Pacific Northwest Region 

Invasive Plant Program 

Preventing and Managing Invasive Plants 

Final Environmental Impact Statement 

USDA Forest Service 

Pacific Northwest Region 

States of Oregon and Washington, Including Portions of Del Norte and Siskiyou Counties in 

California, and Portions of Nez Perce, Salmon, Idaho, and Adams Counties in Idaho 

Lead Agency: USDA Forest Service 

Responsible Official: Linda Goodman, Regional Forester 

Pacific Northwest Region 

333 SW First Ave. 

PO Box 3623 

Portland, OR 97208 

For More Information: IPEIS, Eugene Skrine, Team Leader 

PO Box 3623 

Portland, OR 97208 

Ph: (503) 808-2685 

Fax: (503) 808-2699 

Email: r6_IPEIS@fs.fed.us

www.fs.fed.us/r6/invasiveplant-eis 

Abstract: The Forest Service proposes to add management direction to all existing National 

Forest Land and Resource Management Plans in the Pacific Northwest Region (Region Six). 

This direction would standardize invasive plant prevention, and expand the set of invasive 

plant treatment tools available for use on National Forests in Region Six. 

The FEIS considers four alternatives in detail (including No Action). Adoption of the 

standards in any of the action alternatives would likely reduce the extent and rate of spread of 

invasive plants across the region, and help prevent new infestations. All of the action 

alternatives include standards to protect human health and the environment. The Forest 

Service preferred alternative is the Proposed Action. 
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

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

activities on the basis of race, color, national origin, gender, religion, age, disability, political 

beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all 

programs.) Persons with disabilities who require alternative means for communication of 

program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET 

Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write 

USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and 

Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and 

TDD). USDA is an equal opportunity provider and employer. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Contents 

SUMMARY ...........................................................................................................................1 

Purpose and Need...................................................................................................................1 

The Proposed Action ..............................................................................................................2 

Decision to be Made...............................................................................................................3 

Public Involvement and Issues...............................................................................................7 

DEIS Comment Period .......................................................................................................7 

Key Issues...........................................................................................................................7 

The No Action Alternative .....................................................................................................8 

The Other Action Alternatives ...............................................................................................9 

Alternative B ......................................................................................................................9 

Alternative D ......................................................................................................................9 

Inventory and Monitoring.....................................................................................................10 

Effects of the Alternatives....................................................................................................11 

No Action .........................................................................................................................11 

Action Alternatives...........................................................................................................11 

CHAPTER 1 PURPOSE AND NEED FOR ACTION ...........................................................1-1 

1.1 Introduction ...................................................................................................................1-1 

1.2 Need for Action .............................................................................................................1-2 

1.3 Decision to be Made......................................................................................................1-3 

1.4 Project Location.............................................................................................................1-4 

1.5 What is Not Included.....................................................................................................1-5 

1.6 Public Participation, Scoping and Issues.......................................................................1-9 

1.6.1 Key Issues.............................................................................................................1-10 

1.6.2 Other Issues..........................................................................................................1-13 

1.6.3 DEIS Comment Period.........................................................................................1-14 

CHAPTER 2 ALTERNATIVES, INCLUDING THE PROPOSED ACTION ......................2-1 

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

2.2 Alternatives Considered in Detail .................................................................................2-1 

2.3 Current Direction and the No Action Alternative .........................................................2-4 

2.3.1 Prevention...............................................................................................................2-5 

2.3.2 Treatment and Restoration .....................................................................................2-8 

2.3.3 Inventory and Monitoring.......................................................................................2-9 

2.4 Management Direction Common to All Action Alternatives......................................2-11 

2.4.1 Desired Future Conditions, Goals and Objectives ...............................................2-12 

2.4.2 Inventory and Monitoring Plan Framework.........................................................2-15 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

2.5 Management Direction Unique to Each Action Alternative .......................................2-16 

2.6 Comparison of Alternatives.........................................................................................2-25 

2.7 Alternatives Considered but Eliminated From Detailed Study ...................................2-33 

2.7.1 Prohibiting OHVs, Grazing, Logging, and other Land Management Activities..2-33 

2.7.2 No Treatment of Invasive Plants..........................................................................2-33 

2.7.3 No Use of Herbicides ...........................................................................................2-34 

2.7.4 Additional Use of Herbicides...............................................................................2-35 

2.7.5 No use of Biocontrol Agents................................................................................2-35 

2.7.6 Prohibit Aerial Application Of Herbicides...........................................................2-36 

2.7.7 Restore Native Ecosystems Alternative (RNEA).................................................2-36 

CHAPTER 3 AFFECTED ENVIRONMENT ........................................................................3-1 

3.1.1 Current Extent of Invasion .....................................................................................3-2 

3.1.2 Invasive Plant Species in Region Six .....................................................................3-5 

3.1.3 Mechanisms of Invasion.........................................................................................3-9 

3.2 Influence of Invasive Plants on Ecosystem Components............................................3-26 

3.2.1 Soils......................................................................................................................3-27 

3.2.2 Water Quality .......................................................................................................3-31 

3.2.3 Riparian ................................................................................................................3-35 

3.2.4 Aquatics................................................................................................................3-37 

3.2.5 Native Plants and Plant Communities..................................................................3-40 

3.2.6 Wildlife.................................................................................................................3-47 

3.2.7 Threatened, Endangered, Proposed and Sensitive Species ..................................3-49 

3.2.8 Social and Economic ............................................................................................3-66 

3.2.9 Congressionally Designated Areas.......................................................................3-70 

3.3 Invasive Plant Management ........................................................................................3-75 

3.3.1 Prevention.............................................................................................................3-75 

3.3.2 Treatment and Restoration ...................................................................................3-76 

CHAPTER 4 ENVIROMENTAL CONSEQUENCES...........................................................4-1 

4.1 Introduction ...................................................................................................................4-1 

4.1.1 Basis for Cumulative Effects Analysis...................................................................4-1 

4.2 Effectiveness of Preventing and Reducing the Spread of Invasive Plants....................4-4 

4.2.1 Introduction ............................................................................................................4-4 

4.2.2 Background.............................................................................................................4-5 

4.2.3 Direct and Indirect Effects......................................................................................4-8 

4.2.4 Cumulative Effects...............................................................................................4-22 

4.2.5 Methodology.........................................................................................................4-23 

4.2.6 Incomplete and Unavailable Information.............................................................4-26 

4.3 Effects of Herbicides on Non-target Plants and Native Plant Communities...............4-27 

4.3.1 Introduction ..........................................................................................................4-27 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

4.3.2 Background...........................................................................................................4-27 

4.3.3 Direct and Indirect Effects....................................................................................4-28 

4.3.4 Cumulative Effects...............................................................................................4-39 

4.3.5 Methodology.........................................................................................................4-40 

4.3.6 Incomplete and Unavailable Information.............................................................4-41 

4.4 Effects of Herbicides to Certain Birds, Mammals and Amphibians...........................4-42 

4.4.1 Introduction ..........................................................................................................4-42 

4.4.2 Background...........................................................................................................4-44 

4.4.3 Direct and Indirect Effects....................................................................................4-50 

4.4.4 Cumulative Effects...............................................................................................4-61 

4.4.5 Methodology.........................................................................................................4-63 

4.4.6 Incomplete or Unavailable Information ...............................................................4-64 

4.5 Human Health and Safety Effects ...............................................................................4-66 

4.5.1 Introduction ..........................................................................................................4-66 

4.5.2 Direct and Indirect Effects....................................................................................4-67 

4.5.3 Alternative Comparison........................................................................................4-88 

4.5.4 Cumulative Effects...............................................................................................4-89 

4.5.5 Methodology.........................................................................................................4-90 

