Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-1

APPENDIX A Public Involvement 

Public involvement is an integral and important part of conducting environmental analyses 

and subsequent documentation in this environmental impact statement. This Appendix serves 

to document the public involvement effort to date, and show how information acquired 

through outreach has been utilized in the preparation of this Final Environmental Impact 

Statement (EIS). 

Invitation to Participate 

Public involvement for this project was officially initiated with publication of a Notice of 

Intent to Prepare an Environmental Impact Statement (Figure A-1) in the August 28, 2002, 

edition of the Federal Register. 

In late August 2002, the Invasive Plant EIS website (www.fs.fed.us/r6/invasiveplant-eis) was 

brought on-line. This website is a repository of information about invasive plants, their 

presence in the Pacific Northwest, integrated weed management and the EIS project schedule. 

In mid-September we issued a news release (Figure A-2) to approximately 100 television, 

radio stations, and newspapers throughout Oregon and Washington State. Several telephone 

interviews were conducted, resulting in several radio and newspaper articles. 

The Pacific Northwest Region as a whole did not have a mailing list of people and 

organizations interested in the invasive plant management program when the Invasive Plant 

EIS team was assembled in early 2002. We created our list by merging small lists from 

Forests and other administrative offices in the Region. The resultant list identified about 

3,000 potentially interested people, organizations, businesses, tribes, and local, state and 

federal government agencies. 

A letter to inform and identify interested public (Figure A-3) was sent out in late September 

2002. In that letter we identified the problem, briefly explained our project and asked people 

for their thoughts on invasive plant management issues. In that same letter we invited people 

to attend public forums scheduled for Wenatchee, WA, Baker City, OR, and Roseburg, OR. 

A separate letter was sent to tribal leaders in the Pacific Northwest. 

A second mailing was sent out in May 2003. This mailing (Figure A-4) was sent to the entire 

mailing list to confirm interest in the project and determine the extent of our printing needs. 

Public Meetings and Outreach Activities 

Other meetings took place in addition to the three public forums scheduled. The Team Leader, 

and a mix of team members participated in about 40 meetings with special interest groups, 

organizations, and representatives of local, state and federal agencies. A list of the meetings 

and dates are enclosed (Figure A-5). Many Pacific Northwest Region National Forests 

referred to this project in their quarterly newsletters. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-2

Public Comment 

The comment period for the public scoping letter was open for sixty days from September 18 

through November 19, 2002. We continued to accept and process issues in letters received 

between November 20 and the completion of public comment analysis on December 12. 

During this time we processed 263 letters of comments. While most respondents replied by 

mail, about 50 people responded by email. Sixteen letters were received between December 

13 and February 27, 2003. These letters were reviewed and copies were circulated among 

team members. Issues identified by the authors of these sixteen letters were not included in 

the formal analysis, though their issues were likely covered by other respondents, as there was 

a lot of overlap among comments. 

Comments collected at the public forums in November were included in the comment analysis 

process. 

Comment Analysis 

The team decided to use an abbreviated method of content analysis to evaluate the comments. 

Comments provided by respondents were categorized into 11 topic categories, derived from 

the letters themselves (Table A-1). 

Issue Identification 

On December 16, 2002, the EIS Team met to discuss, evaluate, consolidate, and clarify 

issues. During this meeting the team considered the issues brought up by the public, 

organizations, other agencies and those of team members. Following two days of long 

discussion, and a few weeks of reflection and re-evaluation, the team completed the process 

of issue identification. The following list represents the final evaluation of relevant issues. 

• Native Plant Communities 

• Effectiveness of Treatment 

• Invasive Plants and Land Management 

• Human Health 

• Wildlife 

• Threatened and Endangered Species 

• Aquatic Ecosystems 

• Soils 

• Tribes and treaty Rights 

• Social Concerns 

• Economics 

• Congressional Designations 

• Recreation 

Additional information on the relevant issues and those issues considered to be irrelevant is 

located in Chapter 2. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-3

Figure A-1 Notice of Intent 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-4
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-5

Figure A-2 News Release 

News Release 

USDA Forest Service 

Pacific Northwest Region 

Contacts: Rex Holloway, 503-808-2241

Gene Skrine, 503-326-4310

USDA Forest Service takes on invasive weed challenge 

PORTLAND, September 17, 2002 - The Pacific Northwest has a serious invasive plant 

problem. The USDA Forest Service is looking at integrated ways to prevent future infestations, 

manage existing problems, and restore affected sites, says acting Regional Forester Linda 

Goodman. 

Goodman notes approximately 400,000 acres of national forests and national grasslands 

in the Pacific Northwest are affected by infestations of invasive, non-native plants. 

Most invasive plant species are introduced to North America from Europe or Asia. They 

may come accidentally, or they may have been brought in on purpose. Examples of accidental 

introduction include the transport of seeds or plants in the ballast of ships, in the fleece and hair 

of livestock, in clothing, and as contaminants in seed lots. Intentional introductions are made for 

reasons including medicine, dyes, forage, erosion control and ornamental plants, to name a few. 

“For the purpose of this project, invasive plants (aka noxious weeds or exotics) are those 

plants that harm natural resources or the people who enjoy them,” Goodman adds. “To date 

approximately 95 invasive plant species have been reported on national forest lands in Oregon 

and Washington.” 

To address it, the Forest Service in the Pacific Northwest has chartered a team to prepare 

an environmental impact statement that looks at integrated ways to deal with the invasive plant 

species problem. 

“This environmental impact statement project will give us a clearer and more 

comprehensive set of standards and guidelines for our Forest Plans, and allow us to be more 

effective in preventing and more timely in controlling invasive species,” says team leader Gene 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-6

Skrine. “Prevention, early detection, early treatment and restoration are our best and most costeffective tools for combating invasive plants.” 

Team members will consider a variety of prevention and treatment strategies. Among the 

possibilities are biological controls (insects that feed on undesirable plants), herbicides, cultural 

measures such as hand pulling plants, and prevention practices (for example, cleaning equipment 

or assuring that only weed-free hay goes into uninfested areas). 

When done, the resulting environmental impact statement will be the basis for changes to 

the Forest Plans for national forests in the Pacific Northwest. Public forums will be part of that 

process, says Skrine. The Forest Service will host three invasive plant forums in Oregon and 

Washington communities this fall. 

“Our team expects to be done by the end of 2003,” says Skrine. “Time is of the essence,” 

he notes. “These infestations have a high potential to expand and further degrade national forests 

and grassland through loss of wildlife habitat, loss of rare or endangered plants, decreased 

biodiversity, degradation of water quality, and loss of recreation opportunities.” 

Sidebar 1 

Where to find out more... 

