Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-47 

Comments and Responses to the DEIS by Topic with Summaries 

Appendix A 

R6 Invasive Plant EIS 

March 2005 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-48 

Table of Contents 

Introduction........................................................................................................................................................................51

Scope of the EIS.................................................................................................................................................................52

Purpose and Need...............................................................................................................................................................60

Desired Future Conditions, Goals and Objectives..............................................................................................................67

Information Availability.....................................................................................................................................................75

Invasive Plants and Mechanisms of Invasion .....................................................................................................................76

Standards (General)............................................................................................................................................................93

Standard 1: Address prevention of invasive plant introduction, establishment and spread in land management 

assessments/analyses..........................................................................................................................................................97

Standard 2: Equipment washing......................................................................................................................................100

Standard 3: Use weed-free straw and mulch ...................................................................................................................102

Standard 4: Use weed-free feed.......................................................................................................................................102

Standard 5: Maintain native vegetation and forest canopies around project areas...........................................................111

Standard 6: Manage grazing to reduce the spread of invasive plants ..............................................................................113

Standard 7: Inspect stockpiles and quarries.....................................................................................................................118

Standard 8: Schedule road blading ..................................................................................................................................119

Standard 9: Close roads...................................................................................................................................................120

Standard 10: OHV use.....................................................................................................................................................121

Standard 11: Establish treatment priorities......................................................................................................................124

Standard 12: Develop long-term strategy for restoring/revegetating treated infestations................................................125

Standard 13: Revegetate with native plants.....................................................................................................................126

Standard 14: Biological control........................................................................................................................................128

Standard 15: Licensed applicator requirement ................................................................................................................128

Standard 16: Herbicide formulations available................................................................................................................128

Standard 17: Reduce herbicide use over time...................................................................................................................136

Standard 18: The use of adjuvants...................................................................................................................................139

Standard 19: Reduce effects to water quality and aquatic biota ......................................................................................140

Standard 20: Reduce or eliminate impacts to proposed and listed species and their critical habitat................................142

Standard 21: Buffers........................................................................................................................................................142

Standard 22: Municipal watersheds.................................................................................................................................143

Herbicide Use...................................................................................................................................................................143

Public Notification of Herbicide Use ...............................................................................................................................160

Merits of the Alternatives.................................................................................................................................................161

Alternatives Considered But Eliminated from Detailed Study .........................................................................................172

Inventory, Monitoring and Adaptive Management ..........................................................................................................176

Implementation Funding ..................................................................................................................................................180

Cost of Treatment.............................................................................................................................................................181

Effectiveness Preventing and Reducing Invasive Plants ..................................................................................................184

Effects on Non-Target Species and Native Plant Communities .......................................................................................192

Effects on Worker Health and Safety ...............................................................................................................................197

Herbicide Risk Assessment and Human Health Effects ...................................................................................................199

Effects on Wildlife ...........................................................................................................................................................211

Effects on Land Uses........................................................................................................................................................218

Effects on Soils.................................................................................................................................................................221

Effects on Aquatic Organisms..........................................................................................................................................223

Effects on Species Listed under the Endangered Species Act ..........................................................................................231

Cumulative Effects...........................................................................................................................................................234

Partnership, Coordination and Public Education..............................................................................................................239

Tribal Concerns................................................................................................................................................................243

Glossary ...........................................................................................................................................................................246

Miscellaneous Other Comments.......................................................................................................................................247
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-49 

Table of Tables 

Table 1. Correspondence Received during DEIS comment period by Organizational Type..51 

Table 2. Comments and Responses about Scope of the EIS ...................................................52 

Table 3. Comments and Responses about Purpose and Need.................................................60 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives .....67 

Table 5. Comments and Responses about Information Availability.......................................75 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion.......77 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments..................86 

Table 8. Comments and Responses about Standards (General) ..............................................94 

Table 9. Comments and Responses about Standard 1.............................................................98 

Table 10. Comments and Responses about Standard 2.........................................................100 

Table 11. Comments and Responses about Standard 3.........................................................102 

Table 12. Comments and Responses about Standard 4.........................................................103 

Table 13. Comments and Responses about Standard 5.........................................................111 

Table 14. Comments and Responses about Standard 6.........................................................113 

Table 15. Comments and Responses about Standard 7.........................................................118 

Table 16. Comments and Responses about Standard 8.........................................................119 

Table 17. Comments and Responses about Standard 9.........................................................120 

Table 18. Comments and Responses about Standard 10.......................................................122 

Table 19. Comments and Responses about Standard 11.......................................................124 

Table 20. Comments and Responses about Standard 12.......................................................125 

Table 21. Comments and Responses about Standard 12.......................................................126 

Table 22. Comments and Responses about Standard 13.......................................................126 

Table 23. Comments and Responses about Standard 16.......................................................128 

Table 24. Comments and Responses about Standard 17.......................................................136 

Table 25. Comments and Responses about Standard 18.......................................................139 

Table 26. Comments and Responses about Standard 19.......................................................140 

Table 27. Comments and Responses about Standard 20.......................................................142 

Table 28. Comments and Responses about Standard 21.......................................................142 

Table 29. Comments and Responses about Herbicide Use ...................................................143 

Table 30. Comments and Responses about Public Notification of Herbicide Use ...............161 

Table 31. Comments about Merits of the Alternatives..........................................................162 

Table 32. Comments and Responses about Alternatives Dismissed from Detailed Study ...172 

Table 33. Comments and Responses about Inventory, Monitoring and Adaptive Management

........................................................................................................................................176 

Table 34. Comments and Responses about Implementation Funding ..................................180 

Table 35. Comments and Responses about Cost of Treatment .............................................181 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants................................................................................................................184 

Table 37. Comments and Responses about Effects on Non-Target Plant Species................192 

Table 38. Comments and Responses About Worker Health and Safety ...............................197 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human 

Health .............................................................................................................................199 

Table 40. Comments and Responses about Effects on Wildlife ...........................................211 

Table 41. Comments and Responses about Effects on Land Uses........................................218 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-50 

Table 42. Comments and Responses about Effects on Soils.................................................221 

Table 43. Comments and Responses about Effects on Aquatic Organisms..........................223 

Table 44. Comments and Responses about Effects on Species Listed Under The ESA.......231 

Table 45. Comments and Responses about Cumulative Effects ...........................................234 

Table 46. Comments and Responses about Partnership, Coordination and Public Education

........................................................................................................................................239 

Table 47. Comments and Responses about Tribal Concerns ................................................243 

Table 48. Comments and Responses about the EIS Glossary...............................................246 

Table 49. Miscellaneous Other Comments and Responses...................................................247 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-51 

Comments and Responses by Topic with Summaries 

Introduction

This report summarizes all comments received during the 90 day DEIS comment period. 

Comments from Native American tribes and federal, state, county, and other local agencies 

are published in total at the end of this report. In total, 286 pieces of correspondence were 

received. 

Most of the correspondence (approximately 250 letters) originated in Oregon and 

Washington. Approximately 83 letters with 140 signatures were from Lane County, Oregon. 

Approximately 27 letters with 28 signatures were received from Multnomah County, Oregon. 

Fewer than 20 pieces of correspondence were received from any other county. 

The comments were 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. 

In some cases, comments did not warrant further agency response. The rationale for why no 

further action was taken is discussed in the tables below. 

Table 1. Correspondence Received during DEIS comment period by Organizational Type 

Organizational Type Number of 

Responses 

Number of 

Signatures 

Individual 216 245 

Academic 2 3 

Agricultural Interest 2 2 

Timber Interest 2 2 

Other Industry or Business Interest 6 6 

Tribal Agency or Official 1 1 

Government Employee Group 1 1 

Federal Agency or Official 4 4 

State Agency or Official 6 7 

Regional Agency or Official 3 3 

County Agency or Official 12 15 

Preservation/Conservation 

Organization 

22 60 

Place-Based Organization 1 1 

Recreation User Organization 8 8 

Total 286 358 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-52 

The analysis files contain a database linking these comments to the correspondence received. 

Lists of commenters and detailed demographic information are in the files. 

Scope of the EIS

Several letters contained comments about the scope of the EIS. Many people questioned the 

type of analysis appropriate for a programmatic NEPA document; versus what should be 

analyzed in future project NEPA documents. 

The FEIS contains additional discussion regarding how site-specific projects will tier to the 

Regional EIS in response to these comments. 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

How will site-specific EIS [GP, Mt Hood, Gorge] tier to 

Regional EIS if the latter is behind the former in preparation? 

NEPA does not allow tiering of two contemporary EIS’s to 

each other. Both EIS area present and/or reasonably 

foreseeable future actions that must be assessed together. 

Invasive plant treatment projects are being 

planned concurrently with the Regional effort. 

For instance, target species may be inventoried, 

site objectives may be defined, and public 

outreach may be ongoing. The final decision on 

the Regional EIS will influence the design and 

development of site-specific projects 

[The Nature Conservancy believes] this thorough draft 

addresses the key issues in a frank, professional manner. Its 

treatment of the real risks of chemical and biological control 

treatments is excellent, and provides a good basis for the 

selection and use of herbicides and other methods described in 

the Proposed Action. There are also provisions in this EIS to 

support adequate and appropriate monitoring to detect change 

due to management actions. This draft EIS takes into 

consideration potential off-target impacts, especially health 

and safety issues when using herbicides, and we believe that 

the Proposed Action strikes the right balance in guarding 

against the risks to human and environmental health from 

these methods, and the risks of a failed invasive plant 

management program. 

The FEIS further addresses these considerations. 

The rationale for the final decision will be in the 

Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-53 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

In addition to the important changes to the Standards prior to 

publication of the DEIS, the scope of the action has also 

changed. During the early NEPA process, NOAA Fisheries 

worked with the FS on the development of project design 

criteria (PDCs). The PDCs were intended to be included in 

the DEIS for use at the sub-Regional or individual National 

Forest level. The PDCs were designed to provide clear 

guidance to FS staff regarding how to conduct invasive plant 

management actions which avoided or minimized effects on 

listed species or the ecosystems upon which they depend. At 

present, there are no PDCs in the DEIS, and no plans to 

develop them at the Regional level. The FS was concerned 

that Regional PDCs could not be developed to fit the variation 

that occurs at the local level. NOAA Fisheries understands 

this concern and would still like to jointly pursue development 

of PDCs that can accommodate the variation at the local level. 

NOAA Fisheries recommends that the FS develop PDCs, or 

commit to a schedule for future PDC development. 

Project design criteria would be established at 

the project scale depending on potential effects 

on listed species. The EIS includes appropriate 

management direction for Forest Plans in the 

Region. 

The ROD and Mediated Agreement called for the Forest 

Service to "detect and resolve vegetation problems before they 

cause serious losses or require large correction projects (such 

as envisioned in the IPEIS). It also directed agency managers 

to continue to "evaluate and monitor tools and intensity of 

application" and to monitor research findings about vegetation 

management methods. Nothing in the IPEIS indicates any of 

these management directions stipulated in the Mediated 

Agreement and implemented in the 1988 ROD were clarified 

or followed on a region wide basis. 

Headwaters believes that during the past 15 years, the Forest 

Service has failed to implement the comprehensive direction 

outlined in the 1988 ROD and Mediated Agreement. It 

appears the agency is now scrambling to solve an expanding 

invasive plant problem (created at least in part by failure to 

implement the 1988 decision) by increasing the use of 

herbicides and lowering prevention standards. Although the 

Forest Service has incorporated all pertinent documents 

(including the ROD and Mediated Agreement) into the 

existing Region 6 forest plans, only one forest has amended its 

forest plan to any degree to include specific direction for 

prevention of invasive plants. This situation is not the fault of 

the existing documents, but the failure of the Forest Service to 

take the threat of invasive plants seriously enough to amend 

all its Region 6 forest plans years ago. The fact is, current 

management efforts to prevent the spread of invasive plants 

have failed, not because of inadequate or outdated 

methodologies, but through a lack of agency will, staff and 

money to incorporate and implement the specific mandatory 

prevention direction required by the 1988 ROD to get the job 

done. 

The DEIS emphasized early detection and action 

so that invasive plants are treated when 

populations are small. It also included 

information about monitoring. “Large corrective 

projects” were “envisioned,” to occur 

infrequently. The 1988 ROD did not focus 

specifically on invasive plants; it had a broader 

scope that included unwanted, native vegetation.

The Forest Service and wider community has 

learned a lot about the spread of invasive plants 

since 1988. The DEIS considered new 

information in light of the current situation. It 

addressed the mechanisms of spread that include 

actions controlled by the Forest Service. This 

EIS is an indication of the “agency [‘s] will, staff

and money to incorporate and implement 

...prevention direction.” 

 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-54 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

Also missing is even a rudimentary analysis of how 

differences in climate, soil, topography and other factors will 

impact what treatments may be used and how efficacious they 

will be. 

Differences in climate are beyond the scope of 

the EIS. The discussion in DEIS Chapter 3.2 

included potential vegetation groups which are a 

reflection of climate, topography, elevation, and 

other factors. The FEIS notes that the 

effectiveness of any treatment is related to site 

characteristics and biology of the invasive 

species. These factors will be considered as a 

part of project planning. 

The DEIS fails to inform the decision maker by making 

several very serious lapses in the description of the 

environmental consequences of the proposed program. The 

primary assumption is that for a programmatic EIS the Forest 

Service is absolved from analysis of the relative need for any 

of the means of control. No attempt is made to provide even 

broad brush strokes of what could be expected of, for 

example, herbicide usage amounts. The FS can and must 

come up with, at the very least, pie charts and graphs that 

illustrate the proportion of each treatment option that may be 

anticipated to be used in R6. This is not an impossible task, or 

if it is, why it is impossible should be described in the EIS. 

How can a decision maker be informed without this basic 

information? 

The DEIS provided extensive discussion about 

expected herbicide usage for each alternative. 

The environmental consequences section 

disclosed the estimated acreage treated by 

herbicide and non-herbicide methods. The 

DEIS estimated the annual acreage that 

various herbicide formulations would be 

applied at typical and maximum label rates. 

Pages 4-88 and 4-89 display the estimated, 

relative mix (percentage) of herbicide 

formulations. A bar chart displays the relative 

annual treatment acreage by method, estimated 

for each alternative. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-55 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

Without a description of which species are most problematic, 

what their response is to various treatment options, what their 

current and anticipated scope of invasion is or what are the 

various regional influences, the DEIS fails to provide the 

evaluation necessary for informing the public and making an 

informed decision. For all the DEIS tells us regarding the 

influences of the environment of Region 6 on the program, we 

could guess that the problem is occurring on Mars, or in the 

sands of Saudi Arabia, or perhaps in Arizona and New 

Mexico. NEPA requires more than this of a programmatic 

EIS. Without adequate description of the problem and the 

RANGE of responses that may be taken, and with constant 

assurance that all that's necessary will be described at the 

more site-specific level in an EA or EIS, it is not possible to 

gain an adequate vision of what is in store under the various 

alternatives with the current DEIS. That is not consistent with 

the demands of NEPA. The analysis cannot be delayed to the 

future because those future NEPA documents must tier to this 

one, and without a solid basis in the programmatic EIS, those 

documents will fail. To put it plainly, such piecemealing is 

patently illegal under NEPA. The decision maker and the 

public would have to scramble in the future to read every 

project proposal and NEPA document that flows from the 

current EIS to piece together a picture of the extent of the 

program, the priority given to particular species, the treatment 

options most likely to be employed, and what effects regional 

differences may make in the approach to controlling invasive 

plants. This is the primary failure of the DEIS as it is currently 

written. 

Chapter 3 provided a detailed description of the 

invasive plant problem in Region Six, described 

vegetation communities at risk, listed the species 

of greatest concern, identified treatment 

priorities, and suggested effective treatment 

methods. Table 3-6 focused on vegetation 

conditions in the Region and the susceptibility of 

specific vegetation types to invasive from nonnative species. Chapter 4 estimated acres that 

would be treated annually, based on treatments 

that would be effective on priority species. The 

DEIS adequately disclosed direct, indirect and 

cumulative effects at this programmatic scale. 

Appendix N provides a link to the document, 

“Common Control Measures for Invasive Plants 

of the Pacific Northwest.” This document is 

available on request for those without internet 

access. The document discusses how invasive 

plant species respond to treatment methods. 

The DEIS focuses too exclusively on native plant 

communities - and does not put enough emphasis on Noxious 

Weeds 

A fundamental part of the purpose and need is to 

prevent or reduce spread of invasive plants so 

that desired future condition of lands can be 

attained, thus the DEIS focused on the desired 

condition of healthy native plant communities 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-56 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

Applicable laws affected by this document should be listed, 

along with the sections of those laws that are unchanged by 

this EIS outside of Region 6. It is not clear whether the 

standards in Appendix F are legal requirements or merely 

guidelines and recommendations. 

No laws would be affected by this document. 

Forest Plan management direction includes both 

binding standards and more flexible Goals and 

Objecitves (Chapter 2). The selection of an 

action alternative would impose standards for 

invasive plant prevention and treatment. The 

effect of these standards on land uses was 

discussed in Chapter 4. 

The goal of a control program could be to eradicate 

completely a plant everywhere, it could be to eradicate it only 

in a specific area, or it could be to reduce its population to a 

level that does not significantly displace native flora and 

fauna. The DEIS does not make this analysis. Furthermore, it 

does not provide an adequate system for making decisions for 

each site. How can R6 FS staff prepare NEPA documents in 

the future when they have no decision making guidance in the 

programmatic EIS? 

Treatment Standards 10 and 11 relate to setting 

objectives and priorities for invasive plant 

treatment. Chapter 3 of the DEIS discussed that 

“an effective [invasive plant treatment] strategy 

should include: (1) prevention of the conditions 

that favor invasive plants and encouragement of 

conditions that resist them (controlling invasive 

colonization), (2) treatments that not only control 

the invasive species (controlling invasive species 

performance), but also purposefully manage for 

desired vegetation (designing a disruption to the 

undesired successional pathway). Chapter 3 also 

stated: “Infestations need to be assessed when 

developing a treatment strategy as to whether 

they can be eradicated, controlled, contained, 

suppressed or tolerated.”1

 At the site-specific 

scale, objectives ranging from eradication to 

suppression to would be established. 

Scope of the Programmatic EIS not fully disclosed. Since the 

proposal is a programmatic EIS, the scope of analysis includes 

tiered, subsequent project-level decision documents; we asked 

for the scope of project plans to be limited by the scope of 

tiered programmatic planning documents. This was only 

partially disclosed in the section on scoping (p. Summary-5), 

which proceeds directly to a list of issues without defining the 

scope of analysis. This is a flaw in the EIS, which will likely 

lead to the preparation of tiered project documents exceeding 

the scope authorized by this EIS. 

The DEIS stated: “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. The selected alternative would 

become part of the amended Forest Plans, and 

provide management direction for project level 

decisions. Management direction provided by 

the selected alternative would apply to future 

projects and activities... The action would revise 

only that portion of existing management 

direction that addresses prevention, and 

management of invasive plants, as well as 

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.” Invasive plant projects would 

be required to follow applicable management 

direction incorporated into the Forest Plans. 

 

1

 These terms are defined in the EIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-57 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

Additionally, we are pleased that the DEIS proposes to 

empower the forest manager to select from the range of 

approved tools to address the unique and often unpredictable 

conditions encountered in the field. The alternative approach 

of dictating specific management treatments by species, places 

unworkable constraints on forest managers by ignoring the 

complexity of field conditions and the rapid pace of learning 

and innovation that is occurring in the weed management 

field. 

Your comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

The Summary implies a number of generalities that may not 

be understood by the general public, but will be taken for 

granted by anyone in the invasive species business. Some of 

these are, for example: (1) each site and situation will be dealt 

with on its own merits, e.g., a new 0.1 acre spot will not be 

given the same treatment as a 500 acre patch, and some 

species may be treated with bio-control agents and others 

species have no known bio-controls. (2) The Region has 

specialists to provide assistance regarding endangered species, 

bio-control agents, proper herbicides, rates and timing, and 

riparian area sensitivity. 

The FEIS Summary has been supplemented to 

state that future treatment choices would be 

based on the biology of invasive plant species, 

the site location, condition, and objectives, and 

the size of infestation. The FEIS summary also 

states that that project-level decisions would 

require additional interdisciplinary (NEPA) 

analysis before being implemented. 

The Draft Environmental Impact Statement (DEIS) utterly 

fails to address prevention in a meaningful way; therefore, the 

problem of spreading invasive plants will worsen. The DEIS 

is basically an herbicide spray program, and tragically, even 

an herbicide spray program will not solve the problem. 

This planning effort responds to three needs for 

action, which are detailed in the DEIS: 

1. Forest Plan direction that will prevent or 

reduce the spread of invasive plants. 

2. Release from the 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 DEIS recognized that herbicides alone will 

not address this need for action and thus includes 

a suite of prevention and treatment standards and 

approves a variety of treatment methods. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-58 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

In regard to the December 2002 U.S. District Court decision, 

"Blue Mountains Biodiversity Project v. U.S. Forest Service," 

CV 01-703-HA, we observe that the current DEIS for Region 

6 ("for the Pacific Northwest Region Invasive Plant 

Program/Preventing and Managing Invasive Plants", hereafter 

referred to as "DEIS" or "EIS") fails to meet all the Courtordered Forest Service obligations set by that ruling. In some 

cases the DEIS fails to meet the spirit of the Court's ruling 

regarding full disclosure of herbicide effects; in other cases 

relevant information is simply missing or not incorporated 

within the EIS itself for NEPA-required accessibility to the 

public and decision-makers prior to a decision being made 

(i.e. within the Draft EIS before the public comment period.) 

Specifically missing from the DEIS is the following Courtordered information or subsets of that information: 

• evidence of the neuron- and immuno-toxicity of 

herbicides 

• specific scientific study results on toxic effects and 

increased susceptibility of amphibians to herbicide 

impacts 

• specific details within the DEIS itself of effects from 

additives to herbicide full formulations (eg. 

information on inerts, surfactants, adjuvants, etc. for 

all the herbicides proposed for use, disclosure of 

toxic effects of kerosene, ethanol and other known 

additives within the DEIS document itself) 

• results of studies (with detail re: effects observed 

and study citations on metabolites, the break-down 

products of herbicides. 

These items were addressed at length in the risk 

assessments. These assessments were 

adequately summarized and referenced in the 

DEIS. 

We are also concerned that the spirit and letter of Forest 

Service obligations under the 1989 Mediated Agreement may 

not be met by this DEIS and may not currently be met by all 

Forest Service Districts in practice. While not incorporating 

all new information or changes that should be made, the 1989 

Mediated Agreement is nonetheless a good starting point, and 

as a court-ordered agreement, warrants full respect and 

adherence. 

The 1989 Mediated Agreement was the starting 

point for the current effort. The DEIS disclosed 

that the No Action alternative (no change to the 

1988 ROD or 1989 Mediated Agreement) has 

less likelihood of effectively preventing and 

reducing invasive plant spread than the action 

alternatives. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-59 

Table 2. Comments and Responses about Scope of the EIS

Comment Response 

The DEIS stated that aquatic invasive plants are beyond the 

scope of the EIS. The USFS does not appear to have an 

overall strategy for preventing and managing aquatic invasive 

plants. There needs to be a more programmatic approach to 

aquatic, invasive plant management in the National Forests. 

This could be achieved by development of joint management 

plans between state and federal entities both of which have 

legitimate interests in this resource. 

Aquatic invasive plants are beyond the scope of 

this EIS because: 

1) The purpose and need is focused on the need 

for invasive plant management within upland 

and riparian areas; the need to manage aquatic 

plants is not as evident within Region Six; 

2) The conditions, treatments and issues are 

different for aquatic invasive species; 

3) The Forest Service does not have expertise in 

dealing with aquatic invasive species; 

4) Aquatic invasive species are managed by the 

states. 

Aquatic invasives are addressed on a case-bycase basis by individual National Forests as 

needed via coordination with state and other 

agencies with expertise and responsibility in this 

area. 

The EIS should compare the impacts of the treatment of 

noxious weeds with the impacts of not treating noxious weeds. 

It should not compare treatment with no weeds. 

Within the DEIS, No Action (current 

management) was compared with three 

alternative new approaches to invasive plant 

management. None of these approaches would 

result in “no weeds;” however, the DEIS 

disclosed that all alternatives improve 

effectiveness in reaching desired conditions as 

compared to No Action. 

NEDC is concerned that the Forest Service plan will leave too 

much discretion to those individuals implementing the plan on 

the local level and that, in practice, the more harmful 

chemicals will be used when the plan permits their use as one 

of several options. 

The alternatives vary in how much discretion is 

given managers implementing projects. 

Standards for Alternative B tend to be more 

prescriptive and allow for less flexibility that 

other alternatives. This is discussed in Chapter 2 

of the FEIS. This comment will be considered 

and the rationale for the selection of alternative 

will be in the Record of Decision. 

The Forest Service cannot ignore its role as trustee, 

responsible for managing the nation's natural resources. 42 

U.S.C. [section] 4331(b)(1). This duty includes managing 

natural resources "without degradation, risk to health or 

safety, or other undesirable and unintended consequences." Id. 

at [section] 4331 (b)(3). The Forest Service is also responsible 

for carrying out Congress' promise of providing aesthetically 

pleasing surroundings for all Americans. Id. at [section] 4331 

(b)(2). Moreover, each person at the Forest Service is 

responsible for contributing to the preservation and 

enhancement of the environment. Id. at [section] 4331(c). 

Consequently, Forest Service should not implement a plan 

that leaves so many factors to the discretion of individual 

forest managers. Critical analysis, necessary to ensure that 

these Congressional policies are met, is lacking in the Pacific 

Northwest Region Invasive Species Plant Program Draft 

Environmental Impact Statement. 

The DEIS stated that consistent application of 

prevention measures across the region is key to 

effectively reducing the spread of invasive 

plants. However, the Forest Service recognizes 

that local discretion is imperative so that sitespecific physical, biological and social 

conditions can be fully integrated in any project. 

The Proposed Action includes standards that 

acknowledge the role of local managers in 

established desired conditions for each land unit.
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-60 

Purpose and Need

Comments about purpose and need ranged from those who expressed the purpose and need 

was biased toward herbicide use (“The purpose and need of the Environmental Impact 

Statement (EIS) is identified as "making new practices, technologies and chemical formulas 

of herbicides available for use on National Forest lands in Region Six" rather than preventing, 

controlling and where possible, eradicating invasive exotic weeds. This narrow definition of 

the plan's purpose and need is used by the Forest Service to justify their dismissal of proposed 

alternatives less risky to native plants, wildlife, soil fertility, water quality and human 

health.”), and others who expressed that the purpose and need did not go far enough to allow 

early detection and rapid response (“One of the complaints that I personally hear time and 

time again from County Noxious Weed Control Boards is that the USFS is not able to react 

quickly to treat small, early infestations. Early Detections and Rapid Response should be 

implemented whenever possible. It is important that USFS be able to react quickly to an early 

infestation before it becomes an even larger problem.”). 

The purpose and need was edited for clarity in response to these comments. Planning for 

future projects could be streamlined by tiering to the analysis in this FEIS, but all projects on 

National Forest would be subject to site-specific NEPA analysis and decision prior to 

implementation. 

Table 3. Comments and Responses about Purpose and Need

Comment Response 

Your Purpose and Need is identified as "making new 

practices, technologies and chemical formulas of herbicides 

available for use on National Forests in Region Six." This is 

very scary. Our primary concern is the your downplaying 

"prevention" in favor of "management" which has long been 

ineffective in stopping the increase in the invasive species. 

