum concentrations in the saltwater or

sediments, biodiversity should not be adversely affected by use of glyphosate in IPM.

Control to prevent monotypic stands of Spartina would protect biodiversity of plants,

wildlife, and invertebrates.

4.3.3 Social Environment

4.3.3.1 Human Health

Little potential exists for acute toxicity to human health nor long-term health impacts

associated with cancer or other maladies from exposure to glyphosate associated with

Rodeo® applications to control Spartina. Knowledge regarding the acute toxicity of

glyphosate to humans comes from a study conducted by Japanese physicians who

investigated 56 poisoning cases, most of which were suicides or attempted suicides,
139

involving Roundup®. For the 9 cases in which the suicide attempts were successful, the

mean amount ingested was 200 ml (3⁄4 of a cup) of herbicide; however, the

polyethoxylated tallowamines (surfactant in Roundup® but not Rodeo®) likely caused the

herbicide toxicity (Sawada et al. 1988). Short- and long-term non-cancer health effects

were below levels of regulatory concern for adults and children (1 in 1,000,000). 

Similarly, all risks calculated for cancer effects were also below the regulatory concern

level (1 in 1,000,000). Because no carcinogenic effects were found for chronic studies

with rats and mice, glyphosate has been classified by the U.S. Environmental Protection

Agency as noncarcinogenic to humans (Washington State 1993).

Because nonylphenol polyethoxylates did not persist in seawater or sediment (see

subsections 4.3.1.1 and 4.3.1.3) after herbicide applications to control Spartina (Paveglio

et al. 1996), estrogenic effects upon humans associated with alkylphenol polyethoxylate

base surfactants are unlikely.

There are certain health problems that have occurred with a statistically higher frequency

in Pacific County than in the State as a whole. However, there are no indications that any

of these health problems are associated with environmental conditions (See 3.4.2.1). The

low potential for movement of approved chemical compounds off of treatment sites, the

tendency for these compounds not to persist, and the low toxicity of concentrations found

on treatment sites make it unlikely that the chemical component of IPM would generate an

environmental health hazard or contribute to existing health problems. 

Health problems associated with Spartina pollen production and mosquitos that breed in

Spartina meadows on the Refuge would be reduced within 10 years by Spartina control. 

This alternative also provides the greatest opportunity for the Refuge to reduce such

impacts off-refuge.

Control workers would be exposed to the risks of cuts, bruises, sprains, etc., associated

with manual labor. They would also be exposed to high noise levels generated by

airboats, hovercraft, and weedeaters. The use of appropriate safety procedures and

equipment, including hearing protection, would minimize these risks.

4.3.3.2 Concerns

IPM would involve the use of a chemical herbicide (glyphosate) and adjuvants to control

Spartina. Current information about these chemicals is provided in other parts of this

document. The intent of the proposal is to maximize efficacy of control efforts and

minimize risks of all methods. Efforts to find new methods and chemicals that improve

efficacy and safety would continue.

There is a high level of consensus among interest groups within Pacific County on the use

of IPM for the control of Spartina. However, resistance to the chemical component of

IPM persists from those that have taken the position that no agricultural chemicals should

be used in Willapa Bay and that Spartina expansion in the bay is not a serious problem. 

Information regarding the physical, biological, and socio-economics problems posed by

Spartina in Willapa Bay can be found throughout this document. Since there is a
140

substantial body of evidence that the concentrations of chemicals that would be applied

would pose little risk to humans and the environment, and that the chemicals would not

persist or bioaccumulate, concerns about chemical use assume that there are hidden risks,

people are exposed to those risks involuntarily, and/or the hazards would be irreversible.

While there are risks in any endeavor and complete knowledge of biological systems is

impossible, the widespread use and investigation of the chemicals used for Spartina

control has reduced the likelihood that serious hidden risk remains. The known risks

associated with the chemicals proposed for use are accepted by most with a stake in

maintaining the diversity and health of Willapa Bay. However, the known risks of failure

to control Spartina are not acceptable to stakeholders and this, of course, is why

aggressive control is on-going through out the bay.

On Willapa Bay, most of the known risk associated with chemical use is borne by the

stakeholders in the resource voluntarily. This is particularly true on the one-third of the

tidelands that are privately owned. On these lands, 59% of the owners that have been

contacted have expressed a willingness to use chemicals to control Spartina. 

Furthermore, resistance to chemical use is based more on efficacy and cost concerns rather

than health concerns (Lebovitz 1997). Risk is borne voluntarily by these stakeholders

both in terms of cost and exposure to the chemicals. The tendency of chemicals not to

persist, bioaccumulate, or move off site minimizes involuntary exposure to risk off site. 

Chemical dilution, degradation, and incorporation into plant tissue and sediment minimizes

involuntary risk of exposure to recreational users visiting tidelands previously treated.

Current understanding of the chemicals approved for use on Spartina indicate that effects

would not continue long after use of these chemicals ceased. There is no evidence that the

use of these chemicals would have irreversible impacts. However, the uncontrolled spread

of Spartina might not be reversible by any practical means.

4.3.3.3 Recreation

Noise from airboats, hovercraft, helicopters, and/or weedeaters would be heard by nonmotorized boaters on the bay and users of the Long Island and Leadbetter Point Units

during operations. These sounds would be most noticeable in the immediate vicinity of

operations or along transport routes. This could distract from their recreational

experiences. Disturbance of waterbirds during the low tide operations would occasionally

interfere with bird watching in the vicinity of control activities. Fishermen would not

normally be affected by operations since operations would occur on exposed flats during

low tides.

In the long term, recreational boating, shellfish gathering, sportfishing, hunting, and bird

watching would benefit by Spartina control via the restoration and maintenance of

habitats, and access and navigation capabilities.

4.3.4. Economic Environment

Integrated Pest Management would provide the greatest contribution of resources to offRefuge control efforts.
141

4.3.4.1 Tourism

The project would contribute to the overall health of local tourist-related businesses in

future years by protecting the recreational qualities listed above.

4.3.4.2 Mariculture and Fisheries

The oyster mariculture industry would benefit directly from Spartina control. The export

of Spartina seed from the Refuge to other tidelands accelerates the spread of Spartina, 

threatening valuable shellfish beds in the Bay. Under IPM, Spartina seed production from

Refuge tidelands would be minimized in the shortest period of time. It also provides the

maximum opportunity for the Service to work cooperatively with adjacent tideland

owners. For these reasons, IPM would provide the greatest benefits to mariculture and

fisheries of the alternatives discussed in this EA.

NOTE: For more discussion of the consequences of the Integrated Pest Management

Alternative, see pages 174-175 and the Element D, EA, EB, and F reports of the

State FEIS on Noxious Emergent Plant Management, 1993.

4.4 EFFECTS OF PHYSICAL/MECHANICAL MEANS ONLY ALTERNATIVE

Practical limitations on the scale of physical/mechanical control would allow the continued

growth of Spartina in large areas. The large amount of effort required per unit of treated

area would limit the total acreage that could be treated in this alternative.

4.4.1 Physical Environment

The transformation of open tidal flats to higher elevation Spartina marsh would be

slowed. The removal of seedlings would prevent the development of large clones in

control areas. In areas where clones were killed, wave and current action might erode

some sediments trapped by the plant thus restoring tidal flats to their original elevation. 

Alternately, native marsh plants might occupy the sites, maintaining the elevation while

increasing plant diversity. The extent to which either response would occur is unknown -

both may occur to some degree.

4.4.1.1 Soils and Topography

The sediment buildup and changes in substrate composition and topography resulting from

Spartina growth would be slowed or halted in control areas. The existing mudflat

topography would be preserved where Spartina seedlings are removed. Where meadows

could not be controlled, sediment would continue to be captured at high rates for many

years.

The entrapment and accretion of sediments by Spartina would be reduced or prevented in

control areas. This would result in more normal movement and distribution of sediments in

the water column.

Control operations might result in temporary increases in sediment load in the water

column due to disturbance of the substrate and erosion of previously accreted sediments
142

where clones were controlled. The weight of people and equipment might cause

temporary compaction of bottom sediments.

4.4.1.2 Hydrology

Natural tidal drainage patterns would be preserved in areas where Spartina growth was

halted or prevented. Some changes might still occur because of the presence of nearby

Spartina stands. The potential for flooding resulting from the restricted runoff associated

with Spartina growth would be reduced.

4.4.1.3 Water Quality

Where Spartina clones were mowed, decomposition of the resulting plant litter could

temporarily reduce dissolved oxygen levels in the immediate area. As work areas were

tidally reflooded, disturbance to the substrate caused by people and equipment might

result in greater local increases in suspended sediments than with other alternatives.

Fuel spills/leakages could result from the use of power tools and vehicles in control

operations. Incomplete fuel combustion during torching could result in pollution. 

Protocols would be established to minimize risks (Sec. 2.3). 

The potential effects of Spartina on water quality, including increased surface water

temperatures and reduced levels of dissolved oxygen (see subsection 4.2.1.3), would be

ameliorated to the degree that control was successful.

Beginning in the spring of 1997, the Washington Department of Ecology is conducting an

EPA-funded project to study water quality parameters in Willapa Bay. Water

temperature, dissolved oxygen, nutrients, chlorophyll, pH, light transmission, and

turbidity, as measured by Secchi disk depth, will be measured at six locations (Newton

1997).

4.4.1.4 Ambient Sound

Considerable noise would be generated by weedeaters, airboats, hovercraft, etc., during

work periods. Work would normally occur during the daylight hours. However, selfpropelled mowing equipment would be equipped with lighting to extend operations into

the night. A higher reliance on large machinery that could work night and day would

likely result in more noise than with other alternatives.

4.4.1.5 Air Quality

Of the action alternatives, total reliance on physical and mechanical control of Spartina

would require the greatest consumption of fossil fuel and, consequently, would generate

the highest degree of associated air pollution. There would, however, be no potential for

herbicide drift. 

4.4.2 Biological Environment

Physical and mechanical control would prevent Spartina from occupying all of the

Refuge's intertidal lands. Some mudflats and native saltmarsh would be preserved and

would continue to be utilized by birds, fish, and invertebrates that flourish in these
143

habitats. However, this type of control is labor intensive and costly, and would be applied

only on a limited scale. A large proportion of tidelands would continue to be colonized

and occupied by Spartina and substantial seed production would still occur.

4.4.2.1 Vegetation

It is anticipated that much of the existing and expanded Spartina growth on the Refuge’s

southern units would be converted to native saltmarsh in 10 years. Around Long Island,

Spartina would continue to gradually expand into existing native saltmarsh. Little, if any,

land currently dominated by Spartina would be converted to native saltmarsh.

About 1,800 acres of intertidal mudflats supporting seagrass and macroalgae beds would

be maintained on the southern units. Little or no mudflat habitat would be maintained

around Long Island to provide seagrass and macroalgae environment.

The lower efficacy of this alternative would permit more seed and propagules to move off

refuge and establish Spartina colonies that would crowd out desirable vegetation on

adjacent tidelands.

The movement of people and vehicles across tidelands during control efforts might result

in damage to native vegetation such as saltmarsh plants, eelgrass beds, and macroalgae

beds. It is expected that negative impacts would be minor and temporary. Damage would

be minimized by using mudwalkers and low-impact vehicles (hovercraft and airboats). 

Native plants living in Spartina clones would be damaged or destroyed by mowing and

burning.

The beneficial effect of this alternative would be to prevent Spartina from completely

taking over shallow mudflats and associated plant habitats. Some existing areas of native

plant habitat would be preserved. Where Spartina clones were killed, native saltmarsh

plants might increase because sediment accrual in the clones has raised the elevation of the

mudflats to a suitable level. Depending on the elevation, either saltmarsh plants or

eelgrass would quickly recolonize areas where Spartina was controlled. However, unless

erosion in these accumulated sediment areas occurred, mudflat habitat would continue to

be lost.

4.4.2.2 Spartina

It is estimated that it would take about 10 years for Spartina seed production to be halted

in the southern units. Without Washington Department of Natural Resources assistance,

seed production around Long Island would not be stopped. Less control over seed

production would interfere with Spartina control by others on adjacent tidelands and

sustain the potential for viable seed movement out of Willapa Bay.

This degree of control would not keep pace with the spread of Spartina. On the southern

units, Spartina meadows would continue to expand for several years before the trend is

reversed. Some Spartina meadow would remain after 10 years there. Around Long

Island the meadows would expand as long as space allows.
144

4.4.2.3 Wildlife

Human activity and noise associated with control efforts would cause some disturbance to

wildlife. Most waterbirds, shorebirds, herons, and raptors, including bald eagles, would be

expected to flee from and/or avoid localities where work was in progress. Human

movements to and from work areas, along with the noise of airboats and other watercraft

used to transport workers, would also disturb birds temporarily. 

Little is known concerning marsh and waterbird use of Spartina on the West Coast. Some

species that prefer dense vegetation, such as bitterns, could be displaced from feeding

habitat by removal of Spartina.

Disturbance would be minimized by the relatively small scale of control operations. On a

typical day, a crew of two to four people (larger crews might be used at times) would be

working on a few acres at a time. Birds disturbed at the project site would probably move

to nearby areas and continue their activities. Work would occur during the spring and

summer when use of the bay by black brant, geese, ducks, shorebirds, loons, and many

other waterbirds was low to nonexistent.

As larger, more effective mowing machines are developed and used, disturbance to

wildlife would be expected to increase. Total dependence on mechanical control would

expand the need to conduct night mowing operations, thus extending the amount of

disturbance.