Additional information about the environmental impact statement and the invasive plant problem 

can be found at http://www.fs.fed.us/r6/invasiveplant-eis by contacting Gene Skrine at 503-326-

4310, or by writing the team at: 

Invasive Plant Project, USDA Forest Service, PO Box 3623, Portland, OR 97208 

The dates and locations for invasive plants forums are as follows: 

Location Host Forest Date 

Wenatchee, Washington 

Wenatchee Conference Center, 

North Ballroom 

Okanogan/Wenatchee National Forest November 13, 2002 

6:30 pm – 9:30 pm 

Baker City, Oregon 

Best Western Sunridge Inn 

Wallowa-Whitman National Forest November 16, 2002 

10:00 am – 4:00 pm

Roseburg, Oregon 

Roseburg Public Library 

Umpqua National Forest November 20, 2002 

6:30 pm – 9:30 pm 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-7

Sidebar 2 

What are invasive plants... and what’s the big deal? 

• Invasive species are distinguished from other unwanted plants by their ability to spread 

(invade) into native ecosystems. 

• In the western United States, invasive species have been spreading at a rate of about 

4,600 acres per day on federal lands. 

• Oregon State Department of Agriculture estimates indicate that existing and potential 

invasive plants are costing Oregon citizens a total of about $100 million per year. 

Invasive species are typically non-native, however, not all non-native species are invasive. The 

terms alien and exotic are used interchangeably to describe an unwanted plant that has been 

introduced to an environment. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-8

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-9

Figure A-3 Inform Public Letter 

File Code: 1950/2080 

Date: September 18, 2002 

 

Dear Interested Citizen 

We have a serious problem with the establishment and spread of invasive plants (AKA noxious 

weeds and exotics) on National Forests and Grasslands in the Pacific Northwest Region. We 

need your help as we look for ways to more effectively prevent the establishment of invasive 

plants, and to control and restore areas that are currently infested. 

In recent years invasive plant populations have skyrocketed all over the country. The problem 

has been particularly bad throughout the West. Public lands here in the Pacific Northwest 

Region are no exception. Approximately 400,000 acres of National Forests and Grasslands are 

currently infested with invasive, non-native plants. These infestations have the potential to 

expand at the rate of 8-12 percent per year. 

Invasive plants threaten to permanently degrade hundreds of thousands of acres of wildlife 

habitat, eliminate rare and endangered plants, impair water quality and watershed health, and 

adversely affect a wide variety of other resource values. Invasive plants spread across 

landscapes, unimpeded by ownership boundaries. These infested areas represent potential seed 

sources for continuation of the invasion on neighboring lands. Infestations can be prevented, 

eliminated, controlled or made worse by the use of specific management practices. 

Our management direction addressing invasive plant prevention, early detection, treatment, 

inventory and monitoring, and subsequent site restoration needs to be expanded and clarified. 

There is a critical need for the development of clear, and comprehensive Forest Plan standards 

and guidelines that allow for more effective prevention and timely management. 

I have assigned an interdisciplinary team to conduct an environmental analysis to evaluate 

invasive plant prevention practices and management strategies relating to invasive plants in our 

Region. The team’s analysis will be documented in a Region-wide environmental impact 

statement. 

Our question to you is: How can we improve our management of the Region’s forests and 

grasslands to 1) prevent the establishment of invasive plants; 2) detect and respond rapidly 

to control populations of invasive plants in a cost-effective and environmentally sound 

manner; 3) restore native plant communities and habitat conditions in ecosystems that 

have been invaded. 

Your issues and concerns will be important to us as we develop the scope of the project, analyze 

the situation and the data, develop alternatives and select a preferred alternative. We welcome 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-10

your comments anytime during the project. However, your comments would be most helpful if 

received within the next 60 days. A comment form is attached for your use. A draft document 

will be published in mid summer 2003, followed by a 45-day public comment period. 

The interdisciplinary team will be conducting a series of “Invasive Plant Forums” this fall as part 

of our project scoping. The purpose of the forums is to encourage a dialogue about the 

prevention and control of invasive plants, and the restoration of native plant communities that 

have been invaded. We encourage your participation at the forums. 

Location Host Forest Date 

Wenatchee, Washington 

Wenatchee Conference Center, 

North Ballroom 

Wenatchee/Okanogan National Forest November 13, 2002 

6:30 pm – 9:00 pm 

Baker City, Oregon 

Best Western Sunridge Inn 

Wallowa-Whitman National Forest November 16, 2002 

10:00 am – 4:00 pm

Roseburg, Oregon 

Douglas County Public Library 

Umpqua National Forest November 20, 2002 

6:20 pm – 9:00 pm 

We have developed a website for your convenience, which contains information about our 

project, as well as updates on the time and location of our forums and other events. The website 

address is: http://www.fs.fed.us/r6/invasiveplant-eis. Instructions for providing comments via 

email are available on the website. 

To discuss the project or arrange for meetings please contact Eugene Skrine, Team Leader, at 

503-326-4310 or by mail at the following address. 

Invasive Plant Project 

USDA Forest Service 

PO Box 3623 

Portland, OR 97208 

We look forward to your participation in this project. 

Sincerely, 

/s/ Richard Sowa (for) 

LINDA GOODMAN 

Acting Regional Forester 

 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-11

Comment Form 

What do you consider to be the major issues and/or concerns that should be addressed in 

our analysis? 

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

________________________________________________________________________ 

Please share your thoughts with us on how we can improve our management of National 

Forests and Grasslands in regards to preventing invasive plants, improving our control of 

invasive plant populations, and protecting and restoring our native plant communities. 

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______ 

Please mail your comments to: 

Invasive Plant EIS Team 

USDA Forest Service 

PO Box 3623 

Portland, OR 97208-3623 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-12

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-13

Figure A-4 Confirm Printing Needs 

USDA Forest Service 

Invasive Plant EIS Team 

EGWW Room 585 

PO Box 3623 

Portland Oregon 97208 

RE: Draft Environmental Impact Statement, Invasive Plants 

Greetings: 

In July 2003, USDA Forest Service anticipates publishing and distributing a DRAFT 

Environmental Impact Statement (DEIS) for prevention and control of invasive plants in 

the Pacific Northwest. 

We anticipate the hard copy of the DEIS and Appendices to be quite large and we need 

your help in effectively sharing information contained in DEIS, reducing expenses and 

saving paper. 

Please check the box that describes how you would like to receive a copy of the DEIS 

and the preferred format. 

Hard copy format: 

 DEIS only 

 DEIS plus Appendices

 Summary only 

Electronic format: 

 CD Rom 

 I will review on the Internet or at my local Forest Service office. 

 Do not send a copy and remove me from the mailing list. 