Preventive management should be given more than lip service 

and chemical alternative used only as the last resort. 

The DEIS considered management direction 

for prevention, as well as treatment and 

restoration. Alternative B emphasizes 

prevention; as stated in the DEIS: 

“Alternative B builds on the Proposed Action 

by increasing the emphasis on preventing 

invasive plants by reducing conditions that 

contribute to their introduction, establishment 

and spread. Disturbance to intact ecosystems 

would be avoided where possible. Land uses 

that contribute to increased risk of spread of 

invasive plants would be modified or curtailed 

as needed. Under Alternative B, invasive 

plant treatment tools associated in the 

scientific literature with human and/or 

ecological harm would be avoided where 

possible and herbicides would be a tool of last 

resort.” 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-61 

Table 3. Comments and Responses about Purpose and Need

Comment Response 

The Forest Service says the existing direction does not 

provide "adequate tools to effectively respond to the invasive 

plant threat." The 1988 ROD takes the opposite view stating, 

"Alternative H (the adopted alternative) makes all tools 

available while working toward the goal of reducing reliance 

on herbicides (ROD pg. 5). "All tools manual, mechanical, 

burning, biological, herbicides and no action are appropriate 

responses under Alternative H" (ROD 14). In addition, "forest 

managers will continue to evaluate and monitor tools and 

intensity of application. Methods will continue to change 

based on new research, analysis of completed projects, 

improvements in technology and public need." (ROD pg. 6). 

It seems the IPEIS needs to clarify which tools are missing, 

inadequate or inflexible, since the above quotations mirror 

those in the proposed action except for the use of some 

additional herbicides. Headwaters believes the Forest Service 

has the ability to incorporate new tools (such as the 

Slashbuster in southern Oregon) including herbicides by 

following Part III of the Mediated Agreement which is a 

process for incorporating new information. Furthermore, the 

1988 ROD establishes policy and direction for subsequent 

site-specific environmental analysis using the process 

described by the National Environmental Policy Act (NEPA).

As stated in the DEIS, 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. The Forest 

Service has not been able to effectively 

address invasive plants under the 1988 ROD. 

Litigation related to invasive plant 

management revealed that the Forest Plans in 

Region Six do not currently provide sufficient 

management direction or adequate tools for 

effectively controlling invasive plants. 

We believe there is a comma that should not be between the 

words "prevention" and "and" in Chapter 1-5 second 

paragraph. If left as is, the meaning of the sentence is quite 

different and could mean the Forest Service is not going to 

consider prevention. We can not believe this is the agency's 

intent. 

The FEIS now reads: “The action would revise 

only that portion of existing management 

direction that addresses prevention and 

treatment of invasive plants, along with 

restoration activities associated with the 

removal of invasive plants.” 

You have stated the problem in a general way, presented some 

evidence of how the problem came about and has been 

exacerbated, and proposed solutions that if implemented could 

cost millions of dollars and be unenforceable. In my 

estimation, you have not addressed all of the contributors to 

the problem, do not have good scientific evidence of what or 

who are the major contributors to the problem, and have 

proposed solutions that may or may not reduce and/or prevent 

a further extension of the problem. In short, what you propose 

has not been scientifically proven to be the answer(s) or the 

solution(s) for the problem of the invasion of non-native plant 

species in the National Forests of Region 6. 

The proposals in the DEIS are based on 

scientific evidence and scientific experience. 

The environmental assessment process follows 

applicable environmental laws. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-62 

Table 3. Comments and Responses about Purpose and Need

Comment Response 

The definition of the plan's purpose is too narrowly defined by 

the Forest Service. As a result alternatives that are less risky 

to native plants, wildlife, soil fertility, water quality and 

human health are all but eliminated. 

The purpose and need of the Environmental Impact Statement 

(EIS) is identified as "making new practices, technologies and 

chemical formulas of herbicides available for use on National 

Forest lands in Region Six" rather than preventing, controlling 

and where possible, eradicating invasive exotic weeds. This 

narrow definition of the plan's purpose and need is used by the 

Forest Service to justify their dismissal of proposed 

alternatives less risky to native plants, wildlife, soil fertility, 

water quality and human health. 

The DEIS provided evidence that collectively, 

the Forest Plans in Region Six do not provide 

sufficient direction, nor do they provide 

adequate tools for effectively responding to 

the invasive plant threat. Thus, Forest Plan 

direction that will prevent or reduce the spread 

of invasive plants, and new practices, 

technologies, and chemical formulations of 

herbicides are needed. The relative risks of 

the alternatives, including No Action, are 

described throughout Chapter 4. 

The DEIS fails at the outset to state a firm goal. The Need for 

Action statement, p. 1-3 sates that its goal is to prevent or 

reduce the spread of invasive plants. A clearer and more 

meaningful statement would read, "prevent and reduce." 

There appears to be a typographical error in the Need for 

Action, p. 1-3. The list of underlying needs omits a statement 

that there is a need to control invasive plants, and it gives an 

either/or proposition when two types of needs are both 

intended to be addressed. Instead, no. 1 states that the need is 

to, "prevent or reduce the spread of invasive plants". We 

assume this is a typographical error, and you meant to say, 

"prevent the spread and reduce the extent of invasive species". 

Is this correct? Our comments address the need for weed 

control as well as prevention. Without clarification, the 

Regional Forester's decision would leave doubts as to the 

applicability of this document. 

The FEIS now states the need as “Forest Plan 

direction that will reduce the extent and rate of 

spread of invasive plants and help prevent new 

infestations.” 

A better definition and prioritization process for "invasive 

plants" is needed. Non-native species that are not eradicable or 

controllable need to be recognized as such. The DEIS does not 

recognize some of the significant values associated with nonnative plants currently well established on the national forests 

and throughout the west. 

The importance of non-native cultural plants 

was discussed in DEIS Chapter 3. The 

treatment objective ‘Tolerate’ is part of the 

management scheme to deal with non-natives 

that are beyond control. 

It is imperative that the regional EIS helps managers move 

ASAP from discovery of a new site to treatment. The EIS 

team should develop standard site evaluation formats (i.e. a 

flow chart of site conditions that dictate required activities for 

NEPA and Consultation on new sites and new weeds with the 

regulation agencies). The EIS should outline the process-and 

estimated costs and timeframes-for the forest level EIS's, and 

new site clearance processes in detail. 

This programmatic scale decision helps 

managers move from new site discovery to 

treatment by 1) addressing weaknesses 

recognized by the court, 2) establishing 

standards for treatment and prevention, 3) 

approving a suite of herbicides based on 

thorough risk assessment and 4) establishing 

treatment priorities. Site-specific analysis 

would still be needed for treatment projects, 

but the analysis will be streamlined and 

focused on site-specific issues. Consistent 

site treatment forms are available. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-63 

Table 3. Comments and Responses about Purpose and Need

Comment Response 

The document does not look at ecosystem function enough; 

rather, it focuses on the health of native plant communities as 

it's sole measure of ecosystem health. 

Ecosystem health and function is addressed in 

this part of the purpose and need: “The 

purpose of the new management direction is to 

eliminate or control invasive plants so that the 

desired future condition of lands can be 

attained.” The desired future condition is 

(partially) defined as: “In National Forest 

lands across Region Six, healthy native plant 

communities remain diverse and resilient, 

providing high quality habitat for a full suite 

of native organisms.” The FEIS also states, 

“Factors influencing the Regional Forester’s 

decision on selection of an alternative 

include... the potential effects to human health 

and the environment, ...and...the associated 

costs” (see Chapter 1). 

The project purpose includes the statements, "Reduced 

process" and "timely responsiveness" that can lead to failing 

to take the time necessary to analyze the problem and the 

proposed solutions in sufficient depth. Once invasive species 

are present, it is imperative that removal begins as soon as 

possible but the method must be environmentally safe. 

The Forest Service will follow all applicable 

environmental laws, regulations and policies 

when implementing projects. NEPA applies 

to invasive plant treatment projects. The 

amount of time between detection and 

treatment would vary depending on a variety 

of factors including site conditions and 

objectives, the size of the infestation, the 

values at risk from the infestation, and other 

environmental and social considerations. 

The stated need that invasive plants are damaging ecosystem 

integrity, leads to the foregone conclusion that invasives must 

be reduced. But at what cost, and how will this be changed 

and how will change be measured? The needs statement could 

and should be stated better to include both a clause 

(1) about costs and a clause 

(2) that invasive species are part of a cycle of decreasing 

ecosystem integrity which tends to get worse before 

getting better. 

By themselves, invasive species are as much of a symptom as 

a cause. Like treating leprosy with bandaids, the patient is 

eventually doomed to die. The management of "ecosystem 

integrity" is the true need for this EIS. 

The FEIS has been edited to clarify that “the 

purpose of the new management direction is to 

eliminate or control invasive plants so that the 

desired future condition of lands can be 

attained” (see Chapter 1). 

The desired future condition is (partially) 

defined as: “In National Forest lands across 

Region Six, healthy native plant communities 

remain diverse and resilient, providing high 

quality habitat for a full suite of native 

organisms.” The FEIS also states, “Factors 

influencing the Regional Forester’s decision 

on selection of an alternative include... the 

potential effects to human health and the 

environment, ...and...the associated costs.” 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-64 

Table 3. Comments and Responses about Purpose and Need

Comment Response 

The Wallowa County Stockgrowers are very concerned that 

new sites or new species of noxious weeds be treated 

immediately. The EIS should identify a process that would 

take no more than two weeks between detection of a site and 

clearance for treatment. This will reduce the area needed to be 

treated, reduce the cost of the treatment, reduce the impact on 

the watershed and stop the spread. 

One of the complaints that I personally hear time and time 

again from County Noxious Weed Control Boards is that the 

USFS is not able to react quickly to treat small, early 

infestations. Early Detections and Rapid Response should be 

implemented whenever possible. It is important that USFS be 

able to react quickly to an early infestation before it becomes 

an even larger problem. 

The ROD should outline a process for adding new sites and 

developing EAs in a timely manner. An example of planning 

delays is a meadow and orange hawkweed infestation that was 

first detected on the Mt. Hood National Forest in 1997. This 

original infestation was less that 1/4 acre in size and the 

required manual and mechanical control methods proved to be 

futile. It was not until the spring of 2003 that the EA was 

completed to allow for use of selective herbicides. Due to the 

delay in effective treatment options the hawkweed infestation 

has now expanded to nearly 2000 acres and is threatening a 

near by Wilderness Area. The new direction provided by 

Proposed Action in the USFS Invasive Plant DEIS is a 

positive step forward. The implementation of active 

prevention and control of invasive noxious weeds as outlined 

in the DEIS will be a key to the overall protection and 

restoration of natural resources statewide. 

Early detection and timely treatment is 

emphasized in the Proposed Action and other 

action alternatives. It is discussed as part of 

the first goal that would be added to Forest 

Plans under all action alternatives. The 

amount of time between detection and 

treatment would vary depending on a variety 

of factors including site conditions and 

objectives, the size of the infestation, the 

values at risk from the infestation, and other 

environmental and social considerations. 

The DEIS stated that the ability to detect and 

destroy the new, small infestations was crucial 

to control of invasive species and should be 

combined with efforts to control established 

populations. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-65 

Table 3. Comments and Responses about Purpose and Need

Comment Response 

The DEIS addresses the need for control of new invaders (i.e. 

Chapter 2.4.4, Goal 1, Objective 1.5 and Chapter 3-96, table 

3-15) but does not appear to provide a process or mechanism 

for rapid response to new invading weeds. Adding a standard 

or incorporating first strike language into the existing 

standards to address rapid response for new invading noxious 

weeds would improve the Record of Decision 

(ROD).Devising a "First Strike Standard" for rapid response 

and treatment of new invading weeds would permit early 

treatment and rapid response activities for new small 

infestations or for high priority listed noxious weeds. This 

would avoid delays that enable new small infestations to 

increase and establish on USFS lands. All usual EIS 

procedures could be followed after the initial treatment has 

occurred. 

We recommend the incorporating following criteria into a first 

strike: - Include high priority weeds listed by the State. - 

Include invading weeds new to a Forest or Ranger District. - 

Include the area if the infestation falls within the parameters 

of certain site types (i.e., roadsides, right-of-ways, stockpiles, 

designated OHV sites, corrals, or when found outside of 

known sensitive sites like T&E sites). - Include small sites 

falling under a defined infestation size (<1 net acre).It is 

important that NEPA documents are developed in a timely 

and concise manner to aggressively treat new invader species 

before they become large-scale problems. It is not clear in the 

DEIS how this concern will be addressed, and many questions 

remain unanswered. How are new treatment sites added? Is 

the decision at the Forest or District level through the 

Environmental Assessment (EA) procedures? The ROD 

should outline a process for adding new sites and developing 

EAs in a timely manner. An example of planning delays is a 

meadow and orange hawkweed infestation that was first 

detected on the Mt. Hood National Forest in 1997. This 

original infestation was less that 1/4 acre in size and the 

required manual and mechanical control methods proved to be 

futile. It was not until the spring of 2003 that the EA was 

completed to allow for use of selective herbicides. Due to the 

delay in effective treatment options the hawkweed infestation 

has now expanded to nearly 2000 acres and is threatening a 

near by Wilderness Area. The new direction provided by 

Proposed Action in the USFS Invasive Plant DEIS is a 

positive step forward. The implementation of active 

prevention and control of invasive noxious weeds as outlined 

in the DEIS will be a key to the overall protection and 

restoration of natural resources statewide. 

NEPA applies to projects that may affect the 

human environment; a programmatic EIS 

cannot anticipate all possible site-specific 

effects. However, the analysis would be tiered 

to this EIS, streamlined and focused on sitespecific issues; regional issues addressed in 

this EIS need not be repeated. 

Treatment sites would be considered at the 

local level. The scale of future NEPA analysis 

would depend on the scope of a project and 

any connected actions. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-66 

Table 3. Comments and Responses about Purpose and Need

Comment Response 

While it is our understanding that the program's intent 

includes eradication of invasive plant species where possible, 

the DEIS does not clearly articulate that in the executive 

summary or elsewhere. Limiting the introduction and spread 

of invasives is extremely important, but so it the need to 

eradicate invasive populations wherever possible. Eradication 

should be clearly identified as the goal, retreating to 

containment only when the population cannot be eradicated. 

Eradication will not likely be possible for many species that 

are already widespread, but it will be possible for localized 

populations, and this goal should be stated where practicable. 

The FEIS summary has been updated to 

explain that treatment strategies vary between 

eradication, control, containment, suppression, 

and tolerance. These terms are defined in 

Chapter 3. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-67 

Desired Future Conditions, Goals and Objectives

Several commenters suggested changes in the wording of desired future condition, goals and 

objectives and their relationship to the standards and purpose and need for action. The FEIS 

contains further discussion about the relationship between the purpose and need for action and 

the goals, objectives and standards proposed. Many of the rewording suggestions are 

adopted (in spirit if not to the letter) in the FEIS. 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

Objective 1.2 is great but there is no implementation monitoring to 

see if the objective is being achieved. For instance, what percentage 

of North Bend Ranger District employees recognize knapweed? 

What percentage of hikers or other National Forest users know 

what an invasive plant is or understand why invasive plants are a 

problem? The same hold for Goal 5. Is there implementation 

monitoring that could help assure the goal is being achieved? 

The Forest Service is continually educating 

its employees in the identification and 

consequences of invasive plants. The type 

of monitoring you propose has merit from a 

program management perspective, but this is 

not a NEPA issue, and doesn’t warrants 

including in our monitoring framework. 

The Forest Service should work to manage forestry and recreational 

activities in a manner that does not increase the spread of noxious 

weeds and should reduce herbicide use to the lowest levels 

possible. 

Alternative B emphasizes preventing 

invasive plants by reducing conditions that 

contribute to their introduction, 

establishment and spread. Disturbance to 

intact ecosystems would be avoided where 

possible. Land uses that contribute to 

increased risk of spread of invasive plants 

would be modified or curtailed as needed. 

Under Alternative B, invasive plant 

treatment tools associated in the scientific 

literature with human and/or ecological 

harm would be avoided where possible and 

herbicides would be a “tool of last resort.” 

Treatment projects would be prioritized to 

favor those projects with the highest 

likelihood of restoring native plant 

communities. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-68 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

NOAA Fisheries understands that the proposed standards act as 

management direction for all future invasive plant management 

projects and activities. However, in their current version, the 

standards do not provide Regional direction to consider 

biological diversity and function while prioritizing treatment 

efforts. This risks potential misinterpretation or disregard of 

ecosystem protection at the individual Forest- or sub-regionallevel. In addition, neither the current standards, nor the goals 

and objectives address the development of long-term vegetation 

goals, once again risking misinterpretation or similar disregard 

for development of a long-term strategy. In sum, without 

management direction provided by the Region to the Forests, in 

the form of standards speaking specifically to ecosystem 

protection, long-term vegetation goals, and inventory and 

monitoring, no ecosystem-wide strategy would exist which 

could result in uneven levels of weed management and 

protection of ESA-listed species and their habitats...If the FS 

proposed vegetation management programs will not be driven 

by ecosystem-level protections, the risks to threatened and 

endangered species and their ecosystems may be 

underestimated. 

Goal 4 in the FEIS has been updated to 

read: 

“Maintain biological diversity and 

function within ecosystems.” 

Laws, current Forest Plan language, 

National and Regional policy, Forest 

Service manual and handbook direction all 

contribute to attaining the goals and 

objectives in Chapter 4.2. Conserving 

biological diversity and ecosystem 

function is already a legal and ethical 

responsibility of the Forest Service. 

The relationship between the Desired Future Condition, Goals, 

and Objectives is clearly explained on pages 2-14 through 2-16. 

However, the connections of individual Standards to the 

Objectives they are intended to implement are often unclear. In 

order to further the understanding of the Proposed Action the 

supporting relationship between the Goals and Objectives and 

Standards should be made clearer. In addition, the DEIS should 

identify when Goals and Objectives are not supported by 

Standards. In some places in Table 2-4, a Standard is present in 

one of the unselected action alternatives, but is missing from the 

Proposed Action. Often, that Standard is "addressed" as an 

Objective. If the Standards are the "binding", implementable part 

of the Proposed Action subject to analysis in the DEIS (and ESA 

Section 7 process), how is a non-existent Standard to be 

considered as "addressed" by an Objective? As stated on page 2-

13, "each action alternative contains a unique suite of standards 

developed so that projects will contribute to meeting goals, 

objectives, and desired conditions." Thus, it appears that some 

Objectives will not be implemented due to the lack of supporting 

Standards. These relationships should be clarified. 

Some of the objectives do not have 

specific standards because these objectives 

can be met by complying with existing 

laws, policies and plans. This is discussed 

in FEIS Chapter 2.4. 

It appears that [the Desired Future Conditions], Goals and 

Objectives center more around the criteria that the tools and plan 

will need to meet, rather than the actual outcome being pursued. 

Focus on the method, rather than focus on the real goal, a resilient 

vegetation community, may hinder achieving that goal. 

The DEIS stated the desired condition is 

for healthy native plant communities that 

remain diverse and resilient, providing 

high quality habitat for a full suite of 

native organisms. The goals, objectives 

and standards highlight elements of a 

successful program to achieve the desired 

condition. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-69 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

Table 3-15 Priorities for treatment and Selection of Treatment 

Methods - Additional "Highest Priority for Treatment" under 

"Areas of concern" should be waterways including rivers, creeks 

(live, ephemeral and dry), streams and wetland areas that flood into 

rivers, creeks and streams under high moisture events. 

The Table in Chapter 3 has been corrected to 

acknowledge that riparian corridors are 

special areas considered high priority for 

treatment. 

Reducing reliance on herbicides is the core goal of the existing 

direction for invasive plants and other competing and unwanted 

vegetation. James Torrance, the Regional Forester who signed the 

1988 ROD, heard the concerns of the public. He adopted a 

program that doesn't pose a health threat to the people who use 

national forest system land, to the people who work there, or to the 

agency's neighbors, while at the same time meeting the basic land 

management goals. That policy was arrived at following extensive 

and exhaustive efforts to reach a workable consensus. It should be 

continued. The Forest Service has used herbicides with restraint 

these past years. It would be folly to open the floodgates of this 

controversy again. Changing directions to increase reliance on 

herbicides is not warranted given the fact that there is no credible 

science to support a conclusion that pouring on herbicides is a safe 

or effective approach to achieving the Desired Future Conditions 

outlined in the IPIES. 

The intent of this EIS has never been to 

“increase reliance on herbicides.” Rather, 

the intent is to allow for effective treatments 

that are not currently allowed. See Goal 3 

and Objectives 3.1 and 3.2. The safety and 

effectiveness of the herbicides considered 

for use was discussed in detail in the DEIS. 

Objective 2.2 will not work for Eastside forests - particularly in 

light of fuels reduction and thinning for forest health-and therefore 

should not be a regional standard. 

 Objective 2.2 may not achieve the stated goal. Some invasive 

plants are capable of increasing in shaded areas. The objective 

appears to target only certain situations and shouldn't be a regional 

objective as it may unnecessarily hinder fuels or forest management 

actions. If resource professionals consider their projects in relation 

to invasive plants as stated in Goal 1, this objective is not needed. 

Objective 2.2 has been reworded to ensure 

that it consistent with other management 

objectives Region-wide, such as fuel hazard 

reduction: “Retain native vegetation 

consistent with site capability and integrated 

resource management objectives to suppress 

invasive plants and prevent their 

establishment and growth.” 

Incorporate a cost benefit analysis with Goal #2 so that the benefits 

of management actions can be weighed against the potential 

negative impacts 

All invasive plant treatment projects would 

be subject to NEPA, which ensures that the 

benefits of management actions are weighed 

against the potential negative impacts. 

Additional management direction is 

unnecessary. 

Goal #3 is good as it is recognizing that the reduction in herbicide 

use over time is the result of effective management and not simply 

a reduction for the sake of negative attitude toward herbicides. 

The desired future condition also reflects an 

emphasis on effective treatment: “The need 

for invasive plant treatment is reduced due 

to the effectiveness and habitual nature of 

preventative actions and the success of 

integrated treatment/restoration efforts.” 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-70 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

Goal #4 Balance the good objectives of this goal with the impact of 

ineffective or no treatment that might result from being overly 

cautious. Objective 4.1 Use the word pollution instead of 

contamination. As a legal term it is more exact in describing your 

intended meaning. 

In the FEIS, Goal 4 has been amended to 

read: “Implement effective invasive plant 

treatment strategies that protect sensitive 

ecosystem components, and maintain 

biological diversity and function within 

ecosystems. Reduce loss or degradation of 

native habitat from invasive plants while 

minimizing adverse effects from treatment 

projects.” Objective 4.1 has been amended 

to read, “Maintain water quality while 

implementing invasive plant treatments.” 

Goal #5 is a good goal and should be followed up with funding for 

cooperative treatment and educational efforts (i.e. CWMA's) across 

property ownership and jurisdiction. 

The Forest Service recognizes that funding 

will be required to implement proper 

invasive plant management. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-71 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

The DFC needs to be clarified in regards to "healthy native plant 

communities". The DFC currently reads: "In National Forest lands 

across Region 6, healthy native plant communities remain diverse 

and resilient, providing high quality habitat for a full suite of native 

organisms. The need for invasive plant treatment is reduced due to 

the effectiveness and habitual nature of preventative actions, and 

the success of restoration efforts." Native Plant Communities are 

obviously highly valuable and should be maintained and enhanced 

to the best of our ability. However, they are hard to define 

spatially, temporally, and nominally. It is debatable, in some cases, 

what would constitute "native". To add to the confusion, our 

ecosystems have been managed, and in many cases radically 

altered, by human influence since before European settlement in 

the west. It is possible that we cannot achieve a truly "native" 

ecosystem ever again. Moreover, we may be experiencing enough 

climate change that historic Potential Natural Communities may 

have been altered. Many non-native species have been introduced 

into the area and have established themselves to a degree that they 

should be considered "naturalized" for all management purposes. 

Some of these species provide ecosystem function in terms of 

forage, habitat structure, nutrient cycling and soil stability - making 

their presence beneficial. They all provide competition for noxious 

weeds. The DFC should address non-native plants that can be 

accepted as naturalized in our systems and ecosystem function 

should be an integral part of the DFC. To leave out the existence, 

naturalized state, and in some cases usefulness of "non-native 

species" in our ecosystems is unreal and may well lead to confusing 

and unreasonable goals and possible openings for litigation in the 

future. 

Goal 1 needs to recognize that maintaining ecologically functional 

weed free ecosystems-native or non-is essential to the whole 

system, not just the native communities. "Invasive plant" needs to 

be broken down into noxious weed, non-native invasive, and nonnative and prioritized as such. Risk assessments similar to those 

used by Oregon Department of Agriculture should be incorporated 

to allow a priority rating of these weeds. 

A DFC is intended to describe how National 

Forests should look and function in the 

future. DFC’s are optimistic descriptions of 

what would result from successful plan 

implementation over time. We recognize, 

because of certain site conditions and/or past 

site degradation healthy native plant 

communities may not be attainable. 

Standard 13 describes national policy 

regarding the usefulness of non-native 

plants. 

Goal 1 has been reworded to remove 

reference to native plant communities. It 

now reads: “protect ecosystems from the 

impacts of invasive plants...” 

The DFC should recognize to some degree or another that mankind 

and multiple use are integral parts of a USFS vision. The omission 

of the human role in and benefit from USFS lands is a gross and 

potentially costly error. We will not invigorate local communities 

and provide for multiple use with this narrow a definition DFC. 

The local communities, especially those with a long-term vested 

interest in the health of the land around them, are the key to 

maintaining the National Forests in their best possible condition. 

This sentence has been added to the Desired 

Future Condition statement in the FEIS: 

“Invasive plants do not jeopardize the ability 

of the National Forest to provide goods and 

services communities expect.” 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-72 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

The second sentence of the DFC statement should include the idea 

that effective integrated treatment is part of the equation for 

decreasing the need for further treatments in the future. 

In the FEIS, Goal 4 is: “Implement effective 

invasive plant treatment strategies that 

protect sensitive ecosystem components and 

maintain biological diversity and function 

within ecosystems. Reduce loss or 

degradation of native habitat from invasive 

plants while minimizing adverse effects 

from treatment projects.” Objective 4.1 is 

now: “Maintain water quality while 

implementing invasive plant treatments 

It is our opinion that the primary goal of this project should be 

more than "to protect native ecosystems from invasive, non-native 

plants" but to preserve native ecosystems. Preserving ecosystems 

will sustain the healthiest and most productive forests, grasslands, 

and waterways. The animals and plants of the Pacific Northwest 

are an integral part of a complex biological system that cannot 

survive disruption by invasive species, chemicals, or methods of 

control that cause the breakdown of their natural systems. 

The Forest Plans in Region Six would be 

amended to include the new invasive plant 

management direction proposed in the EIS. 

The focus of the EIS is limited to invasive 

plant management, rather than the overall 

program. The Forest Plans contain detailed 

descriptions of broad desired conditions for 

the ecosystems in the region. So while the 

overall goal for the National Forests may be 

to preserve sustainable ecosystems, the goal 

of this EIS is to protect them from invasive 

plants. 

We think it is impossible to devise eradication methods for invasive 

species as fast as our global economy can introduce them. 