Overall, Spartina control would be beneficial to wildlife. Some native habitat would be

preserved for aquatic migratory birds that have historically used the mudflats and

saltmarsh on the Refuge. Black brant, Canada geese, American wigeon, northern pintail,

and mallards would continue to feed on eelgrass. Loons, grebes, scaup, and other diving

birds would continue to use open water areas. Although some existing mudflat habitat

would be lost, a portion of the mudflats would remain for shorebird feeding. There would

be less eelgrass for aquatic migratory birds, and less area of open mudflat for shorebirds

and bald eagles. Nearly all Spartina meadow killed by this alternative would convert to

native saltmarsh. Of the action alternatives, this would preserve the least mudflat habitat

for migratory bird use.

4.4.2.4 Fish

Physical/mechanical control would not be expected to have short-term negative impacts

on fish, except for the slight risk of a fuel spill and a possible temporary, localized

sedimentation increase in work areas.

Potential benefits are associated with preservation of some areas of native fish habitat (i.e.,

intertidal mudflats). The mudflats support a rich and diverse benthic fauna upon which

fish feed (Nichols and Pamatmat 1988) and are accessible through a substantial part of the

tide cycle. Species that depend on open water, eelgrass, algae, or mudflat communities to

meet one or more of their life requirements could utilize areas where Spartina was

controlled.
145

The practical limitations of physical/mechanical control would preclude large-scale control

operations. Spartina growth would continue on the majority of Refuge tidelands. The

composition of the benthic fauna and hence the food web of fish would likely change. 

Over time, trapped sediments would raise the elevation of Spartina clones and they would

be inundated (and thus available to fish) during less and less of the tide cycle. 

4.4.2.5 Microbes and Marine Invertebrates

The presence of people and equipment on the tidelands would have some negative impact

on invertebrates. Organisms living in or on the mudflats, salt marsh, and Spartina clumps

would be more likely to be crushed, burned, or dislodged with this alternative. The

Newcomb’s littorine snail, a Federally recognized Species of Concern and State Candidate

Species living on pickelweed plants, would be in greater danger of such a fate, than with

other alternatives. When seedlings were removed, organisms adhering to the seedlings

would perish. Impacts would be minimized by the use of mudwalkers and low-impact

vehicles such as hovercraft and airboats. The affected area would be relatively small

because of the limited scale of physical/mechanical control. However, as larger, more

effective machines are developed for mowing, impacts to invertebrates would increase,

particularly on Spartina meadows where such machinery would be used.

By preserving mudflats, eelgrass, and macroalgae beds, Spartina control would benefit

shellfish and other invertebrates associated with these habitats. In areas dominated by

Spartina, many species of shellfish and other benthic macroinvertebrates would either not

survive or be reduced in numbers (Washington State 1993, Atkinson 1992, Simenstad et

al. 1996).

4.4.2.6 Biodiversity

A limited amount of native saltmarsh and mudflats, with their diverse flora and fauna,

would be preserved. However, Spartina clones and seedlings would continue to occupy

tidelands and spread into new areas. The development of monotypic Spartina clones

would decrease biodiversity.

4.4.3 Social Environment

4.4.3.1 Human Health

The continued growth of Spartina would be expected to result in increases in salt water

mosquitos (Washington State 1993), flies (Zipperer 1996), and airborne pollen. The

Mechanical Control Only Alternative would reduce these effects but would be less

effective than other alternatives at doing so. Use of aerially-sprayed chemical larvicides to

control saltwater mosquitoes is prevalent along many East Coast Spartina marshes.

Control workers would be exposed to the risks of cuts, bruises, sprains, etc., associated

with manual labor. They would also be exposed to high noise levels generated by

airboats, hovercraft, and weedeaters. The use of appropriate safety procedures and

equipment, including hearing protection, would minimize these risks.

4.4.3.2 Concerns

Concerns about the use of chemicals to control Spartina on the Refuge would be
146

alleviated. Because Spartina would continue to colonize and grow on a substantial

portion of tidelands, concerns about its spread in the Bay would be only partially

addressed. Seed from the Refuge would continue to move to other areas of the Bay.

4.4.3.3 Recreation

Protection of native habitats and their associated fish and wildlife values would continue to

provide for human recreational uses including sport fishing, waterfowl hunting, wildlife

viewing, recreational shellfish harvesting, and boating to the extent that control could be

accomplished. Because the efficacy of physical/mechanical control would be limited,

Spartina meadows would continue to grow on Refuge and other tidelands and, thus,

recreational opportunities would continue to decline accordingly.

The noise from weedeaters, boats, and self-propelled mowing machines used in control

operations could bother some recreationists. Noise disturbance to recreational users

would likely be greater than that of other alternatives due to greater reliance on large

machinery and more night operations.

4.4.4 Economic Environment

The Refuge is linked to regional and local economies through its association with tourism,

mariculture, and commercial fisheries. Few, if any, of the Refuge’ resources would be

applied to off-Refuge control efforts.

4.4.4.1 Tourism

The Refuge received approximately 14,000 public visits in 1994. No studies have been

conducted on the origins or motivations of these visitors, but it can be reasonably assumed

that many tourists are drawn to Willapa Bay and the Refuge for outdoor experiences,

including wildlife and plant viewing, boating, hunting, and fishing.

Physical/mechanical control only would mean that while some native habitats, and

associated wildlife and open water were preserved, large areas of tidelands would

continue to be colonized by Spartina. Recreational opportunities, and thus tourism,

would be expected to decrease because of declines in wildlife and fish, native plants, and

open water. Fewer tourists translates to fewer dollars spent at local businesses.

4.4.4.2 Mariculture and Fisheries

Spartina on Refuge tidelands produces seed that spread to adjacent private and State

tidelands, many of which support oyster mariculture and clam harvesting. Spartina

inhibits shellfish production by creating unfavorable habitat and thus has a high potential

for negatively impacting the shellfish industry.

Spartina seed production, especially on Refuge lands, would be reduced by this

alternative. However, seed from the Refuge would continue to be a problem for the

shellfish industry in other parts of the Bay.

Under this alternative, there would be little opportunity to engage in cooperative control

efforts off-refuge. Refuge resources would likely be exhausted in dealing with control
147

work on high priority sites on the Refuge.

NOTE: For more discussion of the consequences of Physical/Mechanical Means Only

 Alternative, see the State FEIS on Noxious Emergent Plant Management, 1993.

4.5 EFFECTS OF CHEMICAL MEANS ONLY ALTERNATIVE

4.5.1 Physical Environment

4.5.1.1 Soils and Topography

The sediment buildup and changes in substrate composition and topography resulting from

Spartina growth would be slowed or halted in control areas. This would result in more

normal movement and distribution of sediments in the water column. The existing mudflat

topography would be preserved where Spartina seedlings, clones, and meadows were

removed.

Glyphosate is not environmentally persistent and would not accumulate within sediment

from ground applications of Rodeo® tank mixes. Kroll (1991) found that glyphosate

concentrations in sediment of tidal marshes treated by hand-held sprayer with Rodeo®

(0.75% solution) and Arborchem Aquatic surfactant (0.5% solution) declined 88% by 56

days post-treatment. For Spartina clones treated by a hand-held sprayer with Rodeo®

(5% solution) and LI-700 (2% solution) in Willapa Bay, average concentrations of

glyphosate in substrates underneath Spartina declined 14% (1.39→ 1.18 ppm DW; North

River) and 29% (2.23→ 1.58 ppm DW; Lewis Unit on the Refuge) to 43% (3.60→ 2.05

ppm DW; Nemah Beach) and 73% (5.31→ 1.44 ppm DW; Leadbetter Point) for muddy

and sandy substrates between spray day and 30 days post-treatment, respectively (Major

and Grue 1997). After 1 year post-treatment, glyphosate concentrations from treated

clones with the highest levels at 30 days after application ranged from 0.088 to 0.772 ppm

DW and 0.134 to 1.84 ppm DW for sandy (Nemah Beach) and muddy substrates (Lewis

Unit on the Refuge), respectively (Major and Grue 1997). Greater declines in glyphosate

concentrations occurred for sandy substrates because less glyphosate likely was

translocated to Spartina rhizomes incorporated into sediment samples. Application rates

were 14 (Leadbetter Point) to 47 liters/ha (Nemah Beach) and 54 (North River) to 63

liters/ha (Lewis Unit on the Refuge) for clones on sandy and muddy substrates,

respectively.

Glyphosate also would not accumulate within sediment from aerial applications of Rodeo®

tank mixes. Paveglio et al. (1996) found that average concentrations of glyphosate in

sediment directly exposed to spray significantly declined (51% [1.16→ 0.563 ppm DW] to

72% [2.82→ 0.799 ppm DW]) 119 days after aerial application of Rodeo® (4.7 liters/ha)

and X-77® Spreader (1 liter/ha) to control Spartina in Willapa Bay. Average

concentrations of glyphosate in sediment underneath Spartina declined (31%

[0.420→ 0.290 ppm DW]) 30 days after aerial application of Rodeo® (8.8 liters/ha) and X77®

 Spreader (1.2 liter/ha) to a Spartina meadow in Willapa Bay (Major and Grue 1997).

 For sampling locations within this treated meadow with the highest concentrations 30

days after application, glyphosate levels ranged from 0.088 to 0.404 ppm DW at 1 year

post-treatment (Major and Grue 1997). Feng et al. (1990) reported a 92 to 96% decline
148

in glyphosate concentrations 360 days after aerial application of Roundup® (2.0 kg/ha

glyphosate) to a watershed in a Canadian forest. 

Alkylphenol polyethoxylates, the principal active ingredient potentially hazardous to fish

and wildlife within X-77® Spreader (nonylphenol polyethoxylates) and R-11® Spreader

Activator (octylphenol polyethoxylates), also would not accumulate within sediments

because they undergo rapid and complete primary degradation (Naylor 1992). 

Alkylphenol polyethoxylates degradation occurs through shortening of the ethoxylate

chain by microbial activity (Swisher 1987), which produces polyethylene glycols that are

biodegradable and less toxic than the precursors (Conway et al. 1983). Extensive

biodegradation (>90%) occurred within 14 days post-treatment for shake-culture tests

where nonylphenol polyethoxylates were placed in flasks with a bacterial-inoculated

medium (Huddleston and Allred 1965, Lashen et al. 1966). In contrast, Paveglio et al.

(1996) found that average concentrations of nonylphenol polyethoxylates in sediment

directly exposed to spray declined 42% (0.181→ 0.105 ppm DW) within 14 days following

aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1 liter/ha) to control

Spartina (Willapa Bay). Lower temperatures and reduced microbial activity associated

with later sampling periods may have contributed to the stabilization of nonylphenol

concentrations. Unlike shortening of the ethoxylate chain, ultimate degradation

(conversion to carbon dioxide and water) of alkylphenol polyethoxylates may not be

complete (Swisher 1987). Laboratory studies (Fuka 1978, 1980; Pitter 1979) found 80-

90% ultimate biodegradation for nonylphenol polyethoxylates.

No information is available regarding the degradation of LI-700®; however, it is composed

of a natural lipid (phosphatidylcholine [lecithin]) that is likely subject to biodegradation

Drift of Rodeo® tank mixes to non-target areas associated with ground applications to

Spartina would be minimal under favorable environmental conditions. For sites in Willapa

Bay with Spartina clones treated by a hand-held sprayer with Rodeo® (5% solution) and

LI-700® (2% solution), average concentrations of glyphosate in off-target substrates 0.5 m

from the clone edge immediately after treatment ranged from 1.07 to 5.28 ppm DW

(Major and Grue 1997). The highest concentration of glyphosate (5.28 ppm DW) for

sediments adjacent to hand-treated Spartina clones on spray day occurred at the site

(Lewis Unit on the Refuge) with the highest rate of Rodeo® application (63 liters/ha). 

Grue and Major (1997) also found glyphosate in substrate samples 5 m from edges of

hand-sprayed clones, but concentrations were less than 0.087 ppm DW. Glyphosate likely

was detected 5 m from clones because the height of the Spartina resulted in applications

directed up or across clones rather down onto plants.

Drift of Rodeo® tank mixes to non-target areas associated with aerial applications to

Spartina also would be minimal under favorable environmental conditions. Grue and

Major (1997) found that drift associated with aerial application of Rodeo® (8.8 liters/ha)

and X-77® Spreader (1.2 liter/ha) to a Spartina meadow in Willapa Bay was minimal.

Glyphosate concentrations in sediment 3 and 10 m from the plot boundary immediately

after spray ranged from below the detection limit (0.02 ppm DW) to 0.114 ppm DW and

below the detection limit (4 of 5 samples) to 0.117 ppm DW, respectively. No visible
149

mortality of non-target vegetation on mudflats or salt marsh was found immediately

adjacent to a Spartina meadow (152 ha) at Kaffee-Lewis Slough as well as a 12-ha

meadow at Seal Slough 5 weeks following aerial application with Rodeo® (8.8 liters/ha)

and R-11® Spreader Activator (0.5% solution) in 1996 (C. Moore, Washington Dept.

Agric., pers. commun.). Feng et al. (1989) found that average off-target distance between

the spray boundary and healthy vegetation associated with aerial application of Roundup®

(2.0 kg/ha glyphosate) was 2 m.

On intertidal mudflats where Spartina was treated with Rodeo® tank mixes, erosion and

transport of sediments might occur. Tidal action, wind, waves, and rainstorms might

erode, transport, and redistribute fine sediments. The extent of erosion would depend

upon the magnitude of tidal exchanges, storm(s) size, and area treated. Because roots of

Spartina controlled by Rodeo® applications might take several years to decay and permit

erosion, eroded sediment would not be expected to contain measurable quantities of

glyphosate and surfactant. Erosion could be minimized through natural revegetation by

native species.

4.5.1.2 Hydrology

Hydrologic patterns in the project area would be directly affected by the removal of

Spartina, especially dense clones and meadows, with herbicide application. Removal of

Spartina plants would allow increased flow velocities and unobstructed flow patterns. 