If you wish to remain on our mailing list and receive the DEIS in the format you 

requested, please fold, secure and return to the mailing address below before June 2, 

2003. 

If we do not receive a response, we will consider you are no longer interested in the 

project and will remove your name from our mailing list. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-14

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-15

Figure A-5 Meetings w/Public, Groups, Other Government Agencies 

Date Person or Group Location 

11-27-01 Bette Coste, Oregon Dept of Trans. Portland 

03-11-02 Les McConnell, Tribal Relations Portland 

04-12-02 Terry Witt, Oregonians of Food and Shelter Portland 

04-17-02 Alan Holt, The Nature Conservancy Portland 

04-30-02 George Stankey, PNW Portland 

05-01-02 R6 Range Conservationists Pendleton 

05-09-02 Forest Stewards Guild Wilsonville 

05-21-02 Washington State Weed Board Vancouver 

06-03-02 Northwest Coalition for Alternatives to Pesticides Eugene 

06-13-02 Douglas Johnson, Oregon State Univ. Corvallis 

07-08-02 Joanna Cline Portland 

07-11-02 Eric Coombs, Oregon Dept. of Agri. Hood River 

07-23-02 Wallowa-Whitman NF La Grande 

08-12-02 Jerry Asher, BLM (retired) Portland 

08-28-02 National Park Service/ US Geological Survey Portland 

09-17-02 Umatilla National Forest Pendleton 

09-24-02 Deschutes NF./Blue Mtn Biodiversity Bend/Deschutes NF 

09-26-02 Regional Ecosystem Office (REO) Portland 

10-08-02 Stan Loop, Eastern Oregon Public Relations Project Portland 

10-16-02 R6 Forest Supervisors and Deputies Portland 

10-17-02 Skamania County Weed Board Skamania 

10-29-02 Mandy Tu, The Nature Conservancy Portland 

11-07-02 Washington State Weed Conference Yakima 

11-13-02 Invasive Plant Public Forum Wenatchee 

11-16-02 Invasive Plant Public Forum Baker City 

11-20-02 Invasive Plant Public Forum Roseburg 

12-04-02 John Day/Snake River RAC Pendleton 

01-07-03 Oregon Equestrian Trails Sunnyside 

01-22-03 NOAA Fisheries Portland 

 U.S. Fish and Wildlife Services 

01-24-03 Will Lackey, ODOT Portland 

01-29-03 R6 Weed Coordinators Workshop Wilsonville 

02-20-03 Tim Butler, Oregon Dept. of Agri. Portland 

 Greg Haubrich, Washington Dept of Agri. 

03-07-03 Oregon Equestrian Trails Gresham 

03-17-03 Umatilla/Wallowa-Whitman/Malheur NFs Pendleton 

03-20-03 Washington State Weed Coordinators Association Lake Chelan 

04-05-03 Oregon Equestrian Trails Canby 

04-22-03 Caroline Cox, NCAP Portland 

06-04-03 R6 Forest Supervisors and Deputies Bend 

06-04-03 Deschutes and Ochoco NF Bend 

 Botanists/Planners/Silviculturists 

06-12-03 Caroline Cox, NCAP Portland 

06-20-03 Oregon Cattlemen’s Association Klamath Falls 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-16

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Appendix A-17

Table A-1 Comment Analysis 

Issues clarified from the scoping letters for the Invasive Plants EIS (version 7/20/03)

Comments Related to Human Health Effects 

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

Concerned about risks to human health as a result of herbicide use in the Proposed Action. 

Yes 57, 40, 80, 76, 

66, 154, 165, 166, 167, 168, 169, 172, 174 

These comments are addressed in Issue #4 and associated analysis. Alternative B was developed to reduce risk of human health impacts. 

Many supposed inactive/inert ingredients within herbicides included in the Proposed Action can pose serious threats 

Yes 18, 131, 154, 

168, 181, 13, 177, 178, 182, 183 

These comments are addressed in Issue #4 and associated analysis. Alternative B was developed to reduce risk of inactive/inert ingredients. 

Request full disclosure on effects of hormone disruption on humans from chemicals included in the Proposed Action. 

Yes 131 This comment is addressed in Issue #4 and 

associated analysis. Alternative B was developed to reduce risk of hormone disruption. 

Health of people who live near forestlands may be adversely affected by herbicide spraying. 

Yes 174 These comments are addressed in Issue #4 and 

associated analysis. Alternative B was developed to reduce risk of human health impacts. 

When composing chemical vs. manual weed control also analyze the economic costs to pesticide applications in terms of health risks 

No 83 This comment relates to an indirect economic 

impact, assuming increased health risks from pesticides. There is no evidence that the Proposed Action or any other alternative has the potential to measurably increase health care costs. 

EIS should cover the cumulative and synergistic effect of chemical herbicide application. 

Yes 183 Analysis for Issue #4 addresses cumulative effects 

from herbicides on human health. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-18

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

Spraying toxic chemicals across public lands is not a very pleasant thought and must be avoided at all costs. We do not want herbicides in our food chain, water supply, or the air we breathe. One of the worst ways to imbalance nature is to use herbicides. Another is clear-cutting. 

No 184, 254, 260 These comments reflect value judgments. These 

comments are factored indirectly into “social acceptability” analysis for Issue #1. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-19

General Comments About Pesticides and Herbicides 

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis

The Forest Service needs to establish goals for reducing agency use of pesticides. 

No 181 This comment is not about the Proposed Action and 

is outside the scope of this analysis. 

General concerns about the use of herbicides and the effects on the ecosystem. 

No 72, 176, 57, 

113, 66, 229, 225, 174, 169, 168, 10, 18, 131, 165, 167 

This comment is too vague to analyze. Risk assessments for various herbicides were evaluated for potential effects on non-target species, wildlife, human health and aquatic organisms. 

Herbicide use may aggravate the problem rather that solve it. 

Yes 230 This comment is addressed through disclosure 

regarding herbicide resistance, discussed specifically under Issue #1. 

Do not use aerial applied herbicides; too risky. Yes 17, 196, 229, 

219, 233, 92, 119, 143, 168, 188, 225, 228 

An alternative that completely eliminates aerial use of herbicide was considered but dismissed because it could not meet the purpose and need in certain cases (see Chapter 2 for more information). Alternative B was developed to reduce the acreage of annual spray. 

Set a quantified target for the reduction in use of herbicides on NF’s. 

Yes 18, 143, 167, 

170, 184, 186, 188 

Alternative B was developed to reduce reliance on herbicides in the invasive plant management program. 

Always try to use the least toxic method of control. Yes 252 Alternative B was developed to only include the 

least toxic methods of control. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-20

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-21

Comments About Invasive Plant Prevention and Treatment Effectiveness 

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis

Grazing/overgrazing is cause of invasive plant problem. The Proposed Action does not go far enough to stop or reduce grazing on NF land. 