4.5.6 Incomplete or Unavailable Information ...............................................................4-92 

4.6 Costs of Treatment and Effects on Land Use..............................................................4-93 

4.6.1 Introduction ..........................................................................................................4-93 

4.6.2 Costs Of Invasive Plant Treatment.......................................................................4-94 

4.6.3 Effects of Prevention Standards ...........................................................................4-98 

4.6.4 Costs of Heavy Equipment Work.......................................................................4-102 

4.6.5 Weed Free Feed Requirements...........................................................................4-104 

4.6.6 Tendency for Standards to Affect Range Allotments and Permittees................4-106 

4.6.7 Tendency for Standard to Affect Road and Off-Highway Vehicle Access........4-107 

4.6.8 Alternative Comparison......................................................................................4-109 

4.7 Other Issues...............................................................................................................4-109 

4.7.1 Soil Productivity.................................................................................................4-109 

4.7.2 Aquatic Organisms.............................................................................................4-113 

4.7.3 Threatened, Endangered and Sensitive Species .................................................4-125 

4.7.4 Environmental Justice and Tribal/Treaty Rights................................................4-163 

4.8 Specifically Required Disclosures.............................................................................4-165 

4.8.1 Adverse Environmental Effects that Cannot be Avoided...................................4-165 

4.8.2 Short-term Uses and Maintenance of Long-term Productivity ..........................4-173 

4.8.3 Irreversible or Irretrievable Impacts...................................................................4-173 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Tables 

Table S-1 Key Features of the Alternatives Considered in Detail. ..........................................10 

Table S-2 Alternative Comparison/Decision Factors...............................................................13 

Table 2-1 Key Features of the Alternatives.............................................................................2-3 

Table 2-2 Action Alternative Standards................................................................................2-17 

Table 2-3 Treatment Methods Under the Alternatives..........................................................2-27 

Table 2-4 Summary of Environmental Effects of Implementing the Alternatives ..............2-29 

Table 2-5 Components of the RNEA Dismissed From Detailed Consideration...................2-38 

Table 3-1 Biological Traits That Enable Invasive Plants to Colonize New Areas ...............3-11 

Table 3-2 Regional Road Mileage by Maintenance Level and Surface Type.......................3-16 

Table 3-3 Regional Road Mileage Summary ........................................................................3-17 

Table 3-4 Annual Grazing Statistical Detail (Grazing Season 2002)....................................3-20 

Table 3-5 Known Effects of Invasive Plants on Ecosystems................................................3-27 

Table 3-6 Potential Vegetation Groups.................................................................................3-41 

Table 3-7 Known Effects of Invasive Plants to Wildlife ......................................................3-49 

Table 3-8 Federally Listed Plant Species Documented or Suspected in Region Six ............3-51 

Table 3-9 Federally Listed Mammals, Birds, and Invertebrates in Region Six ....................3-57 

Table 3-10 Endangered and Threatened Fish and Mollusks.................................................3-62 

Table 3-11 Tribes and Treaty Rights.....................................................................................3-69 

Table 3-12 Priorities for Treatment and Selection of Treatment Methods. ..........................3-79 

Table 3-13 Herbicides included in this EIS and analyzed in Chapter 4................................3-91 

Table 3-14 Summary of Treatment Methods ........................................................................3-97 

Table 4-1 Projected Use of Various Herbicides in Oregon and Washington..........................4-2 

Table 4-2 Relative Ranking of Prevention Effectiveness by Alternative Standards.............4-15 

Table 4-3 Invasive Plant Species Effectively Treated by Herbicides ...................................4-19 

Table 4-4 Years to Control 420,000 Acres of Invasive Plants*............................................4-21 

Table 4-5 Years to Control at Current Funding Levels.........................................................4-22 

Table 4-6 Potential Herbicide Doses for Bees in a Direct Spray Scenario ...........................4-34 

Table 4-7 Summary of Effects by Measuring Factors...........................................................4-38 

Table 4-8 Toxicity indices used and LOAELs reported for Mammals. ................................4-47 

Table 4-9 Toxicity indices used and LOAELs reported for Birds ........................................4-48 

Table 4-10 Plausible Exposure Scenarios - Birds and Mammals - Alternative B.................4-53 

Table 4-11 Plausible Exposure Scenarios - Birds and Mammals - Proposed Action ...........4-55 

Table 4-12 Plausible Exposure Scenarios - Birds and Mammals - No Action .....................4-57 

Table 4-13 Plausible Exposure Scenarios - Birds and Mammals - Alternative D ................4-60 

Table 4-14 Summary of Effects by Measuring Factors.........................................................4-61 

Table 4-15 Acres of Treatment and Worker Days of Exposure, Manual Treatment ............4-68 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Table 4-16 Worker Potential Health Risks (No Action) .......................................................4-77 

Table 4-17 Public Potential Health Risks (No Action) .........................................................4-77 

Table 4-18 Public Consumption of Contaminated Pond Water (No Action)........................4-78 

Table 4-19 Worker Potential Health Risks (Proposed Action) .............................................4-79 

Table 4-20 Public Potential Health Risks (Proposed Action) ...............................................4-80 

Table 4-21 Public Consumption of Contaminated Pond Water (Proposed Action)..............4-81 

Table 4-22 Worker Potential Health Risks (Alternative B) ..................................................4-82 

Table 4-23 Public Potential Health Risks (Alternative B) ....................................................4-83 

Table 4-24 Public Consumption of Contaminated Pond Water (Alternative B)...................4-83 

Table 4-25 Worker Potential Health Risks (Alternative D)..................................................4-85 

Table 4-26 Public Potential Health Risks (Alternative D)....................................................4-86 

Table 4-27 Public Consumption of Contaminated Pond Water (Alternative D)...................4-86 

Table 4-28 Number of Plausible Exposure Scenarios (excludes drinking water scenarios).4-87 

Table 4-29 Public Consumption of Contaminated Water: Herbicide + NPE........................4-88 

Table 4-30 Summary of Effects by the Measuring Factors...................................................4-88 

Table 4-31 Current Annual Treatment Acreage and Cost.....................................................4-94 

Table 4-32 Average Per Acre Herbicide Treatment Costs by Alternative............................4-96 

Table 4-33 Treatment Acres by Alternative Holding Total Cost Constant at $4.8 MM.......4-97 

Table 4-34 Cost of Heavy Equipment.................................................................................4-103 

Table 4-35 Acres Where Weed Free Feed Would Be Required .........................................4-105 

Table 4-36 Effects on Grazing and Range Management.....................................................4-107 

Table 4-37 Effects of Road and OHV Use Closures...........................................................4-108 

Table 4-38 Summary of Effects by Measuring Factors.......................................................4-109 

Table 4-39 Predicted Annual Acreage of Herbicide use - NFS lands, Region Six .............4-111 

Table 4-40 Factors for Determining Herbicide Exposure to Aquatic Organisms. ..............4-115 

Table 4-41 Forest Service SERA Exposure Results for Sensitive Aquatic Organisms......4-117 

Table 4-42 Potential Effects and Determination Statements for Federally Listed Plants...4-127 

Table 4-43 Summary of Worst-Case Exposure Scenarios for Federally Listed Wildlife ...4-135 

Table 4-44 Potential effects and Determination Statements for Federally Listed Wildlife 4-137 

Table 4-45 Exposure Groups, Exposure Scenarios, and Species Included .........................4-141 

Table 4-46 Potential Effects to Sensitive Species. ..............................................................4-143 

Table 4-47 Acute Exposure Results for Sensitive Aquatic Organisms - EPA Protocol .....4-152 

Table 4-48 Potential Effects to Proposed, Endangered, and Threatened Aquatic Species. 4-157 

Table 4-49 Potential Effects to Sensitive Fish Species.......................................................4-160 

Table 4-50 Potential Effects to Commercially Important Fish Species..............................4-162 