Over time, redistribution of sediments from treated clone sites and meadows would likely

allow tidal and runoff flows to return to pre-Spartina velocities and patterns. Natural tidal

drainage patterns would be preserved in treated areas where early stages of Spartina

growth is halted or prevented. Some changes may still occur because of the presence of

nearby uncontrolled Spartina. The potential for flooding resulting from the restricted

runoff associated with Spartina growth on Refuge tidelands would be avoided or reduced.

4.5.1.3 Water Quality

Beginning in the spring of 1997, the Washington Department of Ecology is conducting an

EPA-funded project to study water quality parameters in Willapa Bay. Water

temperature, dissolved oxygen, nutrients, chlorophyll, pH, light transmission, and

turbidity, as measured by Secchi disk depth, will be measured at six locations (Newton

1997).

The degree of water-quality degradation would be dependent upon the amount of Rodeo®

tank mix that reached the water and its subsequent biodegradation. Because Spartina

intercepts most of the aerially (Kilbride et al. 1995, Major and Grue 1997) and

ground-applied herbicide tank mix (Major and Grue 1997) and overspray or drift are

minimal (Feng et al. 1989, Major and Grue 1997), the primary source for glyphosate and

surfactant in seawater results from the initial washing of target vegetation by the first tidal

inundation or rainfall that occurs before chemical incorporation into Spartina tissue.

Dilution, dissipation, and biodegradation quickly diminish waterborne concentrations of

glyphosate and adjuvant. Paveglio et al. (1996) found that concentrations of glyphosate

and nonylphenol polyethoxylates in seawater were below the detection limit (0.5 ppb) 1
150

day (2 tidal cycles) after aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader

(1.0 liter/ha) to control Spartina in Willapa Bay. Similarly, Kroll (1991) found seawater

concentrations of glyphosate dropped below the detection limit (5 ppb) by 7 days posttreatment in tidal marshes with Phragmites communis patches treated by a hand-held

sprayer with Rodeo® (0.75% solution) and Arborchem Aquatic surfactant (0.5% solution).

 

Because the sea-substrate microlayer (seawater-sediment interface) provides habitat for a

wide variety of marine biota, concern exists regarding toxicity resulting from exposure to

Rodeo® tank mixes from drift or overspray particularly during low tides. Paveglio et al

(1996) found that average concentrations for glyphosate and nonylphenol polyethoxylates

from the leading edge of the first high tide after treatment were ≤25.6 and ≤16.0 ppb,

respectively; and they quickly declined (≤ 9.77 and ≤ 0.5 ppb [detection limit] for

glyphosate and nonylphenol polyethoyxlates, respectively) as a result of water-column

dilution from the subsequent tidal inundation. Similarly, Sundaram et al. (1980) found

that after aerial application of 0.47 liters/ha nonylphenol (to determine the environmental

fate of nonylphenol associated with applications of the pesticide Metacil) the highest

concentration (9.1 ppb) in a stream 1 hour post-treatment declined to undetectable levels

(<1.0 ppb) within 24 hours post-treatment; they attributed the rapid dissipation of

nonylphenol to dilution by water flow. Consequently, hazards to microlayer biota at low

tide are unlikely because glyphosate and alkylphenol polyethoxylates would be present at

non-toxic concentrations (see subsection 4.2.2.5) that are relatively short-lived as a result

of water-column dilution. 

Water-quality degradation through interaction of Rodeo® tank mixes with other pesticides

used in and adjacent to Willapa Bay would be unlikely. In intertidal areas where Spartina

has been sprayed with Rodeo® tank mixes, dilution, dissipation, and biodegradation

quickly diminished waterborne concentrations of glyphosate and adjuvant (Paveglio et al.

1996). Areas with Spartina are geographically separated from areas where oyster beds

with burrowing shrimp are sprayed with Sevin (carbaryl) and cranberries (grown in inland

bogs) are sprayed with a variety of insecticides, herbicides, and fungicides. Moreover,

carbaryl concentrations in water on oyster tracts treated for shrimp were only detectable

for 20 to 30 minutes following the first tidal inundation after treatment (Tufts 1990). The

detectable levels of carbaryl were only found within 68 m (225 feet) of treated tracts

(Tufts 1989). For cranberry crops, water applied to bogs along the Long Beach peninsula

generally drains into freshwater wetlands rather than directly into Willapa Bay (Patterson

1994).

Although degradation of water quality from Rodeo® tank mixes likely would be minimal,

decomposition of treated Spartina could temporarily reduce dissolved oxygen levels and

release nutrients (nitrogen and phosphorus) which could result in algal blooms. 

Conversely, nutrient releases from decaying Spartina could beneficially increase primary

production.

4.5.1.4 Ambient Sound

Operation of airboats, hovercraft, skiffs, and/or helicopters to support wand, wick, or

aerial application of herbicide would increase the sound level on and around the proposed
151

project site. Higher noise levels would include the transport of staff, equipment and

supplies to and from work sites as well as herbicide application. The increase would be

most noticeable to those in non-motorized boats in the vicinity of the activity or along

transport routes. Work on refuge-owned and refuge-associated tidelands would

temporarily elevate noise levels around Long Island, along highway 101 from Stanley

Point south to Greenhead slough, and near Leadbetter Point. On calm days the sounds

would become more noticeable along the east side of the Long Beach Peninsula. In spite

of its use of aircraft, this alternative would generate less total noise than other action

alternatives mainly because of reduced work opportunity. Ground-based chemical

application machinery tends to generate less noise than mechanical methods.

4.5.1.5 Air Quality

Of action alternatives, this alternative would create a higher potential for herbicide spray

drift due to total reliance on chemical control. Drift is discussed further in 4.5.1.1.

Pollution from burning fossil fuels would be comparable to that of the Physical/Mechanical

Alternative.

4.5.2 Biological Environment

4.5.2.1 Vegetation

Most of the existing and expanding Spartina meadow on the Refuge’s southern units and

around Long Island would be converted to native salt-marsh within 10 years. About 2,000

acres of intertidal mudflats supporting seagrass and macroalgae beds would be maintained

on the southern units. Around Long Island most of the existing mudflat habitat would be

maintained but little, if any, existing Spartina meadow would be restored to mudflat.

Rodeo®tank mixes have had variable effects upon non-target marine plants. Japanese

eelgrass growth was adversely affected at 1 of 2 plots aerially treated with Rodeo® (4.7

liters/ha) and X-77® Spreader (1.0 liter/ha) in Willapa Bay (C. Fresh et al 1996). The

affected plot had shallower water depth and, therefore, greater eelgrass exposure during

the herbicide application. Rodeo® (10.3 [4.44 quarts/acre] to 0.7 liter/ha [0.3

quarts/acre]) and X-77® Spreader applied by hand-held sprayer to eelgrass (Zostera spp.)

in Padilla Bay did not affect biomass during an 8-week study period (Bulthuis and

Hartman 1994). Rodeo® (4.7 liters/ha) and X-77® Spreader (1% solution) applied by

hand-held sprayer to plots with native salt marsh vegetation had no effect upon density,

cover, and biomass of pickleweed or salt grass up to 1 year post-treatment; however,

cover and biomass of saltbush were reduced at 60 days post-treatment likely because

exposure time (>8 hours) was longer for this species located higher in the intertidal zone

(Bulthuis and Scott 1993). No adverse effects were found to marine microalgae after

aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0 liter/ha) to control

Spartina in Willapa Bay (Simenstad et al. 1996). Direct application of Rodeo® to marine

macrophytes would likely result in impacts. However, these impacts might be reduced or

eliminated if non-target macrophytes are covered with seawater. No impacts to marine

microalgae would result from herbicide control of Spartina. 

The 96-hour LC50 for the marine alga is 27 ppb for nonylphenol (Naylor 1992), which is

the nonylphenol polyethoxylate degradation product with the greatest toxicity to aquatic
152

organisms. This value is 1.7 times greater than the maximum average concentration of

nonylphenol polyethoxylates (16 ppb) from the leading edge of the first high tide following

aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0 liter/ha) from the

Paveglio et al. (1996) study. 

Chemical control would prevent Spartina from completely taking over shallow mudflats

and associated plant habitats. Most existing areas of native plant habitat would be

preserved. Where Spartina clones were killed, native saltmarsh plants might increase

because sediment accrual in the clones has raised the elevation of the mudflats to a suitable

height. Depending on the elevation, either saltmarsh plants or eelgrass would quickly

recolonize areas where Spartina was controlled. Seed production on the Refuge would

likely be stopped over time, reducing impacts to plant communities on adjacent tidelands.

4.5.2.2 Spartina

Spartina seed production would be stopped within 5 years on the southern units and 10

years around Long Island. Over time, this alternative would control seed production

affecting neighboring lands and reduce the potential for viable seed movement out of

Willapa Bay. Expansion of Spartina meadows on southern units would continue for a few

years before the trend was reversed. No meadow would be expected to remain after 10

years there. Some Spartina meadow would probably remain in 10 years around Long

Island.

Ground applications with Rodeo® tank mixes would control Spartina within the intertidal

zone. Kilbride et al. (1996) sprayed Spartina clones on the Refuge (Porter Point) by

hand-held equipment and achieved 84% control (reduction in stem densities) 1 year posttreatment. R. Crockett (Monsanto Agric. Co., pers. commun.) found ≥90% declines in

Spartina 1 year after treatment with Rodeo® (0.56 to 2.24 kg glyphosate/ha) and R-11®

Spreader Activator (1% solution) by hand-held boom. Major and Grue (1997) found 80

to 90% and 89 to 93% reductions in stem densities 1 year after treatment of Spartina

clones in Willapa Bay on sites with muddy substrates (North River and Lewis Unit on the

Refuge) associated with spraying Rodeo® (5% solution) and LI-700 (2% solution) by

hand-held equipment alone and in combination with mowing 6 weeks prior to herbicide

application, respectively. Lesser control (6 and 69% reductions for spray alone and

mowing/spraying treatments, respectively) was found for a site (Nemah Beach) identically

treated on sandy substrate (Major and Grue 1997). Differences in efficacy may have been

related to Rodeo® delivery rates, where muddy sites received 54 to 63 liters/ha compared

with 47 liters/ha at the sandy site. Garnett et al. (1992) found a 74 to 89% decrease (1

year after treatment) in stem densities of Spartina anglica sprayed by hand-held boom

with Roundup® (1.80 kg glyphosate/ha) and Pro-Mix surfactant (2% solution). Pritchard

(1995) applied glyphosate (Glyphosate 360 at 40 liters/ha) to plots within a Spartina

meadow (Victoria, Australia) by held-held sprayer and achieved 84% control after 1 posttreatment year.

Aerial applications of Rodeo® tank mixes to Spartina would also result in control. 

Kilbride et al. (1996) found 32% declines in stem densities of Spartina for three 1-ha plots

with clones aerially sprayed in August 1992 with Rodeo® (4.7 liters/ha) and X-77®
153

Spreader (1 liter/ha) in Willapa Bay. Short exposure time (≤5.5 hours) and low rate of

Rodeo® application (4.7 compared with 8.8 liters/ha [maximum rate by label]) likely

prevented cuticular penetration of sufficient amounts of glyphosate to affect better

control. In August 1995, a 2-ha plot within a Spartina meadow in Willapa Bay (KaffeeLewis Slough) was aerially sprayed with Rodeo®

 (8.8 liters/ha) and X-77® Spreader (1.2

liter/ha). Pre- and post-treatment (1 year) data (stem densities) were collected and

indicated no Spartina control (Grue and Major 1997). In addition, the Spartina meadow

(152 ha) in Kaffee-Lewis Slough, which included the 2-ha plot treated in 1995, as well as

a 12-ha meadow in Seal Slough were aerially sprayed in early July 1996 with Rodeo® (8.8

liters/ha) and R-11® Spreader Activator (0.5% solution). Visual (aerial) observations of

the treated meadows 5 weeks after application indicated approximately 65 to 75% brown

down with no seed set (C. Moore, Washington Dept. Agric., pers. commun.). Greater

control likely will be achieved with meadow spraying during 1996 compared with the

1992 and 1995 treatments because exposure time was greater. The 1996 application was

conducted during a rising low-high tide with 12 hours of exposure before most of the

treated Spartina was inundated; whereas, exposure times for the 1992 and 1995

treatments were about 6 hours.

Spartina would be directly affected by the application of herbicide and surfactant. The

action would kill or retard treated Spartina seedlings, clones, and meadows, slow the

spread via asexual growth, and prevent seed production. It would not effectively prevent

the establishment of seedlings from seed sources outside the treated area.

4.5.2.3 Wildlife

Under this alternative, most of the existing mudflat and native saltmarsh habitat on the

Refuge would be maintained. Former areas of these habitats, now occupied by Spartina

would revert mostly to native saltmarsh due to the sediment accretion that has occurred. 

Wildlife use similar to existing conditions on the Refuge would be sustained.

Because toxic dietary thresholds are not likely to be reached after Rodeo® applications to

control Spartina, no effects upon aquatic migratory birds are expected. Dietary toxicity

tests with mallard ducklings found a LC50 value of 4,640 ppm for glyphosate (Heydens

1991), which classifies glyphosate as practically non-toxic. This LC50 level would require

an average daily intake of 1,106 mg/kg (Heydens 1991). Female mallards exposed to

dietary concentrations ≤1,000 ppm (equivalent to an average daily intake of 126 mg/kg)

showed no reproductive effects. In addition, the highest average concentration of

glyphosate in Spartina, which might be similar to what could be expected in sprayed

eelgrass (a species consumed by aquatic birds) 1 day after aerial application of Rodeo®

(4.7 liters/ha) and X-77® Spreader (1 liter/ha) in Willapa Bay was 65.6 ppm (Paveglio et

al. 1996). Because this value is 71 times less than the LC50 value for mallard ducklings,

toxic dietary thresholds for aquatic birds would not likely be reached after Rodeo®

applications to control Spartina.