Yes 121, 148, 98, 225, 

226, 233, 12, 17, 18, 23, 25, 26, 29, 31, 96, 97, 122, 153, 14, 42, 57, 81, 74, 77, 56, 60, 116, 118, 112, 111, 102, 123, 154, 137, 105, 164, 165, 168, 169, 170, 171, 172, 173, 177, 180, 181, 182, 150, 138, 183, 186, 188, 189, 194, 195, 196, 198, 244, 247, 216, 219, 184, 

All alternatives consider effects of grazing on invasive plants when determining allotment management plans and invasive plant treatment plans. Alternative B includes a standard to limit grazing that may increase spread of invasives. Analysis for Issue #1 addresses effectiveness of Prevention Standards (including grazing restrictions) in reducing spread. Analysis for Issue #5 discusses effects on land uses, including grazing, from the Prevention Standards. 

Livestock are vectors for weed transport. No 121 This is a general comment and not related to the 

effects of the Proposed Action. 

Use weed-free hay/pellets before/while on NF 

Yes 57, 105, 248, 26, 98, 

54 

Alternative B was developed to require weed-free feed on all acreage of National Forest in Region Six. The other alternatives apply this standard to fewer acres. Analysis for Issue #1 addresses effectiveness of Prevention Standards (including weed-free feed requirements) in reducing spread. Analysis for Issue #5 discusses effects on land uses, including weed-free feed requirements, from the Prevention Standards. 

Encourage diverse native plant communities No 76, 189, 196, 44, 97 This comment is not related to the effects of the 

Proposed Action. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-22

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis

Use manual control techniques whenever possible; not herbicides. 

Yes 23, 57, 76, 153, 164, 

170, 171, 173, 177, 178, 181, 182, 183, 186, 187, 188, 191, 193, 196, 198, 200, 224, 225 

Alternative B was developed to respond to this comment. 

Off-road vehicles spread weeds. Reduce/study ORV use. Restrict off-road vehicles to designated trails, roads, or controlled areas. 

Yes 57, 77, 56, 1, 100, 21, 

164, 168, 169, 170, 171, 173, 177, 181, 182, 183, 186, 188, 189, 194, 195, 196, 198, 244, 216, 219, 222, 18, 25, 96, 143, 138, 154, 123, 128, 48 

Alternative B was developed to reduce OHV use that may lead to invasive plant spread on National Forests in Region Six. Analysis for Issue #1 addresses effectiveness of Prevention Standards (including OHV use restrictions) in reducing spread. Analysis for Issue #5 discusses effects on land uses, including OHV area closures, from the Prevention Standards. 

Require mandatory equipment cleaning before equipment enters weed free areas and as equipment leaves weed-infested areas. 

Yes 01, 27, 60, 147, 243, 

233 

Alternative B was developed to address this comment. The effectiveness of the alternatives in reducing the rate of spread of invasive plants is discussed under Issue #1. 

Restore/reseed disturbed areas to prevent weeds 

Yes 57, 60, 13, 36, 37, 

136, 152 

All alternatives include restoring/reseeding disturbed areas to prevent weeds. 

Study weed dispersal. Prevent movement of weeds from infested to non-infested areas. 

No 80, 70 8, 65, 178, 60, 

103, 106, 162, 216, 17, 25, 29, 

This comment is reflected in the purpose and need for action. 

Close areas and exclude operators/users where weed problems persist; including roads that have been/are major weed vectors. 

Yes 01, 07 Alternative B was developed to respond to this 

comment. The effectiveness of the alternatives in reducing the rate of spread of invasive plants is discussed under Issue #1. 

Need to pay close attention to closed roads limited use roads, and other disturbed areas; not just focus on primary roads. 

Yes 02 Alternative B was developed to respond to this 

comment. The effectiveness of the alternatives in reducing the rate of spread of invasive plants is discussed under Issue #1. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-23

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis

Keep all livestock penned-up for at least two or three days prior to turn out on NF pastures. Limit, or more closely manage, grazing in sensitive areas, riparian areas; excessive grazing can damage native plant communities and bring in invasive seeds. 

Yes 03, 27, 60, 116, 180, 

07, 17, 11, 216, 244 

All alternatives would require consideration of invasive plant management in annual permits. The effects on range management are discussed under Issue #5. 

Use bio controls whenever possible. Yes 14, 60, 66, 71, 72, 83, 

90, 91, 102, 145, 180, 209, 220, 246 

All alternatives provide management direction for biological control of invasive plants. 

Use grazing animals, particularly geese, cows, sheep, and goats, to help control the invasive plant problems. 

Yes 20, 126, 56, 61, 79, 

92, 105, 112, 53, 133, 130, 151, 157, 195, 201, 209, 214, 243 

All alternatives provide management direction for cultural control of invasive plants. 

Discontinue grazing permits. No 21, 23, 24, 11, 90 The suggestion to discontinue grazing permits is 

beyond the scope of this EIS. All alternatives require consideration of invasive plants in allotment management plans. 

Limit soil disturbance associated with all forest activities. 

No 24, 140, 216 Limitations on soil disturbance already exist through 

the Regional Guide and individual Forest Plans. 

Conduct regular surveys to detect weeds early. 

No 219, 232 This comment is not related to the effects of the 

Proposed Action. 

It’s impossible to stop weeds, so don’t try. The spread of plants is normal. The Garden of Eden will not remain the same no matter how much taxpayer money you throw at it. Attempting to control invasives is costly. Nature will cure itself. Don’t waste working on unrealistic projects, i.e. bull thistle, St. John wart, they are too ubiquitous. 

No 9, 14, 28, 239, 60 These comments are value judgments that are 

outside the scope of this EIS. Reducing the spread of invasive plants is part of the purpose and need for action. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-24

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis

Employees in field should pull weeds. That would reduce spread. 

No 94 The labor force to be used to treat invasive plants is 

outside the scope of this EIS. 

Don’t allow horses, mules, or other pack animals on NF. 

No 105 This suggestion is outside the scope of this EIS. 

The effects of pack stock are an issue that would be 

addressed through use of weed-free feed. 

Treat roadsides and rock pits and power line right-of-ways. 

Yes 192 All alternatives include standards for treatment of 

vectors of invasive plant spread. Effectiveness of the alternatives is discussed under Issue #1. 

The Proposed Action does not address the major issue of vehicle use on logging roads, instead looks for technical solutions to try to fix the damage after it has occurred. 

Yes 226 Prevention Standards in Alternative B were 

developed to address this issue. Effectiveness of the alternatives in reducing invasive plant spread is discussed under Issue #1. Effects on land uses are discussed under Issue #5. 