Table 4-51 Adverse Effects that Cannot be Avoided..........................................................4-167 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Figures 

Figure S-1 USDA Forest Service Pacific Northwest Region.....................................................5 

Figure 1-1 Pacific Northwest Region National Forests...........................................................1-7 

Figure 3-1 Invasive Plants Inventory, April 2003...................................................................3-3 

Figure 3-2 Three Phases of Invasion.....................................................................................3-10 

Figure 3-3 Occurrence of Listed Water Quality Limited Water Bodies...............................3-33 

Figure 3-4 Potential Vegetation Groups................................................................................3-43 

Figure 3-5 Federally Listed Plant Species Occurrence .........................................................3-53 

Figure 3-6 Federally Listed Terrestrial Wildlife Species Occurrence...................................3-59 

Figure 3-7 Federally Listed Aquatic Species Occurrence.....................................................3-63 

Figure 3-8 Congressionally Designated Areas......................................................................3-73 

Figure 4-1 Acres Treated Annually by Type Holding Budget Constraint at $4.8 MM ........4-97 

Figure 4-2 Annual Heavy Equipment Costs (in Millions) ..................................................4-104 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

List of Preparers 

Distribution List 

Literature Cited / Personal Communication 

Glossary 

Index 

Appendices 

Appendix A Public Involvement 

Comments and Responses to the Draft EIS 

Letters from Federal, Tribal, State, Local Agencies and Elected Officials 

Appendix B Invasive Plant List 

Appendix C Threatened, Endangered, and Sensitive Plant and Animal Lists Locator 

Appendix D PNW Causal White Papers 

Appendix E USDA Forest Service Guide to Noxious Weed Prevention 

Appendix F Current Forest Plan Standards and Guidelines (No Action) 

Appendix G Herbicide Risk Assessment Locator 

Appendix H Biological Controls 

Appendix I Current PNW Region Six Strategy for Supporting Invasive Plant 

Management on State and Private Lands 

Appendix J The Effects of Non-Herbicide Methods of Invasive Plant Treatment on 

Wildlife, Fish and Plants 

Appendix K Related Legal History 

1988 Record of Decision for Managing Competing and Unwanted 

Vegetation and 1989 Mediated Agreement 

Appendix L Restore Native Ecosystems Alternative (RNEA) 

Appendix M Inventory and Monitoring Plan Framework 

Appendix N Common Control Measures for Invasive Plants of the Pacific Northwest 

Locator 

Appendix O North American Weed Management Association Standards (NAWMA) 

Appendix P Summary of Herbicide Effects to Wildlife 

Appendix Q Human Health Risk Assessment 

Appendix R Proposed Road Rule 36 CFR – Travel Management 

Appendix S National Strategy and Implementation Plan for Invasive Species 

Management Locator 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

SUMMARY 

This Final Environmental Impact Statement (FEIS) documents the analysis of the potential 

environmental consequences of amending all Pacific Northwest Region (Region Six) Land 

and Resource Management Plans (Forest Plans) to improve the ability of the National Forests 

to prevent and manage invasive plants1

. Existing direction would be replaced with updated 

and more comprehensive direction (Chapter 1.1). 

This FEIS has been prepared in compliance with the National Environmental Policy Act 

(NEPA) guidelines as set by the Council of Environmental Quality in 40 CFR 1500-1508 and 

Forest Service (FS) Handbook 1909.15. The document describes the purpose and need for 

action, the alternatives including the Proposed Action, the affected environment, and the 

effects of the alternatives. Chapter references are provided in this summary to help readers 

access these topics in the four chapters. 

Purpose and Need 

Invasive plants are currently damaging biological diversity and ecosystem integrity of lands 

within and outside the National Forests of the Pacific Northwest. Invasive plants create a host 

of adverse environmental effects, including: displacement of native plants; reduction in 

habitat and forage for wildlife and livestock; loss of threatened, endangered, and sensitive 

species; increased soil erosion and reduced water quality; reduced soil productivity; and 

changes in the intensity and frequency of fires. Invasive plants spread between Nation Forest 

system lands to neighboring areas, affecting all land ownerships. 

An estimated 420,000 acres of National Forest System lands in the Region are currently 

infested with invasive plants (Chapter 3.1)

2

. Invasive plants continue to increase and occupy 

previously uninfested areas. Collectively, the current National Forest System land and 

Resource Management Plans (Forest Plans) in the Region do not provide adequate 

management direction and tools to effectively address this problem. Current direction, based 

on a Region Six-wide 1988 Record of Decision and 1989 Mediated Agreement related to 

unwanted vegetation, limits the treatment tools allowed on the National Forests within the 

Region. 

 

1 In this FEIS, invasive plants are defined as “non-native plant whose introduction does or is likely to cause 

economic or environmental harm or harm to human health” [Executive Order 13122]. 

2 This total does not include invasive plants floating or submerged in water. Floating or submerged invasive 

plants are not included in this action (Chapter 1.5). 

Summary-1
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

There exists an underlying need on National Forests for: (1) Forest Plan direction that will 

reduce the extent and rate of spread of invasive plants and help prevent new infestations; (2) 

Release from the Forest Plan direction established by the 1988 Record of Decision (ROD) and 

1989 Mediated Agreement so that new practices, technologies, and formulations of herbicides 

are available for use in invasive plant management3

; (3) An, updated list of herbicides 

available for use by the Forests (Chapter 1.2). 

Not meeting this underlying need would mean the adverse effects from invasive plants would 

continue to increase on National Forests and Grasslands within the Region, compromising our 

ability to manage for healthy native ecosystems. Invasive plants would continue to spread to 

neighboring lands, creating adverse effects on and off National Forest System land. (See 

Figure S-1) 

The Proposed Action 

The Proposed Action amends all Forest Plans within Region Six4 to improve and increase 

consistency of invasive plant prevention, and allows the use of an expanded set of invasive 

plant treatment tools. The Proposed Action also includes restoration requirements and an 

inventory and monitoring plan framework. 

Key features of the Proposed Action include: 

• Expanded invasive plant prevention that focuses on reducing ground disturbances and 

limiting the introduction and spread of invasive plants; 

• Increased emphasis on early detection and treatment of new invasive plant sites; 

• An expanded and modernized invasive plant treatment toolbox; 

• Increase emphasis on protecting and restoring healthy native plant communities; 

• A monitoring plan framework that provides a consistent blueprint for more detailed 

future monitoring plans; 

• Long-term site goals that provide the mechanism to link treatment to prevention, 

revegetation/restoration and monitoring in an integrated and adaptive process; 

 

3 Parts of the 1988 ROD and 1989 Mediated Agreement that apply to unwanted vegetation that are not 

considered invasive plants are not affected by this FEIS. 

4 Region Six is 24.9 million acres of National Forest system land in Oregon, Washington, and small portions of 

Western Idaho (Hell’s Canyon) and Northern California. 

Summary-2
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

The selected alternative would amend all Forest Plans in Region Six and provide management 

direction for projects, but it would not approve any site-specific projects. Site-specific 

treatment decisions would be based on location, biology and size of the target invasive plant 

species, site conditions, and integrated resource objectives. Invasive plant treatment projects 

would be subject to future NEPA analysis before being implemented. 

Decision to be Made 

The Region Six Regional Forester is the responsible official for this EIS. The Regional 

Forester will decide whether to implement the Proposed Action, another action alternative, or 

to implement no change at all (No Action). Factors influencing the decision on selection of 

an alternative include: (1) how well the alternative meets the underlying need for action, (2) 

the potential effects to human health and the environment, (3) the effects on existing 

uses/management activities on the National Forest System land, and (4) the associated costs 

(Chapter 1.3). 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

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Summary-6
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Public Involvement and Issues 

Members of the public have provided the Forest Service extensive help with this EIS. 