Therefore, controlling introduction is superior to all forms of 

eradication in solving the problem. 

The DEIS acknowledged that treatment 

alone cannot effectively slow the spread of 

invasive plants, thus prevention standards 

are included in the alternatives. 

Our scoping comments were insistent that goals and objectives 

should follow from clearly stated needs, yet this appears to have 

been patently ignored in the EIS. We provided the team with a 

report detailing how invasive species management should occur 

within a framework of ecosystem management 

(www.kettlerange.org/weeds/reference/weedmgt.html). As stated, 

the EIS will allow managers to count their failures as successes. 

We suggest that if you do not agree with the goals and objectives 

presented in our scoping comments, that the EIS should at least 

provide a rationale of why your alternate goals are better. 

The goals and objective flow directly from 

the need stated in Chapter 1.2. They 

represent our best judgment of how to meet 

this need. Public scoping input was 

considered in the development of these goals 

and objectives. 

Chapter 2 of the FEIS discusses the 

relationship between the purpose and need 

for action and the goals, objectives and 

standards proposed. 

Goal 4 - Please add a third sentence to this goal recognizing there is 

a negative environmental impact associated with choosing not to 

treat invasive species. This may also be accomplished by adding 

an objective recognizing the impact of not treating an invasive 

plant population. 

The second sentence of Goal 4 is: “Reduce 

loss or degradation of native habitat from 

invasive plants while minimizing adverse 

effects from treatment projects.” The intent 

of this sentence is to recognize that habitat 

loss and degradation may occur if invasive 

plants are not treated. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-73 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

Goal 5 - Good discussion on the role the FS would like to play in 

collaborative efforts. The FS is already involved in many of these. 

Perhaps instead of focusing on expansion of efforts, FS should play 

a more active part in those efforts already existing. Please focus on 

implementation of higher priority strategies on national forest 

lands. At present, many collaborative efforts have holes in their 

agreed upon strategies where Forest Service lands require active 

treatment. 

The Forest Service continues to focus on 

working with recreation and other user 

groups to prevent the spread of invasive 

plants. 

Pg 2-14 Desired Future Condition Statement -- We understand that 

for any vision statement brevity is a must. This is an honorable 

DFC and we assume the FS is choosing to focus on their currently 

uninfested lands in relation to this statement. Perhaps by omitting 

those lands already converted to invasive weeds, this statement is 

attainable through implementation of aggressive IWM strategies, 

but the Forest Service must not provide the illusion that all is well 

in the native plant world on forest lands. In some areas, the 

invasion is well underway and at present, economically viable 

technologies for restoration do not exist that can return the plant 

communities to exclusively native ecosystems. Areas like this are a 

fact in the Hells Canyon NRA. Perhaps addition of a second DFC 

statement for those lands already converted to invasive weeds 

would be a way to address this issue. This statement could focus 

on an attainable vision for providing a perennial, stable plant 

community that emulates values provided by the native plant 

communities that may have existed on that site. 

The Desired Future Condition statement 

has been amended to included damaged 

ecosystems: 

“In National Forest lands across Region Six, 

healthy native plant communities remain 

diverse and resilient and damaged 

ecosystems are being restored. High quality 

habitat is provided for native organisms 

throughout the region. Invasive plants do not 

jeopardize the ability of the National Forest 

to provide goods and services communities 

expect.” 

We also support the DEIS's requirement of setting long-term goals 

and objectives based on desired future conditions (rather than on 

amount of weed control conducted) and using an adaptive 

management process to determine the effectiveness of those 

prevention, early detection, and management actions in abating the 

invasive species threat. 

The DEIS recognized the fundamental role 

of monitoring and adaptive management to 

ensure that management direction is 

followed and desired conditions are 

achieved. 

What will you do to ensure that herbicides will be the last resort as 

opposed to the first resort? What factors will cause you to use 

herbicides besides an inability to get into a certain area? How can 

you assure, we the public that herbicides will be used as little as 

possible? 

Standard 17 is modified in the FEIS to 

clarify that the Proposed Action requires 

managers to provide rationale for using 

herbicides over non-chemical treatment 

methods. In Alternative B, managers would 

have to demonstrate that non-herbicide 

methods did not work. 

Herbicides are not the answer. Though they may be of short-term 

benefit in certain specific instances, widespread reliance on them 

does not solve the infestation problem, and it is not good for overall 

health, human or otherwise. Herbicides are not the solution to this 

problem. Their negative effects are not worth the cost and the risk 

(to health), and they do not eliminate the invasives. We are looking 

for you to develop specific measurable goals in your move to 

ratchet down the amount of herbicides you apply to the forests. 

All alternatives would attempt to decrease 

the need for invasive plant treatment by 

increasing the effectiveness of control of 

current populations and preventing new 

infestations. Alternative B includes a 

specific standard related to reducing 

herbicide use over time. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-74 

Table 4. Comments and Responses about Desired Future Conditions, Goals, Objectives

Comment Response 

The USFS needs to focus on watershed function and watershed 

health and less on native plant communities - the DEIS and does 

not put enough emphasis on Noxious Weeds. 

DEIS Chapter 3 described a system for 

prioritizing invasive species based on the 

potential of a species to cause significant 

ecological impact, and stated that such a 

system could be used to direct prioritization 

decisions on any species. The DEIS makes 

the point that newly detected species must 

be assessed for their potential to naturalize, 

become invasive and alter ecosystem 

functioning. 

The USFS should not focus on pristine conditions. They should 

recognize the value of non-native species that are providing erosion 

control, livestock grazing, wildlife habitat, and competition for 

noxious weeds. 

The DEIS did not focus on pristine 

conditions, rather it stated the desired 

condition is for healthy native plant that 

communities that remain diverse and 

resilient, providing high quality habitat for a 

full suite of native organisms. Treatment 

would focus on invasive plant populations 

that threaten environmental values. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-75 

Information Availability

Some people expressed concerns that the risk assessments were not published in the DEIS or 

posted on the Internet. The Forest Service responded to individual requests and has updated 

the website to ensure that the risk assessments are available for review. 

Table 5. Comments and Responses about Information Availability

Comment Response 

Risk assessment for all herbicides under consideration in this DEIS 

were not available or could not be found at the risk assessment 

website listed in the DEIS. Only information on herbicides currently 

used in Region 6 could be found when the website was accessed. 

This inadvertent oversight was brought to 

our attention via this comment. It has 

been corrected for release of the FEIS; 

risk assessments are now linked to the IP 

EIS website 

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

Risk assessments were provided free of 

charge on request. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-76 

Table 5. Comments and Responses about Information Availability

Comment Response 

:* all SERA risk assessments for the herbicides proposed for use under any 

of the alternatives 

* all material safety data sheets and product specimen labels for: all formulas 

proposed for use which contain chlorsulfuron, clopyralid, imazapic, 

imazapyr, metsulfuron methyl, sethoxydim, sulfometuron methyl, triclopyr, 

and any new formulas (since 1988) under consideration for use containing 

2,4-D, dicamba, picloram and glyphosate. 

 * the Pacific Northwest Weed Management Handbook (OSU 2002) 

 *"Common Control Measures for Invasive Plants of the Pacific Northwest 

Region" (Mazzu 2004)* the Soil Scientist report and any other Forest 

Service I.D. team reports used in the preparation of the EIS 

* Spencer and Prevost, 1993; USDA, 2000-APHIS 

We believe that all of the above listed documents should have been 

incorporated within the DEIS itself. Although Appendix G is 

characterized as "a source of information for every herbicide 

considered for use in this EIS,” not everyone has access to the 

internet or knows how to use it, so putting appendices only on a 

website limits their availability to the public. Full sources of the 

Forest Service (FS) information on the new herbicides proposed for 

use and specific results of studies and risk assessments for these 

chemical formulas (including additives) should have been disclosed 

within the DEIS as well as the documents on the "Appendix G" 

website. All methodology used in risk assessments should have been 

disclosed in the DEIS, including the basic assumptions underlying 

the risk assessments and any models used to predict risk. 

The appropriate timing for full disclosure of the potential impacts of 

new herbicides proposed for use, including incorporation of 

specimen labels and Material Safety Data Sheets as well as citations 

for all research studies used for DEIS information and all available 

SERA risk assessments within the DEIS. Inclusion within the FEIS 

is too late for informed decision-making unless another comment 

period is allowed prior to a decision being made. 

The Forest Service "Herbicide Information Profile" for triclopyr is 

not incorporated within the EIS as it should have been. 

Information pertinent to this decision was 

included in the DEIS. Detailed risk 

assessments, safety data sheets and 

product label information were 

incorporated by referenced and 

summarized to the extent necessary to 

understand the effects and trade offs 

associated with the alternatives. 

Specialist reports include more detail, but 

relevant information is summarized in the 

body of the EIS. The FEIS includes some 

new appendices, including Mazzu’s 

report: Common Control Measures for 

Invasive Plants of the Pacific Northwest 

Region. 

The public was informed of the 

availability of the detailed assessments 

and specialist reports and requests for this 

information were filled in a timely 

manner. Few requests for this type of 

information were received during the 

public comment period. 

 

Invasive Plants and Mechanisms of Invasion

Several comments pertained to how invasive species are classified. Factual corrections were 

made in the FEIS in response to these comments. Other commenters expressed disagreement 

with how the Forest Service characterized the potential for land use to exacerbate invasive 

plant spread. Corrections were made in response to these comments. The Forest Service also 

modified the Proposed Action by including the proposed rule for travel management as 

Standard 10. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-77 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

The DEIS provides a list of 107 species, but does not prioritize species 

with respect to management action. Some species are particularly 

detrimental and still in relatively localized small patches. Although each 

forest may have a somewhat different species mix to contend with, it may 

be helpful to identify a few top priority species for which there is a 

general "no tolerance" goal, and that will be eradicated with haste, as 

opposed to monitoring their location for later action. It may also be 

helpful to indicate in the management program how new invasive species 

will be listed and treated as they are discovered. 

Priority invasive plant species were 

identified in Chapter 3 of the DEIS. 

This section was supplemented in the 

FEIS to respond to this comment. 

USFS needs to recognize the value of non-native species that have been 

introduced or established on their own. These species should be 

considered naturalized for all management purposes. 

One of the treatment objectives is 

“tolerate”; included to address such 

species. 

The discussion on use of invasive plants for food and cover (paragraph 3) 

leaves out the fact of comparing the utilization of the invasive plant to 

utilization of the native plants that have been out competed. For 

example; 1) Although the Willow flycatcher utilizes saltcedar for nesting, 

survival and reproduction of the flycatcher is higher when it nests in a 

native willow. 2) Although Bighorn sheep utilize cheatgrass, native 

bunchgrass, yields 12 times more forage in a wet year and four times 

more forage in a drought year. Therefore, for sites where cheatgrass has 

invaded native bunchgrass, these sites have a lower carrying capacity of 

Bighorn sheep. 

The DEIS Table 3-7 addressed the 

known effects on invasive plants on 

wildlife. Change in population through 

nutritional deficiencies, altered food 

web, and lack of proper forage quality 

were all discussed in the DEIS. 

I suggest that a reference be made on p.25 to Appendix B Current 

Invasive Plant Species on National Forests in the Pacific Northwest 

Region. Reference should also be made on p.25, to the informational 

paper on control measures, which Linda Mazzu is preparing to provide 

FS staff with currently available information documented in literature. 

Presumably supplemental or new information will be provided 

continually to FS staff. A review of the information provided in 

Appendix B showed several instances of incomplete information, 

inconsistencies with statements made in one part of the region, which do 

not apply in western Washington where I have extensive, lifelong 

experience. 

Appendix B has been revised in the 

FEIS to address this comment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-78 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

The heading HABIT is misspelled "habitat". Buddleja davidii, butterfly 

bush: "Roots may perish in wet soil" might be left out. Since a major 

concern in Washington is its colonization of gravel bars on rivers, this 

may be confusing. The gravel bars may dry sufficiently in summer so 

that they are not truly wet soil. However, some people may interpret 

them as wet area, and suggest there is no need for control work. 

Centaurea biebersteinii, spotted knapweed Reference should be included 

to the information quoted in Chap. 3, p. 28-29: that areas of heavy 

infestation have more bare ground and soil erosion than uninfested areas, 

and that soil exposure to sun have higher temperatures by day and lower 

temperature at night, thus making it more difficult for native seedlings to 

become established. A short form of this point might be: Infections 

change soil conditions to the advantage of this species; see Chap. 3, p.28-

29.Centaurea diffusa, diffuse knapweed: That it is a tumblewee should be 

included under Mode of Reproduction, as is done for several other 

species on the list.Centaurea debeauxii, meadow knapweed: Add the 

other frequently used name, C. pratensis, which is used in Linda Mazzu's 

paper on control measures. Hedera helix, English ivy: Add seed to Mode 

of Reproduction. Seeds in berries eaten by birds and then dropped in 

nearby forested areas are the primary way in which ivy is spread into 

areas of native vegetation. Rubus discolor, Himalayan blackberry: That 

this species "tends to prefer wet sites" may be true in other parts of the 

region, but the prevalence of Himalayan blackberry on dry roadbanks all 

over western Washington suggests this is not true here. Either leave out 

this phrase or specify the part of the region where this has been reported. 

Rubus laciniatus, cutleaf blackberry: "Found on disturbed upland sites 

which get bright sunlight" Leave out "bright sunlight". Seedlings will 

germinate in partial shade when seeds are dropped by berry-eating birds 

in places in places such as our family's managed forest which has been 

thinned and is adjoined by an infested pasture Lewis Co. in sw 

Washington).Vinca major, bigleaf periwinkle: Add to Mode of 

Reproduction: Trailing and freely branches. Personal observation in our 

neighborhood and C.L.Hitchcock and A. Cronquist, Flora of the Pacific 

Northwest, US Pr. 1973, 1976, p.363: "Branches 1-6 dm, often trailing 

and freely rooting". 

Chapter 3 of the FEIS has been edited 

in response to this comment. 

Chapter 3, page 3-34, Table 3-8. Perhaps italicize the Linnaean names? 

Table 4-40 at page 4-111. Perhaps italicize the Linnaean names? 

Scientific names are italicized where 

appropriate in the FEIS. 

Table 3-1. You might add "ability to hybridize or mutate to become 

capable of sexual reproduction even if initially only able to spread 

vegetatively". We see this potential with knotweed species, alarmingly 

so. You do mention this problem on page 3-47 re Spartina. It needs to be 

integrated elsewhere. [Grammar error in bullet 11-the word "affects" 

refers back to plural "compounds" and should be "affect".] 

The FEIS has been edited in response to 

this comment. 

Under 3.1.3, page 24 of Chapter 3-you forgot giant knotweed, as much or 

even more of a problem than Japanese knotweed. And, there are 

indications these sterile species may be hybridizing into something that 

can reproduce sexually, but we defer to experts on that. Our remarks are 

hearsay. [Same problem in last paragraph of 3.2.3 on page 3-37.] 

Chapter 3 of the FEIS has been updated 

in response to this comment to include 

information about other knotweeds. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-79 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

Because the surveys and evaluations for the presence of invasive plants in 

the Region 6 provided for the current analysis NFs varies from Forest to 

Forest -- with some doing a good or even exemplary job, some barely 

getting by and others in-between -- no adequate determination of a range 

of values for presence of invasive plants can be made. Indeed, it isn't 

made, with only lists of invasive plants provided to guide the decision 

maker and no informative description of where and particularly HOW 

MUCH of the plants are currently present and how they are expected to 

spread given current knowledge. By not taking on the challenge of giving 

broad brush descriptions of this status, the DEIS leaves the future under 

any of the alternatives subject to uninformed speculation. 

The DEIS estimate of 420,000 acres of 

invasive plants in Region Six was made 

based on the best information available 

from the National Forests. See DEIS 

Chapter 3.1.1. Inventories will 

continually be updated and concerns 

regarding the size of infestations would 

be taken into account when designing 

treatment projects. 

The EIS should state the environmental impacts that could result from the 

ineffective treatment (or no treatment) of noxious weed populations. 

What would be the impact of noxious weeds and invasive species if not 

treated? This is a more appropriate yardstick to compare to the risks of 

treatments than the simply unintended impacts on native plants from X 

chemical. 

The adverse effects from invasive 

plants themselves were discussed in 

Chapter 3 of the DEIS. These are the 

impacts that will drive the need for 

action at the project scale. Projects 

would be evaluated based on their 

effectiveness in reducing the adverse 

effects of invasives and restoring native 

plant communities. 

Another new management category should be developed for species such 

as species with some beneficial uses (particularly escaped pasture 

grasses, which are appropriate in pastures, but not in Wilderness), and 

undesirable species, which are nonetheless not very invasive (such as 

poisonous plants, or some of the cultivars such as "Luna", (an 

Agropyron) which caused the $3.5 million Libby South fire when driven 

across.This category should include invasives with lower priority for 

invasiveness, but higher risks to degrading ecosystems and forest health. 

Elymus repens (quackgrass) is on the list, as it should be, but cultivars 

with this plant such as E. intermedium are not. We recommend that 

cultivars be included in the list of partly beneficial invasives. 

Examples of species on the list which need to have a new management 

category for widespread species needing control but beyond eradication 

include: Phalaris arundinacea, Melilotus officinalis (used to plant 

roadsides), and Secale cereal[e]. 

Examples of species which should be in a new management category for 

non-invasive, but still undesirable species include Conium maculatum. 

The invasive plant list is a listing of 

those species inventoried by Forest 

Service botanists and weed 

coordinators. It is not a static list. If a 

species is not on the list, it is because 

no locations have been added to the 

inventory. Upon addition to the 

inventory, such species will be added to 

the species list. The use of 

management categories would be useful 

at the Forest level during site-specific 

NEPA but may not be valid at a 

regional scale. 

Calculation of weed extent uses incorrect mathematics. The calculation of

rate of increase of 8-12% made on p. 3-2 is made for the aggregate of all 

weeds, when it should be for individuals. It should be obvious that the 

Forests are not going to be 100% weeds in ten years. 

The assumptions and methodology of 

analysis of rate of spread was discussed 

in Chapter 4.2. 

Fire reduces biomass, not plant vigor (p. 3-19). This statement was corrected in Chapter 

3 of the FEIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-80 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

The EIS claim that the list of invasive plants was developed by experts 

should be documented. The list of invasive species has inexplicably had 

certain plants removed from inclusion. For instance, Kentucky bluegrass 

was submitted as an invasive species in our scoping comments (in Risky 

Business, Wooten and Renywck, 2001). The invasiveness of this species 

was first brought to my attention by Mel Bennett on the Okanogan 

National Forest, who was noxious weed coordinator during the initiation 

of scoping for the EIS. So it is hard to understand how this species, which 

is already considered a problem both inside and outside the USDA, could 

have been missed unless it was intentionally removed. 

The invasive plant list includes those 

species inventoried by Forest Service 

botanists and weed coordinators. It is 

not a static list. If a species is not on 

the list, it is because no locations have 

been added to the inventory. Upon 

addition to the inventory, such species 

will be added to the species list. 

The invasive species list needs to have a means of being updated. The 

incomplete nature of the invasive plants list highlights the need for the 

EIS to describe the method of updating the invasive species list as well as 

updating it. The method of using expert consultation as already done may 

suffice in the future, provided that the names of the experts are published, 

and reasons are given for the exclusion of any suggestions. A schedule of 

planned updates should be listed and the list of experts consulted should 

not be limited to USDA or agency scientists, but should include academic 

botanists, noxious weed coordinators, and private botanists. 

The invasive plants list reflects only 

those species located and added to the 

Region Six database. It is not a static 

list nor limited to particular experts. 

The list may be updated as needed. 

The use of a special list of National Forest invasive species in Appendix 

B of the EIS is a good tool. The list is developed using a new set of 

criteria, rather than borrowing existing lists from the states. There are 

problems with the list however. For instance, the inclusion of Urtica 

dioica (nettles) is problematic in that presumably this is the non-native 

species separate from Urtica lyallii. Nettles are considered an important 

spring green by many cultures. Many botanists still refer to our native 

species as U. dioica ssp. lyallii. It is a certainty that the spray contractors 

will not be able to tell these two apart, with the result that plants will be 

indiscrimately sprayed with herbicide and wild food gatherers and Indian 

cultural plant gatherers will be poisoned. Even botantists have a hard time 

telling these species apart, and indeed, the apparent distinction (which has 

only recently been recognized, may be an ecotypic variant, rather than a 

taxonomic one). In an experiment, I planted seed of U. dioica ssp. dioica 

in eastern Washington, and within one year, the plants were 

indistinguishable from U. lyallii.The list includes Plantago lanceolatum 

(lanceleaf plantain), but then omits Taraxacum officinale (dandelion), 

despite the fact that these two have similar occurrence patterns. * The 

invasive species list is incomplete. The list is does not include Bromus 

inermis, Poa pratensis (Kentucky bluegrass), Melilotus alba (white sweet 

clover, used to plant roadsides). 

Appendix B was revised to address this 

comment. 

Use of slang botany is confusing. The EIS should be scientifically 

defensible. On p. 3-9, the use of false brome is confusing. Do you mean 

slender false brome or purple false brome? Always use the Latin. 

Scientific names are used in the 

Invasive Plant list in Appendix B. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-81 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

Would propose the creation of a Noxious Medicinal Plant database 

throughout the region, which would track and publicize the locations of 

infestations of which are also considered to be Medicinal Plants (I see 

many on your list, including St. John's Wort, please write back if you 

don't know which noxious weeds on your list are valued for their 

medicinal properties). With the encouragement of the Forest Service and 

a permit-free process, preparers of naturalized plant medicines could help 

the Forest Service mechanically remove noxious weeds that are useful to 

those practicing natural healing. It will of course be necessary to avoid 

contaminating medicinal plant sites with chemical or biological agents. 

Medicinal plants are addressed under 

cultural plant discussions, which have 

been expanded in Chapter 4 of the 

FEIS. Creation of a Noxious Medicinal 

Plant database is beyond the scope of 

this EIS and would not be subject to 

NEPA. 

Justify why mustard, beneficial to soil, must be considered an IP and 

eradicated with a chemical that is an invasive poison. 

Only a few mustard species are 

identified as invasives; the mustard 

family is very large and most would not 

be the target of treatment. 

Please explain why St. Johns Wort needs to be eradicated as an invasive 

plant, what harm it causes and how it is more harmful than the herbicides 

used to eradicate it. 

St. Johns wort may need to be a 

treatment target to meet long term site 

objectives. While tolerated in many 

areas, some native plant communities 

are threatened by the species. 

Interestingly, even though the Draft EIS is not intended to deal with 

aquatic weeds, there is one invasive, aquatic plant listed in Appendix BInvasive Plant Species List. That plant is Myriophyllum spicatum 

(Eurasian watermilfoil) which is an aggressive mat forming species 

common in the Columbia River drainage and throughout the Pacific 

Northwest region. The appendix entry for this species is incomplete and 

the well-documented impacts of M. spicatum infestations throughout the 

region are not addressed in the Draft EIS. 

Corrections have been made to the 

FEIS to address this comment. 

A better definition for "invasive plants" is needed. Its way to inclusive. It 

should focus on noxious weeds. The EIS should adopt State and County 

weed lists. They should work in close partnership with State and County 

entities that prioritize weed control efforts 

The list in the EIS was developed to 

maintain flexibility for Forest Service 

Managers to respond to new invasives 

from adjacent states or regions. It also 

allows managers to treat invasives that 

may not be on a noxious weed list, but 

may be a problem in a natural area 

where intact native plant communities 

are high priority. 

USFS needs to recognize the value of non-native species that have been 

introduced or established on their own. These species should be 

considered naturalized for all management purposes. 

Not all invasive species would be the 

target of treatment in any alternative; 

invasive populations that are not 

adversely affecting environmental 

values would likely be tolerated. 

Consider hazardous fuels introduction, especially line of fuel 

management zone creation, affects noxious weed introduction and spread.

Chapter 3 discussed the mechanisms of 

invasion including from fuels 

management. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-82 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

Fire suppression [dozer lines, etc] is having a huge impact on the spread 

of noxious weeds [i.e. Cache Creek, Cache Mountain, McCache, B and B 

Fires]. How are you going to address this activity? Prevention is not 

happening here. 

The DEIS discussed how current fire 

suppression activities can lead to spread 

of invasive plants in Chapter 2 and 3. 

The standards in all action alternatives 

would impose specifications about use 

of native seed and mulch in post-fire 

rehabilitation. 

The FEIS acknowledges that the 

standards would not require prevention 

practices (such as vehicle washing) 

during emergency fire situations where 

this practice would delay response time. 

These areas [fire lines] increase ORV use, and another vector for 

introduction and spread. 

Fire/fuels management and OHV use 

are discussed as vectors of invasive 

plant introduction, establishment and 

spread in Chapter 3. The Forest 

Service modified the FEIS by including 

the proposed rule for travel 

management as Standard 10 in the 

Proposed Action (See FEIS Chapters 2 

and 4). 

I have personal experience that road construction introduces invasive 

plants into an area. After ridding my property (5 acres) of tansy ragwort, 

by hand, and it being tansy free for many years, the spring following a 

road-building project, one hillside was covered with tansy where a load 

of rock had been brought in to stabilize a slope. After again eliminating it 

by hand without the use of any herbicides, it is again tansy free. Please 

take heed to both these aspects of this problem. 

The DEIS acknowledged that road 

construction may spread invasive plants 

and includes standards in all 

alternatives to reduce this mechanism of

invasion. Effective manual and 

mechanical invasive plant treatments 

would be approved in all alternatives. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-83 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

We are highly disconcerted by the way the FS has dealt with the issue of 

recreational saddle and pack stock use in the context of the planned 

invasive Plant Program as described in the July 2003 DEIS. In short, 

without documentation of scientific information that resulted from either 

designed experiments or observational data collected in a scientifically 

disciplined manner, the FS has categorically identified the use of saddle 

and pack stock as a significant contributor to the spread of invasive 

plants. It was highly disturbing for us to study EIS Appendix D, Influence 

of Ungulates on Non-Native Plant Invasions in Forest and Rangelands 

which concludes that the existing science on the role of ungulates in 

invasive plant spread is inconclusive, and then find the authors of the 

body of the EIS are certain that the science demonstrates that saddle and 

pack stock are significant contributors to the problem. As we follow the 

statements of the EIS authors and apparent line of logic, we can conclude 

only that the FS has accepted a dogma against the recreational use of 

saddle and pack stock on wildlands, and Wilderness Areas in particular. 

For example, towards the end of the EIS, the authors write: "regardless of 

choice of alternative, pack stock will continue to be a source of invasive 

plant spread" (Chapter 4-98) If this is a true statement, the FS should 

have no trouble validating it with information that is presumably already 

in hand and showing increased occurrences and rates of spread of 

invasive plants that are statistically related to the occurrence of and 

intensity of use of saddle and pack stock. The BCHA position is that until 

the FS publishes that data in the DEIS, the above assertion is unfounded 

and has no place in a document as important as an EIS. 

Acreages for No Action and Alternative 

D have been factually corrected to show 

that weed free feed is currently required 

on at least 2.5 million acres of National 

Forest land in Region Six. Expanded 

discussion of weed free feed has been 

added to Recreation and Recreation 

Management and Congressionally 

Designated Areas sections of FEIS 

Chapter 3 and Chapter 4 includes added 

discussion of why the was included and 

how the standard and range of 

alternatives for the standard were 

designed. 