Grazing should be eliminated alltogether. Raising grazing fees closer to market rates would likely decrease this practice. 

No 229 This is a value judgment that is beyond the scope of 

this EIS. 

The environmental preservation associated with the Proposed Action may affect proper forest management. 

Yes 85, 86, 145 This comment is addressed under Issue #5, which 

discusses effects of prevention standards on land management and use. 

Concern with timely intervention. (Why wait so long). Streamline EIS process for quicker response time. Concern with overcoming “bureaucratic regulations” to accomplish work on the ground. Time spent in excessive studies allows weeds to spread. 

No 86, 78, 34, 39, 14, 20, 

45, 155, 107, 148, 121, 124, 127 71, 20, 45, 155, 7, 45, 91 

The NEPA process itself takes a certain amount of time. This is not an issue that can be addressed in the EIS. 

The Proposed Action may not be adaptable enough to switch to more effective and environmental friendly “chemicals” if found. 

Yes 78, 34, 124 Theses comments were addressed by the 

alternatives, thru the development of the standards and the underlying adaptive nature of IPM. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-25

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis

Create a weed control department in charge of control and prevention. 

No 02 This comment is outside the scope of this EIS. 

Organizational decisions are not subject to NEPA. 

The Proposed Action may not go far enough using chemical weed treatment on FS roadsides infested with spotted knapweed, meadow hawkweed and others. 

Yes 91 Alternative D was developed to address this 

comment. The effectiveness of each alternative in reducing spread of invasive plants is discussed under Issue #1. 

Close roads that are serving as weed vectors and limit construction of new roads. 

Yes 07, 258 Prevention Standards in Alternative B were 

developed to address this issue. Effectiveness of the alternatives in reducing invasive plant spread is discussed under Issue #1. Effects on land uses are discussed under Issue #5. 

The Proposed Action may not provide for rapid/early treatment with herbicides. 

Yes 07, 12, 52, 78, 89, 99, 

190, 221, 235 

Alternative D was developed to address this comment. The effectiveness of each alternative in reducing spread of invasive plants is discussed under Issue #1. 

Place a bounty on the most damaging of the invasive plants and pay cash for bagfuls of them. 

No 08, 132 Use of cash incentives to affect an outcome is 

beyond the scope of this EIS and is not subject to NEPA. 

Use integrated weed management in assessing prioritizing and treating infestations. 

Yes 17, 21, 24, 96, 141, 

178, 245, 234 

All alternatives use integrated weed management concepts in assessing and prioritizing infestations. See all EIS Chapters for discussions about integrated weed management. 

Require weed free certified hay for livestock on federal lands. 

Yes 17, 60, 204, 245 Alternative B was developed to require weed free 

feed on all acreage of NF within Region Six. 

Must have interagency cooperation. No 20, 155, 54 This comment is reflected in the purpose and need 

for action. 

Allow local Govt. decision-making authority. No 142, 126 Processes for local, state and federal decisionmaking are beyond the scope of this EIS. Become more aggressive on control. Yes 144 Alternative D was developed to respond to this 

comment. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-26

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis

Amend the forest plan to provide strong standards and guidelines that help forests address prevention, treatment, restoration, and management of noxious weeds. 

Yes 155, 49, 167 This comment is addressed through prevention and 

treatment/restoration standards in all alternatives. The effectiveness of these standards is discussed under Issue #1. 

“One size fits all” will not work; allow individual forests and ranger districts to deal with problems found in their districts. 

Yes 126 This comment led to the refinement of the standards 

to allow for maximum flexibility for management at the Forest and District level, while still maintaining consistency across the region. 

Do not close forest roads. Keep roads open for invasive plant early detection. 

Yes 126 Alternative D was developed to address this 

comment. 

Need inventory and mapping of invasive plant locations. 

No 52 This comment is not about the effects of the 

Proposed Action. 

Never apply non-native seeds; use native seeds whenever possible. 

Yes 24, 221, 241, 243, 

245 

Alternative B was developed to require use of native seed and weed free hay in erosion control projects. 

Require commercial users to post an invasive plant “bond” which could be used to hire eradication crews. 

No 138 Funding mechanisms are beyond the scope of this 

EIS. 

Do not lock yourselves into a limited selection of herbicides; use any/all that are approved by EPA and prescribed by a trained weed control expert. 

Yes 139, 219, 235 Alternative D was developed to respond to this 

comment. 

Consider all the new alternatives such as felted wool mulch, flaming, etc. 

Yes 189 This comment was addressed by the alternatives. 

Maintain the flexibility to use herbicides in roads and road ROW’s. 

Yes 175 All alternatives retain flexibility to use some 

herbicides, although the choices are relative cost and effectiveness varies between the alternatives. 

To restore invaded ecosystems, use hand removal, seed planting, and the introduction of natural predators. 

Yes 260 Alternative B was developed to respond to this 

comment. 

Provide a combination treatment of chemical application with seeding of non-persistent exotics. 

Yes 255 All alternatives would approve the suggested 

strategy. 

Keep tree canopy and reduce disturbances. Yes 193, 196 Alternative B was developed to address this 

comment. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-27

Comments About Social and Economic Effects 

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

Concern that use of herbicides will negatively affect tribal basket weavers and practitioners of traditional life ways. 

Yes 10 These comments addressed in the Environmental Justice 

and Tribal/Treaty Rights Issue and associated analysis. Alternative B was developed to reduce risk of impacts to traditionally used plants. 

Study secondary costs to agricultural producers as weeds move from federal ownership to private land. 

No 240, 225 This comment is not about the effects of the Proposed 

Action. This comment is related to the purpose and need, which includes reducing spread of invasive plants from National Forest to other ownerships. 

Concern that more dollars need to be directed toward invasive plant control. FS should reprioritize funding to spend more on invasive plant research. Noxious weeds need their own budgeting line item. How would the forest service acquire sufficient funding to carry out the task? Existing funding could be used more effectively with lobbying from congress to allow moving funds across line items like fire suppression money is transferred during fire emergencies. Funding for small governments so they can staff up to deal with this. Money better invested in hands-on-field work. Request designated funding through the revenue generated from Forest pass Program for those areas that qualify. 

No 42, 69, 

45, 202, 91, 13, 15, 152, 204, 206, 262, 263 

These suggestions are outside the scope of this EIS. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-28

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

Mitigation and control of invasive plant populations should be forced on the prioritization of large scale and lowest cost treatments first. Prioritize areas for treatment by identifying the most “at risk” areas. To the extent that invasives interfere with the economic use of USFS lands they should be removed. Rivers and steam are conduits for the spread of invasive plants; upstream areas need treatment as targeted areas. 