Scoping outreach was conducted to elicit participation from the general public, interest 

groups, government agencies, and Forest Service employees. Methods used to solicit 

comment included: Notice of Intent filed in the Federal Register (August 28, 2002); a project 

website; a direct mailing to approximately 3,000 interested members of the public, 

organizations, governments, and tribes. Public meetings were held in Oregon and 

Washington. Outreach yielded 275 letters of comment and a compendium of input from the 

public meetings. The letters were reviewed and significant issues were identified. Significant 

issues include both key issues that are sensitive to the differences in alternatives, and other 

issues that have effects that do not vary between alternatives. The key issues were used to 

help formulate the alternatives. 

DEIS Comment Period 

The DEIS was circulated for public review and comment in August 2004. The Forest Service 

received approximately 300 pieces of correspondence during the comment period. The Forest 

Service responded to the comments in a variety of ways: modifying alternatives (changing 

language in the DFC, goals, objectives or standards), supplementing the analysis, or making 

correction to the analysis. A detailed summary of all public comments to the DEIS is 

provided in Appendix A. 

Key Issues 

Issue 1: Strategies to prevent and control invasive plants can vary in 

effectiveness. 

The alternatives vary in their potential to prevent or reduce the spread of invasive plants. 

Each action alternative adds a unique set of invasive plant management standards to Forest 

Plans in Region Six. 

Chapter 4.2 focuses on characteristics of the standards and how they influence the 

introduction, establishment and spread of invasive plants. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Issue 2: Invasive plant treatments may harm non-target plants and native 

plant communities. 

Invasive plant treatments, especially herbicides, may harm non-target plants, including 

culturally significant, and threatened, endangered and sensitive species. Certain herbicides 

and the methods by which they are applied could also harm plant pollinators. 

Chapter 4.3 focuses on the potential for herbicides to harm non-target plants and plant 

pollinators. 

Issue 3: Application of certain herbicides may harm some vegetation-eating 

or insect-eating birds and mammals and/or amphibians. 

The use of herbicides to treat invasive plants may harm free-ranging wildlife, vegetationeating or insect-eating birds, mammals, and/or amphibians. 

Chapter 4.4 focuses on the risks to wildlife associated with the use of herbicides. 

Issue 4: Invasive plant treatments may result in risks to human health,

including contamination of drinking water. 

The health and safety of forestry workers and the public may be at risk from exposure to 

herbicides. The public expressed particular concern about human health effects related to 

herbicide and fertilizer treatments in municipal watersheds, small watersheds with individual 

drinking water systems, or other areas where forest visitors may consume forest water. 

Chapter 4.5 focuses on the health and safety of forestry workers and the public. 

Issue 5: Cost of treatments and effects on land uses. 

The prevention and management of invasive plants can be costly and fiscal resources are 

always limited. Increased operating costs due to expanded invasive plant management may 

result in direct or indirect transfer of costs to users of National Forest System lands. Also, 

invasive plant management may compete with other important land management needs, 

resulting in opportunity-cost tradeoffs. 

Chapter 4.6 focuses on the cost of invasive plant management, both in terms of monetary 

costs and the opportunity cost tradeoffs. 

The No Action Alternative 

The No Action alternative represents no change from the current direction as established by 

the 1988 EIS and 1988 ROD for Managing Competing and Unwanted Vegetation and an 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

accompanying 1989 Mediated Agreement, the individual Forest Plans for the nineteen 

National Forests in Region Six, the FSM, and letters of Regional policy (Chapter 2.3). 

The Other Action Alternatives 

In addition to the Proposed Action, two other “action alternatives” (Alternatives B and D) 

were developed to meet the underlying need for action and address the identified issues. All 

three action alternatives would amend Forest Plans within the Region by approving four kinds 

of invasive plant management direction (DFC, goals, objectives, and standards), along with an 

inventory and monitoring framework. 

Alternative B 

Alternative B builds on the Proposed Action by increasing the emphasis on preventing 

invasive plants, and reducing the conditions that contribute to the introduction, establishment 

and spread of invasive plants, while taking a “precautionary” approach to treatment methods. 

Alternative B further restricts land management practices, such as road building and road 

maintenance. Under Alternative B, the use of herbicides for treatment of invasive plants is a 

“tool of last resort5.” 

Alternative D 

Alternative D is similar to the Proposed Action, but it is designed to maintain greater planning 

and operational flexibility at the Forest/Ranger District level. It is the least prescriptive of the 

action alternatives. Greater flexibility is intended to reduce the treatment costs and impacts 

on land uses and user groups. In addition, Alternative D includes the use of two, less 

expensive and potentially more risky herbicides (2,4-D and Dicamba). 

 

5 “Tool of last resort” means that tool will be used only if all other methods for managing invasive plants are 

ineffective or too expensive. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Table S-1 Key Features of the Alternatives Considered in Detail. 

Key 

Feature No Action Proposed Action Alternative B Alternative D 

Overall 

Approach 

Adaptive 

management, 

focusing on 

prevention, early 

detection, early 

treatment of 

invasive plants. 

Adaptive 

management, with 

increased emphasis on 

prevention, updated 

treatment tools, 

restoration and longterm site management 

goals. 

Similar to the 

Proposed Action, 

increases the 

emphasis on 

reducing the 

conditions that 

contribute to 

invasive plants. 

Similar to the 

Proposed Action, 

with a less 

“prescriptive” 

approach to 

prevention and more 

flexibility in the use 

of herbicides. 

Inventory 

Emphasizes early 

detection. 

Emphasizes early 

detection and requires 

inventories be 

consistent with 

nationally accepted 

data structures. 

Same as the 

Proposed Action. 

Same as the 

Proposed Action. 

Prevention 

Direction for 

prevention is 

provided primarily 

by the 1988 

EIS/ROD and the 

1989 Mediated 

Agreement 

Requires the use of a 

suite of invasive plant 

prevention standards. 

Similar to the 

Proposed Action 

with additional, 

more prescriptive 

prevention 

standards. 

Similar to the 

Proposed Action, 

with fewer and less 

prescriptive 

prevention 

standards. 

Treatment 

Treatment 

methods, including 

five herbicides. 

2,4-D is a tool of 

“last resort”. 

Treatment methods 

include ten 

herbicides, but not 

2,4-D. 

Emphasis is on 

non-chemical 

methods. 

Includes four 

herbicides and 

they are 

considered “tools 

of last resort”. 

Treatment methods 

include twelve 

herbicides, 

including 2,4-D. 

Restoration 

Favors the use of 

native plants and 

allows the use of 

non-native plants 

in certain 

situations. 

Favors the use of 

native plants for 

restoration, allows use 

of non-invasive nonnative plants in 

certain situations. 

Requires use of 

native species for 

restoration, except 

as an intermediate 

step toward native 

restoration. 

Requires the use of 

plant species that do 

not invade or 

persist. 

Inventory and Monitoring 

In addition to the monitoring already required under various Forest Plans, an inventory and 

monitoring plan framework is part of all action alternatives. The framework will guide future 

development of detailed monitoring plans at the Forest or site-specific project level (Chapter 

2.4 and Appendix M). 

Summary-10
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Effects of the Alternatives 

The effects of the No Action, the Proposed Action, Alternative B, and Alternative D are 

disclosed in Chapter 4 and compared in Chapter 2.6. 

No Action 

Under No Action, invasive plant prevention would remain inconsistently applied across the 

Region and the herbicides available to land managers would remain limited. Under this 

alternative the underlying need for action would not be met. Continued invasive plant spread 

would compromise land managers’ ability to manage the Forests for healthy native 

ecosystems and limit the ability of the Forest Service to reach the high priority goal of 

controlling invasive plants. 

No Action would also mean that National Forest System land would be a source of invasive 

plants spreading to neighboring lands. 