The DEIS acknowledges the fact that saddle and pack stock usage has 

declined substantially: "A recent study by the Oregon Parks and 

Recreation Department (2003) found that between 1987 and 2002.. 

Activities (of relevance to national forest lands) with declining 

participation include(d) horseback camping (-38.5 percent), dune buggy 

driving (-32.7 percent), and horseback riding (-31.5 percent)." (Chapter 

3-19) It is very difficult to understand how the conclusion embodied in 

this document that recreational saddle and pack stock became a major 

contributor to the problem when our usage is declining and other 

recreationists' usage is substantially increasing. 

The use of livestock is the only 

recreational use where (potentially 

weed infested) animal feed is 

intentionally carried onto National 

Forest lands. Chapter 3 discussed that 

livestock can also carry weed seeds 

internally and deposit them with dung. 

The DEIS states that all of the major human caused disturbances, grazing, 

logging, road building, and prescribed fire can be used to encourage 

desirable plant communities (Chapter 3-9). We are aware of no instances 

where road building favors native plant communities over invasive 

plants, and the DEIS provides no evidence supporting this claim. These 

activities are generally contradictory to the prevention of invasive plant 

infestations. 

Page 3-9 of the DEIS stated, 

“.Disturbances can create conditions 

favorable for desired species, 

depending upon its size, severity, 

frequency, and timing (Sheley et al., 

1996).” 

This is not intended to imply that “all of

the major human caused disturbances, 

grazing, logging, road building, and 

prescribed fire can be used to encourage 

desirable plant communities. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-84 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

Discussion of seed scarification is inadequate on p. 3-11. One of the 

primary determinants of invasive plant biology is the germination rate 

and requirements. There is practically no discussion of this topic, except 

for a brief mention in the specialist paper on grazing animals scarifying 

seed. Range managers are aware of the importance of seed scarification, 

and in the case of invasives, the lack of such a requirement. Furthermore, 

scarification is a common component of timber sale operations. The EIS 

should also note that scarification typically benefits woody species, and 

that adventives come in as a side-effect. 

Chapter 3 of the FEIS contains further 

discussion about seed scarification. 

Fire initiates primary, not secondary succession (p. 3-18). Thus in 

general, fire has more potential to increase weeds, at least in the short 

term, than unburned areas. The conclusion should be that while fire is a 

good thing, it must be carefully managed to prevent new infestations of 

invasive plants. This should indicate that cumulative impacts should be 

avoided, i.e., when an area burns, grazing and logging should be deferred 

until vegetative recovery. 

Chapter 3 of the FEIS now reads, “Fire 

initiates succession in a plant 

community.” Fire can initiate primary 

and/or secondary succession, but this 

point is not particularly relevant to the 

discussion. 

Resting an area after a burn is a 

prevention measure available to 

managers in all alternatives. 

Table 3-5 (Ch 3-97), gives roadsides only second priority treatment. I 

feel that roadsides are often the first area of infestation and cooperation 

between the USFS and the local highway departments is essential in 

order to catch the invasive weeds before they spread to areas that are 

much more difficult to treat and are much less noticeable. 

The priority for roadsides given in the 

DEIS is appropriate. The DEIS 

acknowledged the need for cooperation 

between the Forest Service and other 

agencies to reduce the spread of 

invasive plants. 

The Final EIS should display the estimated comparative acreage on 

which activities that favor invasive species introduction, establishment, 

and spread take place, e.g.: Livestock grazing Off-road driving for 

recreational purposes (e.g., for dispersed camping. Roadside ground 

disturbance (e.g., the acreage based on 15 feet on either side of all roads 

and motorized routes)o Heavy equipment driving off-road for operations 

authorized or conducted by the Forest Service Tree-cutting ground 

disturbance For each of those activities, the standards that are applied to 

that activity should be displayed. Without such a chart, there is no way 

for the public to readily see the degree to which Region 6 is addressing 

invasive species. 

The DEIS discussed how various land 

use activities can contribute to the 

establishment and spread of invasive 

plants. The DEIS also evaluated how 

effective each alternative would be in 

reducing the risk of this actually 

occurring. The “estimated comparative 

acreage on which activities that favor 

invasive species introduction, 

establishment, and spread take place” 

does not necessarily indicate the 

effectiveness of each alternative 

because mitigation other than avoiding 

the activity could effectively reduce risk 

from the activity. The standards are 

already explicit in terms of the activities 

to which they apply. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-85 

Table 6. Comments and Responses about Invasive Plants and Mechanisms of Invasion

Comment Response 

As a general comment, it was hard to compare the effects or 

reasonableness of each alternative's impacts on land use because the 

document does not clearly rank which human activities are the greatest 

threats to the spread of invasive plants. For example, if non-weed free 

hay used by horse packers is only responsible for a negligible percentage 

of the weeds in the forests, then placing a restriction on using such hay 

would seem much more unreasonable than if it is, in fact, a major source 

of weeds. Similarly, washing vehicles is expensive and inconvenient, but 

if doing so will save millions of dollars over the long-term because cars 

are a major source of weeds, then such a measure might be reasonable 

and cost-effective -or even required for success. While the DEIS is right 

to propose limitations on human activities that need to be addressed to 

successfully control weeds (e.g., OHV's, grazing, weed-free hay, general 

land disturbance, etc.), the problem is that there is little data in the DEIS 

to support a rationale for choosing one restriction or mitigation over 

another (if you don't know how bad a certain activity is, how can you 

determine how aggressively it should be managed?). Therefore, we ask 

that before proposed land use restrictions are assigned to each alternative 

(which appears to have been done somewhat randomly in the current 

document), that the DEIS disclose, according to the requirements of 40 

CFR 1502.22 and 40 CFR 1502.24, a baseline level of information on the 

relative threat levels presented by each human activity so that the public 

can base its comments on the most relevant data. 

The proposed Forest Plan management 

direction (including DFC, goals, 

objectives and standards) address 

mechanisms of invasive plant spread 

related to land uses and activities under 

the control of the Forest Service. 

Section 4.2 discusses the relative 

effectiveness of the standards 

(individually and collectively) in 

reducing risk of invasive plant spread. 

The standards may result in 

implementation of mitigation measures 

that reduce risk but do not eliminate the 

land use. The effects on land uses must 

be evaluated against the effectiveness of

each standard. The final decision may 

blend standards from more than one 

alternative in order to balance the 

impacts on land use against the 

effectiveness of a standard in achieving 

invasive plant management goals. 

Integrated Weed (Pest) Management and Non-Herbicidal Treatment Methods

Several commenters addressed the concepts of integrated weed management and encouraged 

the Forest Service to emphasize non-herbicidal treatment methods. 

Literature related to livestock grazing was reviewed and in some cases references have been 

corrected in the FEIS in response to comments about cultural treatments. Standard 6 was 

modified in Alternative B in response to comments about grazing. 

Discussions about non-herbicidal treatment methods were added to the FEIS to ensure they 

are given full consideration. Information about biological agents in Appendix H has been 

updated in response to comments. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-86 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

Aggressive treatment must take priority. Manual treatment or hand 

pulling is not very effective. It is like using a squirt gun to try to 

extinguish a house fire. Biological control methods are a little more 

effective than manual treatments but the real success will only come by 

repeated use of effective herbicides. Spraying at the right time with 

effective herbicides is going to be the only way that you have that you 

have a chance to get on top of this invasive plant problem. Prevention and 

awareness programs all help in this battle to fight invasive weeds but will 

not be the solution to this growing problem. 

There is no better way to create a healthy growth on national lands than 

to judiciously use herbicidal controls. Manual and biological controls are 

fine where they can be cost-effectively used, but herbicidal spraying is 

easily more effective than those labor intensive measures. 

The Preferred Alternative includes 

emphasis on both prevention and 

treatment/restoration. None of the 

alternatives rely on prevention alone 

or eliminate all herbicide use. 

I favor biological controls adequately tested. Testing requirements for biological 

controls are addressed in Chapter 3 of

the EIS. Nothing that hasn’t been 

tested and approved by APHIS would 

be used as per Standard 14 in all 

alternatives. 

As determined by water testing on private land right here in Elk River 

watershed, herbicides sprayed up hill and away from the river produced 

drift and erosion into feeder streams and testable amounts entering the 

river. On the other hand, over the last two decades, Elk River's roadside 

vegetation on many miles of Elk River Road (county road from Mile Post 

4 to forest entry and all the way deep into the forest along USFS roads) 

has been adequately managed by mowing. Don't poison our fish, don't 

kill our fishing industry. Don't poison our forests, don't kill our tourism 

industry. IPM works. Use it. 

All alternatives incorporate IPM 

principles and practices. Effective, 

non-herbicide methods are approved 

in all alternatives. 

We are far too dependent on chemicals. We are still learning about 

chemicals; how they interact with each other and the environment. Most 

man made chemicals have only been in use since World War II, which 

isn't very long. I ask the Forest Service to please use non-chemical means 

to eradicate weeds in an area that has not seen chemical use. There are no 

quick and easy fixes. I 'expect' the Forest Service to exhaust all [non] 

chemical means of control before even contemplating chemical use. 

The alternatives include management 

direction to address this public issue. 

The Proposed Action would require 

managers to provide rationale for 

herbicide use. Alternative B would 

only utilize herbicides as a last resort. 

The rationale for the selection of 

alternatives will be in the Record of 

Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-87 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

In the first three paragraphs of the "Livestock Grazing" section on page 

3-15, the mechanisms by which cattle grazing contributes to invasive 

plant establishment and spread are well explained. Immediately 

following the third paragraph, the statement is made, without any 

supporting citation, that "prescribed grazing, when properly designed and 

implemented, can be used as a tool to maintain healthy and vigorous 

vegetation that is capable of resisting invasion." However, a research 

study (Sheley et al. 1997) is referred to later in the same paragraph as 

documenting that "...establishment of diffuse knapweed was enhanced 

only when defoliation of native bluebunch wheatgrass exceeded 60%; in 

many undefoliated plots, knapweed density was higher than where 

moderately grazed. Periodic grazing appeared to favor stronger plants, so 

long as they were able to fully recover before the next defoliation." 

There are two substantial problems with using the Sheley et al. (1997) 

paper to support the assertion that livestock grazing can be used as a tool 

to resist invasive plant infestations. First, the Sheley et al. paper was 

based on hand clipping the grasses, livestock grazing was not involved, 

whereas the DEIS discussion states that it was. The final paragraph of 

the Sheley et al. paper clearly states that "...disturbances associated with 

grazing, such as trampling and exposed mineral soil, were not examined." 

In addition, upon examination of Figures 2 and 4 (which display 

increases of knapweed with increasing grass defoliation) in the Sheley et 

al. paper, and a careful reading of the discussion section of the paper, it is 

clear that the primary conclusion of the study was that "diffuse knapweed 

successfully established on both the bluebunch wheatgrass and crested 

wheatgrass sites without grass defoliation," not that clipping of grasses 

(or grazing) provided any protection from knapweed invasion. Protection 

of grasslands from knapweed invasion by livestock grazing was not a 

hypothesis tested in the study. Thus, the interpretation of the Sheley et al. 

(1997) study does not support the assertion of the DEIS that livestock 

grazing can be a tool for resisting invasive plant invasion. 

Literature related to livestock grazing 

was reviewed and in some cases 

references were corrected in the FEIS 

in response to this comment. 

Additional citations have 

incorporated into the discussion. 

NOAA Fisheries is concerned that the discussion of grazing in paragraph 

two on page 3-16 may lead those using the EIS as management direction 

(i.e. National Forest managers) to get the mistaken impression that 

general cattle grazing can be considered as an invasive plant control tool. 

If livestock grazing is later found not to be an effective tool to control 

invasive weeds, the FS could increase the use of herbicides and thereby 

expose ESA listed fish to greater adverse affects than expected. 

Herbicide use would not be the 

assumed response if livestock grazing 

was expected to be an effective 

treatment method but was later found 

ineffective. Cultural methods would 

be used rarely (estimated at 1 to 5 

percent of annual invasive plant 

treatments) in all alternatives. If 

these methods were found to be 

ineffective, a variety of other 

methods would be available. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-88 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

The subsequent paragraph in the DEIS notes that "proper" grazing of 

some invasive plants by sheep and goats is the grazing component of 

"cultural" treatments considered in the DEIS as an invasive plant control 

tool. In addition, the paragraph states that grazing treatments are 

described in greater detail in Chapter 4.1. NOAA Fisheries could not 

locate any discussion of grazing treatments in Chapter 4.1. However, 

page 3-82 does contain some information on grazing as a cultural 

treatment. The more detailed discussion, on page 3-82, made clear that 

the cultural treatments by grazing animals is intended to be a tool used 

carefully "...based on selecting the appropriate grazer for the target 

invasive species." In addition, the ability to manage "...larger infestations 

on the forest is limited because of the difficulty of maintaining and 

managing the animals. A long-term commitment to small ruminant 

grazing is necessary for effective invasive plant management." 

Grazing is discussed in the EIS 

Chapter 3 and in Appendix J, The 

Effects of Non-Herbicide Methods of 

Invasive Plant Treatment on Wildlife, 

Fish and Plants. Corrections have 

been made to the document to 

address this comment. 

I would live to see more consciousness around invasives, and crews 

dispatched to problem areas in a timely manner, to pull invasives before 

they go to seed, and to destroy the young plants with hoes and such 

before they are as large and difficult to deal with. 

This technique is available under all 

alternatives. 

Forest Service Road 3310 that meets the main road at the corner of our 

property has much less scotch broom in the past as a result of mechanical 

removal followed by traffic curtailment with water bars. Further control 

of sun-loving invasive weeds has been accomplished with less general 

brush removal-some invasive plants are being shaded out by brushy 

salmonberry, thimbleberry, and vine maple, etc. 

Mechanical removal is a technique 

available under all alternatives. 

Objective 2.2 addresses retaining 

shade as well as Standard 5, 

Alternative B. 

We understand that all alternatives propose the use of herbicides (even 

those untested or known to have deleterious effects on non-targeted insect 

species) and exotic biocontrol agents. At the very least, each project 

should be site specific and open to other alternatives for control such as 

hand pulling, mowing, burning, grazing by goats, etc. Expertise in 

experimenting with control such as has been gained by the Nature 

Conservancy should be used in site-specific situations. 

The EIS directs site-specific analysis 

in NEPA documents. Alternatives 

control measures are discussed in 

Chapter 3 and in Appendix J, The 

Effects of Non-Herbicide Methods of 

Invasive Plant Treatment on Wildlife, 

Fish and Plants. 

Pesticides simplify ecosystems. The healthiest forests are the most 

complex, biologically. Predatory insects, restrictions on grazing, timed 

burning or mechanical harvest are better alternatives, dead invasives are 

not the same as healthy forests. 

This subject is adequately covered in 

Chapter 4. Integrated Weed 

Management (IWM) philosophies are 

incorporated into all alternatives. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-89 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

Please don't rely on herbicides when better methods are available. 

The EIS should prioritize and emphasize the use of biological controls 

where effective or potentially effective as part of an integrated control 

strategy. 

Integrated pest management needs to be given the highest priority 

regardless of which alternative is selected. 

ISDA supports the use of Integrated Weed Management, which is the use 

of all available and feasible weed control techniques in an organized, 

coordinated, and mutually supportive manner. Major components of 

IWM include education, plant inventories and surveys, prioritization of 

weed problems, review of all available weed control techniques for each 

weed problem, selection and integration of effective control techniques as 

necessary. Weed control techniques used in IWM are often categorized as 

mechanical, such as hand pulling; cultural such as tillage; domestic 

animal, such as controlled grazing; chemical; and biological. Limiting the 

availability of tools that may be used to control weeds can severely 

reduce control activities effectiveness. 

Herbicides are one tool of many 

available. When better methods are 

available they would be used. 

Biological controls are included in all 

alternatives as part of an Integrated 

Weed Management (IWM) strategy 

(see Chapter 3 for details). All of the 

alternatives follow IWM principles 

and allow a range of effective tools. 

I want to see our public agencies take a hands on approach, hire people to 

manually remove these infestations. 

There are also great opportunities for the needs of invasive weed 

prevention and the staggering economy of our region to be united in the 

great effort of hand pulling. 

All alternatives incorporate IWM 

principles and practices. Effective, 

non-herbicide methods are approved 

in all alternatives. 

3.3.2 Treatment and Restoration. The section is well written, adequately 

reviewing the pros and cons of each control method; however; risks of all 

control methods should have been reviewed in this section. There are 

environmental risks to hand pulling such as trampling desired species and 

soil compaction. Environmental risks are associated with use of 

prescribed burns, including release of invasive species, death of nontarget species and wildfire. There are also risks to the environment from 

mechanical control including spread of invasive species, species shift, 

soil compaction and environmental contamination by oil and fuel. For 

the public to fully understand the risk and benefits of the proposed "tools" 

including herbicide use, the risks of all other control methods should be 

equally evaluated. 

Appendix J, The Effects of NonHerbicide Methods of Invasive Plant 

Treatment on Wildlife, Fish and 

Plants has been added to the FEIS to 

discuss these effects. The EIS 

chapters focus on the effects that are 

of primary public concern. 

4.6.6 Tendency for Standards to Affect Range Allotments and Permittees

Grazing is an important IPM tool for invasive plant management. In 

grazed allotment areas, no ability to make suitable changes in grazing 

locations, timing, intensity and outputs will render all other management 

tools useless and increase the cost of invasive plant containment while 

further degrading the environment. Flexibility for adjustment stated in 

Alternative B is needed. The EIS stated in 3.3 Invasive Plant 

Management "Moving an undesirable plant community towards a desired 

state takes a repeated, sequential process of: designing a disruption to the 

undesired successional pathway". Altering grazing that has become a 

disruption causing an undesired successional pathway will be key to 

invasive plant control and prevention. 

The grazing standard (6) in 

Alternative B was adjusted to provide 

more clarity and implementability. 

The analysis for Standard 6 has also 

been edited for clarity in response to 

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

Appendix A-90 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

Recent research on the efficacy of Acetic acid (vinegar) as a weed control 

have shown poor results for perennial and biennials. In fact the 

concentrations required to cause any damage at all are high enough to be 

a health hazard for the applicators and may cause damage to the soil 

biota. The KC noxious weed control board does not recommend Acetic 

Acid as an effective weed control tool. 

Acetic acid was removed as a tool 

considered for use in the EIS. 

The DEIS does not describe the various methods for controlling the most 

problematic plant species, whether they are currently or anticipated to 

become the most problematic. Not all plant groups respond the same to 

herbicide application, for example. Some may be knocked back only to 

resurrect in a year or two. Others require considerably more herbicide and 

stronger adjuvants than "usual" before a dose is lethal. An analysis at the 

programmatic level, for example, could describe plants by the 

characteristics that most influence the ability and the means to control it 

by providing guidance such as the following: "Herbicides will not be the 

control method of choice for invasive plants that spread by profuse seed 

production such as purple loosestrife, et cetera (listing other species with 

this characteristic in R6). These seeds are relatively long-lived and 

germinate sporadically, therefore the seed bank of an established 

population of such a plant is at little risk since it is not affected by a 

control program that removes only the current year's standing crop of 

growing plants. Plants should be removed before they go to seed and the 

entire plant including all roots and root tips must be removed. Plant 

locations should be flagged and rechecked every year." 

Discussion was expanded on this 

subject in Chapters 3 and 4. 

Biological Controls cannot be adequately tested. All Action Alternatives 

support the use of exotic bio-controls. It is believed that since these 

plants do not have natural enemies, then perhaps we could import these 

predators as well. The problem with this line of logic is that there are no 

scientific means to ensure that the imported organism will restrict itself 

exclusively to the plant in question. One simply cannot devise a setting as 

complex as a forest ecosystem, nor ascertain that the organism will not 

threaten native plants as well. 

Biological controls have been tested 

adequately and used effectively for 

many years by APHIS. Negative 

effects have occurred and were 

disclosed in the DEIS, however in 

many cases benefits outweigh risks. 

It is very disappointing to hear that the Forest Service may be turning to 

herbicides to control invasive plants. Not only is the Forest Service a 

guardian to what is left of natural habitat it also has the potential to be a 

powerful leader in invasive species control. Controlling vehicle access & 

utilizing alternatives to pesticides such as hot sugar foam are examples of 

actions that could address the invasive problem without using chemicals. 

I hope that you will do what it takes to be the best guardian possible. 

Herbicides are one tool of many 

available. In the DEIS, controlling 

vehicle access is discussed as a 

prevention practice, and use of hot 

foam is discussed among many other 

treatment methods. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-91 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

Integrated Pest Management definition lacking. While Appendix F assists 

in understanding how the EIS might affect Forest Plans, the Forest Plans 

themselves are such a hodge-podge of conflicting rules that it is difficult 

to make sense of the EIS. As an example, consider the statement in the 

EIS on p. 2-5 that "current policy supports an Integrated Pest 

Management Approach [IPM]". Which policies, what is meant by 

support, is there a legal mandate, and what specifically is IPM are all left 

for guesswork by the decision-maker. The EIS should define IPM in no 

uncertain terms. It is plainly obvious that the Forest Service is misusing 

the term IPM to the detriment and confusion of the public. Without a 

definition of IPM, the EIS lacks authority to propose alternatives. We 

suggest that you consider using the following definition, which does at 

least have the merit of some research: True IPM is an interdisciplinary 

system of techniques for controlling invasive plants that is both practical 

and environmentally sensitive. Policies and plans should rely on 

objectives to control invasive species based on a rational decision-making 

framework, which can reasonably attain stated goals without significant 

negative impacts. Such a framework could be based on principles of true 

Integrated Pest Management, and its plant counterpart, Integrated Weed 

Management, or IWM (Wooten and Renwyck, 2001, Wooten, 1999b): 

Components of a true IPM program should include (Appendix A):" 

monitoring" integration of multiple objectives" integrated strategies" 

periodic re-evaluation. A wide variety of pest control options is 

considered in true IPM with preference for: " Practicality -programs 

should be effective and cost-efficient." Environmental sensitivity -

programs should reduce environmental risks. Please correct the EIS by 

defining IPM. 

The section on Integrated Weed 

(Pest) Management has been edited in 

the FEIS to improve clarity in 

response to this comment. 

Grazing controls are not adequately analyzed. The promise of using 

grazing to reduce invasive plants was presented in simplistic level, and 

did not give details about the difference between trained weed-eating 

goats and a wandering herd of cattle. Lacking was any discussion of 

breed of goats, or costs, or management requirements and limitations, 

how long it would take, whether return visits were necessary, how the 

type of stomach and teeth affect the species. For instance angora goats 

reduced leafy spurge (Euphorbia esula) biomass by 44% in 3 years in 

North Dakota (Sedivic and Maine, 1993). The cited references lead one 

to believe that the Team is not familiar with the details on the use of 

grazing to reduce invasive plants, and would benefit from consultation 

with a range manager. 

FEIS Chapters 3 and 4 have been 

edited regarding use of grazing for 

invasive plant management in 

response to this comment. 

Scoping comments were not considered in the specialist report. It does 

not appear that the Team gave much consideration to public comments 

submitted during scoping. A list of about fifty different control methods 

for invasive species was submitted during scoping was apparently not 

considered by the Team 

(www.kettlerange.org\weeds\reference\control.html). For instance, the 

EIS did not even consider treatments using hot water, steam, infra-red 

light, tillage (a.k.a. road grading), The description and analysis of the use 

of fire to impact invasives (both positively and negatively) was too short 

and didn't give enough information. It certainly didn't have the depth 

sufficient to conclude, as it did, that only fire combined with herbicide 

would be effective. 

The treatments listed in this comment 

were considered in the DEIS and 

supplemental discussion was added to 

the FEIS about non-herbicidal control 

methods. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-92 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

The EIS Team should propose a means of managing widespread 

invasives more like a maintenance schedule than an eradication schedule. 

Many weeds are known to follow a lag-log curve in going from minor 

species to major ones in a landscape. While it is appropriate to try and 

eradicate weeds in the lag phase, it is economically unfeasible to try and 

do so for large acreages. However, it may still be worthwhile to control 

these species in a limited fashion, either within localized areas or by 

maintaining them as a non-dominant component. We recommend that 

you consider different management strategies for species in lag phase 

than in log phase. The appropriate means to determine whether a species 

is in lag or log phase is to monitor control costs and when these exceed 

the budget, then remove those (out of control) species to a maintenance 

schedule. Otherwise you will just be throwing money away. A good 

example of this is common Crupina along Lake Chelan. The current 

spending of $16 million, I believe, is about at the limit of what can be 

brought to the fight. Beyond this we have to admit defeat in eradicating 

the plant, but if we succeed, then other species can benefit from that 

money in future budgets. But even if we lose the battle, there will still be 

a need to keep Crupina in a maintenance program, to halt its spread and 

research new methods to control it. 

Discussion regarding strategies for 

invasive plant management 

considering population dynamics was 

expanded in the FEIS Chapters 3 and 

4. 

The use of approved natural enemies as classical biological control agents 

is encouraged wherever invasive plants are unlikely to be controlled by 

other methods. Numerous natural enemies are listed in Appendix H that 

are not approved for use in the U.S. Most of those are accidental 

introductions, which are not considered as Classical Biological Control 

Agents of weeds. These should be deleted from the table as they go 

against the International Code of Best Practices for Biological Control of 

Weeds (Balciunas and Coombs 2004).Miscellaneous Clarifications: The 

knapweeds can all be included together, as most of the agents attack both 

diffuse and spotted knapweeds. The Scotch broom seed weevil has been 

changed from Apion fuscirostre to Exapion fuscirostre. Tamarix should 

be listed as salt cedar, and the leaf beetle Diorhabda elongata has only 

been approved for one site in Malheur County as of 2004. Future release 

sites are pending USFWS approval. 

Appendix H discloses all biological 

control agents known to occur within 

Region Six. Table 2-3 lists the 

criteria for choosing from this table. 

Appendix H lists primary hosts. 

Entries for Scotch broom seed 

weevil, tamarix and salt cedar leaf 

beetle have been changed to respond 

to this comment. 

The DEIS is lacking needed specific analysis of a complete listing of all 

biological control agents proposed for use and the exact criteria by which 

they were selected. 

The DEIS is lacking needed specific analysis of examples of known 

biocontrol escapes from management control which affect native plants 

and food webs, known other effects of biocontrols, knowledge gaps 

relating to the use of biocontrols--with enough specific detail to draw 

well-informed conclusions about the potential risks of different 

biocontrols proposed for use. 

All biocontrol agents known in 

Region Six are listed in Appendix H. 

Criteria for choosing from these 

agents are given in Table2-3. 

The FEIS now contains Appendix J, 

The Effects of Non-Herbicide 

Methods of Invasive Plant Treatment 

on Wildlife, Fish and Plants. 

Included is an analysis of information 

gaps and known impacts to non-target

plants and food webs from biological 

control agents. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-93 

Table 7. Comments and Responses about IWM and Non-Herbicidal Treatments

Comment Response 

For the selected alternative, it will be useful to incorporate a variety of 

approaches. In particular, it will be helpful to include some biological 

control techniques or other potentially low impact efforts so that their 

effectiveness can be better understood. It is likely that herbicides will be 

needed, but it is also important to study the alternatives to herbicides so 

that this becomes an iterative process. Thus, over time, management 

techniques tried in small areas that are found to be less damaging to the 

environment, can be expanded to larger areas. 