No 11, 83, 

125, 01, 24, 82, 98 

Chapter 3 discusses a prioritization process; location, cost and economic impact of invasives are factors in prioritizing and determining treatments. 

Cost effectiveness should be paramount in determining treatment. The Proposed Action does not include the most cost-effective chemicals available. 

Yes 71 Alternative D was developed to allow use of the most 

cost-effective chemicals available. Effects on treatment costs are discussed under Issue #5. 

How much will control of invasive plants cost? Yes 59,142 Relative costs of invasive plant treatment are discussed 

under Issue #5. 

Cost to local economics of not treating weeds? No 240 No alternatives exist that would not treat weeds; 

therefore this comment is outside the scope of this EIS. 

Hand pulling large populations of weeds is not cost effective. 

Yes 202 The relative effectiveness and costs of various treatment 

measures are discussed under Issues #1 and #5. 

Public apathy is a major issue. No 29 Public apathy is not an issue related to the effects of the 

Proposed Action. 

Opposed to weed free hay. 116 Alternative D was developed to address this issue. The spread of noxious weeds has negatively impacted the exercise of treaty rights by members of the Nez Perez Tribe. Noxious weeds impact important Nez Perez cultural plants. Protection of these plants should be addressed in any alternative the FS requires. 

Yes 15, 221 Effects on tribal and treaty rights are discussed in 

Chapter 4 under other issues. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-29

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

The Proposed Action may unreasonably restrict use or access on National Forest. The rights of citizens to use National Forest should not be restricted. OHV have a right to use the land 

Yes 83, 136, 

93, 175, 210, 262 

Alternative D was developed to reduce potential for road and OHV use area closures. Analysis for Issue #5 describes the effects of potential road closures from Prevention Standards. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-30

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-31

Comments About Interagency Coordination and Partnerships 

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

Use help from volunteers, non-profit organizations, county soil and water conservationists, hikers, fishers, boy and girl scouts, migrant workers, farmers, ranchers, timber companies, inmates, recreational users, hunters, sportsmen, VMRC, other agencies, prison crews. Partner with groups that currently participate in trail maintenance for assistance with invasive plant control and removal. Develop new programs to pay unemployed to conduct physical control of invasive plants. Use work crews (inmates, volunteers, etc.) for manual treatment and herbicide treatment.

No 84, 81, 80, 71, 72, 73, 

74, 79, 61, 63, 67, 69, 01, 24, 35, 15, 20, 144, 133, 137, 50, 114, 125, 126, 109, 43, 173, 175 192, 157, 197, 203, 242, 228, 236, 206, 262, 263, 258, 03, 14, 30, 35, 39, 83, 115, 137

This comment is outside the scope of this EIS. The workforce suggested could be utilized under all alternatives. 

Research what others are doing i.e. Oregon Dept. of Agriculture Noxious Weed Program, Oregon State University Vegetation Management Research Coop., R-5.

No 62 This is not an issue relating to the effect 

of the Proposed Action. Cumulative effects discussions for all issues include consideration of invasive plant management off Forest. 

Cooperate with neighbors, other agencies, and NGO’s to create a landscape scale weed database. 

No 20 This is not an issue relating to the effect 

of the Proposed Action. Cumulative effects discussions for all issues include consideration of invasive plant management off Forest. 

The problem is in the cities. Exert pressure on city/county administrative counterparts to have them force property owners to clean up their lots in the towns. 

No 101 This comment is outside the scope of 

this EIS. This EIS relates to decisions about standards that would apply to invasive plant management on National Forests in Region Six. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-32

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

Lack of weed-free feed regulations in the state of WA. No 104 This comment is outside the scope of 

this EIS. This EIS relates to decisions about standards that would apply to invasive plant management on National Forests in Region Six. 

Funding needs to be made available for projects on private lands. 

No 99 Funding for projects outside of National 

Forests in Region Six is beyond the scope of this EIS. 

Penalize private landowners who do not combat weeds on their own land. 

No 132, 33 This comment is outside the scope of 

this EIS. This EIS relates to decisions about standards that would apply to invasive plant management on National Forests in Region Six. 

Examine creation of incentive programs such as Audubon Society golf course/ wildlife sanctuary programs. Partner with nursery associates, nursery growers, landscape contracts and landscape architects. Use incentives to attract volunteers for weed pulling and restoration such as free forest passes, T-shirts, etc. 

No 197, 208, 235, 228 This comment is outside the scope of 

this EIS. This EIS relates to decisions about standards that would apply to invasive plant management on National Forests in Region Six. 

Develop a giant program. Use grants to acquire funding. 

No 50 This comment is outside the scope of 

this EIS. This EIS relates to decisions about standards that would apply to invasive plant management on National Forests in Region Six. 

Ask forest users to report weed infestations. No 57 Public reporting scenarios are beyond 

the scope of this EIS and could occur regardless of selected alternative. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-33

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

The Forest Service to work cooperatively with private landowners to reduce invasive species on private land. Establish better communication with states/local communities concerning their noxious weed concerns. Establish standard GIS and reporting across all federal and state jurisdictions to facilitate information sharing. Concern with poor consistency across jurisdictions in methods and approved chemicals for treatment. Obtain grants for schools, non-profit organizations, and other interested parties to do invasive removal. Partner with educational institutions, elementary, high school, colleges, they can be trained to work on projects and perhaps gain credit for them. Expand Americorps and have them pull weeds. Working with groups like the Okanogan Highland Alliance, the Sierra Club, and the Cattle Range Conservation group would produce workers and volunteers to achieve the most cost effective outcome. Partner with State, County, and local boards to treat all roads on and off the forest.

No 42, 71, 65, 13, 15, 16, 

47, 21, 54, 121, 212, 259, 78, 142, 144, 4, 238, 33, 15, 20, 124, 204, 155, 150, 98, 99, 112, 124, 127, 52, 241, 220, 221, 257, 237, 255, 260 

This comment is outside the scope of this EIS. This EIS relates to decisions about standards that would apply to invasive plant management on National Forests in Region Six. The EIS does discuss how invasive plant management on National Forest may affect off-Forest spread of invasive plants and off-Forest management techniques. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-34

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-35

Comments Related to the Terrestrial Environment 

Comment Substantive Issue? Letter Number How Comment is Addressed in Analysis 

Objections to aerial herbicide application based on concerns about risks to the health of terrestrial environment from the Proposed Action. 

Yes 57, 80 This comment is addressed in analysis for 

Issue #3, which discusses the relative risk of herbicide exposure to wildlife. Alternative B was developed to reduce the number of acres of herbicide projected for annual use and restricts the formulations to those with only negligible effects to wildlife. 

General concerns over the spread of invasive plants and the impacts on native species and the loss of functioning wildlife habitats. 