Action Alternatives 

All of the action alternatives are expected to decrease the rate of spread for invasive plants as 

compared to No Action. The Proposed Action and Alternative B are predicted to reduce the 

rate of spread most effectively. Alternative B is the most restrictive of current land 

management and land use activities. Alternative D has the highest treatment effectiveness, 

with the greatest reliance in the use of herbicides. Alternative B is least effective in treatment, 

as it emphasizes the use of non-herbicide treatment methods over herbicides, and considers 

herbicides “tools of last resort”. 

All action alternatives would comply with environmental standards to protect soils and water, 

native plant communities, fish and wildlife and human health. There is a higher degree of risk 

and uncertainty associated with the use of herbicides under Alternative D. 

All action alternatives have the potential to increase costs and/or reduce program 

accomplishments due to consistent application of prevention standards. 

Table S-2 provides a summary/comparison of the effects of implementing each alternative 

found in Chapter 4. 

Despite careful design of the management direction for the action alternatives, a risk of 

adverse effects remains (Chapter 4.8.1). Some potential effects cannot be fully mitigated. An 

accidental herbicide spill, for instance, may kill non-target species even though a spill plan is 

in place. Mitigation measures will be applied at the project scale to avoid these effects to the 

Summary-11
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

extent possible. No additional mitigation would be reasonable to apply at this programmatic 

scale. 

The Forest Service Preferred Alternative is the Proposed Action 

Summary-12
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Table S-2 compares the key features of the four alternatives considered in detail in Chapter 2 of this FEIS. 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

How Well the Alternative Meets the Underlying Need for Action Reduce the Extent and Rate of Invasive Plant Spread 

Does not include new prevention standards. 

Control may never be reached. 

Moderate to high potential for reducing rate of spread from 

adherence to new prevention standards. Control may be reached within 32 years assuming effective annual treatment of 30,000 acres and spread reduced by half. 

Highest potential for reducing rate of spread from adherence to new 

prevention standards. Control may be reached within 47 years if 20,000 acres are effectively treated annually and spread is reduced to 4 percent. 

Mra

nem40anpe

Release from Forest Plan Direction so that new practices/ technologies/ and herbicides are available; provides an updated list of herbicides 

Maintains current Forest Plan management direction, 

no new tools available. 

High potential to result in effective treatments because it provides for a 

suite of tools (including herbicides) that are adequate to effectively treat all known infestations. 

Alternative B lacks sufficient variety of tools for adapting to different 

environmental circumstances. For 

example, Alternative B provides only one tool, sethoxydim, for invasive grass control. Success using sethoxydim on different grasses varies from good when treating reed canarygrass to no effectiveness on quackgrass (Tu et al, 2001). Alternative B may not be effective in remote, difficult to access terrain due to restrictions on aerial spray. Herbicide resistance may increase under Alternative B because there are fewer herbicide choices. 

Sad

AfaPadD re

Potential Effects to Human Health and The Environment 

Summary-13
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Potential to harm non-target plants 

Herbicide use on an estimated 13,000 acres 

annually includes four herbicides with potential to harm nontarget plants: picloram, glyphosate, triclopyr, dicamba 

Herbicide use on an estimated 8,500 acres annually includes three 

herbicides that have potential to harm non-target plants: picloram, glyphosate, imazapyr. Less risk to non-target plants than No Action, more than Alternative B. Implementing Standard #16 would mitigate potential effects of chlorsulfuron, metsulfuron methyl, sulfometuron methyl, and triclopyr. 

Herbicide use on an estimated 2,000 acres annually includes one 

herbicides with greater potential to harm non-target plants: glyphosate Least risk to non-target plants. Implementing Standard #16 would mitigate potential effect of triclopyr. 

H15

hehchsuglM

Number of herbicides included in each alternative that have known potential to cause toxic effects to honey bees 

Current herbicide list includes three herbicides with 

potential to harm pollinators (honeybees): 2,4-D, glyphosate and triclopyr. 

Herbicide list includes two herbicides with potential to harm pollinators 

(honeybees): glyphosate and triclopyr. Less risk to pollinators than No Action, more than Alternative B 

Herbicide list includes one herbicide with potential to harm pollinators 

(honeybees): glyphosate. Least risk to pollinators 

S

Effects on birds and mammals Please note that the number of exposure scenarios is not influenced by the estimated acres treated annually.

There are 25 plausible scenarios where 

herbicide exposure could harm individual animals. Use of herbicides associated with these harmful exposure scenarios occurs on approximately 13,646 acres annually 

There are 21 plausible scenarios where herbicide exposure could harm 

individual animals. Reduced risk to birds and mammals as compared to No Action. Use of herbicides associated with these scenarios is predicted to occur on about 9,000 acres annually 

There are 12 plausible scenarios where herbicide exposure could harm 

individual animals. Reduced risk to birds and mammals as compared to Proposed Action. Use of herbicides associated with these scenarios is predicted to occur on about 2,500 acres annually. 

Tw

haInmAUthocan

Summary-14
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Number of herbicides included that may harm amphibians 

Three herbicides approved for use 

currently are known to potentially harm amphibians. 

Reduces herbicides from 3 to 1 known to potentially harm 

amphibians. 

Reduces herbicides from 3 to 1 known to potentially harm 

amphibians 

S

Worker exposure to manual treatment hazards 

Approximately 36,500 worker days of 

exposure annually from manual treatments. 

Approximately 30,500 worker days of exposure annually from manual 

treatments. Reduces potential for exposure as compared to No Action. 

Approximately 45,000 worker days of exposure annually from manual 

treatments. Increases potential for exposure as compared to No Action. 

Aof 

trexA

Worker exposure to harmful doses of herbicide and/or NPE 

No plausible scenarios for harm to workers 

applying herbicides at typical application rates. Current Herbicide use is associated with an estimated 13 plausible scenarios that could harm workers at maximum label rates. These scenarios are associated with herbicide use that occurs annually on about 12,281 acres. 

No plausible scenarios for harm to workers applying any approved 

herbicides at typical application rates. Projected herbicide use is associated with an estimated 11 plausible scenarios that could harm workers at maximum label rates (less than No Action). These scenarios are associated with herbicide use that is projected to occur annually on about 4,960 acres under this alternative. 

No plausible scenarios for harm to workers applying any approved 

herbicides at typical application rates. Projected herbicide use is associated with an estimated 7 plausible scenarios that could harm workers at maximum label rates (less than Proposed Action and No Action). These scenarios are associated with herbicide use projected to occur annually on about 508 acres under this alternative. 

Ow

apPasplw(mscheanun

Summary-15
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Public Exposure to Harmful Doses of Herbicides and/or NPE (other than through drinking water contamination) 

No plausible scenarios for harm to the public 

from herbicides applied at typical application rates. Current herbicide use is associated with an estimated 9 plausible scenarios that could harm people when applied at maximum label rates. These scenarios are associated with herbicide use that occurs annually on about 591 acres. 

No plausible scenarios for harm to the public from herbicides applied at 

typical application rates. Herbicides allowed are associated with an estimated 4 plausible scenarios that could harm people when applied at maximum label rates (less than No Action). These scenarios are associated with herbicide use that is projected to occur on about 1,000 acres each year. 

No plausible scenarios for harm to the public from herbicides applied at 

typical application rates. Herbicides allowed are associated with an estimated 4 plausible scenarios that could harm people when applied at maximum label rates (same as Proposed Action). These scenarios are associated with herbicide use that is projected to occur on about 500 acres each year. 

Tto 

tyIn hewscwraTheanun

Potential for Drinking Water Contamination 

No scenarios known for herbicide to reach 

harmful concentrations in drinking water from drift. 

No scenarios known for herbicide to reach harmful concentrations in 

drinking water from drift. 