 

Field studies have not found direct adverse effects of glyphosate on birds. Solberg and

Higgins (1993) found nesting success of waterfowl was not affected in wetlands sprayed

with Rodeo® (2.8 liters/ha) and X-77® Spreader (0.33% solution) to control cattails
154

(Typha spp.). Roundup® (2.3 liters/ha) applied to an Oregon coastal forest for conifer

release (control of competing deciduous shrubs and trees) did not affect the bird

community although habitat was altered for 2 years post-treatment (Morrison and Meslow

1984). In contrast, Santillo et al. (1989) found that aerial application of Roundup® to

clearcuts in north-central Maine reduced total numbers of birds, but this was a result of

changes in habitat structure.

Several field studies have been conducted to determine the effects of glyphosate on

mammals. Sullivan (1979) found that black-tailed deer (Odocoileus hemionus) did not

alter browsing habits and showed no adverse effects following consumption of forage in

areas aerially treated with Roundup®. Anthony and Morrison (1985) found that aerial

application of Roundup® (2.25 liters/ha) in coastal forests of western Oregon increased the

abundance and diversity of small mammal populations. D’Anieri et al. (1987) found that

richness of the small mammal community was not affected after clearcuts in northern

Maine were aerially treated with Roundup® (2.25 liters/ha). 

Short-term (acute) toxicity based upon a limited number of laboratory studies indicate that

X-77® Spreader and R-11® Spreader Activator are non-toxic to mammals. For

nonylphenol polyethoxylates, the oral LD50 for rats and mice ranges from 2,000 to 4,000

ppm (Benson and Nimrod 1994). No nonylphenol polyethoxylates were detected in

Spartina 1 day after aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1

liter/ha) in Willapa Bay (Paveglio et al. 1996), and nonylphenol polyethoxlates were found

at an average concentration of 0.181 ppm in sediment on spray day. Because these values

are at least 11,000 times less than the LD50 value for rats and mice, effects on mammals

are not likely after applications of alkylphenol ethoxylate-based surfactants to control

Spartina.

Through laboratory studies (Mueller and Kim 1978, Soto et al. 1991, Jobling and Sumpter

1993), alkylphenol polyethoxylates have recently been recognized as xenoestrogens

(environmental estrogens) capable of mimicking estrogen and, therefore, affecting

reproductive endocrine function in biota. However, nonylphenol polyethoxylates did not

persist in sediment and seawater (see subsections 4.5.1.1 and 4.5.1.3) after herbicide

applications to control Spartina (Paveglio et al. 1996) and, consequently, estrogenic

effects upon wildlife are unlikely.

Noise from the airboats, hovercraft, skiffs, and/or helicopters would likely drive

waterbirds from project areas during operations at low tides. Swimming-type birds would

be expected to return during high tides. The disturbances would be minimal because

operations would be outside the peak-use period (fall and winter) for migratory waterfowl

and shorebirds which concentrate on the mudflats and shallow water. In order to avoid

disturbances, aerial control activities would not take place within 1⁄2 mile of any active bald

eagle nest.

4.5.2.4 Fish

Most of the existing fish habitat on the refuge would be preserved under this alternative. 

However, some mudflat habitat would be lost and native saltmarsh would likely increase.
155

The maximum average concentration of glyphosate (25.6 ppb) found during the first tidal

inundation for the Paveglio et al. (1996) study was 23,000 to 56,000 times less than 96-

hour LC50s (Rodeo® and X-77® Spreader) for chinook and coho salmon fingerlings,

respectively (Mitchell et al. 1987a); and 108 times less than concentrations that did not

disrupt seawater adaptation or growth of coho salmon smolts (Mitchell et al. 1987b). 

Acute toxicity based upon a limited number of laboratory studies indicate that X-77®

Spreader and R-11® Spreader Activator are moderately and non-toxic to fish, respectively.

 LC50s (96- and 48-hour) values for nonylphenol and nonylphenol polyethoyxlates were ≤

3.0 ppm, and range from 0.13 ppm for Atlantic salmon (McLeese et al. 1980) to 3.0 ppm

for saltwater cod (Swedmark 1968) and flounder (Swedmark et al. 1971). In general,

young fish have been found to be more sensitive than adults. For example, developmental

abnormalities and increased mortality rates occurred for cod eggs and larvae exposed to

>0.2 ppm (Swedmark et al. 1971). Because the maximum mean concentrations of

nonylphenol polyethoxylates in the leading edge of the first high tide after treatment

(worst case) was significantly less (16 ppb [Paveglio et al. 1996]) than these LC50 values,

toxicological effects upon fish are unlikely. 

Estrogenic effects upon fish associated with alkylphenol polyethoxylate-base surfactants

are unlikely. Sheahan and Harries (1992) found nonylphenol concentrations between 20

and 50 ppb induced the production of vitellogenin (protein usually found only in sexually

mature females) in male rainbow trout. Jobling et al. (1996) found induction of

vitellogenin synthesis and reduction in testicular growth for juvenile male rainbow trout

continuously exposed to 3 and 10 ppb nonylphenol and octylphenol, respectively, during 

a 3-week laboratory study. Jobling et al. (1996) also found that the degree of inhibition

for testicular growth associated with nonylphenol and octylphenol depended upon the

timing of exposure as well as sexual maturity, where inhibition was less pronounced for

exposure toward the end the gonad growth phase and no inhibition was found for sexually

mature fish. Although Paveglio et al. (1996) found higher average concentrations of

nonylphenol polyethoxylates (≤16 ppb) in the leading edge of the first tidal inundation

after herbicide application, nonylphenol polyethoxylates were undetectable (≤2.0 ppb) in

seawater during the first high tide after treatment.

4.5.2.5 Microbes and Marine Invertebrates

The results of field and laboratory studies indicate that Rodeo® tank mixes applied to

Spartina likely would not affect marine invertebrates through seawater exposure. 

Simenstad et al. (1996) found no short- (28 days post-treatment) or long-term (119 days

post-treatment) effects to epibenthic invertebrate communities associated with aerial

application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0 liter/ha) to control

Spartina in Willapa Bay. Kubena (1996) conducted 96-hour bioassays with marine

amphipods native to the Atlantic Coast (Leptocheirus plumulosus) and the Pacific

Northwest (Eohaustrorius estuarius) that were placed in various dilutions (0.1 to 10%) of

the herbicide tank mix representing the maximum application rate for aerial control of

Spartina (8.8 liters/ha for Rodeo® [500 ppm glyphosate] and 2% solution for a nonionic

surfactant [25 ppm nonylphenol polyethoxylates {X-77® Spreader}, 40 ppm octylphenol
156

polyethoxylates {R-11® Spreader Activator}, or 22 ppm phosphatidylcholine {LI-700®}]).

 Amphipod survival was not affected for these 96-hour bioassays up to the highest

concentrations tested (50 ppm glyphosate and 2.5, 4.0, or 2.2 ppm for nonylphenol

polyethoxylates, octylphenol polyethoxylates, and phosphatidylcholine, respectively). In

another series of 96-hour bioassays, amphipod survival was reduced by 30%, and 25 to

80% at 248 ppm glyphosate and 11 ppm phosphatidylcholine, and 124 ppm glyphosate

and 6.2 or 9.9 ppm nonylphenol polyethoxylates or octylphenol polyethoxylates,

respectively. Bioassays (48-hour) with echinoderm larvae (Dendraster excentricus)

indicated that glyphosate and nonylphenol polyethoxylates, octylphenol polyethoxylates,

phosphatidylcholine concentrations up to the highest concentrations tested (5 ppm and

0.25, 0.40, or 0.22 ppm, respectively) did not affect survival. Kubena et al. (1996)

conducted a 96-hour bioassay with Pacific oysters (Crassostrea gigas) in which seawater

spiked with Rodeo® and R-11® Spreader Activator was added to 2.8 ml chambers with

seawater from Puget Sound. For this 96-hour bioassay, glyphosate and octylphenol

polyethoxylate concentrations at 250 and 20 ppm, respectively, reduced survival of larval

oysters. The maximum average concentration of glyphosate in seawater (25.6 ppb) found

on sprayed plots during the first high tide after application in the Paveglio et al. (1996)

study was 4,844- and 9,766-fold less than glyphosate concentrations that reduced survival

of amphipods and oysters, respectively, in bioassays.

The results of field and laboratory studies indicate that Rodeo® tank mixes applied to

Spartina likely would not affect marine invertebrates through sediment exposure.

Simenstad et al. (1996) found no short- (28 days post-treatment) or long-term (119 days

post-treatment) effects to benthic invertebrate (infauna and meiofauna) communities

associated with aerial application of Rodeo® (4.7 liters/ha) and X-77® Spreader (1.0

liter/ha) to control Spartina in Willapa Bay. Kubena (1996) conducted 10-day bioassays

with Leptocheirus plumulosus and Eohaustrorius estuarius in which Refuge (Lewis Unit)

sediment spiked with Rodeo® and R-11® Spreader Activator were added to the 1-liter test

chambers with seawater from Puget Sound. For these 10-day bioassays, glyphosate and

octylphenol polyethoxylates up to the maximum concentrations tested (2,066 and 165

ppm, respectively) did not affect amphipod survival. Kubena et al. (1996) conducted 96-

hour bioassays with Pacific oysters in which Refuge sediment spiked with Rodeo® and

surfactant (X-77® Spreader, R-11® Spreader Activator, or LI-700®) was added to 2.8 ml

chambers with seawater from Puget Sound. For these bioassays, glyphosate and

nonylphenol polyethoxylates, octylphenol polyethoxylates, or phosphatidylcholine

concentrations at 5,122 ppm and 256, 410, or 224 ppm, respectively, reduced survival of

larval oysters. The maximum average concentrations of glyphosate and nonlyphenol

polyethoxylates in sediment (2.82 and 0.181 ppm DW, respectively ) found on treatment

plots in the Paveglio et al. (1996) study were 1,816- and 1,414-fold less than glyphosate

and nonylphenol polyethoxylate concentrations, respectively, that reduced survival of

oysters in bioassays.

The results of LC50 tests with glyphosate or alkylphenol (nonylphenol and octylphenol)

polyethoxylates also indicate that Rodeo® tank mixes applied to Spartina likely would not

affect marine invertebrates. The maximum average concentration of glyphosate in

seawater found on sprayed plots during the first high tide after application in the Paveglio
157

et al (1996) study was 25 to 39,000 times less than 96-hour LC50s for fertilized eggs of

Atlantic oysters (Crassostrea virginica), fiddler crabs (Uca pugilator), grass shrimp

(Palaemonetes vulgaris), a marine alga (Skeletonema costatum), mysid shrimp

(Mysidopsis bahia), and sea urchins (Tripneustes esculentus) tested with glyphosate

(Heydens 1991). For alkylphenol polyethoxylates, 96-hour LC50s values of 2.9 to >100

ppm and <5 to >100 ppm were found for marine crustaceans and bivalves, respectively

(Talmage 1993:270), but nonylphenol polyethoxylates were not detected (<2.0 ppb) in

seawater found on sprayed plots during the first high tide after application for the Paveglio

et al. (1996) study. Laboratory studies also indicate that LI-700® is nontoxic to aquatic

invertebrates.

Because nonylphenol polyethoxylates did not persist in seawater or sediment after

herbicide applications to control Spartina (Paveglio et al. 1996), estrogenic effects upon

invertebrates associated with alkylphenol polyethoxylate-based surfactants are unlikely. 

Of the action alternatives, this alternative would result in the least amount of trampling

impact to invertebrates. By preserving and restoring mudflats, eelgrass and macroalgae

beds, Spartina control would benefit shellfish and other invertebrates associated with these

habitats. By reducing seed production in the bay, fewer Spartina seedlings would be

expected to sprout on Refuge and neighboring tidelands, thus maintaining more mudflat

habitat for invertebrates. In areas still dominated by Spartina, many species of shellfish

and other benthic macroinvertebrates would either not survive or be reduced in numbers

(Washington State 1993, Atkinson 1992, Simenstad and Thom 1995).

4.5.2.6 Biodiversity

With careful procedures to avoid application to non-target organisms and the unlikeliness

of toxicological effects of maximum concentrations in the saltwater or sediments,

biodiversity should not be directly affected by use of Rodeo® to treat Spartina. Control to

prevent monotypic stands of Spartina would protect biodiversity of plants, wildlife and

invertebrates.

4.5.3 Social Environment

4.5.3.1 Human Health

Little potential exists for acute toxicity to humans nor long-term health impacts associated

with cancer or other maladies from exposure to glyphosate associated with Rodeo®

applications to control Spartina. Knowledge regarding the acute toxicity of glyphosate to

humans comes from a study conducted by Japanese physicians who investigated 56

poisoning cases, most of which were suicides or attempted suicides, involving Roundup®. 

For the 9 cases in which the suicide attempts were successful, the mean amount ingested

was 200 ml (3⁄4 of a cup) of herbicide; however, the polyethoxylated tallowamines

(surfactant in Roundup® but not Rodeo®) likely caused the herbicide toxicity (Sawada et

al. 1988). Short- and long-term non-cancer health effects were below levels of regulatory

concern for adults and children (1 in 1,000,000). Similarly, all risks calculated for cancer

effects were also below the regulatory concern level (1 in 1,000,000). Because no

carcinogenic effects were found for chronic studies with rats and mice, glyphosate has

been classified by the U.S. Environmental Protection Agency as noncarcinogenic to

humans (Washington State 1993).
158

Because alkylphenol polyethoxylates did not persist in sediment and seawater (see

subsections 4.5.1.1 and 4.5.1.3) after herbicide applications to control Spartina (Paveglio

et al. 1996), estrogenic effects upon humans associated with alkylphenol polyethoxylatebased surfactants are unlikely.