The DEIS considered methods other 

than herbicide. The Proposed Action 

would require managers to document 

rationale for use of herbicide and 

Alternative B requires herbicide use 

be a tool of last resort. All 

alternatives would require projects to 

utilize low risk, effective treatments. 

Standards (General)

Many readers provided general comments about the merits of the standards viewed 

collectively. A common theme is the call for greater emphasis on prevention. One individual 

asserted: “the least costly and most effective strategy of weed control is to adopt standards 

aimed at modifying the activities that cause invasive plants to be introduced to USFS lands.” 

Another common complaint is that the standards are too vague, demonstrating a lack of 

commitment to the specific prescriptions that will be needed to reduce weed spread resulting 

from land management activities. Respondents ask for details on how silviculture, timber 

harvest, fuel reduction projects, monitoring and management for roads, range, wildlife, and 

fire will be modified to enhance prevention. 

The greatest attention was focused on the lack of specific direction regarding livestock 

grazing, road construction and off-road vehicle use. 

NOAA Fisheries criticized the Forest Service for not considering biological diversity and 

function or developing long-term vegetation goals in the development of standards. They 

maintained that “without management direction provided by the Region to the Forests, in the 

form of standards speaking specifically to ecosystem protection, long-term vegetation goals, 

and inventory and monitoring, no ecosystem-wide strategy would exist which could result in 

uneven levels of weed management and protection of ESA-listed species and their 

habitats...If the FS proposed vegetation management programs will not be driven by 

ecosystem-level protections, the risks to threatened and endangered species and their 

ecosystems may be underestimated.” 

The Forest Service revised several of the standards in response to these comments. The 

Regional Forester may select an alternative that blends standards from multiple alternatives; 

the rationale for the final decision will be in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-94 

Table 8. Comments and Responses about Standards (General)

COMMENT RESPONSE 

The proposed action and Alternative B do speak to 

enforceable standards but my reading finds these sections 

nearly as vague and indeterminate as that of the common 

alternative language on Desired Conditions. In the Final, I 

would like to see clear language and firm commitment to 

specified standards. As a specific example of vague and 

unenforceable language, the Draft speaks of Forest Service 

and livestock permittees "cooperating" in deciding what 

prevention measures (if any) will be implemented. 

 Several changes were made to the standards in the 

FEIS to improve their clarity and implementability. 

If Standards are said to be "binding", but simply a Forest 

Plan amendment for individual projects can "modify, 

remove, or waive application of the standard", then 

Standards are not binding. The DEIS has made a 

worthwhile effort to outline Standards and Guidelines for 

Weed Management, and Standard requirements should 

remain binding. 

Forest Plans may be amended/revised over time to 

remain up-to-date with new science findings and 

unanticipated resource situations. This should not 

imply that the standards are not “binding.” 

We are discouraged that the DEIS lacks specific 

prescriptions for reducing and eliminating weed spread 

from livestock grazing, roads and off-road vehicle use on 

Forest Service lands and from other activities such as postfire treatments. It is, in fact, impossible to know whether the 

minor management requirements that are contained in the 

document - weed-free feed in Wilderness, washing tires on 

heavy equipment - will have any impact on reducing 

invasive species while these landscape-scale activities 

continue unabated. Region 6 should systematically 

determine what activities are associated with the most 

invasive species, how those activities contribute to weed 

spread, and then develop prescriptions that prevent invasion 

before more drastic measures are required to control weeds 

and restore landscapes. 

 Standards 4, 6, 7, and 10 have been revised to include 

more specificity in response to this and similar 

comments. 

Add to proposed action: Minimize herbicide use and 

prohibit broadcast spraying in riparian reserves and in 

known amphibian habitat (including breeding, rearing, and 

overland dispersal areas). Avoid use of herbicides with 

adverse effects on aquatic species and amphibians. 

These ideas are included in Alternative B. The 

Regional Forester has the option of combining elements 

of more than one alternative in the final decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-95 

Table 8. Comments and Responses about Standards (General)

COMMENT RESPONSE 

A saner approach would be to stop the sources of exotic 

weed introduction and dispersal through comprehensive 

public education, vehicle inspections and cleaning, less 

overall disruption of the ground (which encourages exotic 

invasion), avoidance of heavy equipment/vehicle use in 

known weed populations, the mandatory use of weed-free 

feed for pack animals and livestock entering public lands, 

etc. Numerous alternative methods of exotic weed 

eradication and control exist, including hand-pulling, 

pruning, mowing, pruning, grazing by goats, etc. 

Maintenance and restoration of tree canopy closure and 

vigorous native plant communities should also be 

emphasized to discourage exotic weed establishment and 

spread. 

These ideas are included in the range of alternatives. 

The Regional Forester has the option of combining 

elements of the alternatives in the Record of Decision. 

I urge you to reconsider using pesticides to control invasive 

plant problems! If you want to solve the problem of 

invasive plants in our national forests consider changing the 

way your agency manages livestock grazing, off-road 

vehicle use, timber harvest and road construction and use -

all of which currently encourage invasive weeds on the 

national forest. Stop the cycle now by good management 

practices. 

These ideas were addressed in Chapter 2.7 of the DEIS. 

I want the Forest Service to identify causes of weed 

infestations, and deal with them, rather than having to deal 

with the consequences. 

The causes of invasive plants introduction and spread 

were discussed in DEIS Chapter 3.1. 

Please help protect our forests from invasive species by 

keeping livestock and roads out of them. It's dangerous and 

a waste of our taxpayer dollars to rely on herbicide 

management. 

The purpose of this EIS is not to eliminate grazing and 

roads from the National Forests, but to improve our 

ability to reduce the introduction and spread of invasive 

plants. This topic was discussed in DEIS Chapters 1 

and 2. 

Please restrict [herbicide] spraying to the minimum required 

to fix serious problems, and enact management priorities 

that actively prevent invasions without the further use of 

herbicides. 

These ideas are included in Alternative B. 

Proposed Action standards for invasive species management 

in Region 6 will place no restrictions and will have "No 

Direct Effect" on "road closures and loss of off-highway 

vehicle access;" and will place no restrictions and will have 

"No Direct Effect" on "grazing locations, timing, intensity, 

and outputs" (DEIS 2-33). In other words, Region 6 is 

proposing to leave utterly intact the two major causes of the 

4,600 acre-per-day spread of invasive species on federal 

lands in the West, including the PNW forest lands. 

Standards 6 and 8 have been rewritten to improve 

clarity and enforceability. The analyses in Chapter 4 

have also been modified. 

For example, Alternative B should include under 

"Prevention Measures" such as: Identify lands at risk to 

weed invasion, and limit or eliminate livestock grazing in 

these areas in order to prevent weed invasion and spread. 

Identify better condition native plant communities, and limit 

or eliminate livestock grazing in these areas in order to 

prevent weed invasion and spread. 

The Forest Service considered this suggested wording 

and found it is too subjective to be enforceable as a 

standard. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-96 

Table 8. Comments and Responses about Standards (General)

COMMENT RESPONSE 

Include clear standards to ensure forest management 

activities (e.g. grazing, OHVs, roads) do not create 

conditions conducive to the introduction and spread of 

weeds. This will by necessity require grazing to be 

restricted to ensure maintenance of diverse communities of 

vigorous plants that can best resist invasion by weeds. 

Standards 6, 8 and 10 have been rewritten to improve 

clarity and enforceability. The analyses in Chapter 4 

have also been modified. 

In vegetation management projects such as fuel reduction 

projects, retain canopy to suppress weeds, minimize soil 

disturbance, and avoid new roads. 

These ideas are included in Alternative B. 

Use concepts of bio-complexity as a tool to prevent 

invasives (e.g. avoid homogeneity). 

This topic was discussed in DEIS Chapter 3.2. 

There is not enough detail of which existing management 

activities do or don't include prevention or management of 

invasive plants. We infer, but cannot be completely sure, 

that the EIS intends to modify existing management 

activities associated with the control and prevention of 

spread of invasive species, including activities of 

silviculture, timber management, road management, range 

management, wildlife management, fire management, and 

monitoring. 

Current direction was discussed in DEIS Chapter 2.3. 

We are discouraged that the document lacks specific 

prescriptions for reducing and eliminating weed spread 

from livestock grazing, roads and off-road vehicle use on 

Forest Service lands. Indeed, it is impossible to know 

whether the minor management requirements that are 

contained in the document--weed-free feed in Wilderness, 

washing tires on heavy equipment-will have any impact on 

reducing invasive species white these landscape-scale 

activities continue unabated. Region 6 should systematically 

determine what activities are associated with the most 

invasive species, how those activities contribute to weed 

spread, and then develop prescriptions that prevent invasion 

before more drastic measures are required to control weeds 

and restore landscapes. 

 Standards 6, 8 and 10 have been rewritten to improve 

clarity and enforceability. The analyses in Chapter 4 

have also been modified. 

On Appendix A-22 you say that reseeding disturbed areas to 

prevent weeds is not a substantive issue. Please explain how 

re-seeding is not a substantive issue and how it does not 

relate to the effect of the proposed action? Isn't the proposed 

action to eliminate the spread of non native and noxious 

weeds? And isn't re-seeding after a disturbance a main 

factor in controlling the problem? 

Reseeding to prevent weeds is indeed a substantive 

issue. Appendix A-22 has been re-written to correct 

this error. 

Mandate that after a logging operation a reseeding program 

in implemented right away by the timber companies. They 

must pay for the cost of buying native seeds. If native plants 

are re-introduced right away they may help deflect the 

invasive species. 

Reseeding is already a requirement of timber sale 

contracts. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-97 

Table 8. Comments and Responses about Standards (General)

COMMENT RESPONSE 

Alternatives such as prevention (ie roadless rule) avoiding 

clearcuts, leaving virgin forests or undisturbed forests intact 

are just some examples that need to be implemented as well 

as off road vehicles banned in areas where the weeds have 

been eradicated or have not begun. 

The causes of invasive plants introduction and spread 

are discussed in Chapter 3.1. It is not the purpose of 

this EIS to eliminate grazing and timber harvest from 

the National Forests, but to improve our ability to 

reduce the introduction and spread of invasive plants. 

This topic was discussed in Chapters 1 and 2. 

We propose that road building practices be revised to 

minimize impact on ecosystems. 

Standards 2 and 3 apply to road construction and will 

help minimize the introduction and spread of invasive 

plants. 

Additional Treatment Standards Recommendations: A rapid 

response element should be included in any treatment plan. 

If a small or easily confinable infestation is discovered, the 

tools should be in place to allow land manager to take care 

of this situation immediately. This includes spot spraying 

and all other control methods. This ability will enable land 

managers to stop new infestations before they are able to 

entrench and become more costly, destructive long term 

problems. 

Rapid treatment response and prioritization of treatment 

sites was discussed in DEIS Chapter 3.3. 

Weed disposal is not mentioned. Comprehensive disposal 

plan should be established. Weeds that have been hand 

pulled should be disposed of in garbage bags and placed in 

land fill if they are in seed or are known to propagate 

vegetatively. They should not be added to mulch piles. 

Proper disposal of handpulled plants is important. If 

pulled weeds are not disposed of properly the situation 

can be exacerbated, rather than improved. It is standard 

procedure for handpull projects on National Forests to 

follow this procedure. 

Areas controlled must be revegetated to insure success. Restoration/revegetation of treatment sites was 

emphasized throughout the DEIS and specifically 

discussed in Chapter 3.3. 

Standard 1: Address prevention of invasive plant introduction, establishment and 

spread in land management assessments/analyses

Commenters stated they preferred Alternative B and expressed a desire for greater emphasis 

on prevention. One respondent favored the provisions in Alternative B because “they give the 

USFS a chance to spell out exactly what is needed for healthy ecosystem management.” 

Standard 1 has been expanded to specifically require that vegetation management plans and 

recreation management plans address the prevention of invasive plant introduction, 

establishment and spread. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-98 

Table 9. Comments and Responses about Standard 1

COMMENT RESPONSE 

Alternative B requires that USFS documents address the 

conditions that lead to invasion, and emphasize maintaining and 

restoring healthy ecosystems as a first line of defense against 

plant invasions. We support the Alternative B provisions because 

they give the USFS a chance to spell out exactly what is needed 

for healthy ecosystem management 

All alternatives follow direction contained 

in Executive Order 13112, Invasive 

Species, which already directs Federal 

Agencies to disclose the effects of land 

management actions on the spread of 

invasive species. Alternative B further 

emphasizes this requirement by making it a 

Forest Plan standard. 

The Forest Service must look to stronger prevention-based 

standards to discourage invasive plants. More funding need to be 

allotted to monitoring and prevention, not short term, shortsighted 

use of herbicides. 

This comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Please consider life and health while you devise invasive weed 

control programs. Let's practice prevention instead of poison in 

our forests 

Human health and safety is discussed in 

Chapter 4.5 of the EIS. 

As a farmer living amidst commercial and federal timber lands, I 

am especially concerned with the rampant spread of noxious 

weeds, knapweed, thistles, scotch broom, ivy & blackberries to 

name the worst, which spring up in every cut. Personal 

observation of units that have been "pre-emergent" sprayed with 

herbicides shows me that spraying does no good. The weeds just 

do better than the baby trees. Logging companies and 

recreationists must be held accountable for the spread of weeds 

on vehicle tires, and must be charged for or forced to do manual 

release and weed killing. 

 Standard 1 has been expanded to 

specifically require vegetation management 

plans and recreation management plans to 

address prevention of invasive plant. 

Standards 2, 3, 4, 5, 9 and 10 also address 

issues related to logging practices and 

recreation. 

The impact that logging has in spreading invasive plants is not 

sufficiently documented in the DEIS. Factors that cause logging 

to be associated with invasive plant outbreaks include increased 

irradiance at forest floor, soil disturbance, exposed mineral soil, 

and human and vehicle traffic. Questions that the USFS should 

answer in regard to this EIS include the following:" What 

percentage of USFS thinning projects have created a greater than 

8% irradiance? " What percentages of USFS thinning projects 

have created exposed mineral soils " How much mineral soil has 

been exposed in these thinning projects? " To what extent have 

increases in mineral soil exposure and irradiance led to invasive 

plant outbreaks in USFS Thinning projects? " This information is 

not provided in the EIS. The USFS should try to create standards 

that translate the best available scientific evidence into policy. 

The conclusion that thinning creates less ground disturbance is 

anecdotal. On Tonasket District of the Okanogan NF, thinning 

proposals are accompanied by piling and burning, which cause 

large amounts of soil disturbance. Furthermore, salvage sales and 

restoration forestry both operate on ground that has already been 

heavily disturbed. The conclusion should be that forestry and 

associated road-building is potentially just as damaging to the soil 

as it has ever been. 

These questions would most appropriately 

be addressed in site-specific analysis for 

thinning projects. Standard 1 in all 

alternatives requires that prevention be 

considered in vegetation management 

projects. The DEIS acknowledged that 

thinning tends to leave more canopy and 

therefore is less subject to invasive plant 

establishment than regeneration 

harvesting. At the project scale, associated 

activities such as road building would be 

considered for their increased potential for 

invasion. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-99 

Table 9. Comments and Responses about Standard 1

COMMENT RESPONSE 

Several concerns arise out of the comparison of the alternatives. 

First, prevention and treatment are evaluated separately with a 

much greater emphasis on the effect of treatment (i.e., killing 

invasive plants) than on the effects of preventative measures (i.e., 

preventing invasive plant introduction, establishment, and 

spread)). Thus, the meaning of the phrase "An ounce of 

prevention is worth a pound of cure" is turned on its head in this 

DEIS. Here, the bulk of attention is given to the pound of cure 

rather than the ounce of prevention. 

Specifically, though there is great emphasis on the success of 

alternative B in preventing the spread of invasive species it is 

summarily dismissed as an option because of its limited choice of 

herbicides. The court in Blue Mountains Biodiversity Project v. 

US Forest Service held that the EA was insufficient because it 

failed to look at the impacts of preventative methods. 229 F. 

Supp. 2d 1140, 1145-46 (D. Or. 2002). The Forest Service clearly 

has the ability to combine the preventive measures of Alternative 

B with the treatments involved in the proposed alternative. There 

is no attempt to balance the effects of prevention and treatment. If 

there is greater prevention less treatment will be needed over 

time. 

Prevention, treatment, and restoration are 

all important aspects of effective invasive 

plant management. These elements are 

analyzed separately and collectively in 

Chapter 4.2. The alternatives as structured 

in the EIS represent a reasonable range of 

alternatives. We recognize that there are 

infinite possibilities for mixing or 

recombining elements of the different 

alternatives. This approach is addressed in 

Chapter 4.2. In addition, the Regional 

Forester has the option of mixing or 

recombining elements of the alternatives as 

she chooses in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-100 

Standard 2: Equipment washing

Most respondents expressed preference for the more stringent provisions in Alternative B. 

The rationale for the final selection of standards will be in the Record of Decision. 

Table 10. Comments and Responses about Standard 2 

COMMENT RESPONSE 

Alt. C -[is preferred] Clarify what is meant by "actions ? 

authorized by the USFS" what does this include? 

“Actions” include all projects conducted by the Forest 

Service and its contractors: plus activities by the public 

or permittees authorized by the Forest Service. 

While ALB B could be very restrictive, impractical, 

impossible to monitor and enforce[,] we think the proposed 

action should be more comprehensive than the present 

statement. 

This comment will be considered and the rationale for 

the decision will be published in the Record of 

Decision.

Standard #2 requires cleaning of heavy equipment that will 

operate off of the "road surface" prior to entering National 

Forest lands. The DEIS contains no definition of "road 

surface," and without such a definition, it is unclear whether 

this applies to vehicles that will travel, for example, on 

closed roads. Furthermore, the standard does not apply to 

vehicles such as pickup trucks or SUVs, which might be 

used to commute to an off-road site, and therefore have a 

greater risk of spreading invasive seeds as they will be 

moving over larger areas of the forest. Finally, the standard 

does not prevent the spread of invasives between sites in the 

National Forest on heavy equipment. The Forest Service 

should adopt the stronger language of alternative B, which 

requires all vehicles that will be used off the road surface to 

be cleaned whenever entering Forest Service lands, and also 

requires the cleaning of all vehicles before leaving the 

project site when operating in areas with a high risk of 

spreading invasives. 

These comments will be considered and the rationale 

for the decision will be published in the Record of 

Decision.

Cleaning of public vehicles is great. But logging trucks or 

any commercial vehicles entering the forest should also be 

cleaned before and after their job. Education can inform and 

encourage recreational users to clean and inspect their 

vehicles. This could be accomplished through the use of 

newspapers and bulletin boards and leaflets at the trail 

heads. 

This comment will be considered and the rationale for 

the decision will be published in the Record of 

Decision.

The Proposed Action leaves intact the policy in Region 6 

National Forests to allow all vehicles, whether Hummers, 

stock trucks, pickups, dirt bikes or RVs, to plow through 

roadside weeds and off-road 300 feet out (i.e., a football 

field's length) from essentially every open road for the 

purposes of camping. Region 6 is having the gnat wash its 

feet while leaving the elephant stampede unhindered. 

These concerns are addressed in Alternative B. The 

rationale for the decision will be published in the 

Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-101 

Table 10. Comments and Responses about Standard 2 

COMMENT RESPONSE 

We see no problem with having a contractor clean their 

equipment prior to entering National Forest System Lands, 

as suggested in the 'Proposed Action', as there is generally 

better access to the necessary tools and water supply. 

However, we do have a concern as to whether the public at 

large will be held to the same standard as the logging and 

forestry community. Are people who operate ATV's, offroad vehicles or dirt bikes going to be required to clean 

their vehicles prior to entering National Forest System 

Lands? Operators of these vehicles, as they are usually 

outside the limits of the road surface, could spread invasive 

plant seed or 'vegetative propagules' just as well as a 

contractors logging equipment. Therefore, we request that 

the final standard also have provisions that members of the 

public would be required to clean any motorized vehicle 

that will be operated outside the limits of the road surface 

prior to entering National Forest System Lands and not 

include the provision requiring equipment be cleaned prior 

to leaving a project site. 

These concerns are addressed in Alternative B. Your 

comment will be considered and the rationale for the 

decision will be published in the Record of Decision. 

[Alternative B equipment and washing standards] would be 

expensive and difficult, if not impossible to meet due to the 

logistics of supplying the cleaning equipment of choice 

(pressure washer) and other supplies, such as a sufficient 

water supply, to a remote location in order to clean several 

pieces of equipment and attendant vehicles...if the cleaning 

requirement ends up in the final iteration, it will create an 

undue hardship on our members who have to fulfill it. 

This comment will be considered and the rationale for 

the decision will be published in the Record of 

Decision. 

Require all USFS Vehicles to have their tires clean and 

include educational opportunities for the public. The 

proposed alternative does not account for the transfer of 

invasive plant materials from one site to another within the 

forest. In order to prevent other USFS vehicles from 

spreading Invasive plants from one project area to another, 

more stringent requirements than those listed in the 

proposed alternative should be adopted. As it states in 

Appendix D, hundreds of seed have been found on a single 

car after traveling forest roads. The requirements of 

Alternative B prevent heavy machinery and other vehicles 

from spreading invasive plants within the forest by 

requiring them to be washed between work sites if a high 

probability of spreading invasive plants exists. In order to 

accomplish the goal of reducing the spread of invasive 

plants the Alternative B requirements should be included. 

The proposal should also carry this logic a step further and 

include educational opportunities for the public so that the 

public can also make informed decisions when driving 

USFS roads. 

Your comment will be considered and the rationale for 

This decision will be published in the Record of 

Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-102 

Table 10. Comments and Responses about Standard 2 

COMMENT RESPONSE 

Standard 2 should not be restricted to heavy equipment. All 

vehicles have the potential to transport invasive plant seeds, 

including off-road vehicles. According to Appendix D of 

the DEIS, hundreds of seeds have been found on a single 

car after traveling on forest roads. In order to effectively 

reduce the introduction of invasive plant seeds on Forest 

Service lands, this standard should address all types of 

vehicles that leave forest roads. 

These concerns are addressed in Alternative B. Your 

comment will be considered and the rationale for the 

decision will be published in the Record of Decision. 

Standard 3: Use weed-free straw and mulch

An Oregon State official points out that because Oregon does not currently have a weed-free 

straw program, definitions and guidelines will need to be established and straw suppliers 

notified. He suggests that Oregon State University Seed Certification program field 

inspections should be considered an adequate demonstration of meeting the weed-free 

standard. In response, Standard 3 has been amended for all action alternatives in the FEIS. 

Standard 4: Use weed-free feed

 

Many individuals, county and state agencies, stockgrowers and conservation/preservation 

organizations asserted that weed-free feed should be required throughout National Forest 

lands, not just in Wilderness Areas, and that staging areas and corrals should be inspected 

annually. Several groups called for the adoption of the North American Weed Management 

Association standards across the west, claiming this would “benefit both producers and the 

weed control efforts.” 

Others asserted that the lack of weed-free certification programs and adequate sources of 

affordable weed-free feed in Washington and Oregon makes compliance unlikely. 

Table 11. Comments and Responses about Standard 3

COMMENT RESPONSE 

The state of Oregon currently does not have a weed free 

straw program. A set of guidelines will need to be 

established that defines what "weed-free" means. Straw 

suppliers will need to be notified of the weed-free standards 

to insure a readily available supply of weed-free straw. 

The Oregon State University Seed Certification program 

does however; inspect seed production fields that are in the 

seed certification program. These inspection reports should 

be considered to indicate that material is weed-free and will 

suffice under weed-free standards. 

Standard 3 has been re-written to include language 

suggesting NAWMA or similar standards for weed-free 

material. The Forest Service will coordinate with the 

State Departments of Agriculture in the Region to work 

out the specifics of implementation for this standard. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-103 

Several people suggested that requiring weed-free feed in Wilderness Areas is a good starting 

point for the development of a phased-in weed-free hay program on all Region 6 National 

Forest lands. One group recommended starting with the requirement in Wilderness Areas and 

expanding it to all National Forest lands within three years to allow appropriate government 

agencies time to develop certification programs and growers time to produce adequate 

supplies of feed. 

This standard has been amended in the FEIS for the Proposed Action and Alternative B in 

response to these comments. 

Table 12. Comments and Responses about Standard 4

Comment Response 

Alt B-[is preferred] Use NAWMA identification standards to 

make it easily identifiable and enforceable. No current state 

standard for weed free hay. Annual inspections of every site 

are too costly, every three years is plenty. 

Your comments will be considered and the 

rationale for the decision will be published 

in the Record of Decision. NAWMA 

standards have been added to the Proposed 

Action and Alternative B. 

Weed free hay is not available yet in most areas and pelletized 

feed can be a real problem for horses if not introduced in 

advance, etc. You could suggest but not require weed free hay 

at this time and most horse people would comply. 

The alternatives present a range of weed 

free feed requirements (required on 2.5 

million acres in Alternatives NA and D, 4.5 

million acres in the Proposed Action, and 

24.9 million acres in Alternative B). The 

EIS contains expanded discussions of weed 

free feed, detail changes in alternatives, 

weed free feed importance to Wilderness 

Areas, and weed free feed standard design 

amongst the alternatives in Chapters 3 and 

4. 

I was flabbergasted by the part in the proposed action (is this 

1954?) whereby permittees and packers are allowed to bring 

uncertified (i.e. weed infested) feed onto Forest Service lands 

for livestock and pack animals. The animals then spread 

weeds seeds all over the landscape and travel corridors with 

their dung. This pushes the immense cost of remediation off 

onto the public whereas it is far more cost-effective to cut off 

the problem at the source. Permittees and packers need to be 

held responsible for their impacts to the public lands and the 

$1.35 per AUM fee sure wont go very far after the fact. I 

request a detailed economic cost-benefit analysis in the Final 

EIS beginning with historic costs of remediation as 

documented in the Sierra Nevadas, Hells Canyon, or Pacific 

NW forest data [eg Linton Meadows or PCT, WNF]. 

Standard 4 has been rewritten to include 

language suggesting NAWMA or similar 

standards for weed-free feed. The Forest 

Service will coordinate with the State 

Departments of Agriculture in the Region to 

work out the specifics of implementation for 

this standard. See recreation, and 

congressionally designated areas discussions 

in Chapter 3 and Effects on Land Use in 

Chapter 4. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-104 

Table 12. Comments and Responses about Standard 4

Comment Response 

Standard #4. This Weed Board believes that you must work 

into a weed free system for the whole forest for machinery, 

vehicles and livestock. (464,465) On livestock issues, we have 

been advised that restricting feed and straw to weed free 

material will need to be supplemented by a 48 hour 

confinement period to clear the animal's intestinal tract of 

viable seed. We believe you should install a weed free 

system, that little or nothing will be done if you do not have 

regulations in effect and that the cost to the public of 

controlling an infestation may be many times the cost to the 

animal or equipment owner. 

Comment addresses the importance of 

partnerships and collaboration as well as the 

positive benefits of prevention practices in a 

successful invasive plant program. Prefeeding of weed free feeds was considered, 

but was considered to be an unenforceable 

practice. Such pre-feeding or 

“confinement” periods may be encouraged 

by individual forests and through 

cooperation with equestrian groups. 

We are concerned about how the implementation of the weedfree feed standard will be evaluated with respect to its 

efficacy. Chapter 4-5 clearly defines "(t)he measuring factors 

for comparing the alternatives" with respect to efficacy:-

"Estimated annual rate of invasive plant spread."-"Estimated 

acreage of invasive plants treated annually."-"Number of 

years until invasive plants are controlled. "This suite of 

measures seems to be appropriate to determining whether or 

not what you are doing is making a difference in the problem. 