No scenarios known for herbicide to reach harmful concentrations in 

drinking water from drift. 

O

hecofrhab

Potential for drinking water contaminated by tanker spill into pond 

A tanker spill into a pond could reach 

harmful concentration; four plausible scenarios. 

A tanker spill into a pond could reach harmful concentration; seven 

plausible scenarios, more than No Action. 

A tanker spill into a pond could reach harmful concentration; three 

plausible scenarios. 

A re

plal

Effects on Existing uses/management activities on National Forest Estimated percentage increase in cost of heavy equipment work 

No increase. 2% increase in cost of heavy 

equipment work from adoption of 

prevention standards. 

11% increase in cost of heavy equipment work from adoption of 

prevention standards. 

S

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Table S-2 Alternative Comparison/Decision Factors 

Factor for 

Comparison 

Current Direction/ 

No Action Proposed Action Alternative B 

Tendency for standards to result in road closures and loss of off-highway vehicle access 

No Direct Effect. New restrictions on OHV* 

use may occur from new national policy. 

No new road closures expected from 

invasive plant prevention standards. OHV use allowed only on specifically designated roads, trails, and areas, based on implementation of draft National Policy. 

Tendency for more roads to be closed or decommissioned due to wording 

of standards. OHV use allowed only on specifically designated roads, trails, and areas, based on implementation of draft National Policy. 

Non 

NA

Tendency for standards to affect grazing locations, timing, intensity and outputs 

Reduces grazing levels, due to rangeland 

grazing capacities being diminished by invasive plants. 

Reduces grazing levels, due to more consistent applications of prevention 

measures. 

Highest tendency to reduce grazing levels, due to more rigid and 

consistent applications of prevention measures. 

S

Acres of National Forest where weed free feed would be required 

2.5 million 4.6 million (Wilderness Areas only) 

Increases costs of obtaining feed for pack stock, increases recreation 

administration costs accordingly. 

24.9 million (all National Forests in the Region) 

Increases costs of obtaining feed for pack stock, increases recreation administration costs more than the Proposed Action. 

2

Associated Costs Average Cost of Treatment 

Approximately 25,000 acres per year can be treated given the 

current $4.1 million annual budget. 

Reduces average costs of treatment compared to No Action, so 5,000 

more acres can be effectively treated each year. 

Increases average cost of treatment compared to No Action, so 5,000 

fewer acres can be effectively treated each year. 

Rco

mtr

* Off-Highway Vehicle Recreation – In this document, the term off-highway vehicle (OHV) refers to vehicles used for off-highway pu

wheelers, motorcycles, dune buggies, 4x4 vehicles, and other motorized vehicles. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

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Summary-18
Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

CHAPTER 1 PURPOSE AND NEED FOR ACTION

 

1.1 Introduction 

The Regional Forester proposes to amend all Forest Plans within Region Six6 to improve the 

ability of the National Forests to prevent and manage invasive plants7

. Updated and more 

comprehensive direction would replace existing direction for the prevention and management 

of invasive plants. 

Invasive plants are currently damaging biological diversity and ecosystem integrity of lands 

within and outside the National Forest system in the Pacific Northwest. Invasive plants create 

a host of adverse environmental effects, including: displacement of native plants; reduction in 

habitat and forage for wildlife and livestock; loss of threatened, endangered, and sensitive 

species; increased soil erosion and reduced water quality; and reduced soil productivity. 

Invasive plants spread between National Forest system lands to neighboring areas, affecting 

all land ownerships. 

The economic impact of invasive plants is substantial. A study conducted for the Oregon 

Department of Agriculture estimated that invasive plants are costing Oregon citizens about 

$100 million per year (2000). 

An estimated 420,000 acres of National Forest System lands in the Region are currently 

infested with invasive plants8. Despite current management efforts, invasive plants continue 

to increase and occupy previously uninfested areas, such as Wilderness areas, Research 

Natural Areas, and Hell’s Canyon National Recreation Area. 

The Pacific Northwest and National Forest System land in particular, have not yet been 

invaded to the degree that other Western States (Montana, Idaho) have been affected. If we 

act now, and act effectively, we can still protect our unique and valuable uninfested native 

plant communities. 

The Proposed Action was developed to address the growing threat posed by invasive plants. 

The Regional Forester proposes to amend all Forest Plans within Region Six to give National 

6Region Six is 24.9 million acres of National Forest system land in Oregon, Washington, and small portions of 

Western Idaho (Hell’s Canyon) and Northern California. 

7 Invasive Plants are defined here as a “non-native plant whose introduction does or is likely to cause economic 

or environmental harm or harm to human health” [Executive Order 13122]. 

8 Invasive plant surveys on National Forests in Region Six are not yet complete, and existing inventories vary 

from one National Forest to another. The estimate of 420,000 acres of invasive plants are based on the best 

information available from the 19 National Forests in the Region Six. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Forests the tools and the flexibility they need to better manage invasive plants. The Proposed 

Action (along with other alternatives considered) is presented in detail in Chapter 2. 

1.2 Need for Action 

Invasive plants are spreading at an estimated rate of 4,600 acres per day on all federal lands in 

the West, outside of Alaska (Asher, 2001). This equates to adding approximately 1.7 million 

acres (an area the size of the Willamette National Forest), of new invasive plants every year. 

The spread of invasive plants within Region Six approximates this broader regional trend, 

particularly on National Forest System lands east of the Cascade crest (ICBEMP, 2000). 

Currently, 107 different species of invasive plants have been identified on National Forest 

System land in Region Six (Appendix B). Undoubtedly, this number will increase as other 

new invaders arrive and are discovered. 

Collectively, these invasive plant species disrupt natural ecosystems, and increase the 

potential loss of native plant communities, wildlife, and ecosystem functions. Invasive plants 

can have adverse effects on rare or endemic species, which could result in listing under state 

or federal endangered species laws. Invasive plants threaten all land ownerships (private, 

corporate, tribal, and government), they have the potential to spread from one piece of 

property to the next. 

Current direction for the prevention and management of invasive plants on National Forests in 

Region Six comes to a large degree, but not exclusively, from the 1988 Environmental Impact 

Statement (EIS) and 1988 Record of Decision (ROD) for Competing and Unwanted 

Vegetation, and the associated 1989 Mediated Agreement9. These documents require 

consideration of invasive plant prevention, but specific direction on how to actually prevent 

the spread of invasive plants is not provided.10 The 1988 ROD specified and limited the tools 

available for the treatment of competing and unwanted vegetation, but did not provide 

administrative mechanisms for adapting their requirements and adopting new technologies. 

For example, herbicides approved for use by the Forest Service in the 1988 ROD were 

developed before 1980. Since that time new herbicides have been developed and registered 

for use. The new herbicides have advantages for invasive plant control, such as greater 

selectivity, less harm to desired vegetation, reduced application rates, and lower toxicity to 

animals and people. 

 

9 These documents have been incorporated into the Forest Plans within the Region. 

10 A few National Forests, most notably the Mt. Baker-Snoqualmie, have moved forward in recent years to 

amend their Forest Plan to include specific direction for the prevention of invasive plants; most Forests have not. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Collectively, the Forest Plans, as they are currently written, do not provide sufficient 

direction, nor adequate tools for effectively responding to the invasive plant threat. 

This EIS responds to an underlying need that currently exist on all National Forest System 

land in Region Six for: 

1. Forest Plan direction that will reduce the extent and rate of spread of invasive plants 

and help prevent new infestations. 

2. Release from Forest Plan direction established by the 1988 ROD and 1989 Mediated 

Agreement so that new practices, technologies, and chemical formulations of 

herbicides are available for use. 