There are certain health problems that have occurred with a statistically higher frequency

in Pacific County than in the State as a whole. However, there are no indications that any

of these health problems are associated with environmental conditions (See 3.4.2.1). The

low potential for movement of approved chemical compounds off of treatment sites, the

tendency for these compounds not to persist, and the low toxicity of concentrations found

on treatment sites make it unlikely that the Chemical Means Only Alternative would

generate an environmental health hazard or contribute to existing health problems.

Health problems associated with Spartina pollen production and mosquitos that breed in

Spartina meadows on the Refuge would be reduced within 10 years by this alternative but

to a slightly lesser extent than IPM.

4.5.3.2 Concerns

This alternative would involve exclusive use of a chemical herbicide (glyphosate) and

surfactants to control Spartina. Current information about these chemicals is provided in

other parts of this document. Efforts to find new chemicals that improve efficacy and

safety would continue.

Concerns about chemical risk would be greatest under this alternative. Concerns about

Spartina spread would be reduced.

4.5.3.3 Recreation

Noise from airboats, hovercraft, skiffs, and/or helicopters would be heard by nonmotorized boaters on the bay and users of the Long Island and Leadbetter Point units

during operations. These sounds would be most noticeable in the immediate vicinity of

operations or along transport routes. This could distract from recreational experiences.

Disturbance of aquatic migratory birds during the low-tide operations would occasionally

interfere with bird watching in the vicinity of control activities. Fishermen would not

normally be affected by operations because the operations would be on exposed mudflats

during low tides.

In the long term, recreational boating, shellfish gathering, fishing, hunting, and bird

watching would benefit by Spartina control through maintenance of habitats, access, and

navigation capabilities.

4.5.4 Economic Environment

A moderate level of Refuge resources would go to off-Refuge control efforts.

4.5.4.1 Tourism

Tourism would not be expected to be directly affected by proposed actions in this EA. 
159

The project would contribute to the overall health of local tourist-related businesses in

future years by protecting recreational qualities.

4.5.4.2 Mariculture and Fisheries

Spartina on Refuge tidelands produces seeds that spread to adjacent private and State

tidelands, many of which support oyster mariculture and clam harvesting. Spartina

inhibits shellfish production by eliminating suitable habitat and thus has a high potential for

negatively impacting the shellfish industry. Seed production on Refuge tidelands would

eventually be eliminated by this alternative.

NOTE: For more discussion of the consequences of the Chemical Means Only Alternative,

see pages 152-161 and the Element EA, EB, and F reports of the State FEIS on

Noxious Emergent Plant Management, 1993. 

4.6 CUMULATIVE EFFECTS

Cumulative effects are the environmental impacts resulting from the incremental effect of a

proposed action, when added to other past, present and reasonably foreseeable future

actions, whether or not they are undertaken by the Refuge and related to Spartina control.

 Cumulative impacts can result from individually minor but collectively significant actions

taking place over a period of time. The analysis in this Comprehensive EA focused on the

consequences of long-term control of Spartina on Refuge-owned tidelands. In order to

consider cumulative impacts, the EA also considered this project in light of other control

efforts taking place in Willapa Bay, and continued control to be carried out in future years

through Refuge efforts. The former actions are covered in detail in the State EIS while

the latter are covered in this EA for Spartina control by this Refuge. In addition to the

incremental reduction in Spartina acreage, other substantial, cumulative effects of Refuge

Spartina control include the incremental restoration and protection of fish, wildlife, their

habitats, and associated values and uses on and off Refuge tidelands.

4.6.1 No Action

The cumulative effect would be continued growth and spread of Spartina on the Refuge

added to existing growth. It should be noted that the rate of growth and spread of

Spartina from one year to the next is exponential. Therefore, each year of no action

compounds the amount of control effort needed in the next year.

If Spartina were never controlled, all available tidelands would eventually become

occupied. Both shallow mudflats and native saltmarsh would ultimately become Spartina

marsh. Continued growth and spread of Spartina on Refuge lands would provide an

incremental increase in the quantity of Spartina seed annually on- and off-Refuge. Small

changes in topographic relief and estuarine functions would occur each year until the

spread of Spartina was complete. The cumulative effects of the continued spread of

Spartina would be the near-total loss of existing intertidal habitat for wildlife, fish, and

shellfish, and associated values throughout the bay, including the Refuge.

4.6.2 All Action Alternatives
160

Cumulative effects would be the effects of control efforts on Refuge lands added to all

efforts on State and private lands within Willapa Bay past, present, and future. If

completely successful, the cumulative effect of all control actions in the bay would be the

eradication of Spartina from Willapa Bay over time. Inherent with Spartina eradication

would be the restoration and protection of environmentally and economically important

tidelands, and all the wildlife, fish, shellfish, mariculture, and other values these areas

support. A lesser degree of success would be the elimination of Spartina from sensitive

and valuable habitats and economically important tidelands and prevention of seed

production on the remaining lands.

4.7 UNAVOIDABLE ADVERSE EFFECTS

4.7.1 No Action

The unavoidable adverse effect of the no action alternative is the conversion of open

mudflats to Spartina marsh with resulting changes in topographic relief and estuarine

functions including physical, chemical, and biological modifications, and the social

(recreational) and economic implications of those changes.

4.7.2 All Action Alternatives

Unavoidable adverse effects common to all action alternatives are primarily related to

access to and from the project sites and among Spartina clones, and the aerial application

of herbicide. Operation of airboats, hovercraft, weedcutters, and helicopters will create

unavoidable noise disturbances to wildlife and possibly humans. Where walking on the

mud is required, some level of trampling is unavoidable. Measures to mitigate and/or

minimize these adverse effects, where possible, have been incorporated in all action

alternatives.

4.8 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENT OF RESOURCES

Gasoline will be burned to operate motorized vehicles for access to the site, and weedcutters used to mechanically remove Spartina. Helicopters will burn jet fuel.
161

5.0 CREDITS

This work draws on previous work from a variety of sources, including those listed in the

reference section. Not all sources were directly credited. This is common in documents

of this type and does not represent either a lack of appreciation nor an attempt to claim

their work as our own. The following staff of the US Fish and Wildlife Service

contributed to the preparation of this document:

Name, Position, and

Location

Contribution Degree(s) Years

Experience

Alan C. Clark, 

Wildlife Biologist,

Julia Butler Hansen

Refuge for the

Columbia White-tailed

Deer, Cathlamet, WA

Physical/Mechanical Means

and IPM Sections of

Consequences Chapter

BS: Wildlife

Management

MS: Wildlife

Ecology

PhD: Animal

Nutrition

22

James A. Hidy,

Refuge Manager,

Willapa NWR

Complex,

Ilwaco, WA

Reviewer/Editor; Purpose &

Need for Action and

Alternatives Chapters

BS: Wildlife

Management

MF: Forestry

21

(15 - Spartina)

Kevin M. Kilbride

Wildlife Biologist,

Division of Refuge

Operations Support,

Vancouver, WA

Chemical Means and IPM

Sections of Environmental

Consequences Chapter

BS: Biology

MS: Wildlife

Science

7

(6 - Spartina)

Mark Strong

Wildlife Biologist,

Division of Realty,

Portland, OR

Reviewer/NEPA consultant BS & MS: Wildlife

Biology

29

Stephen B. Moore,

Chief,

Division of Refuge

Operations Support,

Portland, OR

Reviewer; NEPA consultant BS: General

Biology

MA: Natural

Resources

Planning and

Management

23

Fred L. Paveglio,

Wildlife Biologist,

Division of Refuge

Operations Support,

Vancouver, WA

Reviewer BS: Zoology

MS: Wildlife

Management

21

(6- Spartina)

Don A. Williamson,

Wildlife Biologist,

Affected Environment

Chapter, No Action and IPM

BS: Wildlife

Ecology &

21
162

Willapa NWR,

Ilwaco, WA

Sections of Consequences

Chapter

Fisheries

BA: Psychology & 

 English

(4 - Spartina)
163

6.0 LIST OF AGENCIES AND PERSONS RECEIVING NOTICE OF AVAILABILITY

As part of the National Environmental Policy Act of 1969, the Service distributed a Notice of

Availability for this EA to the following agencies, organizations and individuals. The review

period for enviromental assessments is 30 days.
103

Agencies & Organizations

American Assoc. of Univ.

Women/

 Willapacific Branch

Aquatic Habitat Mgt. Corp.

Bay Center Mariculture

Benevolent & Protective Order

of Elks,

Lodge #1937

Canoe & Kayak

City of Ilwaco

City of Long Beach

City of Raymond

City of South Bend

Columbia Pacific RC&D

Columbia Pacific Resources

Center, Inc.

CREST

Eagles Aerie #3602, Ocean Park

Ecotrust

Evergreen State College

Friends of the Earth

Grayland Cranberry Grower's

Assoc.

Grays Harbor Audubon

Jolly Roger Oyster Co.

Kiwanis Club, Long

Beach/Ilwaco Chapter

Kiwanis Club, South Bend

Chapter

Lions Club, Long Beach

Peninsula

Long Beach Cranberry Grower's

Assoc.

Long Beach Visitor's Center

Naselle Chamber of Commerce

Northwest Outdoor Center

NW Decoy Association

Olympic Outdoor Center

Oregon Ocean Paddling Society

Pacific Coast Oyster Grower’s

Association

Pacific Conservation District

Pacific Co. Board of

Commissioners

Pacific Co. Dept. of Community 

Development

Pacific Co. Economic Development Council

Pacific Co. Flood Control District

Pacific Co. Weed Board

Pacific Water Sports

Pack & Paddle

Peninsula Moose Lodge #2362

Peninsula Senior Center

Port of Ilwaco

Port of Willapa Harbor

Puget Sound Paddle Club

Raymond Chamber of Commerce

Sea Kayaker

Sea Resources/Chinook Hatchery

Shoalwater Bay Indian Tribe

Shoretrust Trading Group

South Bend Chamber of Commerce

Steelheader's Association

The Mountaineer

The Mountaineers Kayak Committee

The Nature Conservancy

Trade Association of Sea Kayaking

University of Washington

WA Coop Extension Svc

WA Seagrant Program

WA State Dept. of Agriculture

WA State Dept. of Ecology

WA State Dept. of Ecology - Water Quality 

Program

WA State Dept. of Fish & Wildlife

WA State Dept. of Fish & Wildlife - 

Hatcheries Program

Vancouver Audubon

WA State Dept. of Fish & Wildlife -

Oyster Lab

WA State Dept. of Natural Resources

WA State Weed Control Board
104

Washington Farm Forestry

Washington Kayak Club

Washington Toxics Coalition

Washington Water Trails

Association

Weyerhaeuser Corporation

Willapa Alliance

Willapa Bay Gillnetter's

Association

Willapa Bay Oyster Growers

Assoc.

Willapa Bay Shellfish Laboratory

Willapa Bay Water Resources

Coord.

Council

Willapa Hills Audubon Society

Willapa Salmon Enhancement

Group

WSDA/Pesticide Management

WSU - Long Beach Research &

Extension Unit

Individuals

Jennifer Anderson

Mark Ashley

Spencer Beebe

Jennifer Belcher

Bill Brookreson

Mason Browne

David Burke

Joe Camenzind

David Campiche

Sue Cannard

Rebecca Chaffee

Connie Christiansen

Janie Civille

Darlene Clements

Ed & Fritzi Cohen

Mike Colby

Ronald Cross

Ed Darcher

Russ Davis

Ruth Deery

Diane Dolstad

State Representative Mark

Doumit

Les Driscoll

Brett Dumbauld

Arthur Dye

Louie Echols

Andy Engilis

Helen Engle

Bob Faulkner

Allan Felsot

Karl Ferrier

Bob Fields

Terry Fisher

Kurt Fresh

H. Paul Friesema

Chuck Gale

Bruce Gardner

Scott Gatzke

Steve Gilmore

U.S. Senator Slade Gorton

Jennifer Hagen

Pat Hamilton

Steve Harbell

Brian Harrison

State Rep. Brian Hatfield

Peter Havens

Tom Hayes

Ross Heath

Pete Heckes

David Heimer

John Herrold

Jamie Hill

Vyrle Hill

Jim Hillery

Steve Holloway

Chuck Hoskinson

Mark Huber

Rex Hutchins

Kahle Jennings

Leroy Johnson

Stephen Jones

Jon Kaino

Joe Krupa

John Kuntz

Bob Lake

Terry Larson

Leon Lead
105

Allen Lebovitz

Wendy Lebovitz

Jack Leech

Louie Lembke

Mike Linsenbigler

Governor Gary Locke

Jim Lowery

Fayette Krause

Mike Mandere

Dan'l Markham

Elliot Marks

Mike Marsh

Ann Marshall

Malcolm McPhail

Bob Merkel

Dave Milne

Ray Milner

Vic Moon

Tim Morris

Lee Moyer

U.S. Senator Patty Murray

Brent Naylor

Sandie Nelson

Jim Neva

Dave Nichols

Michael Norman

Brian O'Connor

Jeff Parsons

Kim Patten

Larry Peck

Laurie Penders

Marty Peoples

Charles Perry

Norris Petit

Ken Ramsey

Loree Randle

Allen Richards

Cheryl L. Rinehart

Bob Robinson

Bob and Janie Rose

Carol Rushmore

Bob Ryan

Clyde Sayce

Kathleen Sayce

Jim Sayce

Dean Schwickerath

Sam Schlegel

Bob Schmidt

Sylvia Schneidmiller

Peter Schoonmaker

Rudy and Winona Schuver

Dick Sheldon

John Sims

Charles Simenstad

Larry Skidmore

U.S. Rep. Linda Smith

Tim Smith

Karen Snyder

State Senator Sid Snyder

Michael Spencer

Ray Spurrell

Brad Stracener

Jesse Strope

Bill Stuart

Dennis Stuhaug

Ray Sutter

Jeff Tetraglia

William Thomas

John L. Thompson

Steve Tolzman

James Trick

Dennis Tufts

Elmer Turja

Robert Turner

Jim Walls

Larry Warnberg

Miranda Wecker

Fred Weinmann

Neil Weisener-Hanks

Herb Whitish

Andy Wiegardt

Lee Wiegardt

Dobby Wiegardt

Chris Wiegardt

Peter Williams

Dennis Wilson
106

Richard Wilson

Tim Wilson

Skip Wilson

Libraries

Ilwaco Timberland Library

Naselle Timberland Library

Ocean Park Timberland Library

Raymond Timberland Library

South Bend Timberland Library

Media

Aberdeen Daily World

Chinook Observer

Harbor Herald

KAST

KKEE

KMUN

KSWW

Montesano Vidette

The Daily News

South Beach Bulletin
107
108

GLOSSARY

acute toxicity The capacity of a chemical to cause injury or mortality of organisms within a short

period (hours to several days) after exposure.

adjuvant Any chemical, in addition to water, added to a herbicide tank mix. Adjuvants are used

for a variety of reasons that include the following: improve the wetting or spreading of spray

drops; increase penetration of the herbicide into plant cells; reduce herbicide losses from

evaporation; retard foaming in spray tanks; increase the viscosity of a tank mix to reduce drift,

prevent/reduce over spray or multiple treatment of sprayed areas (dyes), and buffer the pH of

diluting water.

aerobic Free oxygen is present.

algae Chiefly aquatic one-celled or multicellular plants that lack true stems, roots, and leaves. 