No 56, 6, 91, 240 This is not a comment related to the effect of 

the Proposed Action. Chapter 3, Affected Environment, discusses the effects of invasive plants on wildlife. 

Concern over environmental damage from invasive plants. 

No 25, 142, 21, 212 This is not a comment related to the effect of 

the Proposed Action. Chapter 3, Affected Environment, discusses the effects of invasive plants on various ecosystem components. 

Choose actions that have the least negative impacts on the soil, water, wildlife, air quality, and native plants. 

No 168, 164, 212, 249 This comment is too vague to analyze. 

However, the potential for adverse effects on the environment is one of the Regional Foresters decision factors regarding the final selection of alternative. . 

Concern over the spread of invasive plants by wildlife and feral horses and burros. 

No 99, 55 This comment is not about the effects of the 

Proposed Action. The Forest Service cannot control the spread of invasive plants on the feet of wild animals. 

Concern over large scale prescribed fire and potential damage to topsoil/humus layer. 

Yes 76 Effects on soils from prescribed fire and 

other methods of invasive plant control were analyzed under the Soil Productivity issue. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-36

The proposed requirement to restore lands using native plants is unnecessary. Any effort to so should be entirely voluntary. Restore native plant communities; identify where and when native re-vegetation is appropriate 

Yes 9, 221 This comment was addressed by eliminating 

requirements for native plant regeneration in Alternative D. The effects of this are described under Issues #1, #2 and #5. 

Think on a bio-corridor level. No 256 This comment is not about the effects of the 

Proposed Action and is too vague to analyze. 

Herbicides kill bacterial fungi in the soil, which breaks down soil for food. 

Yes 184 This comment was addressed in the Soil 

Productivity Issue. 

Allow for natural fire regime in fire dependant communities. 

No 258 This comment is not about the effects of the 

Proposed Action. 

Use of native seed only on NF land is too expensive and limits the ability to provide soil protection from erosion and noxious weed invasion. 

Yes 255, 260 This comment was addressed by eliminating 

requirements for native seeds for regeneration in Alternative D. The effects of this are described under Issues #1, #2 and #5. 

Non-native beneficial grasses and forage should be considered for vegetation. 

Yes 255 This comment was addressed by eliminating 

requirements for native plant regeneration in Alternative D. The effects of this are described under Issues #1, #2 and #5. 

Locate all non-native invasives that have the greatest potential threat to native species and wildlife. 

No 252 This comment is not about the effects of the 

Proposed Action and is too vague to analyze. 

Concerned about the use of biological controls on “Biotic Integrity.” 

Yes 44 This issue was addressed in the analysis. 

Must consider the effects of seeding areas with other exotics. 

Yes 13 Alternative B was developed to address this 

comment. It requires use of native seed in projects. The effects of this requirement are discussed under several issues. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-37

Comments About the Aquatic Environment 

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis

Concerns about the use of herbicides and the risk they pose to aquatic species health. 

Yes 57, 17, 170, 

171, 261 

This comment is addressed through Treatment/Restoration Standards in all alternatives to reduce the potential for herbicide to enter streams. This issue is analyzed under Issues #4, Human Health, and the Aquatic Organism Issue. 

Concerns for the use of herbicides polluting streams and water systems. 

Yes 72, 17, 113, 

171, 174, 195, 247, 229 

This comment is addressed through Treatment/Restoration Standards in all alternatives to reduce the potential for herbicide to enter streams. This issue is analyzed under Issues #4, Human Health, and the Aquatic Organism Issue. 

Livestock grazing of riparian areas results in removal of native vegetation, trampling of meadows, sloughing and raw stream banks, and introduction of exotic weeds. 

No 153 This comment is not about the effects of the Proposed Action. 

General concern for water quality for salmon and steelhead. 

No 148, 170, 171 Too vague to analyze. Analysis includes required disclosures 

about effects on special status fish species. 

Vitally important to consider all ingredients in herbicides, including those not listed on the label. 

Yes 170 The analysis throughout the EIS considers all potentially toxic 

ingredients in herbicide formulations. 

Concern for providing best protection for riparian and stream values while proceeding on an invasive plant abatement program. 

Yes 80 This comment is addressed in Treatment Standards in all 

alternatives that reduce the likelihood for adverse effects on riparian and stream values. 

Potential for impacts to water quality is a major issue. 

No 254 This comment is too vague to analyze. Effects of herbicide on 

drinking water and fish are discussed. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-38

Comments About Wilderness and Recreation Effects 

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

Imperative to manually remove invasive plants from wilderness areas 

No 50 The Proposed Action does not propose to use motorized 

equipment or herbicide in wilderness areas. 

Invasive plants spread from private land to public land, especially into wilderness areas. 

No 122 This comment is not about the effects of the Proposed 

Action. The fact that invasive plants spread across all land ownerships is considered in the EIS. 

Concern about weeds moving along roads into National Parks and along trails into wilderness areas 

No 232 This comment is not about the effects of the Proposed 

Action. The mechanisms of invasive plant spread and their adverse effects are discussed in Chapter 3, Affected Environment. 

Potential for impacts to wilderness and roadless areas are a major concern. 

No 254 This comment is too vague to analyze. 

General concern for impacts to recreation uses if weeds are left unattended. 

No 261 This comment is outside the scope of the EIS. No 

alternatives would leave weeds unattended. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-39

Comments about Effects on Threatened and Endangered Species 

Comment 

Substantive Comment?

Letter Number

How Comment is Addressed in Analysis

Concerned about the impact of invasive species on the threatened and endangered species. 

No 6, 16, 211, 

190, 201 

This comment is not about the effects of the Proposed Action. The mechanisms of invasive plant spread and their adverse effects are discussed in Chapter 3, Affected Environment. 

Protection of threatened land base of native plants from invasive species. 

No 16 This comment is not about the effects of the Proposed 

Action. It is reflected in the purpose and need for action. 

Effects of herbicides for control of invasive species on endangered and threatened species. Potential impacts to TES species are a major issue 

Yes 164, 167, 

168, 172, 254 

This comment is addressed in the Threatened and Endangered Species issue. All alternatives include standards to reduce risk of herbicide effects to non-target and special status species. 

Effects of herbicides on food and habitat for endangered species. 

Yes 167 This comment is addressed in the Threatened and 

Endangered Species issue. All alternatives include standards to reduce risk of herbicide effects to non-target and special status species. 

Domestic sheep and goats should not be used for weed control in Bighorn sheep habitat; disease concerns for bighorn. 

No 67 This comment is outside the scope of this EIS, and 

appropriately addressed on the site-specific project level thru grazing allotment planning. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-40

Comments about Public Education 

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

Provide free brochures with weed identification. 