3. An updated list of herbicides available for use by the Forests. 

The purpose of the new management direction is to facilitate subsequent actions to eliminate 

or control invasive plants so that: (1) the Desired Future Condition (DFC) of National Forest 

System lands can be attained 11; (2) federal land managers’ ability to provide goods and 

services from the National Forest System lands is maintained; and (3) the Forest Service’s 

ability to cooperate with similar efforts across other ownerships is improved. 

Not meeting this underlying need would mean the adverse effects from invasive plants would 

continue to increase on National Forests and Grasslands within the Region, compromising our 

ability to manage for healthy native ecosystems. Invasive plants would continue to spread to 

neighboring lands, creating adverse effects on and off National Forest System land. (See 

Figure S-1) 

1.3 Decision to be Made 

The Regional Forester is the Responsible Official for this EIS. The analyses and findings 

described in this EIS will help her make a reasoned decision, whether to: 

1. Select No Action and continue with current invasive plant management direction, or 

2. Meet the underlying need for action by adopting an action alternative (Proposed 

Action, Alternatives B or D), or 

3. Select a modified action that meets the underlying need. 

Factors influencing the Regional Forester’s decision on selection of an alternative include: (1) 

how well the alternative meets the underlying need for action, (2) the potential effects to 

 

11 Refer to Chapter 2.4 for more information on Desired Future Condition 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

human health and the environment, (3) the effects on existing uses/management activities on 

the National Forest System land, and (4) the associated costs. 

The Record of Decision for this Environmental Impact Statement would add new Forest Plan 

direction relating to invasive plants, and delete existing Forest Plan direction for invasive 

plants incorporated from the 1988 EIS, 1988 ROD, and the 1989 Mediated Agreement. 

Portions of the 1988 ROD and Mediated Agreement that involve management of other 

unwanted native vegetation would remain in place. The Record of Decision will address 

transition between existing management direction and any new direction selected. 

Management direction provided by the selected alternative would apply to future projects and 

activities. The selected alternative will not by itself change any permitted or authorized 

activity on National Forest System land. Project-level analysis (NEPA) will still be required. 

The final decision for this EIS will influence the design and development of these projects. 

The selected alternative will not be retained as a Regional-scale decision; rather it will 

become part of the individual Forest Plans. Over time, decision makers for individual 

National Forests may modify the decisions that result from this EIS in accordance with 

planning laws, policies and regulations. 

1.4 Project Location 

The Forest Service proposes to modify management direction for all National Forest System 

lands administered by Region Six, which includes the following nineteen National Forests: 

Colville, Gifford Pinchot, Mt. Baker-Snoqualmie, Okanogan, Olympic, and Wenatchee 

National Forests in Washington, and the Deschutes, Fremont, Malheur, Mt. Hood, Ochoco 

(which encompasses the Crooked River National Grassland), Rogue River, Siskiyou, Siuslaw, 

Umatilla, Umpqua, Wallowa-Whitman, Willamette, and Winema National Forests in Oregon 

(see Figure 1-1). The Columbia River Gorge National Scenic Area is also included, as are 

portions of the Payette and Nez Perce National Forests (Hell’s Canyon National Recreation 

Area) in Idaho, managed by the Wallowa-Whitman National Forest, and portions of the 

Rogue River and Siskiyou National Forests that extend into California. 

The National Forest System lands administered by Region Six, total about 24.9 million acres, 

and include approximately 15.5 million acres in Oregon, 9.2 million acres in Washington, 

142,000 acres in Idaho, and 87,000 acres in California. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

1.5 What is Not Included 

This action does not include invasive plants floating on or submerged in water. Floating and 

submerged invasive plants (aquatic invasives) are currently being addressed through other 

federal actions in cooperation with the states. Nor does it include experimental trials of 

herbicides conducted by the U.S. Environmental Protection Agency (EPA) to test new 

products. 

The action would revise only that portion of existing management direction that addresses 

prevention and treatment of invasive plants, along with associated restoration activities 

associated with the removal of invasive plants. It will not alter current management direction 

for competing and unwanted vegetation other than invasive plants, or other restoration not 

associated with invasive plant treatment. 

Under the Wyden Amendment, Section 323 of the Fiscal Year 1999 Department of the 

Interior and Related Agencies Appropriations Act, and the Secure Rural Schools and 

Community Self-determination Act of 2000, federal funding can be authorized for treatment 

of invasive plants on non-federal lands. The Forest Plan amendments proposed in this 

document apply only to the identified National Forest System land. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

1.6 Public Participation, Scoping and Issues 

Ongoing public involvement occurred throughout the NEPA process. Initial scoping included 

the Notice of Intent filed in the Federal Register (August 28, 2002); a project website; a direct 

mailing to approximately 3,000 interested members of the public, and organizations, 

governments, and tribes. Public meetings were held in Oregon and Washington. 

Public issues12 were identified based on the scoping input. Where possible, the Proposed 

Action was refined to resolve issues. Some issues could not be resolved without substantial 

change to the Proposed Action. Alternatives were developed to address these key issues. The 

five key issues identified for this analysis are: 

Issue 1: Strategies to prevent and control invasive plants can vary in effectiveness. 

Issue 2: Invasive plant treatments may harm non-target plant species. 

Issue 3: Application of certain herbicides may harm some vegetation-eating or insecteating birds and mammals and/or amphibians. 

Issue 4: Invasive plant treatments may result in risks to human health, including 

contamination of drinking water. 

Issue 5: Cost of treatments and effects on land uses. 

Some issues raised by the public are inherent to invasive plant management and do not vary 

between alternatives. These “other issues” are: 

• Effects on Soil Productivity 

• Effects on Aquatic Organisms 

• Effects on Federally Listed and Forest Service Sensitive Species 

• Effects on Tribal /Treaty Rights and Environmental Justice 

Chapter 4 presents detailed analysis related to these issues. 

 

12 Issues are points of discussion, debate, or dispute about the environmental effects of an action. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

1.6.1 Key Issues 

Key Issue 1: Strategies to prevent and control invasive plants can vary in 

effectiveness. 

The alternatives vary in their potential to prevent or reduce the spread of invasive plants. A 

combination of prevention, treatment and restoration activities is needed to deter the 

introduction, establishment and spread of invasives. Each action alternative adds a unique set 

of invasive weed management standards to Forest Plans in Region Six. The analysis in 

Chapter 4 focuses on characteristics of the standards and how they influence the introduction, 

establishment and spread of invasive plants. 

The standards vary by degree of emphasis on prevention, treatment, and/or restoration. An 

emphasis on prevention effectiveness will result in reduced introduction and spread rates of 

invasive plants. An emphasis on treatment effectiveness will result in reductions in current 

infestations. The social acceptability of the treatment methods also factors into the 

effectiveness of the alternatives. 

The ability of the Forest Service to meet the purpose and need for action, achieve desired 

future conditions, and contribute to cooperative efforts throughout Oregon and Washington 

are directly correlated to the effectiveness of invasive plant prevention and control strategies. 

Factors for Comparison of Alternatives 

• Estimated annual rate of invasive plant spread 

• Estimated acreage of invasive plants treated annually based on mix of treatments 

approved 

• Number of years until invasive plants are controlled 

Key Issue 2: Invasive plant treatments may harm non-target plants and 

native plant communities. 

Invasive plant treatments, especially herbicides, may harm non-target plants, including 

culturally significant, and threatened, endangered and sensitive species. Different herbicides 

have varying degrees of potency and selectivity (e.g. some herbicides affect certain plant 

families more readily than others), and application methods vary in the potential for off-site 

drift. Shifts in species composition and diversity in native plant communities could occur as 

less herbicide tolerant species are replaced by more tolerant species. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Certain herbicides and the methods by which they are applied could also harm plant 

pollinators. If reduction or shift in pollinators occurs, changes to species composition or 

diversity could follow. 