Many seaweeds are algae.

alkylphenol ethoxylates A general term used to describe an active ingredient within some

nonionic surfactants. The name represents the following three components of its chemical

structure: "alkyl" for a carbon chain, "phenol" for a benzene ring, and "ethoxylate" for a repeating

chain of ethylene oxide groups (-CH2CH2-O-).

anaerobic Free oxygen is absent.

benthic, benthos Refers to the organisms living on or in the bottom of the bay.

benthic macrofauna The larger animals living on or in the bottom of the bay. Oysters and

clams, for example.

bioaccumulate The capacity for a chemical to build up (accumulate) within a plant or animal as a

result of long-term exposure to an environmentally persistent contaminant or repeated

introduction of a nonpersistent one.

biodegradation The process of decomposition by natural biological means.

biota The animal and plant life of a region.

bivalve A mollusk having a shell consisting of two hinged parts. An oyster or clam, for example.

clone One or more organisms descended asexually (by means other than seeds) from a single

parent. In this document, clone refers to the round stands of Spartina plants in which all of the

stems are descended from a single seedling.

cogener A member of the same genus of plant or animal.
109

crustacea A class of arthropods having a segmented body, a chitinous exoskeleton, and paired,

jointed limbs. Includes lobsters, crabs, shrimps, and barnacles.

detritus Disintegrated matter such as pieces of plants.

diurnal Having a daily cycle. Also, occurring or active during the daytime.

drift The airborne movement of a herbicide tank mix from a target to a non-target area, which

occurs during spray operations.

epibenthic Refers to organisms associated primarily with the surface of the bottom but also with

the water directly above the bottom. Includes a wide variety of zooplankton, amphipods, and

worms, as well as oysters and barnacles.

epifauna Animals that live on the surface of the bottom or on elevated or floating surfaces. See

epibenthic, above.

infauna Animals that live beneath the sediment surface. Clams and nematodes, for example.

intertidal Flooded at some parts of the tide cycle and exposed at others.

invertebrate An animal without a backbone - worms, oysters, clams, and insects, for example.

isostatic rebound - the gradually uplifting or rebounding of the earth’s crust in response to

release of downward surface pressure (as with the retreat of glaciers).

LC50 A statistically derived concentration of a chemical that results in mortality of 50% of the

organisms during a toxicity test. Terms such as 48- or 96-hour will usually precede LC50 to

indicate the length of continuous exposure. LC50 values provide a means to convey the relative

hazard of different chemicals.

macroalgae Larger kinds of algae.

macroinvertebrate Larger kinds of invertebrates - oysters, for example.

monospecific, monotypic These terms, as used in this document, refer to a stand of plants, all

the individuals of which are of the same species or type.

mudflat That portion of intertidal lands generally found below the native saltmarsh on which

eelgrass and algae are the dominant vegetation.

mutagenic Chemicals or other extracellular (outside) agents that are capable of causing

mutations.
110

NP - nonylphenol A phenol with a nine (nonyl) carbon chain attached to it. Nonylphenol results

from the complete biodegradation of nonylphenol polyethoxylates (NPEO), which are ingredients

of some surfactants. 

NPEO - nonylphenol polyethoxylate An ingredient of some surfactants. An alkylphenol

ethoxylate with a nine (nonyl) carbon chain and a chain of repeating ethylene oxide groups

attached to the phenol.

oncogen A substance which is capable of causing tumors.

ppb parts per billion

ppm parts per million

ppth parts per thousand

propagule A plant shoot which is capable of taking root and growing.

radionuclide A term used to designate the radioactive isotopes of a particular element.

rhizome A plant stem or branch which produces roots and shoots. A means by which plants

reproduce vegetatively (without seeds).

subtidal Not exposed by the falling tide; flooded even at low tide.

surfactant Surfactants are composed of organic (e.g., carbon chains) and inorganic components

(e.g., ethylene oxide chains) that form a bridge between the plant (organic) and the herbicide

(inorganic). Surfactants are used in conjunction with herbicides to increase plant absorption

through lowering surface tension of the spray solution, which spreads the herbicide more readily

than water over the plant surface.

tank mix A mixture of a herbicide and one or more adjuvants that is applied to a target species

such as Spartina by spray equipment.

technical glyphosate Commercially produced glyphosate.

teratogenic Tending to cause developmental malformations.

use days (birds) The number of birds using an area multiplied by the number of days they were

present.

wrack A mass of seaweed that is floating or washed up on shore.
111

 Bibliography

Aberle, B. 1990. The biology, control and eradication of introduced Spartina (cordgrass)

worldwide and recommendations for its control in Washington. Washington Department of

Natural Resources. Olympia. 87 pp.

Aberle, B.L. 1993. The biology and control of introduced Spartina (cordgrass) worldwide and

recommendations for its control in Washington. A thesis submitted in partial fulfillment of the

requirements for the degree of masters of environmental studies, The Evergreen State College.

176 pp.

Abramowitz, A.W. A cultural resource survey of Lewis, Porter Point and Riekkola Units, Willapa

National Wildlife Refuge, Pacific County, Washington. University Of Washington, Seattle. 19 pp

+ glos.

Allard, D.J. 1991. The occurrence of fish in cordgrass and mudflat habitats on Willapa National

Wildlife Refuge. U.S. Fish and Wildlife Service, Lower Columbia River Fishery Resource Office.

Vancouver, WA. unpubl. rprt 14 pp.

Anderson, R. 1997. Environmental Forest Research. Personal communication. 04/04/97.

Anthony, R.G. and M.L. Morrison. 1985. Influence of glyphosate herbicide on small-mammal

populations in western Oregon. Northwest Science 59:159-168.

Asher, R. 1990. Spartina introduction in New Zealand. In Spartina workshop record, Seattle,

Washington. November 14-15, 1990. Washington Sea Grant Program, University of Washington.

pages 23-24.

Atkinson, J.B. 1992. A preliminary investigation of benthic invertebrates associated with intertidal

mudflats and intertidal mudflats infested with Spartina at one location in Willapa Bay

Washington. U.S. Fish and Wildlife Service, Willapa National Wildlife Refuge. Ilwaco, WA.

unpubl. rpt. 2 pp.

Atkinson, J. 1992. Unpublished data on file at Willapa National Wildlife Refuge, Ilwaco, WA.

Baldwin, J.R. and J.R. Lovvorn. 1994. Expansion of seagrass habitat by the exotic Zostera

japonica, and its use by dabbling ducks and brant in Boundary Bay, British Columbia. Marine

Ecology Progress Series 103:119-127.

Bertness, M.D. and A.M. Ellison. 1987. Determinants of patterns in a New England salt marsh

plant community. Ecological Monographs 57(2):129-147.

Benson, W.H. and A.C. Nimrod. 1994. The estrogenic effects of alkylphenol ethoxylates.

A report submitted to the Chemical Manufacturers Association Alkylphenols and Ethoxylates
112

Panel. University of Mississippi, University, MS.

Bulthuis, D.A. and B.A. Scott. 1993. Effects of application of glyphosate on cordgrass, Spartina

alterniflora, and adjacent native salt marsh vegetation in Padilla Bay, Washington. Washington

Department of Ecology, Padilla Bay National Estuarine Research Reserve Technical Report No.

7.

Bulthuis, D.A. and M.J. Hartman. 1994. Effects of application of glyphosate during the summer

on epiphytes of the eelgrasses Zostera marina and Zostera japonica in Padilla Bay, Washington.

Washington Department of Ecology, Padilla Bay National Estuarine Research Reserve Technical

Report No. 9. 

Callaway, J.C. and M.N. Josselyn. 1992. The introduction and spread of smooth cordgrass

(Spartina alterniflora) in South San Francisco Bay. Estuaries. 15(2):218-226.

Chinook Tribal Council. 1996. August 10, 1996 Resolution of the Chinook Tribal Council.

Conway, R.A., G.T. Waggy, M.H. Spiegel, and R.L. Berglund. 1983. Environmental fate and

effects of ethylene oxide. Environmental Science and Technology 17:707-712.

Conway, R.S. 1991. The economic impact of the oyster industry. Dick Conway and

Associates. unpubl. rprt. 20 pp. + app.

Cook, A.K. and M.W. Jordan. 1994. Assessing county change: the implications of social and

demographic change on the Olympic Peninsula. Washington State University. Pullman, WA. 97

pp.

Crawley, M.J. 1987. What makes a community invasible? in A.J. Gray, M.J. Crawley and P.J.

Edwards, eds., Colonization, succession and stability, Blackwell Scientific Publications, Oxford.

pp 429-453. In Blossey, B. and R. Notzold. 1995. Evolution of increased competitive ability in 

invasive nonindigenous plants: a hypothesis. Journal of Ecology 83: 887-889.

D’Anieri, D.M. Leslie, Jr., and M.L. McCormack, Jr. 1987. Small mammals in glyphosatetreated clearcuts in northern Maine. Canadian Field-Naturalist 101:547-550.

Davis, P. and D. Moss. 1982. Spartina and waders - the Dyfi estuary in P. Doody, ed., Spartina

anglica in Great Britain. pp37-40. Focus on Nature Conservation no.5. Nature Conservancy

Council, Cambridgeshire, England.

Day, J.W., C.A.S. Hall, W.M. Kemp and A.Yán ̃ez-Aranciba. 1989. Estuarine Ecology. John

Wiley and Sons. New York. 557pp.

Daehler, C.C. and D.R. Strong. 1994. Variable reproductive output among clones of Spartina

alterniflora (Poacea) invading San Francisco Bay, California: the influence of herbivory,

pollination, and establishment Site. American Journal of Botany 81(3):307-313.
113

Dumbald, B.R. 1997. Personal communication. 01/09/97. Washington Department of Fish and

Wildlife. Nahchotta, WA.

Ebasco. 1993a. Final Report, Element C: No Action: Efficacy and Impacts. Prepared for

Washington State Department of Ecology. Ebasco Environmental, a division of Ebasco Services

Incorporated. 50 pp.

Ebasco. 1993b. Final Report, Element I: Integrated Weed Management Alternative for Managing

Noxious Emergent Plants. Prepared for Washington State Department of Ecology. Ebasco

Environmental, a division of Ebasco Services Incorporated. 40 pp.

Erwin, R.M. 1996. Dependence of waterbirds and shorebirds on shallow-water habitats in the

Mid-Atlantic Coastal Region: An ecological profile and management recommendations. Estuaries

19(2A): 213-219.

Evans, P.R. 1986. Use of the herbicide dalapon for control of Spartina encroaching on intertidal

mudflats: beneficial effects on shorebirds. Colonial Waterbirds 9:171-175.

Feng, J.C. and S. Navratil. 1990. Sampling for zero-time hexazinone in forest soil dissipation

study. Canadian Journal of Forest Research 20:1549-1552.

Feng, J. and D. Thompson. 1990. Fate of glyphosate in a Canadian forest watershed. 2. 

Persistence in foliage and soils. J. Agric. Food Chem. 38:118-1125.

Fraser-Quick, G.G. and A. Phillips, eds. 1992. The sea has weeds too: proceedings of a

conference on the problem of Spartina. Australian Department of Conservation and Environment.

Melbourne. unpubl. rprt. 33 pp.

Frenkle, R.E. and L.M. Kunze. 1984. Introduction and spread of three Spartina species in the

Pacific Northwest. Association of American Geographers. 4:22-25.

Fresh, K.L., M.I. Carr, F.L. Paveglio, K.M. Kilbride, and C.A. Simenstad. 1996. Effects of

Rodeo® and surfactant used to control smooth cordgrass (Spartina alterniflora) on Japanese

eelgrass (Zostera japonica) in Willapa Bay, Washington. Washington Dept. of Fish and Wildlife.

unpubl. rprt.

Gottrup, O., P.A. O'Sullivan, R.J. Schraa, and W.H. Vanden. 1976. Uptake, translocation,

metabolism and selectivity of glyphosate in Canada thistle and leafy spurge. Weed Research 

16:197-201.

Goss-Custard, J.D. and M.E. Moser. 1988. Rates of change in the numbers of dunlin, Calidris

alpina, wintering in British estuaries in relation to the spread of Spartina anglica. Journal of

Applied Ecology. 25:95-109.

Harrington, J.A., Jr, and L.M.B. Harrington. 1993. Modeling the expansion of Spartina in the

 Palix Estuary. Papers and Proceedings of Applied Geography Conferences. 16:50-56.
114

Hedgpeth, J.W. and S. Obrebski. 1981. Willapa Bay: A historical perspective and a rationale for

research. U.S. Fish and Wildlife Service. FWS/OBS-81-03. 52. pp. 