In contrast, the weed-free feed standard will be evaluated only 

as described in Chapter 4-96:"The measure of this effect is the 

acres of National Forest where weed-free feed requirements 

apply." n other words, to the Forest Service, it really makes no 

difference whether or not the implemented standard 

contributes to the control of invasive plants, or at least not 

enough difference to warrant justification of its continuation. 

Weed free feed requirements are a 

legitimate component of invasive plant 

prevention and will help bring Region 6 in 

line with other Nation Forest Regions in the 

west. The alternatives present a range of 

weed free feed requirements (required on 

2.5 million acres in Alternatives NA and D, 

4.5 million acres in the Proposed Action, 

and 24.9 million acres in Alternative B). 

The EIS contains expanded discussions of 

weed free feed, detail changes in 

alternatives, weed free feed importance to 

Wilderness Areas, and weed free feed 

standard design amongst the alternatives in 

Chapters 3 and 4. 

From the perspective of the recreational saddle and pack stock 

user, this is a major change in management that will 

substantially and adversely impact recreational stock users for 

unsubstantiated reasons, and with no intention by the agency 

to demonstrate the efficacy of the standard in the control of 

invasive plants. Therefore, we formally contest the stated need 

for and appropriateness of the weed-free standard as a 

mandatory standard as described in the July 2004 DEIS for the 

Pacific Northwest Region Invasive Plant Program. 

Parks et al. (Appendix D) state that 

“Landscape-scale spread of invasive plants 

can occur when seeds are moved along 

transportation corridors from infested sites 

or from infested ungulate forage, attached to 

or held within infested animals, or attached 

to vehicles used to transport infested forage 

or animals.” Weed free feed requirements 

are a legitimate component of invasive plant 

prevention and will help bring Region 6 in 

line with other Nation Forest Regions in the 

west. The alternatives present a range of 

weed free feed requirements (required on 

2.5 million acres in Alternatives NA and D, 

4.5 million acres in the Proposed Action, 

and 24.9 million acres in Alternative B). 

The EIS contains expanded discussions of 

weed free feed, detail changes in 

alternatives, weed free phase-in 

enforcement, feed importance to Wilderness 

Areas, and weed free feed standard design 

amongst the alternatives in Chapters 3 and 

4. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-105 

Table 12. Comments and Responses about Standard 4

Comment Response 

Prevention Standard 4: Alternative A preferred -with the 

addition of requiring weed free project staging areas, livestock 

and packhorse corrals and OHV staging areas. Annual timely 

inspection of the areas should also be required. Surveys 

should be conducted when suspected or likely invasives are 

easy to detect. This will enable land manager to detect 

infestations before they are wide spread. The sites with the 

greatest use should have the heaviest inspection schedule. 

Site used less often can be on a less frequent schedule. 

 Your comments will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Prevention Standard 4: Alternative A preferred -with the 

addition of requiring weed free project staging areas, livestock 

and packhorse corrals and OHV staging areas. Annual timely 

inspection of the areas should also be required. Surveys 

should be conducted when suspected or likely invasives are 

easy to detect. This will enable land manager to detect 

infestations before they are wide spread. The sites with the 

greatest use should have the heaviest inspection schedule. 

Site used less often can be on a less frequent schedule. 

Your comments will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Standard #4: Does not require the use of weed-free feed on all 

National Forest system land, apparently based on the 

argument that weed-free feed is not widely available. We 

performed Google searches for "weed free hay Oregon" and 

"weed free hay Washington". In less than 5 minutes we had 

the name and phone number for 17 farmers in Wallowa 

County, Oregon, 1 farmer in eastern Washington, and nearly 

80 farmers in Idaho who sell NAWMA-certified weed free 

hay. Although a phase-in of a weed-free feed requirement 

may be advised, particularly for western areas far from 

sources in eastern Oregon and Idaho, we think the Forest 

Service would be ill-advised to ignore the growing availability 

and utility of weed-free feed. 

The alternatives present a range of weed 

free feed requirements (required on 2.5 

million acres in Alternatives NA and D, 4.5 

million acres in the Proposed Action, and 

24.9 million acres in Alternative B). The 

EIS contains expanded discussions of weed 

free feed, detail changes in alternatives, 

weed free feed importance to Wilderness 

Areas, and weed free feed standard design 

amongst the alternatives in Chapters 3 and 

4. 

Why not a wider use of weed free feed than only Wilderness 

Areas and trail heads. 

The alternatives present a range of weed 

free feed requirements (required on 2.5 

million acres in Alternatives NA and D, 4.5 

million acres in the Proposed Action, and 

24.9 million acres in Alternative B). The 

EIS contains expanded discussions of weed 

free feed, detail changes in alternatives, 

weed free feed importance to Wilderness 

Areas, and weed free feed standard design 

amongst the alternatives in Chapters 3 and 

4. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-106 

Table 12. Comments and Responses about Standard 4

Comment Response 

If we are required to use "weed free" hay, Oregon needs to 

have a "weed free certification" program in place. 

Pelletized feed is allowed and if state 

certified feed is not available, sources 

meeting NAWMA or similar standards can 

be used. Formal and informal cooperation 

with State agencies, local landowners, weed 

control districts and boards, Native 

American tribes and other Federal agencies 

in the management and control of noxious 

weeds are components of a successful 

integrated weed management program as 

discussed in Chapter 2. 

I believe the weed free hay is a good idea, my concern and 

questions are many-Who says its weed free hay? Where can 

we buy it? How do us farmers get our hay certified? As we 

travel with our horses-where can we buy it? Who sets the 

rules? Who governs the rules? How will we know each states 

rules on hay? When will this come into effect? 

 Pelletized, state certified, NAWMA 

certified or similarly certified feed will meet 

the requirement. Certification often 

coordinated by growers and 

county/state/weed board members. An 

example of a certification program can be 

found on the Wallowa County Haygrowers 

Association website as shown in Chapter 2 

of the EIS. Each state or Region may have 

specific rules, information and sources will 

be available on the web, and at Forest 

Service offices and information centers. 

Enforcement of weed free feed requirements 

will be phased in with time to educate users 

and for weed free feed sources to be located 

and become reasonably available. 

1. Oregon state has no certification program for noxious weed 

free hay. Agencies which I have contacted have no interest in 

developing such programs at present. These include the 

county extension agencies and the Oregon Seed Certification 

Program.2. Wallowa County uses Idaho's certification. Some 

hay is available sometimes in Wallowa county. Some alfalfa 

hay is trucked in from Idaho and available locally in 

LaGrande. This is very limited availability compared to needs 

at the many trail heads. No certified grass hay which some of 

us horsemen feed instead of alfalfa is available that I know of 

at present.3. Most horsemen will be very reluctant to feed the 

available pelleted or cubed feed rather than hay at trail heads 

as equines do not change diets and forms of feed readily. Once 

in the wilderness area, processed feeds usually are used only 

to supplement the natural forages as needed. Therefore, I find 

the requirement of certified noxious weed free feeds 

unreasonable to implement until certified hay, both alfalfa and 

grass is commonly available at prices close to good quality 

noxious weed free hay currently available in the state of 

Oregon. 

The EIS acknowledges that “Weed-free feed 

requirements increase the cost of using 

horses and other pack stock because weedfree feed is more expensive to purchase, 

distribution locations for weed-free feed 

may be limited, and pack stock users may 

have to plan ahead to obtain the feed and to 

allow animals to adjust to new feed types. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-107 

Table 12. Comments and Responses about Standard 4

Comment Response 

I will support a proposal requiring the use of feed free 

invasive plants and other undesirable plants providing 

reasonable standards are adopted clearly defining what plants 

are unacceptable. Also, the FS must be willing to make a 

commitment to work with other government agencies and 

producers of livestock feed on the implantation of a 

certification system that will result in supply of acceptable 

feed that is reasonably available before imposing feed 

restrictions. 

Standard 4 has been rewritten to include 

language suggesting NAWMA or similar 

standards for weed-free feed. The Forest 

Service will coordinate with the State 

Departments of Agriculture in the Region to 

work out the specifics of implementation for 

this standard. Formal and informal 

cooperation with State agencies, local 

landowners, weed control districts and 

boards, Native American tribes and other 

Federal agencies in the management and 

control of noxious weeds are components of 

a successful integrated weed management 

program as discussed in Chapter 2. 

A simple system needs to be instituted to get the proper 

certification of hay. For example have the County Agent 

certify a local farmer's fields. Then a certificate would go 

with the hay sold off these fields. Many horses can not 

tolerate the pelleted feed causing colic and behavioral 

problems. 

Your comments will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

I believe the livestock users are willing to use weed free feed 

if it is available in the State of Washington, but pelletized feed 

can cause livestock to colic so that doesn't seem to be a good 

solution. Do hay cubes meet the requirement for weed free 

feed? 

Hay cubes are not necessarily weed free. 

Hay cubes documented to be made from 

certified weed free hay (appropriate state, 

NAWMA or similar standards) will be 

allowed. 

The Proposed Action is minimal, Alternative B is much better. 

Disturbed areas, such as staging areas and corrals are an 

introductory site for invasives, and should be inspected 

annually wherever they are. 

Your comments will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

The Proposed Action leaves intact the policy that weedinfested feed can be brought into the Forest and fed to pack 

animals everywhere except designated Wilderness and 

Wilderness trailheads. Region 6 is thus failing to spur either 

Oregon or Washington to finally join the majority of western 

states which already have certification programs for weed-free 

feed. 

This standard establishes a baseline 

requirement for weed free feed; individual 

forests maintain the option to expand weed 

free feed requirements on additional acres. 

The Final EIS should explicitly display the non-Wilderness 

acreage that will be open for use of weed-infested feed, and 

the Wilderness acreage that will not be open for use of weedinfested feed. 

 Acres of National Forest where weed free 

feed would be required are displayed in 

Chapters 2 and 4. National Forest acres 

where weed free feed would not be required 

can be found by subtracting required acres 

from 24.9 million. Weed free feed would 

not be required on 22.4 million National 

Forest acres under No Action or Alternative 

D, on 20.3 million acres under the Proposed 

Action, or on 0 acres under Alternative B. 

This standard establishes a baseline 

requirement for weed free feed; individual 

forests maintain the option to expand weed 

free feed requirements on additional acres. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-108 

Table 12. Comments and Responses about Standard 4

Comment Response 

Use weed free feed on all National Forest lands 

Using weed free animal feed is an essential part of containing 

the spread of invasive plants throughout National Forest lands. 

Livestock and pack animals already contribute to the spread of 

invasive plants by causing soil disturbances, selective 

foraging, seed dispersal, and other mechanisms. In order to 

control the damage, the USFS should adopt the Alternative B 

standards regulating weed free livestock feed as well. We also 

encourage the USFS to monitor project staging areas for 

livestock, OHV's and pack animals as outlined in Alternative 

B. 

Your comments will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Require "weed free" feed for all stock throughout the forests 

(not just wilderness). If necessary phase this requirement in so 

certification programs can become established. 

Your comments will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Use weed-free feed in all Wilderness Areas and Wilderness 

Trailheads. If State certified hay is not available, individual 

Forests should require sources that meet "weed-free" 

standards or require weed-free palletized feed. WITHIN 

THREE YEARS OF IMPLEMENTATION OF THIS 

INVASIVE SPECIES PROGRAM, REQUIRE WEED-FREE 

FEED ON ALL NATIONAL FOREST LANDS. [add the 

following in CAPS Standard 4][Standard 4] must apply to all 

Forest Service lands. At the present time, however, parts of 

Region 6 lack a weed-free feed certification program and 

adequate, available sources of weed-free feed. These 

limitations could make it difficulty to require weed-free feed 

immediately throughout Region 6. However, by phasing in 

this requirement over the next three years, the appropriate 

agencies will have time to develop certification programs and 

growers will have time to produce adequate supplies of feed. 

The alternatives present a range of weed 

free feed requirements (required on 2.5 

million acres in Alternatives NA and D, 4.5 

million acres in the Proposed Action, and 

24.9 million acres in Alternative B). The 

EIS contains expanded discussions of weed 

free feed, phase in of enforcement, detail 

changes in alternatives, weed free feed 

importance to Wilderness Areas, and weed 

free feed standard design amongst the 

alternatives in Chapters 3 and 4. 

The Proposed Action (alternative C) recommendation for the 

use of 'weed free feed", does have WCBCHO's members 

concerned as there are currently no certifying agents/programs 

for 'weed free feed" or "weed free hay" available in the state 

of Oregon. WCBCHO understands and practices the use of 

"weed free feed" when required. WCBCHO wants the Forest 

Service to note that before this recommendation should go 

into effect a system for certifying "weed free feed" that 

includes hay must be established. The development of 

certifying system needs to set reasonable standards to reduce 

the potential of "weed free feed" production becoming too 

costly for individuals to purchase. If this recommendation 

became policy before the establishment of available certifying 

agents it could create a hardship for not only WCBCHO 

members, but also the many other equine organizations 

through out the Pacific Northwest Region. 

The EIS acknowledges that “Weed-free feed 

requirements increase the cost of using 

horses and other pack stock because weedfree feed is more expensive to purchase, 

distribution locations for weed-free feed 

may be limited, and pack stock users may 

have to plan ahead to obtain the feed and to 

allow animals to adjust to new feed types. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-109 

Table 12. Comments and Responses about Standard 4

Comment Response 

We support the use of weed-free feed in all wilderness areas 

and at wilderness trailheads. Our primary concern is that the 

State of Oregon does not have a certified weed-free hay 

program in place at this time. Pelletized feed has been 

available for years. The problem is that not everyone can, or 

is willing to use pelletized feed for their horses. In some 

cases, horses don't do well on pelletized feed and hay is the 

only viable alternative. We would like to propose that along 

with the pelletized feed program, the agencies involved work 

closely with the State Department of Agriculture and County 

Extension Agencies to implement a weed-free certified hay 

program in the State of Oregon. However, if this program 

becomes law before certified hay is available, it would 

severely affect the ability of horsemen to comply. In addition, 

we feel that it is important to make the program workable 

without excessive guidelines and controls that would 

discourage farmers and ranchers from producing the feed, or 

that would make that production, and the final product, 

prohibitively expensive. 

The EIS contains expanded discussions of 

weed free feed, phase in of enforcement, 

detail changes in alternatives, weed free 

feed importance to Wilderness Areas, and 

weed free feed standard design amongst the 

alternatives in Chapters 3 and 4. Formal and 

informal cooperation with State agencies, 

local landowners, weed control districts and 

boards, Native American tribes and other 

Federal agencies in the management and 

control of noxious weeds are components of 

a successful integrated weed management 

program as discussed in Chapter 2 

You have stated under the proposed action that recreational 

stock and pack stock must have weed free feed in order to 

enter the wilderness areas of Region 6. You do not show any 

scientific evidence that we are a major contributor to the 

problem and definitely have not proven that by having weed 

free feed that the problem will be any less than it already is. 

By requiring weed free feed, it is not going to stop the spread 

of non-native plants that are already established and spread by 

wild birds, wild ungulates, and other mammals including the 

human hiking population. It would seem that the recreational 

equestrian community has been singled out to have 

restrictions placed on it in the wilderness areas when other 

recreationists who are much greater in numbers have no 

restrictions whatsoever. You state that the Mt. BakerSnoqualmie NF has required weed free feed in the wilderness 

areas but you do not have any scientific proof that it has 

lessened the problem. Without scientific proof you can not 

justify and/or legally defend your proposed action. Common 

sense would tell one that by just singling out the recreational 

and pack stock the problem is not going to be solved or even 

begin to be solved. Your inept solution is unenforceable at 

best and specious at worst with an underlying agenda that is 

biased against recreational horse and pack stock. We do not 

dispute the fact that there is a problem of non-native plants 

growing in amongst the native plants. What we dispute is 

your answer to the problem that warrants this restriction; 

especially since you do not have any controlled scientific 

studies that can be utilized as evidence that the equestrian 

community is a major contributor. We are demanding that 

this proposed restriction be deleted from the plan. 

Parks et al. (Appendix D) state that 

“Landscape-scale spread of invasive plants 

can occur when seeds are moved along 

transportation corridors from infested sites 

or from infested ungulate forage, attached to 

or held within infested animals, or attached 

to vehicles used to transport infested forage 

or animals.” The EIS acknowledged that 

wild birds, wild ungulates, and other 

mammals including the hiking population 

could spread invasive plants. These vectors 

of spread however are beyond reasonable 

management control, whereas weed free 

feed is, as other Regions have shown, a 

manageable prevention effort. Weed free 

feed requirements are a legitimate 

component of invasive plant prevention and 

will help bring Region 6 in line with other 

Nation Forest Regions in the west. The 

alternatives present a range of weed free 

feed requirements (required on 2.5 million 

acres in Alternatives NA and D, 4.5 million 

acres in the Proposed Action, and 24.9 

million acres in Alternative B). The EIS 

contains expanded discussions of weed free 

feed, detail changes in alternatives, weed 

free phase in of enforcement, feed 

importance to Wilderness Areas, and weed 

free feed standard design amongst the 

alternatives in Chapters 3 and 4. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-110 

Table 12. Comments and Responses about Standard 4

Comment Response 

Increased Costs to All...Requiring horse owners to use weedfree feed will clearly increase the cost of using saddle and 

pack stock because such feed is more expensive to produce 

and distribution locations are limited, resulting in additional 

purchase and transportation costs to the riders and stock 

providers. Under the Preferred Alternative in the DEIS, the 

amount of area that will be impacted by the weed-free 

standard is substantial. Although it is confined to Wilderness 

Areas, it will result in nearly a 500% increase in the acreage 

involved from the current approximately 1 million acres to 4.6 

million acres. This will result in increased costs to the users 

and will likely dissuade some amount of recreational saddle 

and pack stock use. This additional requirement will also 

increase the cost to the FS for enforcement of the weed-free 

feed standards. 

The alternatives present a range of weed 

free feed requirements (required on 2.5 

million acres in Alternatives NA and D, 4.5 

million acres in the Proposed Action, and 

24.9 million acres in Alternative B). The 

DEIS incorrectly stated that weed free feed 

requirements currently are in place on only 

about 1 million acres of National Forest land 

in Region 6. The EIS resolves this error by 

changing that acreage to about 2.5 million 

acres. The Proposed Action will result in 

less than a 100% increase in the acreage 

where weed free feed would be required. 

Requiring the use of Noxious Weed Free feed is a useful 

prevention practice. The required use of weed-free forage on 

all National Forest System land is preferred.4-94, 

Standard#10, second bullet - Increases the costs or reduced 

ability for stock users to access part of the National Forest due 

to weed free feed requirements for pack stock from 

Standard#4.After reviewing this section of the document 

pertaining to Noxious Weed Free Forage/Straw (NWFFS) and 

pack stock it is not entirely clear why stock users could have a 

reduced ability to access part of the National Forest if NWFFS 

may not be widely available or the costs will be prohibitive to 

recreational stock users and they will chose to recreate 

elsewhere. Regardless of which plan chosen, Oregon and 

Washington State must begin statewide NWFFS programs to 

provide regionally available NWFFS at a reasonable price. In 

Idaho, NWFFS can cost 10-50% more than non-certified hay. 

Equine users normally purchase hay in large quantities direct 

from the grower and pay a commodity price, however, 

NWFFS is usually purchased in smaller quantities from a 

local feed store at a specialty item price. Locally available and 

reasonably priced sources of NWFFS are the key to getting 

equine users to comply with the plans. Processed forages such 

as cubed hay, alfalfa pellets, and packer pellets are widely 

available and met the requirements of NWFFS. Region Four 

USFS has a closure only on non-certified hay and straw; there 

is no closure on processed forage. 

The EIS acknowledges that “Weed-free feed 

requirements increase the cost of using 

horses and other pack stock because weedfree feed is more expensive to purchase, 

distribution locations for weed-free feed 

may be limited, and pack stock users may 

have to plan ahead to obtain the feed and to 

allow animals to adjust to new feed types. 

The measure of this effect is acres of 

National Forest where weed free feed 

requirements apply. Recreation users may 

experience additional travel costs to comply 

with this standard. Animal users may also 

decide not to use certain National Forest 

lands if they do not wish to comply with 

weed free requirements. Thus, some users 

and use impacts may be displaced to other 

federal, state, or private lands.” Region 

Four prohibits use of any non-pelletized or 

non- weed free certified feed on all National 

Forest Lands; see Chapter 3. 

While the exclusion of "weed-free" feed in Wilderness Areas 

and Trailheads is a positive initial step, this management 

standard should be expanded and applied universally across 

all National Forest System forest and grasslands. There is no 

biological or scientific reason to use weed-free feed only in 

designated Wilderness Areas and Trailheads while excluding 

such restrictions on other national forest and grasslands that 

are similarly entrusted to public land managers. 

The alternatives present a range of weed 

free feed requirements (required on 2.5 

million acres in Alternatives NA and D, 4.5 

million acres in the Proposed Action, and 

24.9 million acres in Alternative B). (5) The 

EIS contains expanded discussions of weed 

free feed, detail changes in alternatives, 

weed free phase in of enforcement, feed 

importance to Wilderness Areas, and weed 

free feed standard design amongst the 

alternatives in Chapters 3 and 4. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-111 

Table 12. Comments and Responses about Standard 4

Comment Response 

Standard 4 -- We believe that the Forest Service should define 

this standard such that they will start with requiring weed-free 

feed in Wilderness Areas and then work with the Bureau of 

Land Management, Oregon Department of Agriculture, 

Oregon Department of State Lands, Washington Department 

of Agriculture, Washington Department of Ecology, 

Washington Department of Natural Resources, other affected 

government agencies, and affected grower organizations to 

design and implement a phased-in weed-free hay program 

within the states of Oregon and Washington. 

Formal and informal cooperation with State 

agencies, local landowners, weed control 

districts and boards, Native American tribes 

and other Federal agencies in the 

management and control of noxious weeds 

are components of a successful integrated 

weed management program as discussed in 

Chapter 2. 

Wallowa County Stockgrowers supports that all forage fed on 

USFS lands meet the weed free standards of the North 

American Weed Management Association (NAWMA). This 

standard needs to be consistent across the west. If the USFS 

were to step up and adopt this standard it would benefit both 

producers and the weed control efforts. 

 Standard 4 has been rewritten to include 

language suggesting NAWMA or similar 

standards for weed-free feed. The Forest 

Service will coordinate with the State 

Departments of Agriculture in the Region to 

work out the specifics of implementation for 

this standard. See recreation, and 

congressionally designated areas discussions 

in Chapter 3 and Effects on Land Use in 

Chapter 4 

Standard 5: Maintain native vegetation and forest canopies around project areas

Five individuals commented on this standard. On one extreme was the claim that neither the 

standard in Alternative B nor Objective 2.2 in the Proposed Action should be considered 

because these goals are “often unachievable and inappropriate and overly restrictive” and they 

may “prevent treatment of stands requiring fuels reduction/forest health activities.” Others 

claimed: “Alternative B still allows flexibility to implement the standard as ‘consistent with 

other project objectives,’ while providing significantly stronger buffers against non-native 

invasion.” The Record of Decision will explain the rationale for the final choice of 

standards. 

Table 13. Comments and Responses about Standard 5

COMMENT RESPONSE 

This standard for Alternative B should not be adopted, nor 

should Objective 2.2. This standard should be dropped from 

consideration. Alt B is often unachievable and inappropriate 

and overly restrictive. On Eastside forests it may prevent 

treatment of stands requiring fuels reduction/forest health 

activities. 

The effects of implementing Standard 5 for 

Alternative B was discussed in DEIS Chapter 4.2. 

Your comment will be considered and the rationale 

for the decision will be published in the Record of 

Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-112 

Table 13. Comments and Responses about Standard 5

COMMENT RESPONSE 

Standard #5: The Proposed Action relies on the language in 

objective 2.2: "When working in vegetation types with 

relatively closed canopies, retain shade to the extent possible 

to suppress invasive plants and prevent their establishment 

and growth." This vague, non-binding objective is not 

sufficient to insure that projects preserve intact plant 

communities, which are significantly less susceptible to 

invasion than disturbed ones. The more specific and binding 

language in Alternative B still allows flexibility to implement 

the standard as "consistent with other project objectives," 

while providing significantly stronger buffers against nonnative invasion. 

Your comment will be considered and the rationale 

for the decision will be published in the Record of 

Decision. 

A proven method of invasive weed control and prevention is 

competition from desired plants. In addition to canopy shade 

to prohibit establishment of invasive species, having a mix of 

deep rooted and shallow rooted desired species is also 

important. If a root zone is left unoccupied, this leaves room 

for a shade tolerant invasive plant species to invade. Shading 

of roads results in increased need for road maintenance 

because the road stays wet longer. In areas of high traffic, a 

more effective means of preventing weed spread would be to 

have tree canopy back far enough to allow quick drying of the 

road, and plant competitive, low growing plant species from 

the trees to the road. These plant species should be resilient 

and competitive enough to not allow establishment of 

invasive species. 

Using competition from desired plants to manage 

invasive plants is discussed in Chapter 3. 

In those vegetation types with relatively closed canopies 

retain shade to the extent possible to suppress weeds and 

prevent their establishment and growth. Retain native 

vegetation in and around project activity to the maximum 

extent possible consistent with project objectives. Avoid 

creating soil conditions that promote weed germination and 

establishment. Minimize soil disturbance to the extent 

practical, consistent with project objectives. This language, as 

presented in the "USDA Forest Service Guide to Noxious 

Weed Prevention Practices," should be added to the standards 

in the proposed alternative. It is crucial that the adopted 

standards require the actions specified in the agency's 

prevention guidelines for timber harvest and fuels 

management projects because, as the DEIS states, these 

activities can be an important cause of invasive plant 

problems. The proposed alternative cannot meet the purposes 

of the EIS with respect to timber harvest, other vegetation 

management, and fuels management without modification. 

Objective 2.2 in the Proposed Action and 

Alternative D references the USDA Forest Service 

Guide to Noxious Weed Prevention Practices as the 

corollary to Standard 5 in Alternative B. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-113 

Standard 6: Manage grazing to reduce the spread of invasive plants

Most respondents expressed preference for Alternative B because “livestock are a major 

vector for the establishment and spread of [invasive] plants” and “all of [Alternative B’s] 

practices are known to assist in the recovery of native plants and hold weed invasions at bay.” 

An opposing viewpoint was expressed by a member of the agriculture industry: “This 

standard must not become so stringent as to force permittees out of business...Alternative B is 

simply unacceptable because it is too prescriptive and may open the door to litigation from 

those opposed to grazing.” 

In response to these comments, Standard 6 has been amended to make all alternatives equally 

effective and implementable. 

Table 14. Comments and Responses about Standard 6

Comment Response 

Prevention Standard 6. Alternative B preferred - key 

points in this alternative allow the land manager to alter 

the time when grazing is allowed in certain areas that 

may have sensitive native species in it, rest areas that 

have been heavily impacted and are prone to invasive 

infestations and delaying the reintroduction of livestock 

after fires to allow native plant communities to recover 

more fully. All of these practices are know to assist in 

the recovery of native plants and hold weed invasions 

at bay. 

These comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

Grazing Management direction in the proposed action 

lays out the use of Allotment Management Plans and 

Annual Operating Plans to incorporate prevention of 

weeds.- This is an important measure for grazing 

permits as grazing activities do have potential to 

introduce and/or spread noxious weeds. However, this 

standard must not become so stringent as to force 

permittees out of business. Consider an incentive based 

program to ensure cooperation. Permittees (and all 

vested forest users) are the best ally the USFS has in 

weed management. Permittees spend significant time 

on the ground, are there in various seasons and are very 

conscious of range conditions and threats to range 

condition such as noxious weeds. They help find, map, 

and monitor weed infestations. They are your cheapest 

and best defense against noxious weeds. Alternative B 

is absolutely unacceptable because it is too prescriptive 

and may open the door to litigation from those opposed 

to grazing. Passive restoration rarely works when 

invasive plants (noxious or not) are present. Also, 

several of these policies are already being used and 

therefore not necessary here. 

Standard 6 has been revised in the FEIS. The 

standard now includes provision that planning 

and implementation of prevention practices will 

occur in cooperation with the grazing permit 

holder. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-114 

Table 14. Comments and Responses about Standard 6

Comment Response 

Specific prevention and recovery measure language 

might be incorporated into annual [grazing] operating 

instructions, allotment management plans, and overall 

grazing regs, for example:-permanent allotment 

retirement when the land evidently cannot be grazed by 

any grazing system without becoming/remaining weedinfested, as evinced from current and historical 

condition-allow permit holders to voluntarily put their 

allotments into indefinite rest-obligatory resting of 

other pastures for native plant and rare plant recoveryrequired changes in livestock movement especially 

trailing through riparian areas; trucking is preferablealtering or canceling seasons of use according to best 

interest of public-replanting degraded areas with 

natives at permittee expense-multi-year required rest 

after wildfires for cryptobiotic crust recovery 

These comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

The discussion of cattle grazing throughout the DEIS is 

confusing, appears to be inconsistent, and in at least 

one case, potentially inaccurate. NOAA Fisheries is 

concerned that a weakening of the limits on the use of 

cattle grazing may impact salmonid habitat....Standard 

#6, in Table 2-4, states how "invasive plant prevention 

measures" can be incorporated into grazing allotment 

management plans. This appears to be an appropriate 

management approach. However, page 4-12 explicitly 

stated that "...specific prevention actions are not 

required. This standard allows the flexibility for 

grazing managers and grazing permittees to work 

together to choose effective prevention measures under 

their specific circumstances." In addition, Table 4-37, 

on page 4-100, states that "No Direct Effect" on grazing 

and range management is expected from 

implementation of the Proposed Action. If this is the 

case, it appears that the Proposed Action is at best no 

different from the current direction (the No Action 

alternative). If National Forests are currently able to 

incorporate invasive plant prevention measures into 

grazing allotment management plans, a non-binding 

Standard (an apparent contradiction in terms, see 

Standard definition page 2-13) appears as a weakening 

from the current program. NOAA Fisheries is 

concerned that this could result in unintended increased 

risk to listed species and their habitats. 

Standard 6 has been revised in the FEIS. The 

standard now includes provision that planning 

and implementation of prevention practices will 

occur in cooperation with the grazing permit 

holder. As explained in Chapter 2 of the EIS, 

though not directly required, numerous annual 

operating instructions and grazing allotment 

management plans across the Region already 

include some components of invasive plant 

prevention measures. Standard 6 is not “a 

weakening from the current program”. Rather, it 

builds upon what is currently occurring and 

requires incorporation of invasive plant 

prevention practices in annual operating 

instruction and in revision of allotment 

management plans. Related risks to listed 

species and their habitats, will likely be reduced 

when this standard is implemented. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-115 

Table 14. Comments and Responses about Standard 6

Comment Response 

Alt A - [is preferred] This is an important measure for 

grazing permits as grazing activities do have potential 

to introduce and/or spread noxious weeds. However, 

this standard must not become so stringent as to force 

permittees out of business. Consider an incentive based 

program to ensure cooperation. Educated permittees 

(and all vested forest users) are the best ally the USFS 

has in weed management. Alternative B is absolutely 

unacceptable because it is too prescriptive and may 

open the door to litigation from those opposed to 

grazing. Passive restoration rarely works when 

invasives (noxious or not) are present. Also, several of 

these policies are already being used and therefore not 

necessary here. 

These comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

Standard #6: While the Proposed Action contains a 

standard for incorporating invasive management into 

grazing allotment management plans, its language is 

sufficiently vague to render it unenforceable. In fact, 

the DEIS states (in table 4-37) that this standard will 

have no direct effect on grazing and range 

management. Thus, the proposed standard is inaction. 

The addition of language describing specific invasive 

prevention practices (such as found in Alternative B), 

would still allow flexibility to land managers to 

incorporate a diversity of strategies, while insuring that 

appropriate action is taken to implement invasive plant 

prevention on grazing allotments. In the long run, 

greater strength of native species would lead to a 

healthier range, a potential positive effect of the 

stronger policies in Alternative B that is not examined 

in the DEIS. 

Standard 6 has been improved and analysis 

adjusted for all alternatives to address this 

concern. Affects related to this standard have 

been updated to reflect that “no direct effects” 

for Proposed Action and Alternative D was 

misleading and rather, that the effects are 

currently unknowable as they are dependent on 

individual forest implementation of practices 

from the National Guide. Incorporation of such 

practices is required, where in the No Action 

Alternative no region-wide requirement exists, 

so this is not a case of inaction. Additional 

analysis of Alternative B revealed that a list of 

“may include” prevention practices was in 

essence that same as the Proposed Action. 

Standard 6 is currently the same for all action 

alternatives. See Chapters 2 and 4. Your 

comments will be considered and the rationale 

for the decision will be published in the Record 

of Decision. 

I like alternative B when it comes to cattle grazing. 

This is a more pro-active approach of stopping the 

spread of invasive weeds. 

Your comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

I also think it is particularly important to restrict 

grazing on areas that are impacted with a noxious weed 

infestation. Also pastures should not be overgrazed 

permitting a noxious weed invasion. 

Your comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

Grazers need to be on notice about the need to adjust 

public lands grazing practices to reduce costs to the 

public and effectively maintain native forage condition. 

I have to believe that it is in the interest of livestock 

producers to reduce unpalatable or even poisonous 

weeds from their leaseholds. Concrete standards like 

those provided by the Restore Native Ecosystems 

alternative will promote understanding and voluntary 

compliance as well as be a fair way of allocating 

burdens of adjustment to all grazing permittees. 

Your comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-116 

Table 14. Comments and Responses about Standard 6

Comment Response 

The Proposed Action is a necessary start and the 

permittees should be agreeable to these practices, as 

almost all recognize that invasive plants are detrimental 

to forage. The proposals and Alternative B should be 

incorporated as longer term goals, with input from the 

permittees regarding the best means to accomplish 

them. 

Your comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

The DEIS analyzes the impact of standard 6 as 

currently written and concludes that the standard will 

have "no direct effect" [DEIS 4-100] on grazing and 

range management. Therefore, the proposed alternative, 

according to the analysis in the DEIS, cannot meet the 

underlying need of the EIS without the modification. 

Standard 6 has revised for all alternatives to 

address this concern. Effects related to this 

standard have been updated in the FEIS Chapter 

4 to reflect that “no direct effects” for Proposed 

Action and Alternative D was misleading and 

rather, that the effects are currently unknowable 

as they are dependent on individual forest 

implementation of practices from the National 

Guide. Incorporation of such practices is 

required, where in the No Action Alternative no 

region-wide requirement exists, so this is not a 

case of inaction. Additional analysis of 

Alternative B revealed that a list of “may 

include” prevention practices was in essence that 

same as the Proposed Action. Standard 6 is 

currently the same for all action alternatives. 

See Chapters 2 and 4. Your comments will be 

considered and the rationale for the decision will 

be published in the Record of Decision. 

With regard to invasive alien plants, livestock are a 

major vector for the establishment and spread of these 

types of plants. While Alternative B indicates weed 

prevention measures will be incorporated into annual 

operating instructions and allotment management plans, 

in cooperation with the permittee, this "standard" has 

little substance. It falls far short of identifying an 

aggressive program directed at stopping continued 

introductions and/or allowing for native species 

recovery. It is totally unclear under the standards put 

forth in this alternative if livestock management will be 

changed in any way to reduce the spread of invasive 

plants. It is totally unclear if areas will be periodically 

rested from grazing or retired from grazing to assist in 

the recovery native species. Postfire grazing is another 

practice that needs to be specifically addressed. Areas 

that have been burned often need multiple years of rest 

from grazing to allow native species to reestablish and 

for protecting intact biological crusts. 

Standard 6 has been improved and analysis 

adjusted for all alternatives to address this 

concern. The Standard is designed to elevate the 

importance of invasive plant prevention in 

livestock grazing management,. while allowing 

the flexibility for grazing managers and grazing 

permittees to work together to choose effective 

prevention measures that best suit local 

allotment conditions, ecology, and desired future 

conditions. See Chapters 2 and 4. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-117 

Table 14. Comments and Responses about Standard 6

Comment Response 

Standard 6 -- This standard, if fully implemented, will 

be necessary to enlist the grazing permittees in a 

coordinated effort to control invasive species. The set 

of guidelines for what should go into annual operating 

instructions and allotment management plans should be 

developed for the region to ensure consistency of that 

particular tool. The John Day-Snake RAC stands ready 

to assist with development of such guidelines. 

Your comments will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

[for Standard 6 add the wording in CAPS.]Through 

annual operating instructions, and the revision of 

grazing allotment management plans, incorporate 

invasive plant prevention measures that help reduce the 

spread of invasive plants. CLOSE PASTURES TO 

LIVESTOCK GRAZING WHEN THE PASTURES ARE 

INFESTED TO THE DEGREE THAT LIVESTOCK 

GRAZING WILL CONTINUE TO EITHER EXACERBATE 

THE CONDITION ON SITE OR CONTRIBUTE TO WEED 

SEED SPREAD. DESIGNATE THOSE PASTURES AS 

UNSUITABLE RANGE UNTIL WEED INFESTATIONS 

ARE CONTROLLED. THROUGH THE ALLOTMENT 

MANAGEMENT PLAN OR ANNUAL OPERATING 

INSTRUCTIONS, MANAGE THE TIMING, INTENSITY 

(UTILIZATION), DURATION, AND FREQUENCY OF 

LIVESTOCK ACTIVITIES ASSOCIATED WITH 

FORAGING AND BROWSING TO MAINTAIN THE 

VIGOR OF NATIVE PLANT SPECIES AND RETAIND 

LIVE PLANT COVER AND LITTER. MANAGE 

LIVESTOCK GRAZING ON RESTORATION AREAS TO 

ENSURE THAT VEGETATION IS WELL ESTABLISHED. 

THIS MAY INVOLVE EXCLUSION FOR A PERIOD OF 

TIME CONSISTENT WITH SITE OBJECTIVES AND 

CONDITIONS. CONSIDER PRACTICES WILDLIFE 

GRAZING ON THE AREAS IF NEEDED. INCLUDE 

WEED PREVENTION PRACTICES THAT REDUCE 

GROUND DISTURBANCE IN ALLOTMENT 

MANAGEMENT PLANS AND ANNUAL OPERATING 

INSTRUCTIONS. IN THESE PLANS AND 

INSTRUCTIONS, CONSIDER FOR EXAMPLE: 

CHANGES IN THE TIMING, INTENSITY, DURATION, 

OR FREQUENCY OF LIVESTOCK USE; LOCATION 

AND CHANGES IN SALT GROUNDS; RESTORATION 

OR PROTECTION OF WATERING SITES; AND 

RESTORATION OF YARDIN/LOAFING AREAS, 

CORRALS, AND OTHER AREAS OF CONCENTRATED 

LIVESTOCK USE. Plan and implement these measures 

in cooperation with the grazing permit holder. This 

language, adapted from the USDA Forest Service 

Guide to Noxious Weed Prevention Practices," must be 

added to standard 6 in the proposed alternative in order 

that the standard has enough specificity to adequately 

address the purpose and need of this EIS. 

Standard 6 has been improved and analysis 

adjusted for all alternatives to address this 

concern. The Standard is designed to elevate the 

importance of invasive plant prevention in 

livestock grazing management,. while allowing 

the flexibility for grazing managers and grazing 

permittees to work together to choose effective 

prevention measures that best suit local 

allotment conditions, ecology, and desired future 

conditions. See Chapters 2 and 4.
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-118 

Standard 7: Inspect stockpiles and quarries

Although a couple of respondents favored annual inspection and treatment of stockpiles, some 

said annual inspections would be too costly. One county weed coordinator suggested annual 

inspection for sites that are infested, but only biannual inspections of sites that are found to be 

weed-free. One respondent felt that the wording in Alternative D was clearer than other 

alternatives. 

Standard 7 was amended in the Proposed Action in response to these comments. 

Table 15. Comments and Responses about Standard 7

COMMENT RESPONSE 

We favor inspecting material sources for the presence 

of noxious weeds in the planning stages of any project 

requiring the use of the materials, stripping or avoiding 

infested material sources and treating infested areas 

with herbicide, as mechanical methods are probably not 

effective in those materials. 

Your comment will be considered and the rationale 

for the decision will be published in the Record of 

Decision. 

Prevention Standard 7. Alternative A with this addition 

- conduct inspections annually of gravel pits and 

similar material sources, in a timely manner. Surveys 

must be done when invasive species are most likely to 

be found. Then move to a biannual inspection schedule 

of all sites that did not have invasives in the initial 

survey. Merely requiring inspection without specifying 

when they should be done is not optimal for weed 

detection. 

The timeliness of inspections is discussed in 

Chapter 4.2. 

Alt. C -[is preferred] Should add that the "quarry site" 

should be inspected also. Should be applied to all 3 

alternatives. Annual inspections prescribed in Alt B. are 

too expensive. 

 Standard 7 has been re-written to include this 

suggestion. 

Alternative B is a better way of handling the problem 

when it comes to the sand and gravel stockpiles. 

Your comment will be considered and the rationale 

for the decision will be published in the Record of 

Decision. 

Standard 7 [To further clarify the standard there should 

be reference in this standard to Appendix E]The 

Proposed Action would require treatment of infested 

sources for eradication, and strip and stockpile 

contaminated material before any use of pit material. 

Does treatment for eradication mean that infestations 

will have to be controlled for a period of time before 

the pit material can be used? Will the stripping and 

stockpiling of contaminated material allow for 

immediate use of pit material? The wording in 

Alternative D is clearer, stating that infested sources are 

treated before use of pit material. Stripping and 

stockpiling of contaminated materials could be one of 

the techniques that are used to treat the infestations. 

Stripping and stockpiling contaminated materials is 

one of the techniques used to treat invasive plant 

infestations. Standard 7 was revised to address this 

concern. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-119 

Standard 8: Schedule road blading 

Many respondents preferred this standard in Alternative B, claiming that it provides more 

clear direction that can be standardized throughout the Region and that it would go further to 

reduce the spread of weeds. An environmental resource specialist claimed that the methods 

stated in all Alternatives for Standard 8 are outdated and should be rewritten in consultation 

with a road invasive plant management expert. She outlined several specific techniques that 

minimize the need for blading road shoulders and cleaning ditches, and thus minimize the 

ground disturbance that favors weed establishment, by first treating weeds along roadsides, 

shoulders and ditches and then establishing these areas with “resilient, competitive, desirable 

vegetation that meets the need of the intended use of that site (drainage, parking, etc.).” 

These comments did not result in any substantial changes to the FEIS. 

Table 16. Comments and Responses about Standard 8

COMMENT RESPONSE 

The thinking is correct that a successful prevention 

measure is to manage infested roadsides and early 

detection/rapid response is a key element. However, 

the methods stated in the standard are out dated and uneffective. The standard, for all alternatives and the 

proposed action, need to rewritten with a road invasive 

plant management expert. 

This comment did not lead to any specific 

changes to the standards. The Forest Service 

does not agree that the roads management 

techniques listed are outdated. 

Purposed Action of blading, brushing and ditch 

cleaning will result in disturbed sites that will allow 

establishment of invasive weeds. Treatment first of 

these sites and than blading, brushing and ditch 

cleaning, as proposed for Alternative B, may result in 

control of the invasive plants but will also result in 

again exposing the site for weed invasion. A number 

of other more effective options are available and will 

result in prevention of invasive plant establishment. 

Site-specific options will be considered during 

project-level analysis. 

Alternative B is preferred - this is a more 

comprehensive plan for addressing weeds on the 

roadside. Cleaning of equipment is essential. 

Your comments will be considered and the 

rationale for the decision will be published in 

the Record of Decision. 

Alt. C -[is preferred] Alt B doesn't get at the problem. 

Seed will still be on site after treatment. 

Your comments will be considered and the 

rationale for the decision will be published in 

the Record of Decision. 

Standard 8 requires that blading, brushing, and ditch 

cleaning be done in consultation with invasive plant 

specialists. If the proposed alternative is approved, it is 

unclear what actual changes would occur on a project 

level, since no changes are mandated with this 

prevention standard. Alternative B requires that 

definite measures be taken to prevent the spread of 

invasive plants. Requirements such as cleaning road 

grading equipment and mowers should be standardized 

throughout region 6. 

Cleaning of road equipment will be 

standardized with Standard 3. Crafting a 

standard that provides appropriate specific 

direction for road maintenance for the wide 

variety of conditions and circumstances that 

represented in Region Six is more difficult if 

not impossible. See discussion in Chapter 4.6. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-120 

Table 16. Comments and Responses about Standard 8

COMMENT RESPONSE 

Chapter 2 page 7. We concur that communication is a 

problem with road management. Despite Olympic 

National Park, Clallam County, and Quileute Tribe 

advisories to hold off mowing briefly, some entity 

(WSDOT? County?) keeps mowing down emerging 

spring knotweed on the right of way, facilitating 

spreading before eradication crews can get there. They 

repeat this throughout the year! Is it also a problem of 

overlapping and conflicting jurisdiction? Consider that 

in your final action. Some MOUs may assist matters. 

But they need to include a chain of action on this point. 

Most MOUs do not. 

These issues are addressed by Goal 5 and 

Objectives 5.2 and 5.3. 

Standard 8: To further clarify this standard there 

should be reference in this standard to Appendix E. 

Appendix E is does not need to be referenced 

in this standard. There are other guides, such 

as the 2003 USDA Forest Service 

“Backcountry Road Maintenance and Weed 

Management” publication that will also 

contribute to accomplishing this standard. 

Standard 9: Close roads

Most respondents favor the closure of non-essential roads if they are found to serve as vectors 

for invasion. Standard 9 has been modified in response to the comments to allow 

administrative access to closed roads for invasive plant treatment and site restoration. 

Table 17. Comments and Responses about Standard 9

COMMENT RESPONSE 

We would suggest that you close no road until the area 

served is free of invasive plants. 

High risk, non-essential roads should be closed at the 

discretion of the FS manager if invasives are present to 

allow for treatment and to contain the infestation 

Standard 9 has been modified to allow 

administrative access to closed roads for 

invasive plant treatment and site restoration. 

Alt. C - [is preferred] Roads and weed spread are 

already considered in our programs (i.e. Upper Joseph 

Creek Watershed Assessment). Leave open the 

possibility of treating weeds and keeping the road 

open. 

Standard 9 has been modified to allow 

administrative access to closed roads for 

invasive plant treatment and site restoration. 

Failure to include a standard, such as the one in 

Alternative B, to close or decommission non-essential 

roads where roads may be serving as a vector for 

invasion is a missed opportunity. As described in the 

DEIS, roads can be a major vector of invasion, and the 

Forest Service already has a backlog of maintenance on 

its roads. Road decommissioning in this case creates a 

win-win situation. 

Your comments will be considered and the 

rationale for the decision will be published in 

the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-121 

Table 17. Comments and Responses about Standard 9

COMMENT RESPONSE 

Alternative B should be available for consideration in 

special situations. 

 Forest Supervisors currently have the option 

of closing or decommissioning roads for a 

variety of resource related issues. 

Limit use of non-essential roads that are high risk 

vectors for weeds. 

Your comments will be considered and the 

rationale for the decision will be published in 

the Record of Decision. 

Standard 10: OHV use

Almost all commenters to Standard 10 favored the prohibition of cross-country use of OHVs 

and the establishment of designated routes and areas for their use. Most of the commenters 

stated that OHVs “significantly contribute to the invasive plant problem in Region 6” by 

spreading weeds and creating prime weed habitat. One person stated, “People who want to 

drive-off highway vehicles where they disturb topsoil are using everyone's land as their 

personal playground. This is not socially acceptable.” One organization called for inclusion 

of specific “language adapted from the Forest Service's current proposed rule regarding travel 

management and designated routes and areas for motor vehicle use.” A county noxious weed 

control board advises at a minimum “prohibiting use of OHVs during key times in sensitive 

areas: seed set of certain invasives e.g. knapweeds, times when native vegetation is first 

establishing, when natives are more vulnerable in early spring.” 

The EIS has updated its approach to OHV’s in response to these comments by adopting the 

proposed rule for travel management as Standard 10 in the Proposed Action and Alternative 

B. (See Chapters 2 and 4). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-122 

Table 18. Comments and Responses about Standard 10 

COMMENT RESPONSE 

The Wallowa County Stockgrowers is very concerned 

that the move of the USFS to limit Off Highway Vehicle 

(OHV) use to only open roads at the same time that large 

numbers of roads are being closed. This could limit the 

effectiveness/cost of noxious weed control in the future. 

This EIS should identify that OHV's be allowed to be 

used for weed control on all lands not restricted by 

Congress. 

The EIS has updated its approach to OHV’s by 

adopting the proposed rule for travel 

management as Standard 10 in the Proposed 

Action and Alternative B (See Chapters 2 and 

4). Section 212.51 of the Proposed Rule allows 

for limited administrative use by the Forest 

Service. 

Standard #10. We favor adopting the "closed to OHV use 

unless marked as open". We do not believe that 

ownership of an OHV conveys any rights to degrade 

public lands. 

Your comment will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

Prevention Standard 10. Variation of alternative B 

preferred - ideally OHV use would be dramatically cut 

back as they are known vectors, and their use creates 

prime weed habitat. As stated in the supporting research 

in the DEIS, OHV purchase and use has increased 

dramatically in recent years. The KC Noxious Weed 

Control Board suggests prohibiting use of OHVs during 

key times in sensitive areas: seed set of certain invasives 

e.g. knapweeds, times when native vegetation is first 

establishing, when natives are more vulnerable in early 

spring. 

The EIS has updated its approach to OHV’s by 

adopting the proposed rule for travel 

management as Standard 10 in the Proposed 

Action and Alternative B (See Chapters 2 and 4). 

Alt. C -[is preferred] Maintain the ability to permit ATV 

treatment of noxious weeds on otherwise closed roads 

and non-roaded areas. 

Your comment will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

Standard #10: In explaining the decision to not include a 

strong standard restricting OHV use, such as the one 

included in Alternative B, the DEIS makes the statement 

that a standard is unnecessary because the national OHV 

policy, currently under development, is likely to restrict 

OHV use to designated routes and areas. Implementing 

this standard as part of the invasive plant strategy would 

insure that OHVs cease to be important vectors regardless 

of swings in national policy. OHVs are major 

contributors to the spread of invasives into remote areas, 

as detailed in the DEIS. 

 The EIS has updated its approach to OHV’s by 

adopting the proposed rule for travel 

management as Standard 10 in the Proposed 

Action and Alternative B (See Chapters 2 and 4). 

Close all non-essential roads, prioritizing those where 

analysis indicates spread of invasive species is inevitable 

and have the greatest impacts. Stock trucks, firewood 

trucks, RVs, ORVs, dirt bikes, mtn bikes driving 300 feet 

off each side of every open road to camp in Region 6? - 

that is a license to prepare the ground for an exotic 

invasion. And who is out there to enforce the 300' limitORV tracks are everywhere. Keep vehicles including 

mtn bikes on established open roads. 

Standard 10 addresses your comment. The 

rationale for the decision will be published in the 

Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-123 

Table 18. Comments and Responses about Standard 10 

COMMENT RESPONSE 

People who want to drive-off highway vehicles where 

they disturb topsoil are using everyone's land as their 

personal playground. This is not socially acceptable. I 

would like to see your agency restrict such activities and 

make specific commitments that can be measured, to 

reduce your reliance on herbicides. 

Your comment will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

OHV's are known to spread invasive plants. Prohibitions 

of use in infested areas, as proposed in Alternative B, will 

be a big help in reducing spread of invasives. 

Your comment will be considered and the 

rationale for the decision will be published in the 

Record of Decision. 

[for standard 10 add the wording in CAPS]PROVIDE 

FOR A SYSTEM OF ROADSAND AREAS ON 

NATIONAL FOREST SYSTEM LANDS THAT ARE 

DESIGNATED FOR MOTOR VEHICLE USE. AFTER 

THESE ROADS AND AREAS ARE DESIGNATED, 

MOTOR VEHICLE USE, INCLUDING TH CLASS OF 

VEHICLE AND TIME OF YEAR, NOT IN 

ACCORDANCE WITH THESE DESIGNATIONS IS 

PROHIBITED. MOTOR VEHICLE USE OFF 

DESIGNATED ROADS AND OUTSIDE 

DESIGNATED AREAS IS PROHIBITED. WHERE 

VEHICLE TRAVEL OFF OPEN ROADS IS 

CURRENTLY ALLOWED, THIS MUST BE 

TERMINATED BY 2007.This language, adapted in part 

from the Forest Service's current proposed rule regarding 

travel management and designated routes and areas for 

motor vehicle use, should be added to the standards in the 

proposed alternative. The standard should provide a date 

when Region 6 will be in compliance with the Forest 

Service's proposed rule. We also recommend interim 

retention of some signed dispersed camping routes that 

can establish the practice of on-route dispersed camping, 

while the more comprehensive process of designating 

roads and routes under NEPA-based travel planning 

process occurs. These additions are necessary to address 

the purpose and need of this EIS because, as the DEIS 

states, off-highway vehicles significantly contribute to the 

invasive plant problem in Region 6.The DEIS analyzes 

the impact of standard 10 as currently written and 

concludes that standard will have "no effect" [DEIS 4-

101] on off-highway vehicle use. The proposed 

alternative, therefore, according to the analysis in the 

DEIS, cannot meet the underlying need of the EIS 

without modification. 

The EIS has updated its approach to OHV’s by 

adopting the proposed rule for travel 

management as Standard 10 in the Proposed 

Action and Alternative B (See Chapters 2 and 4). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-124 

Table 18. Comments and Responses about Standard 10 

COMMENT RESPONSE 

Chapter 2, Par. 2.7 on page 35, re OHVs. We have treaty 

obligations and federal court orders to survey for 

salmonid redds, as do WDFW and other tribes. Be sure 

when you ban access to certain types of vehicles essential 

for resource management in difficult and remote terrain, 

that you recognize these obligations and do not attempt to 

exclude them under this EIS and its progeny. That kind of 

oversight can lead to lawsuits and cost everyone a lot of 

time and money, when a little care in drafting can prevent 

same. We have found some FS plans re ATVs lump tribal 

research and public play in the same boat. This is 

improper. Remember the tribal off-reservation rights to 

plants, fish, and wildlife? This includes the right and duty 

of the tribes to manage these; not just the FS. 

The EIS has updated its approach to OHV’s by 

adopting the proposed rule for travel 

management as Standard 10 in the Proposed 

Action and Alternative B (See Chapters 2 and 4). 

Section 212.51 of the Proposed Rule allows for 

limited administrative use by the Forest Service.