Factors for Comparison of Alternatives 

• Number of herbicides included in each alternative that have a relatively higher 

potential to harm non-target plants 

• Number of herbicides included in each alternative that have known potential to cause 

toxic effects to honey bees 

• Acres of annual herbicide treatment with those herbicides that have a relatively higher 

potential to harm non-target plants 

Key Issue 3: Application of certain herbicides may harm some vegetationeating or insect-eating birds and mammals and/or amphibians. 

The use of herbicides to treat invasive plants may harm free-ranging wildlife. Certain 

herbicides have the potential, for example, to affect the vital organs of some wildlife species, 

change body weight, reduce the number of healthy offspring, increase susceptibility to 

predation, or cause direct mortality. Birds and mammals may ingest vegetation or insects that 

have been sprayed with some herbicides and potentially experience these types of effects. 

There is also concern that herbicides may cause some malformations or mortality to 

amphibians, which are exposed in the event herbicides enter water. 

Factors for Comparison of Alternatives 

• The number of plausible exposure scenarios in each alternative that could result in 

harmful doses to birds and mammals 

• Acres of annual herbicide treatment for each alternative where a plausible scenario 

could occur 

• Number of herbicides approved that may harm amphibians 

Key Issue 4: Invasive plant treatments may result in risks to human health, 

including contamination of drinking water. 

The health and safety of forestry workers and the public may be at risk from exposure to 

herbicides, working on uneven/broken terrain, use of hand tools, inhalation of smoke, driving 

vehicles, exposure to fire, exposure to falling/rolling debris, and the other accidents. The 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

public expressed particular concern about human health effects related to herbicide and 

fertilizer treatments in municipal watersheds, small watersheds with individual drinking water 

systems, or other areas where forest visitors may consume forest water. 

Factors for Comparison of Alternatives 

• Number of worker days of exposure to manual treatment hazards 

• Number of herbicide and NPE13 worker scenarios exceeding reference dose (RfD)14

• Total acreage where worker scenarios exceeding RfD may occur 

• Number of herbicide and NPE public scenarios exceeding RfD (other than drinking 

water contamination) 

• Total acreage where these public exposure scenarios exceeding RfD may occur 

• Number of herbicide and NPE public scenarios exceed RfD for drinking water 

contaminated by herbicide spray drift 

• Total acreage where risk of public drinking water contaminated by herbicide spray 

drift exceeds RfD 

• Number of herbicide and NPE public scenarios exceed RfD for drinking water 

contaminated by tanker spill into pond 

Key Issue 5: Cost of treatment and effects on land uses. 

The prevention and management of invasive plants can be costly and fiscal resources are 

always limited. Increased operating costs due to expanded invasive plant management may 

result in direct or indirect transfer of costs to users of National Forest lands. Also, invasive 

plant management may compete with other important land management needs, resulting in 

opportunity-cost tradeoffs. 

Prevention standards may have significant costs and potential to affect programs and users. 

Costs of conducting land management activities may be increased, potentially resulting in 

direct or indirect transfers to users of National Forest lands. Public access may be restricted 

from closing or decommissioning roads or off-road vehicle use areas. Adjustments to range 

 

13 The primary active ingredient in many of the non-ionic surfactants used by the Forest Service when applying 

herbicides is a component known as nonphenol polyethulate (NPE). 

14 A numerical estimate of a daily exposure to the human population, including sensitive subgroups such as 

children, that is not likely to cause harmful effects during a lifetime. RfDs are generally used for health effects 

that are thought to have a threshold or minimum dose for producing effects. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

management such as grazing locations, intensity, timing, or outputs may occur. Recreation 

users may be required to supply weed free feed on some or all National Forest lands, which 

may increase the cost of using pack stock or restrict recreationists’ ability to enter certain 

federal lands. 

Factors for Comparison of Alternatives 

• Annual acres of treatment for each alternative as an indicator of relative costs 

• Estimated percentage increase in cost of heavy equipment work 

• Tendency for standards to result in road closures and loss of off-highway vehicle 

access 

• Tendency for standards to affect grazing locations, intensity, timing, or outputs 

• Acres of National Forest where weed-free feed would be required 

1.6.2 Other Issues 

Soil Productivity 

Healthy soil microorganisms are fundamental to the ability of soil to provide water and 

nutrients to plants. All herbicides proposed under all alternatives affect soil microorganisms 

for a few days, as shown by growth inhibition or some other indirect measure. Picloram and 

sulfometuron methyl are particularly toxic to soil microorganisms and persistent in soil, and 

effects to soil microorganisms may persist beyond a few days. The analysis focuses on 

potential effects to soil microorganisms and productivity. This issue is adequately and equally 

addressed in all alternatives through Forest Service soil protection policies. 

Aquatic Organisms 

The application of herbicides in riparian areas has potential to contaminate water and cause 

mortality to fish and other aquatic species. Herbicides that do not directly affect fish may 

affect their food chain through lethal effects to aquatic plants or algae. Sub-lethal effects, 

such as behavior changes, could result in increased vulnerability to predators. The public also 

expressed concern about estrogenic effects to fish. The analysis focuses on potential adverse 

effects to aquatic organisms. This issue is adequately and equally addressed in all alternatives 

through Forest Service water quality protection policies. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

Threatened, Endangered and Sensitive Species 

Forest Service policy related to the National Forest Management Act and Endangered Species 

Acts require disclosure of effects to threatened, endangered and sensitive species. 

Consultation has been initiated with appropriate regulatory agencies. The analysis focuses on 

the findings of “effect” for threatened and endangered species and “impact” for sensitive 

species. This issue is adequately and equally addressed in all alternatives through Forest 

Service special status species policies. 

Tribal/Treaty Rights and Environmental Justice 

Some Pacific Northwest Indian tribes have reservation lands held in trust status by the 

Secretary of the Interior. Protecting and maintaining traditional uses of plants, animals, fish, 

and water rights on these lands and the treaty rights of American Indian Tribes is an important 

responsibility of the Federal Government. 

Within Region Six, many Native American tribes have treaty reserved or Executive Order 

rights outside the bounds of their respective Indian reservations. Additionally, there are tribes 

without specific off-reservation reserved rights who continue to gather natural resources for 

traditional or cultural purposes. These lands, often called “ceded lands” include much of the 

National Forest System lands in Washington and Oregon. Additionally, invasive plants may 

have negative impacts on other groups or individuals that hunt or gather non-timber forest 

products and forest users seeking floral communities that are within the historic range of 

variability. 

Executive Order 12898 (1994) requires federal agencies to identify and address adverse 

effects to human health and the environment that may disproportionately impact minority and 

low-income people. The Order also directs agencies to consider patterns of subsistence 

hunting and fishing when an agency action may affect fish and wildlife. These issues are 

adequately and equally addressed in all alternatives through Forest Service policies related to 

tribes and treaty rights and environmental justice. 

1.6.3 DEIS Comment Period 

The DEIS was circulated for public review and comment in August 200415. The Forest 

Service received approximately 300 pieces of correspondence during the comment period. 

Most of the correspondence originated in Oregon and Washington. The comments were 

 

15 The 90-day public review period began on August 22, 2004, and ended on November 24, 2004. 

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Preventing and Managing Invasive Plants Final Environmental Impact Statement April 2005 

considered individually and collectively. Comments extracts were categorized based on their 

subject matter. The Forest Service responded to the comments by: 

1. Modifying alternatives – The wording of standards was changed in response to 

comments. One new standard was added to all alternatives. 

2. Supplementing analysis – Several sections of the FEIS include supplemental analysis 

or clarifying discussions in response to comments. 

3. Corrections – Some comments resulted in corrections to the existing analysis. 

Appendix A provides a summary of all public comments to the DEIS. The analysis files 

contain a database linking these comments to the correspondence received. Lists of 

commenters and detailed demographic information are in the files. 

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