Heydens, W.F. 1991. Rodeo® herbicide use to control Spartina: impact of glyphosate on marine

and terrestrial organisms. Monsanto Agricultural Company, St. Louis, MO.

Hidy, J.A. 1995. Personal communications. U.S. Fish and Wildlife Service. Ilwaco, WA.

Hoagland, R.E. 1980. Effects of glyphosate and glyphosate metabolites on growth and

 metabolism of soybean seedlings. Proceedings of the Weed Science Society of America.

Hoines, L. 1996. Fisheries statistical report. Washington Department of Fish and Wildlife

Fisheries Management Program. Olympia. unpubl. doc. 60+ pp.

Huddleston, R.I., and R.C. Allred. 1965. Determination of nonionic surfactant biodegradability: 

physical properties vs. Colorimetry. J. Am. Oil Chem. Soc. 42:983-986.

Jobling, S. And J.P. Sumpter. 1993. Detergent components in sewage effluent are weakly

estrogenic to fish: an in vitro study using rainbow trout (Oncorhynchus mykiss) hepatocytes.

Aquatic Toxicology 27:361-372.

Jobling, S., D. Sheahan, J.A. Osborne, P. Mathiessen, and J.P. Sumpter. 1996. Inhibition of

testicular growth in rainbow trout (Oncorhynchus mykiss) exposed to estrogenic alkylphenolic

chemicals. Environmental Toxicology and Chemistry 15:194-202.

Kilbride, K.M., F.L. Paveglio and C.E. Grue. 1995. Control of smooth cordgrass with Rodeo® in

a southwestern Washington estuary. Wildlife Society Bulletin. 23(3):520-524.

Kroll, R.B. 1991. Field investigations of the environmental fate of Rodeo (glyphosate) in two

tidal marshes. Technical Report 115. Maryland Department of the Environment, Baltimore, MD.

Kubena, K.M., C.E. Grue, and T.H. DeWitt. 1996. Development of concentration response

curves for oyster pediveliger larvae (Crassostrea gigas) exposed to formulations of Rodeo®, a

herbicide used to control smooth cordgrass. Paper presented at the Society of Environmental

Toxicology and Chemistry. 17th annual meeting. Washington, D.C., Nov. 17-21, 1996.

Kunze, L.M. and L.C. Cornelius. 1982. Baseline inventory of rare, threatened, and endangered

plant species/communities along Washington’s Pacific coast. Washington Natural Heritage

Program for Washington Dept. Of Ecology and the National Oceanic and Atmospheric

Administration. Coastal Zone Management G82-029.

Landin, M.C. 1990. Growth habits and other considerations of smooth cordgrass, Spartina

alterniflora Loisel. In Spartina workshop record, Seattle, Washington. November 14-15, 1990. 

Washington Sea Grant Program, University of Washington. pages 15-20.
115

Lashen, E.S., F.A. Blankenship, K.A. Booman, and J. Dupré. 1966. Biodegradation studies on a

p, tert.-ocylphenoxypolyethoxyethanol. J. Am. Oil Chem. 43:371-376.

Lebovitz, W. 1997. Personal communications. Pacific County Noxious Weed Control Board.,

South Bend, WA.

Lehninger, A.L. 1975. Biochemistry. Second edition. Worth Publishers, Inc., New York, NY.

Major, W., 1996. Personal communication. University of Washington. Seattle

Major, W., and C.E. Grue. 1996. Control of Spartina alterniflora in Willapa Bay, Washington:

Efficacy of mechanical and chemical control techniques, and their off target impacts on eelgrass

(Z. japonica). Report submitted to Washington Department of Natural Resources by the

Washington Cooperative Fish and Wildlife Research Unit, University of Washington. 

Major, W. and C.E. Grue. 1997. Control of Spartina alterniflora in Willapa Bay, Washington:

efficacy of mechanical and chemical control techniques, and their off target impacts on eelgrass

(Z. japonica). A draft report submitted to the Washington Department of Natural Resources by

the Washington Cooperative Fish and Wildlife Research Unit, University of Washington.

Marks, E. 1995. Spartina: battling a critical weed problem. Washington Wildlands. The Nature

Conservancy of Washington. 1(1):16.

Mayer, F.L., and M.R. Ellersieck. 1986. Manual of acute toxicity: interpretation and data base

for 410 chemicals and 66 species of freshwater animals. Fish Wildl. Serv. Resour. Publ. 160.

McLeese, D.M., V. Zitko, D.B. Sergeant, L. Burridge and C.D. Metcalfe. 1981. Lethality

and accumulation of alkylphenols in aquatic fauna. Chemosphere 10:723-730.

Miller, A.V. and P.R. Evans. 1982. Colonization of mudflats by Spartina anglica; some effects

on invertebrate and shorebird populations at Landisfarne in P. Doody, ed., Spartina anglica in

Great Britain. pp 41-48. Focus on Nature Conservation no.5. Nature Conservancy Council,

Cambridgeshire, G.B.

Milne, D. 1995. personal communication. Evergreen State College.

Mitchell, D.G., P.M. Chapman, and T.J. Long. 1987a. Acute toxicity of Roundup and Rodeo®

herbicides to rainbow trout, chinook, and coho salmon. Bulletin of Environmental Contamination

and Toxicology 39:1028-1035.

Mitchell, D.G., P.M. Chapman, and T.J. Long. 1987b. Seawater challenge testing of coho

 salmon smolts following exposure to Roundup herbicide. Environmental Toxicology and

Chemistry 6:875-878.

Monsanto. 1990. Label for Rodeo® aquatic herbicide. Monsanto Agricultural Company, St.
116

 Louis, MO.

Moore, Cindy. 1997. Personal communication. 02/12/97. Washington Department of

Agriculture. Olympia, WA.

Morrison, M.L. and E.C. Meslow. 1984. Effects of the herbicide glyphosate on bird community

structure, western Oregon. Forest Science 30:95-106.

Mueller, G.C. and U. Kim. 1978. Displacement of estradiol from estrogen receptors by simple

alkyl phenols. Endocrinology 102:1429-1435.

Mumford, T.S., P. Peyton, J.R. Sayce, and S. Harbell. 1990. Spartina workshop record, Seattle,

Washington, November 14-15, 1990. Washington Sea Grant Program, University of Washington.

Seattle. 73.pp.

Murphy, D.D. 1988. Challenges to biological diversity in urban areas in E.O. Wilson, ed.,

Biodiversity. National Academy Press. Washington. 521 pp.

National Oceanic and Atmospheric Agency. 1977. Tide table high and low water predictions,

West Coast of North America including the Hawaiian Islands. U.S. Department of Commerce.

Washington.

Naylor, C.G. 1992. Environmental fate of alkylphenol ethoxylates. Soap Cosmet. Chem. Spec. 

68:27-31.

Newton, J. 1997. Personal communication. 03/05/97. Washington Department of Ecology.

Olympia, WA.

Newton, M., K.M. Howard, B.R. Kelpsas, R. Danhaus, C.M. Lottman and S. Dubelman. 1984.

Fate of glyphosate in an Oregon forest. Journal of Agricultural Food Chemistry 32:1144-1151.

Nichols, F.H., and M.M. Pamatmat. 1988. The ecology of the soft-bottom benthos of San

Francisco Bay: a community profile. U.S. Fish Wildl. Serv. Biol. Rep. 85(7.19). 73pp.

Norman, M. and K. Patton. 1995. The effects of Spartina and Rodeo/LI 700 treatments of

invertebrate populations in sediments of Willapa Bay. A final report submitted to the U.S.

Environmental Protection Agency. 7pp.

Pacific County. No date. Untitled information pamphlet. Pacific County. South Bend, WA. 8 pp.

Page, G.W. 1992. Shorebird numbers in wetlands of the Pacific Flyway: A summary of counts

from April 1988 to January 1992. Point Reyes Bird Observatory. Stinson Beach, CA. 20pp +

append.

Patterson, B.R. 1994. Pesticide use of the cranberry in Washington: an evaluation of the

environmental risks and regulations. Essay of distinction for Master of Environmental Studies.
117

The Evergreen State College.

Paveglio, F.L., K.M. Kilbride, C.E. Grue, C.A. Simenstad, and K.L. Fresh. 1996. Use of Rodeo®

and X-77® Spreader to control smooth cordgrass (Spartina alterniflora) in a southwestern

Washington estuary. II. Environmental fate. Environmental Toxicology and Chemistry 15: In

press.

Peterson, C., ed. 1996. Ecotourism in Northwest Oregon. Columbia River Estuary Study

Taskforce. Astoria, OR. 152 pp. + appen.

Phillips, R.C. 1984. The ecology of eelgrass meadows in the Pacific Northwest: A community

profile. U.S. Fish and Wildlife Service. FWS/OBS-84/24. 85pp.

Pritchard, D.W. 1967. What is an estuary: physical viewpoint. Pages 3-5 in G.F. Lauff, ed.,

Estuaries. American Association for the Advancement of Science, publ. 83. Washington, D.C.

Proctor, C.M., et al. 1980. An ecological characterization of the Pacific Northwest coastal

region, vol 2. U.S. Fish and Wildlife Service, Biological Services Program. FWS/OBS-79/11

through 79/15. 377pp + appendices.

Ramsay, C.A., G.L. Thomasson. 1990. Washington pesticide laws and safety: a guide to safe 

use and handling for applicators and dealers. Washington State University, Cooperative

Extension. MISC 0056. 88pp.

Ratchford, S.G. 1995. Changes in the density and size of newly settled clams in Willapa Bay, WA,

due to the invasion of smooth cordgrass Spartina alterniflora Loisel. A thesis submitted for the

degree of Master of Science, University of Washington. 48pp.

Reiff, B., R. LLoyd, M.J. How, D. Brown and J.S. Alabaster. 1979. The acute toxicity of

eleven detergents to fish: results of an interlaboratory exercise. Water Research 13:207-210.

Santillo, D.J., P.W. Brown, and D.M. Leslie, Jr. 1989. Response of songbirds to glyphosateinduced habitat changes on clearcuts. Journal of Wildlife Management 53:64-71.

Sawada, Y., Y. Nagal, M. Ueyama, and I. Yamamoto. 1988. Probable toxicity of surface-active

agent in commercial herbicide containing glyphosate. Lancet 1(8580):299.

Sayce, K. 1988. Introduced cordgrass, Spartina alterniflora Loisel., in saltmarshes and tidelands

of Willapa Bay, Washington. USFWS-87058 (TS). Willapa National Wildlife Refuge, Ilwaco,

WA. 70pp.

Sayce, K. 1993. Saltmarsh vegetation field trip to Lewis Unit, Willapa National Wildlife Refuge.

Botanist. Nahchotta, WA.
118

Sayce, K. 1994. personal communication. Botanist. Nahcotta, WA.

Sayce, K. 1997. personal communication. Botanist. Nahcotta, WA.

Scheffer, T.H. 1945 The introduction of Spartina alterniflora to Washington with oyster culture.

Leaflets of Western Botany (4) 63-164.

Schüürman, G. 1991. Acute aquatic toxicity of alkylphenol ethoxylates. Ecotoxicology and

 Environmental Safety 21:227-233.

Shaner, D.L. and J.L. Lyon. 1980. Early effects of glyphosate on free amino acid levels in bean

leaves. Abstracts of the Weed Science Society of America.

Shaw, W.B. 1997. personal communication, March 21, 1997. Wildland Consultants Ltd.,

Whakatane, New Zealand.

Sheahan, D. and J. Harries. 1992. Effects of trace organics in fish. A joint study between The

Directorate of Fisheries Research of the Ministry of Agriculture, Fisheries and Food, Brunel

University, and The Water Research Centre.

Sheldon, D. 1996. personal communication. Oyster grower. Ocean Park, WA.

Sheldon, D. 1997. Comments made at Second International Spartina Conference, March 20-21,

1997. Tumwater, WA.

Shotwell, J.A. 1977. The Willapa estuary: background studies for the preparation of a

management plan. Pacific County. unpubl. rprt. 89pp.

Simenstad, C.A. 1983. The ecology of estuarine channels of the Pacific Northwest coast: a

community profile. U.S. Fish and Wildlife Service. FWS/OBS-83/05. 181 pp.

Simenstad, C.A., J.R. Cordell, L. Tear, L.A. Weitkamp, F.L. Paveglio, K.M. Kilbride, K.L. Fresh,

and C.E. Grue. 1996. Use of Rodeo® and X-77® Spreader to control smooth cordgrass

(Spartina alterniflora) in a southwestern Washington estuary. II. Effects on benthic microflora

and invertebrates. Environmental Toxicology and Chemistry 15: In press.

Simenstad, C.A. and R.M. Thom. 1995. Spartina alterniflora (smooth cordgrass) as an invasive

 halophyte in Pacific Northwest estuaries. Hortus Northwest.

Solberg, K.L. and K.F. Higgins. 1993. Effects of glyphosate herbicide on cattails, invertebrates,

and waterfowl in South Dakota wetlands. Wildlife Society Bulletin 21:229-307.

Soto, A.M., H. Justicia, J.W. Wray, and C. Sonnenschein. 1991. P-Nonyl-phenol: an estrogenic

xenobiotic released from “modified” polystyrene. Environmental Health Perspectives 92:167-193.
119

Sprankle, P., W.F. Meggitt, and D. Penner. 1975. Rapid inactivation of glyphosate in the soil. 

Weed Science 23:224-228.

Stiller, J.W. and A.L. Denton. 1995. One hundred years of Spartina alterniflora (Poacea) in

Willapa Bay, Washington: random amplified polymorphic DNA analysis of an invasive population.