No 57, 87, 82, 60, 04, 

115, 94, 147, 54, 47, 130, 218, 233, 238 

This comment is outside the scope of the EIS. Educational activities such as providing brochures may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Inform public when weed is producing seed and recommend mo travel into national forest for that time. 

No 57, 70, 52 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Hands on help and education to farmers and landowners. 

No 87, 218, 224 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-41

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

General education to public and workers. Create a video about invasive species. Provide educational insert in maps and permits. Create ad campaign with “Smokey Bear” impact. Keep public informed of research. Send out informational letters to property owners. Recruit volunteers to provide information at by-ways. Public outreach and education that focuses on preventative strategies. 

No 87, 80, 74, 71, 65, 67, 

04, 08, 33, 116, 34, 119, 26, 30, 15, 16, 19, 132, 120, 137, 45, 162, 157, 121, 127, 52, 54, 192, 197, 203, 204, 208, 242, 248, 212, 223, 231, 236, 237, 257, 262, 33, 206, 27, 114, 53, 173, 237 

This comment is outside the scope of the EIS. Educational activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Train public and volunteers in handling/ use of herbicides/toxics chemicals. Train all field officers in invasive plant recognition, preventing, and reporting. Train public and workers on early detection. 

No 81, 107, 183, 192, 

148, 202, 242 

This comment is outside the scope of the EIS. Educational activities such as providing training may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Training would help meet the goals of the EIS. 

National campaign to educate recreationists. Provide information at OHV vendors. 

No 78, 103, 189, 236, 52, 

54 

This comment is outside the scope of the EIS. Educational activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-42

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

Start education in schools. No 73, 137, 219 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Develop public reporting system. Create mail-in/drop-off form for reporting. Establish a hot line so people can report weeds. Contact “geocache’s,” a group that hunts for treasure with GIS equipment in hand. They could take exact location of invasive plants they see. 

No 72, 66, 67, 47, 252, 

258 

This comment is outside the scope of the EIS. Informational activities such as coordinating public reporting may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. A public reporting system would help meet the goals of the EIS. 

Education on seed types and where found. 

No 70 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Provide information at campgrounds and trail head bulletin boards, also at hunting license vendors and vehicle registration offices. 

No 175, 189, 219, 233, 

252, 258 

This comment is outside the scope of the EIS. Educational activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Need a “medical dictionary” type book on noxious weeds that lists plants, discusses habitats, and prescribes useful treatments and % of chance or degrees of effective reduction. 

No 199 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-43

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

Use volunteers, individuals, businesses, etc. to help educate the public. 

No 206 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Increase awareness of noxious weeds identification by permittees, timber operators, personnel and the public. 

No 243 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Educate policy makers of the facts regarding invasive plant control. 

No 245 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Visibly promote the economics and efficacy of using herbicides in a responsible manner. 

Yes 213 This comment is addressed in Issue #1, Effectiveness of the 

Alternatives, to the extent that demonstrated treatment effectiveness may affect how others use herbicides. 

Provide the true cost of improving control and restoring native vegetation to congress, NF management and the public. 

No 219 This comment is outside the scope of the EIS. Educational 

activities such as providing information may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 

Areas most susceptible to invasive plants need more restrictions with signs stating the reasons. 

No 228 This comment is outside the scope of the EIS. Educational 

activities such as signage may be categorically excluded from documentation in an EIS and may occur as a complement to all alternatives. Educational projects would help meet the goals of the EIS. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-44

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

Start a control program in the places where people live. This includes all residences whether on private, state or federal land. This is where the most non-natives grow. The plan should not be limited just to “National Forest” lands; the problem crosses multiple ownership boundaries. 

No 252, 257 This comment is outside the scope of the EIS, which deals 

specifically with NF lands. 

Outreach should be non-paternalistic No 256 This comment is outside the scope of the EIS. Decisions 

about style of public outreach are not subject to NEPA. 

Communicate face to face as much as possible. 

No 256 This comment is outside the scope of the EIS. Decisions 

about style of public communication are not subject to NEPA. 

Convey the message that “no single method fits all needs.” 

No 257 This comment is outside the scope of the EIS. Decisions 

about style of public outreach are not subject to NEPA. 

Provide incentive programs for public; i.e. awards, caps, free passes, etc. 

No 258 This comment is outside the scope of the EIS, which deals 

specifically with NF lands. 

Encourage volunteers to adopt a portion of the forest to keep clear of weeds. 

No 203 Workforce decisions are beyond the scope of this EIS. Use 

of volunteers would be consistent with the goals of all alternatives. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-45

Other Comments 

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

Invasive plants should be studied, and ways found to convert them into useful products or resources. Encourage whole plant harvesting of invasive for medicinal purposes. 

No 40, 137 This comment is not about the effects of the Proposed Action. 

Invasive plant study is not subject to NEPA. Harvesting of natives for medicinal purposes may be compatible with treatments in all alternatives. 

Use fire as a tool to keep healthy native plant communities. Mimic natural disturbances with FS activities. 

No 10, 55, 58, 

60, 92, 24, 58, 105, 112, 118, 189 

General use of prescribed fire as a forest management tool is discussed in Chapter 3, but is outside the scope of this EIS. 

FS should measure and predict impacts from proposed activities using a quantitative model with predictive capacities. 

Yes 22, 204 The effects analysis relies on quantitative models and 

measurable comparison factors where possible. 

Consider a separate “restore native ecosystems” alternative. 

Yes 194 This alternative was considered and provided the basis for 

development of Alternative B. Some aspects of the suggested alternative were dismissed from consideration because they are beyond the scope of this EIS. 

Improve the analysis/consideration of invasive in other FS NEPA. 

Yes 24 All alternatives would improve project level consideration of 

invasive plants. 

Encourage local nurseries to increase their output of native species. 

No 24, 82 This comment is beyond the scope of this EIS. An increase 

in native species output would be consistent with the goals of this EIS. 

Schedule regular surveys along FS roads; particularly the year after timber harvest. 

Yes 27 Alternative B was developed to increase the requirements for 

follow up inspections along roads. 

Once invasives are established, use “holistic” restoration/rehabilitation. 

Yes 247 Alternative B was developed to address this comment. 

Invest and build new fences, gates, range improvements to improve livestock distribution on NF grazing allotments. 

No 60 This comment is not related to the effects of the Proposed 

Action. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Appendix A-46

Comment Substantive Comment? Letter Number How Comment is Addressed in Analysis 

Explore the use of natural, organic pesticides. No 78, 180, 

185, 201, 208 

These comments were considered during alternative development, but judged to be too vague. It is outside the scope of this EIS to “explore” unproven or untested new chemical agents.