Sullivan, T.P. and D.S. Sullivan. 1979. The effects of glyphosate herbicide on food preference

and consumption in black-tailed deer. Canadian Journal of Zoology 57:1406-1412.

Sundaram, K.M.S., S. Szeto, R. Hindle, and D. MacTavish. 1980. Residues of nonylphenol in

spruce foliage, forest soil, stream water and sediment after its aerial application. Journal of

Environmental Science and Health 15B:403-419.

Swan, J.G. 1982. The Northwest Coast: or three years residence in Washington Territory.

University of Washington Press. Seattle. 435 pp.

Swedmark, M. 1968. Resistens hos fisk mot glykol, tensider och en vanlig thesidravara. Vatten

5:430-443.

Swedmark, M., A. Granmo and S. Kollberg. 1971. Biological effects of surface active agents on

marine animals. Marine Biology 9:183-201.

Swisher, R.D. 1987. Surfactant biodegradation, 2nd edition. Marcel Dekker, Inc., New York,

NY.

Talmage, S.S. 1993. Environmental and human safety of major surfactants: alcohol ethoxylates

and alkylphenol ethoxylates. Lewis Publishers, Boca Raton, FL.

Tufts, D.F. 1989. The use of the insecticide carbaryl to control burrowing shrimp in Willapa Bay

and Grays Harbor in 1986. Washington Dept. Fish. Special Shellfish Rep. No. 4.

Tufts, D.F. 1990. The use of the insecticide carbaryl to control burrowing shrimp in Willapa Bay

and Grays Harbor in 1987. Washington Dept, Fish. Special Shellfish Rep. No. 5.

U.S. Environmental Protection Agency. 1997. The Shoalwater Bay Reservation, A limited

environmental assessment: 1994-1995. EPA 910/R-96-013. 89pp.

U.S. Fish and Wildlife Service. 1942. Willapa National Wildlife Refuge annual narrative report,

September-December, 1942. U.S. Department of Interior, Fish and Wildlife Service, Willapa

National Wildlife Refuge. Ilwaco, WA. unpubl. rpt. 12+ pp.

U.S. Fish and Wildlife Service. 1982. Chapter 7 U.S. Fish and Wildlife Service Refuge

Manual part 14.4C. Willapa National Wildlife Refuge. Ilwaco, WA.

U.S. Fish and Wildlife Service. 1985. Annual narrative report 1985. Willapa National Wildlife
120

Refuge. U.S. Fish and Wildlife Service, Willapa National Wildlife Refuge. Ilwaco, WA. unpubl.

rpt. pp. 25-27.

U.S. Fish and Wildlife Service. 1988. Species profiles: life histories and environmental

requirements of coastal fishes and invertebrates (Pacific Northwest) - Pacific oyster. U.S. Fish and

Wildlife Biological Report, 82(11.85). U.S. Army Corps of Engineers, TR EL-82-4. 27pp.

U.S. Fish and Wildlife Service. 1989. Species profiles: life histories and environmental

requirements of coastal fishes and invertebrates (Pacific Northwest) - Olympia oyster. U.S. Fish

and Wildlife Biological Report, 82(11.124). U.S. Army Corps of Engineers, TR EL-82-4. 8pp.

U.S. Fish and Wildlife Service. 1990. Annual narrative report 1990, Willapa National

Wildlife Refuge. U.S. Fish and Wildlife Service, Willapa National Wildlife Refuge. Ilwaco, WA. 

unpubl. rpt. 52 pp.

U.S. Fish and Wildlife Service. 1991a. Annual narrative report 1991, Willapa National

Wildlife Refuge. U.S. Fish and Wildlife Service, Willapa National Wildlife Refuge. Ilwaco, WA.

unpubl. rpt. p.10.

U.S. Fish and Wildlife Service. 1991b. Wildlife: Willapa National Wildlife Refuge and Columbia

River Estuary. Brochure. U.S. Fish and Wildlife Service, Willapa National Wildlife Refuge.

Ilwaco, WA. 12 pp.

U.S. Fish and Wildlife Service. 1992. Annual narrative report 1992; Willapa National Wildlife

Refuge. U.S. Fish and Wildlife Service, Willapa National Wildlife Refuge. Ilwaco, WA. unpubl.

rpt. 55 pp.

U.S. Fish and Wildlife Service. 1994. Resource management information system (RMIS), public

use module, yearly report (fiscal year 1994). U.S. Fish and Wildlife Service, Willapa National

Wildlife Refuge. Ilwaco, WA. unpubl. rpt. 3 pp

U.S. Fish and Wildlife Service. 1995. Endangered Species information handbook. U.S. Fish

and Wildlife Service. Washington.

U.S. Fish and Wildlife Service. 1996a. Endangered and Threatened Wildlife and Plants, 50 CFR

17.11 & 17.12, October 31, 1996. Compiled and reprinted by U.S. Fish and Wildlife Service,

Washington, D.C. 46 pp.

U.S. Fish and Wildlife Service. 1996b. Endangered, Threatened, Proposed and Candidate Species,

Critical Habitat and Species of Concern in the Western Portion of the State, North Pacific Coast

Ecoregion. U.S. Fish and Wildlife Service, Western Washington Office, Olympia. unpubl. doc.,

rev. 09/13/96. 3 pp.

Washington Department of Agriculture. 1992. Spartina: threat to Washington’s saltwater

habitat. Washington Department of Agriculture. Olympia. 8 pp.
121

Washington State Departments of Agriculture, Ecology, Natural Resources, Fisheries, Wildlife 

and the State Noxious Weed Control Board. 1993. Noxious emergent plant management: final

environmental impact statement. State of Washington. Olympia. 204 pp + app.

Washington State Department of Ecology. 1995. Currents. The Lower Columbia River Bi-state

Water Quality Program. January issue. 2pp.

Washington Department of Ecology. 1996. Confluence. Washington Department of Ecology. 

Olympia. 1(2). 16 pp.

Washington Department of Wildlife. 1993. Status of the Oregon silverspot butterfly (Speyeria

 zene hippolyta) in Washington. unpubl. rprt. Washington Department of Wildlife. Olympia. 31pp.

Washington Department of Fish and Wildlife. 1994. State listed and candidate species as of

November 18, 1994. Washington Department of Fish and Wildlife, Wildlife Management

Program. Olympia. unpubl. doc. 1 pp.

Washington Department of Fish and Wildlife. 1995. Management recommendations for

Washington’s Priority Species, vol. 1: invertebrates. Larson, E.M., E. Rodrick, and R. Milner,

eds. Olympia, WA. 82 pp.

Washington State. No Date. Standard County/City Profile - Pacific County. State of Washington.

Olympia. 8 pp.

Williamson, D.A. 1997. personal observations. U.S. Fish and Wildlife Service. Ilwaco, WA.

Wilson, T. and W.S. Lebovitz. 1996. management program: integrated weed

management for private and public lands in Willapa Bay, Pacific County, Washington. Pacific

County Noxious Weed Control Board. Section 3-1 and 3-2.

Wolfe, R.J. 1996. Effects of open marsh water management on selected tidal marsh resources: a

review. Journal of the American Mosquito Control Association, 12(4): 701-702, 1996.

Wyllie-Echeverria, S., A.M. Olson and M.J. Hershman (eds). 1994. Seagrass science and policy in

the Pacific Northwest: Proceedings of a seminar series. (SMA 94-1). EPA 910/R-94-004. 63 pp.

Young, B. 1997. personal communication. 04/22/97. Oregon Department of Environmental

Quality.

Zahn, M. 1997. personal communication. 03/06/97. Washington Department of Fish and Wildlife.

Montesano, WA.

Zipperer, V. 1996a. personal communication. University of Washington. Seattle.
122

Zipperer, V. 1996b. Ecological effects of the introduced cordgrass, Spartina alterniflora, on the

benthic community structure of Willapa Bay, Washington. MS thesis. University of Washington, 

Seattle. 120 pp.
123

Appendix

GENERAL INFORMATION ON RODEO® HERBICIDE

and

ADJUVANTS

General Information on Rodeo® Herbicide

Rodeo® (Monsanto Agricultural Company, St. Louis, MO), a nonselective herbicide for postemergent control of undesirable vegetation in and adjacent to freshwater and estuarine sites

(Monsanto 1990), is the only herbicide labeled for use on Spartina in Washington State. Rodeo®

is composed of 53.8% glyphosate (N-[phosphonomethyl]glycine in the form of isopropylamine

salt) and 46.2% inert ingredients (water). Rodeo® is a foliar-applied herbicide that is rapidly

absorbed and basipetally translocated to roots, rhizomes, or meristemically-active tissue. Plant

mortality primarily results from disruption of aromatic amino acid (phenylalanine, tyrosine, and

tryptophan) synthesis from the shikimic acid pathway and subsequent destruction of

photosynthetic pigments in foliage (Hoagland 1980, Shaner and Lyon 1980).

According to EPA, glyphosate is stable to hydrolysis and strongly absorbed to the soil. It has low

potential to contaminate ground water. Biodegradation is considered the major fate process

affecting glyphosate persistence in aquatic environments. It is biodegraded aerobically and anaerobically by micro-organisms present in soil, water, hydrosoil and activated sludge.

EPA classifies glyphosate as Category III, low acute toxicity, (out of IV, with I as the most toxic)

for oral, dermal, and primary eye irritation. It is in Category IV for primary skin irritation. It is

not teratogenic to rats or rabbits and is not mutagenic. EPA classifies glyphosate as a Group E

oncogen - one that shows evidence of non-carcinogenicity for humans.

EPA states that, under label requirements, glyphosate is no more than slightly toxic to birds,

aquatic invertebrates, freshwater fish and marine/estuarine organisms and will not cause avian

reproduction impairment. Glyphosate has very low lipid solubility and thus has very low potential

for bioaccumulation.

While all agricultural chemical compounds are being re-evaluated under the Food Quality and

Protection Act, an inquiry to EPA revealed no indication that glyphosate is on any specific list for

reclassification (Eagle 1997).

General Information on Adjuvants

An adjuvant is a substance added to a pesticide to improve its effectiveness or safety. A

surfactant is a component of many adjuvants that improves the spreading, dispersing, and/or

wetting properties of a pesticide mixture. While adjuvants are classified as pesticides in

Washington State and are defined as such under Washington State pesticide laws, they are not

classified as pesticides by the Environmental Protection Agency (Ramsay and Thomasson 1990). 

To increase herbicide efficacy, a nonionic surfactant is used in conjunction with Rodeo® to
124

increase the absorption of glyphosate across the plasma membrane of the plant (Gottrup et al.

1976). In Washington state, the following 3 nonionic surfactants are permitted for use with

Rodeo® to control Spartina: X-77® Spreader, R-11® Spreader Activator, and LI-700®. X-77®

Spreader and LI-700® are products of Loveland Industries, Inc. (Loveland, CO). R-11® Spreader

Activator is manufactured by Wilber Ellis (Fresno, CA).

X-77® Spreader and R-11® Spreader Activator are alkylphenol polyethoxylate surfactants. 

Alkylphenol polyethoxylates are the principal active ingredients that may have lethal (Reiff 1979,

McLeese et al. 1981, Schüürman 1991 and sublethal (estrogenic; Benson and Nimrod 1994)

effects upon aquatic organisms within these nonionic surfactants. Specifically, the alkylphenol

polyethoxylates in X-77® Spreader and R-11® Spreader Activator are nonylphenoxypolythylene

(nonylphenol polyethoxylates [NPEO]) and octylphenoxypolyethoxyethanol, respectively. In

addition, X-77® Spreader contains isopropanol, glycols, and free fatty acids; whereas, R-11®

Spreader Activator contains isopropanol and compounded silicone. Both surfactants also contain

inert ingredients (10%).

The principal active ingredients with LI-700® are phosphatidylcholine and methylacetic acid. 

Phosphatidylcholine, commonly known as lecithin, is a naturally occurring complex lipid that is a

constituent of most plant and animal cells (Lehninger 1975). Although it is not classified as

corrosive, the methylacetic acid in LI-700® is often used as an acidifying agent.

Appendix Bibliography

Benson, W.H. and A.C. Nimrod. 1994. The estrogenic effects of alkylphenol ethoxylates. A

report submitted to the Chemical Manufacturers Association Alkylphenols and Ethoxylates Panel.

University of Mississippi, University, MS.

Eagle, V. 1997. Personal communication. U.S. Environmental Protection Agency, Office of

Pesticides and Toxic Substances, Reregistration Branch, Arlington, VA,

Gottrup, O., P.A. O'Sullivan, R.J. Schraa, and W.H. Vanden. 1976. Uptake, translocation,

metabolism and selectivity of glyphosate in Canada thistle and leafy spurge. Weed Research 

16:197-201.

Hoagland, R.E. 1980. Effects of glyphosate and glyphosate metabolites on growth and

metabolism of soybean seedlings. Proceedings of the Weed Science Society of America.

Lehninger, A.L. 1975. Biochemistry. Second edition. Worth Publishers, Inc., New York, NY.

McLeese, D.M., V. Zitko, D.B. Sergeant, L. Burridge and C.D. Metcalfe. 1981. Lethality and

accumulation of alkylphenols in aquatic fauna. Chemosphere 10:723-730.

Monsanto. 1990. Label for Rodeo® aquatic herbicide. Monsanto Agricultural Company, St.

Louis, MO.
125

Reiff, B., R. Lloyd, M.J. How, D. Brown and J.S. Alabaster. 1979. The acute toxicity of eleven

detergents to fish: results of an interlaboratory exercise. Water Research 13:207-210.

Schüürman, G. 1991. Acute aquatic toxicity of alkylphenol ethoxylates. Ecotoxicology and

Environmental Safety 21:227-233.

Shaner, D.L. and J.L. Lyon. 1980. Early effects of glyphosate on free amino acid levels in bean

leaves. Abstracts of the Weed Science Society of America.