Standard 11: Establish treatment priorities

All respondents expressed that prioritization is essential. One individual stated that 

Alternative D should have a corollary standard. Most commenters recommended that specific 

direction on how to set priorities be included in the standard. NOAA Fisheries called for 

consideration of “biological diversity and function of the habitat/areas that are infected” when 

prioritizing areas for treatment. 

These comments did not result in any substantial changes to the FEIS. 

Table 19. Comments and Responses about Standard 11

COMMENT RESPONSE 

Alternative D should have a corollary standard. Alternative D has been adjusted to incorporate 

this standard. 

With 420,000 acres already infested, prioritization is 

essential. Prevention of infestation should be the first 

priority. An ounce of prevention is worth many TONS of 

cure later. Almost on an equal level is control and 

eradication of new/small patches and is best thought of as 

prevention. Use of effective bio-control agents should be a 

priority for larger infestations of susceptible species. 

Where to begin with larger infestations may require 

Regional evaluation and considerable judgment. 

Your comment will be considered and the 

rationale for the decision will be published in 

the Record of Decision. 

The Proposed Action is not clear about how to prioritize 

sites. It should include a focus on early detection and rapid 

response of high priority listed noxious weeds when 

prioritizing infestations. It should emphasize early 

detection and treatment of small populations, prioritizing 

small outlier sites. Prioritization should also emphasize the 

role of state departments of agriculture and county and 

other local programs for prioritizing infestations for 

treatment. 

Discussion of criteria for treatment 

prioritization is included in Chapter 3.3 and 

Table 3-15. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-125 

Standard 12: Develop long-term strategy for restoring/revegetating treated infestations

Commenters suggested ways to improve Standard 12. These comments did not result in any 

substantial changes to the FEIS. 

Table 20. Comments and Responses about Standard 12

COMMENT RESPONSE 

For infested sites, develop site strategy within 2 

years of site identification. 

There is no feasible way to enforce a time limit for 

responding to newly identified sites. The response time 

would vary according to many factors, including the 

invasive species itself and potential threats to native 

plant communities or beneficial uses. 

Invasive plants have taken many years to establish 

to the extent that they have. Control will also take 

many years. Restoration is a necessary part of 

long-term control. While a number of invasive 

species will invade "good condition" native 

ecosystems, the rate of invasion is much slower 

and control is easier than "poor condition" native 

vegetation. "Poor condition" is an open invitation 

to invasion. 

Your comment will be considered and the rationale for 

the decision will be published in the Record of 

Decision. 

Add wording in CAPS to Standards 12 

Develop a long-term site strategy for 

restoring/revegetating treated infestations of 

invasive plants. EACH SITE STRATEGY WILL 

IDENTIFY HOW PREVENTION MEASURES 

WILL BE INCREASED AND HERBICIDE USE 

DECREASED OVER THE LIVE OF THE 

STRATEGY. THE SITE STRATEGY WILL 

ALSO PRIORITIZE NON CHEMICAL 

TREATMENTS WHEN TREATMENTS ARE 

REQUIRED, UNLESS THEY ARE 

INEFFECTIVE OR INFEASIBLE. 

Standard 17 has been rewritten to help contribute to 

meeting Goal 3 and Objective 3.2. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-126 

Table 21. Comments and Responses about Standard 12

COMMENT RESPONSE 

In some cases a long-term site strategy for 

restoration/revegetation may not be appropriate or 

needed for all circumstances. There should be a 

qualifier for the size of the site for this standard. 

Many sites are very small and a restoration plan is 

not needed. In some cases it would not be 

appropriate to have a restoration/revegetation plan. 

Many weed sites occur on road shoulders, in 

quarries, stockpiles, rocky outcrops, dry sites or 

thin soils lacking native vegetation that are 

difficult to establish maintain vegetation or may 

not be desirable to have vegetated. Site strategies 

could include other long-term management 

planning goals other then restoration (e.g., 

maintain noxious weed free roadside, parking lots, 

right-of-ways, administrative sites, trailheads). 

A strategy to not restore/revegetate, or to rely on 

passive restoration could be appropriate under certain 

circumstances, such as roadside, parking lots, right-ofways, etc. This topic is clarified in Chapter 3.3 of the 

FEIS. 

Standard 13: Revegetate with native plants

One preservation group favored Alternative B, asserting that “only native plants should be 

used,” and “any non-native plant has the potential to be a problem.” All other respondents, 

including county and state representatives (employees?) and individual members of the 

public, argued that although revegetation with native plants should be a goal, in cases where 

native plant materials are not available, too costly, or unlikely to establish because of site 

conditions, “cover with non-invasive exotic species is far better than no cover.” A state 

official recommended that the revegetation standard should “address obtaining weed-free seed 

and planting stock.” 

These comments did not result in any substantial changes to the FEIS. 

Table 22. Comments and Responses about Standard 13

COMMENT RESPONSE 

Restoration: We favor the use of plant species that do not 

invade. We appreciate and favor the use of native plants 

where native plants are available at a reasonable cost and 

adapted to the site. We note that the cost of native grass seed 

is $14.00/lb & up and may not serve the purpose intended 

such as roadside seedings where a low growing, long lived 

plant may be an asset to maintenance. 

Your suggestions are consistent with Standard 13 

in the Proposed Action. Increasing demand for 

native seed has increased production and is 

resulting in lower prices for native seed. 

Alt. C -[is preferred] Native should be first consideration but 

cost and likelihood of success should be added to the list of 

things that could allow the use of non-natives. Alternative B is 

not a reasonable option- it will only allow for more invasive 

plants to establish! 

Your comment will be considered and the rationale 

for the decision will be published in the Record of 

Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-127 

Table 22. Comments and Responses about Standard 13

COMMENT RESPONSE 

The Proposed Action seems to make the best of a bad 

situation. Native plant materials certainly should be the first 

choice for restoration. For large scale events, such as 

wildfire, these materials may not be available, and cover with 

non-invasive exotic species is far better than no cover. Also, 

in some cases, such as soils without an A horizon, or soils 

contaminated by the allelopath of spotted knapweed, a 

transition species may be needed before native plants can be 

established. 

Your suggestions are consistent with the intent of 

Standard 13 in the Proposed Action.

Only Native seed should be used in rehabilitation Prevention 

Standard 13: This standard applies to what types of plants 

may be used in re-vegetation projects. We believe, like 

Alternative B suggests, that only native plants should be used. 

If actions are taken to reestablish forest, then it only makes 

sense to use the plants, which are adapted to that stage of 

succession in that given locale. Any non-native plant has the 

potential to be a problem plant of the future. 

The Proposed Action follows draft Forest Service 

national policy. This comment will be considered 

and the rationale for the decision will be published 

in the Record of Decision.

The Proposed Action requires native plant material be the first 

choice in revegetation for restoration and rehabilitation where 

timely natural regeneration of the native plant community is 

not likely to occur. Borrow pits, Quarries, Stockpile sites, and 

roadsides typically have had substantial surface disturbance 

that create environments in which invasive plant species outcompete and overrun native plant communities. The addition 

of more persistent non-native plant species, as described in 

Alternative D, may be necessary to out-compete invasive 

plant species in these instances. The emphasis of this standard 

should be to develop and restore sites and communities that 

resist invasion and suppress reestablishment of invasive 

noxious weeds. Plant materials should be selected on their 

ability to establish and exclude unwanted species. Actions 

should be taken to promote establishment of desirable 

vegetation. Cultural practices that alter the site to favor 

desirable outcomes could also be considered by the standard 

(e.g. site preparation, fertility and amendments, sitemanagement changes). The standards (Table 2-4) and the Site 

Restoration/Re-vegetation section of chapter 3 should address 

obtaining weed free seed and planting stock. Contaminated 

seed and planting stock have been documented as sources of 

initial introduction of noxious weeds. State and federal 

programs are in place to assure noxious weed free seed stock. 

Contract language can be suggested for procurement of seed 

and planting stock. The All States Noxious Weed Test and 

other testing procedures are available at a low cost to assure 

purity of seed. 

The Proposed Action follows draft Forest Service 

national policy. The emphasis of this policy and 

Standard 13 is to develop plant communities that 

can resist invasive plants. Standard 13 lists several 

circumstances where the use of non-native plants 

would be appropriate. The cultural practices 

mentioned are considered appropriate tools in the 

EIS (See Chapters 2 and 3). Seed mixes will be 

subject to NAWMA standards (or other similar 

certification system). 

Standard 13 -- The caveat of "nor economically available" 

should be added. 

This spirit of this comment is reflected under 

Alternative D. The rationale for the final decision 

will be in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-128 

Standard 14: Biological control

A single individual commented, “I oppose the use of bio-controls for which there is 

inadequate testing for effect to non-native species.” Standard 14 ensures that all biological 

control agents proposed for use are adequately tested. This comment did not result in any 

substantial changes to the FEIS. 

Standard 15: Licensed applicator requirement

A single county employee stated that standards for “all alternatives equal but needs to be 

reworded so that they follow state and federal laws. This is more restrictive and will limit 

partners ability to participate!” Several alternatives go beyond minimum requirements of the 

law. This may be appropriate for use of herbicides on National Forest. The Forest Service 

recognizes that this may affect how partners’ participate. 

Standard 16: Herbicide formulations available

Several commenters discussed Standard 16 specifically. Some of these types of comments 

are also reflected in the Herbicide Use comment set below. Commenters to Standard 16 

expressed their preference or concern about specific herbicides or herbicide use in general. 

NOAA Fisheries expressed concern that the Proposed Action allows for an unlimited number 

of combinations of the ten approved chemicals. Standard 16 has been re-written in all action 

alternatives to respond to this concern. Several respondents asked the Region to outline the 

process for approving additional herbicides at the forest and project level. In response, 

Standard 16 has been amended to address the process for adding new herbicides and herbicide 

mixtures. 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

The Wallowa County Stockgrowers supports the expanded list of 

chemicals identified in Alternative D. We support Alternative D over 

the proposed action because it includes Dicamba and 2,4-D. 

Dicamba and/or 2-4d should be allowed, they may be critical to the 

successful management of Leafy Spurge, Whitetop, and Rush 

Skeletonweed. One other important issue is that these two chemicals 

are many times the most cost effective tools available. Alternative B 

is unacceptable. It is too restrictive and does not allow for adequate 

tools to be successful. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

The EIS allows for additional chemicals to be added at the forest and 

project level. We feel that due to the cost of analysis that the region 

should primarily be responsible for this process. 

This would be a program decision, not a 

NEPA decision. Risk assessments have 

been conducted under a national FS contract 

to perform assessments as needed. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-129 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

Standard #16 Support of a combination of Proposed Action and 

Alternative D with changes. The chemical list in the Purposed Action 

is reasonable and will support a successful IPM program. The 

addition of dicamba and diflufenzopyr to Proposed Action Standard 

16 would greatly enhance control, reduce the use of the majority of 

herbicides and reduce active ingredient applied to the environment. 

Eliminating the use of 2,4-D may actually enhance the invasive plant 

control program because resource managers would be forced to use 

the effective alternative opposed to the cheap alternative, 2,4-D. 

Diflufenzopyr has been registered for use in corn and non-crop sites 

for several years and has recently been granted a rangeland label. 

Diflufenzopyr is currently only sold in a premix with dicamba, 

however; label rates of the premix only allow for a low rate of 0.125 

lbs ai/acre and a high rate of 0.25 lbs ai/acre dicamba, compared to 

dicamba alone with a low rate of 0.25 lbs ai/acre and a high rate of 

2.0 lbs ai/acre. This decreased rate of dicamba results in less nontarget damage due largely to the decreased volatility formulation and 

the low ai being applied. In addition, the premix is not labeled for 

aerial application, further decreasing environmental concerns. The 

premix can be tank mixed with other herbicides to give an overall 

lower active ingredient applied to the environment without reducing 

invasive plant control efficacy. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Diflufenzopyr is an emerging technology for 

which effective application techniques are 

still under development, including data on 

efficacy in various mixtures, application 

rates, and nontarget effects in field 

applications. This chemical may be 

considered in the future if it complies with 

management direction for evaluating risks 

of mixtures, once studies are sufficient to 

conduct a complete FS risk assessment. 

Many invasive plants can develop resistant biotypes when exposed to 

herbicides. Once this occurs the manager is forced to switch to other 

chemicals for control. Most herbicides have a limited target species 

list. Managing a resistant biotype infestation with a limited number 

of herbicides can greatly reduce the manager's effectiveness. 2,4-D 

and Dicamba are broad-spectrum herbicides. By having the option 

of using these chemicals when dealing with a resistant invasive weed 

population the chances of control can be increased. 

Discussions about herbicide resistance have 

been supplemented in the FEIS. Under the 

Proposed Action and D the risk of herbicide 

resistance from available herbicides is 

minimal; risk increases with limited suites 

of herbicides in No Action and Alternative 

B. 

Alt. C -[is preferred] but add Dicamba and specific formulations of 

2,4-D. Dicamba and/or 2-4d should be allowed by special 

arrangement (similar to 2,4-D in mitigated agreement) in case 

alternatives provided are not successful. Dicamba and 2,4-D may be 

critical to the successful management of Leafy Spurge, Whitetop, 

and Rush Skeletonweed. Leave flexibility open for each forest to 

make decisions on application methods etc. Alternative B is 

unacceptable. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

The Proposed Action makes available one or 

more herbicides that will control every 

invasive plant identified as a hazard to PNW 

National Forests, including those mentioned 

in this comment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-130 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

 Additional application techniques are needed for triclopyr to allow 

for aquatic broadcast applications in aquatic situations for control of 

watermilfoil species. No other herbicide on the list will give control 

of this very invasive group of aquatic invasive plants. Sethoxydim 

has a good fit in cropland but has a very narrow weed control 

spectrum for wildlands (Forest, rangeland, non-crop). Of the 

herbicides listed in No Action and Alternative B, there is not an 

herbicide that can selectively remove a variety of broadleaf invasive 

plants from a variety of non-target broadleaf plants or remove a 

variety of grass invasive plants from a variety of non-target grass 

plants. There is also no low active ingredient herbicide or soil active 

herbicide. Loss of any of the four herbicides to add another herbicide 

that would fill the control voids would result in creating new control 

voids, where the tools would be lacking for an effective IPM 

program. Limiting the herbicide list to three modes-of-action/four 

products will strongly encourage:" a shift in plant species to species 

only tolerant to these four herbicides. " encourage the development 

of resistant type weed species. " result in greater herbicide use and 

weed spread because of the lack of effective control." Invasive 

plants not controlled effectively by other means or these four 

herbicides will reduce overall forest biodiversity. Expanding the list 

to five modes-of-action /10 active ingredients is a great 

improvement. It allows for best vegetation management practices to 

be implemented. Low active ingredient herbicides are included 

reducing the herbicide load to the environment. Having the 

expanded list will allow for using the most effective herbicide 

towards the targeted weed which will result in:" Less herbicide 

applications" Faster regeneration of the treated area" Less injury to 

non-target plants" Ability to use herbicide that have a no-effect level 

on insects, birds, mammals and amphibians" Least risk to humans" 

Lowest cost due to reduced number of applications and quickest 

control" Little effect on land use due to faster land recovery" 

Increased biodiversity. The addition of diflufenzopyr + dicamba is 

needed to further reduce use of chemicals in the Proposed Action. 

The control of submerged aquatic invasive 

plants is beyond the scope of this action. 

Chapter 4.2 displays the estimated effects of 

the alternatives including qualitative 

differences in efficacy of treatment options 

between Alternatives B and C based on the 

availability of different suites of herbicides. 

Diflufenzopyr is an emerging technology for 

which effective application techniques are 

still under development, including data on 

efficacy in various mixtures, application 

rates, and nontarget effects in field 

applications. It may be considered in the 

future if it complies with DEIS standards for 

evaluating risks of mixtures, once studies 

are sufficient to conduct a complete FS risk 

assessment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-131 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

The chemical list in Alternative B is severely lacking, giving no 

control option, with or without IPM control methods for deep-rooted 

perennial species including whitetop, hairy whitetop, bindweed, 

yellow nutsedge, Dalmatian toadflax, butter and eggs, leafy spurge, 

babysbreath, dyer's woad, reed canarygrass, broadleaf bamboo and 

Japanese, Himalayan and giant knotweed and numerous others 

(saltcedar, phragmites) that could be introduced in to the forest 

system. Alternative B also does not allow for long-term control or 

soil pre-emergence control (more effective and selective than 

postemergence control methods) of annual and biannual species 

including common crupina, teasel, kochia, Russian thistle, 

medusahead, Ripgut brome, and cheatgrass. Clopyralid is a narrow 

spectrum growth inhibitor and will give little aid to an inclusive wide 

spectrum invasive weed management program. Glyphosate, 

although wide spectrum, is also a non-selective herbicide. 

Glyphosate can require numerous annual to tri-annual applications at 

high rates to control deep-rooted perennial weeds. During these 

applications, desirable plant composition is continually decreased. 

In infested areas with no desirable species, restoration is delayed due 

to the number of glyphosate applications needed to exhaust the root 

system and seed source of the invasive plant. Overall use of 

triclopyr would be limited by the application restrictions. 

The effectiveness of the herbicides included 

in Alternative B are discussed in Chapter 

4.2. Your comment will be considered and 

the rationale for the decision will be 

published in the Record of Decision. 

Treatment: Adopt the standard for Alternative D. 2-4,D and 

Triclopyr are very effective, economical herbicides and with the 

restrictions you will have in force in addition to label requirements, 

there should be little risk. Please note that Garlon 3A is approved for 

aquatic uses and may be used within the stream buffer zones for 

noxious weeds. 2,4-D is the most common and effective herbicide 

sold over the counter for yard and garden use. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Invasive aquatic weeds have the potential to impact our streams, 

lakes, and reservoirs. Directly impacting several federally listed 

aquatic species. The proposed herbicide list contains three chemicals 

that have an aquatic label, if the target weed cannot be controlled by 

one of these, management is essentially impossible. There are 

several 2,4-D formulations that are labeled for aquatic application. 

This is by no means implies that 2,4-D will control all aquatic 

infestations but having the option to use it will increase the 

likelihood that control can be achieved. Invasive weed management 

in the riparian area is a very difficult task for several reasons. The 

proximity to water being the foremost. 2,4-D will give managers 

another tool to manage weed infestations in the riparian area. 

The control and management of submerged 

aquatic invasive plants is not included in the 

scope of this EIS. To date, reported 

occurrences of these aquatic invasives on 

PNW Region National Forests has been very 

limited, and no control has been initiated. 

NEPA analysis of infestations would occur 

at the project level if a need for their control 

were identified in the future. 

Give the local manager the tools he needs to achieve positive results. 

Limiting which chemicals are available will not reduce the potential 

ecological damage. Only proper chemical application can reduce the 

potential for harmful ecological consequences. We are very aware 

that there will be some collateral damage from herbicide use, but the 

potential for serious ecological damage exists when nothing is done 

or the improper management is applied to the problem. 

This will be considered and the rationale for 

the decision will be published in the Record 

of Decision. The effectiveness of alternative 

suites of available controls and associated 

Regional standards is displayed in Chapter 

4.2, and potential environmental effects are 

displayed in Sections 4.1, 4.3, 4.4, 4.5, and 

4.7. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-132 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

2,4-D and Dicamba can be very cost-effective depending on the 

application rate and target species. With shrinking budgets and 

rising application costs, eliminating an inexpensive herbicide has the 

probability of reducing the number of infestations or acreage treated 

annually. The one two punch of 2,4-D and Dicamba are growth 

regulating herbicides readily absorbed and translocated from either 

roots or foliage. These two chemicals are used largely for noxious 

weed control on County right of ways. 2,4-D and Dicamba have 

been commonly used by millions of homeowners and landscapers in 

landscaping situations for many years. 

The effects of invasive plant management 

program costs and projected treatment for a 

fixed budget are displayed in Chapter 4.6, 

and effectiveness with and without these 2 

herbicides (Alternatives D and Proposed 

Action, respectively) are displayed in 

Chapter 4.2. 

Standard 16 and the availability of a selective phenoxy herbicide 

needs attention and amended to allow for more effective and efficient 

management of invasive brush species (Cytisus, Ulex, and Buddleia) 

in sivilculture practices of Northwest forests. 

The effects of alternative invasive plant 

management program costs and 

effectiveness with and without the phenoxy 

herbicide 2,4-D are displayed in Chapter 4.6 

and 4.2. All alternatives contain one or more 

herbicides that are effective against invasive 

brush species 

The EIS should clarify the process for the adoption of new chemicals 

both at a regional level and on a forest level. The region should take 

leadership in tracking and evaluating new products and for 

performing the appropriate risk assessments to make them available 

to the Forests. 

Standard 16 addresses the process for 

adding new herbicides and herbicide 

mixtures. 

The "No Action" alternative includes dicamba and 2,4-D (the latter 

as a last resort), whereas the "Preferred Action" alternative prohibits 

their use altogether. The document does recognize that elimination of 

these chemicals has the potential impact of increasing the risk of 

developing herbicide resistance among target species (due to overreliance on one or two herbicides in the same family). The rationale 

is that these two chemicals, in a worst case scenario, would have 

unacceptable affects on wildlife. However, the EIS does not show 

that this worst case could indeed ever occur, or how it might be 

prevented from ever occurring, short of total elimination of use of 

these two herbicides. If on a particular Forest or District, the worst 

case scenario is quantitatively probable, then the decision to prevent 

all use of these two chemicals should be made at that level and not 

for the entire Region. If there are warranted concerns for potential 

overuse of these two herbicides (2,4-D and dicamba), a better 

approach would be to place restrictions on their use, such as the 

following: Selection of the specific treatment or combination of 

treatments will not be based solely on lowest cost, but on an 

integrated approach of what is most effective in the long term on the 

target weed in the environment in which it is growing and the 

associated vegetation. Herbicides are most effectively used as part of 

an integrated program or as a "first attack" on newly discovered 

infestations, preventing seed production/dispersal, thus containing 

the weed and increasing the chances for local eradication. They are 

least effective when used without any associated treatments or 

prevention or management activities to favor the desired plant 

community. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-133 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

Reasons for including the full range of herbicides:1) Eliminating 2,4-

D and dicamba reduces the number of options for control of given 

weeds. For example, herbicides recommended for use on Dalmatian 

toadflax (PNW Weed Management Handbook) are dicamba, 

picloram, picloram+2,4-D, and chlorsulfuron (Idaho and Washington 

only). Under the proposed alternative, the only herbicide option in 

Oregon is picloram alone. This needlessly eliminates options that 

may be more appropriate for certain situations, especially because 

picloram should not be used where it can leach to nontarget 

locations. It also has a longer soil residual, which might make it less 

desirable if the target species is intermingled with susceptible 

species.2) Detrimental effects from too heavy reliance on picloram 

and clopyralid on legumes could be mitigated by use of 2,4-DB and 

non-residual and short-residual chemicals (2,4-D and dicamba). Not 

that they would be used in every case, but there may be situations 

where their use would be advantageous.3) These two herbicides 

would reduce risk of developing herbicide resistance in target 

species, by having more options for rotating different chemical 

families.4) Dicamba and 2,4-D are among the herbicides with lowest 

risk for developing resistance in target species.5) In some cases, 

adding 2,4-D in a mix with one of the other approved herbicides 

greatly increases the effectiveness and allows a lower rate of 

application, which not only decreases costs, but environmental 

effects as well.6) Use of a lower cost herbicide may free up more 

money to be spent on use of native species in restoration work, if 

there is a fixed budget for a given project. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Additional analysis of the potential for 

development of herbicide resistance in 

invasive plants for the alternatives is added 

to Section 4.2 in the FEIS. 

I believe that toxic herbicides should only be used as a last resort. I 

don't think that 2-4D should be implemented at all. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

I urge the USFS to explore alternatives to synthetic herbicides, such 

as cultural controls, plant competition, and organic herbicides. 

All alternative follow an integrated weed 

management approach that encourages the 

use of a variety of methods. See Chapter 

2.3. 

The Proposed Action provides for the use of newer herbicides with 

different, and in many cases, improved and/or more selective modes 

of activity. This is commendable. I would strongly suggest that 2,4-

D and dicamba be included as they are in Alternative D. They are 

both still very effective when used with proper expectations, are 

completely safe when used according to label, and are cheap. 

However, I understand their exclusion from the Proposed Action, as 

they carry a lot of emotional baggage from the 1970's, and thus may 

not be acceptable to the uninformed public. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

As to the major issue - herbicide use - we support the prudent 

application of the types of chemicals listed in Standard 16, Proposed 

Action. We also support the addition of new, approved herbicides 

particularly those that are specific to the target species. As an 

environmental organization we generally do not favor the use of 

chemicals in the forest, but we recognize the futility of controlling 

invasive plants without herbicides, indeed the Forest Service is late 

in preparing this document and taking action against this massive 

problem. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-134 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

We recommend against the use of the triazines Chlorosulfuron, 

Metsulfuron methyl, Sulfometuron methyl . The triazines are 

extremely resistant to degradation, more so when they enter ground 

water. Furthermore their narrow range of effective to phytotoxicity 

will increase unintentional non-target mortality, and harm at-risk 

populations of endangered fish dependent on cover, shade and bank 

stability. As the EIS acknowledges, these are new herbicides with 

potentially unknown effects in ecosystems. I am currently working 

with Washington State Department of Agriculture to try and explain 

mortality of conifers which appears to be a synergism between road 

salt and several cocktails which use different formulations of this 

class of chemicals. We recommend against the use of 

hexachlorobenzene (HCB) contaminated pesticides Chlopyralid and 

Picloram. These should only be used in restricted-use permits. We 

recommend against the use of pesticides containing nonylphenol 

polyethoxylate (NPE) or tallow amines and other surfactants which 

has been demonstrated to change the sex ratio and migratory 

imprints of anadromous fish, or in the case of polyethoxylated tallow 

amine, to increase mortality of fry (see Risky Business for a 

discussion). We recommend against the use of Imazapyr since it is a 

more selective congener of Imazapic. We recommend against the 

systemic herbicide Triclopyr. Its toxicity to woody species, higher 

toxicity in wet environments, and likely toxicity to a large number of 

mycorrhizal species indicate that it is too risky to use until more 

information becomes available. Because it is systemic, its ultimate 

environmental fate or that of its degradation products may 

bioaccumulate over time. We recommend against the use of 

Sethoxydim, which does not appear to have very much information 

and appears to be an experimental chemical with large potential for 

accidents (inhibition of lipid synthesis could impact other species). 

Fate of metabolites is likely unknown. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

The respective FS risk assessment reviews 

available scientific studies to evaluate the 

environmental and nontarget hazards 

associated with each chemical considered in 

the range of alternatives. Exposures, 

environmental fate and risks are evaluated in 

the risk assessments, synthesized by 

alternative and compared in the Specialist 

Reports to the EIS, and summarized in 

Chapter 4 of the DEIS. 

Avoidance of use of higher toxicity herbicides such as picloram, 2,4-

D, dicamba, triclopyr and other herbicides consistently showing 

greater likelihood of harm to listed species and amphibians in DEIS 

tables such as clopyralid, sethoxydim, sulfometuron methyl (table 4-

41) and in addition to these, for human health effects: formulas 

containing NPE, glyphosate (also re: fish & amphibians), 

chlorsulfuron, imazapic (see tables 4-17 through 4-28.) Another 

programmatically appropriate means of preventing many worst case 

scenarios and more significant harm that was not analyzed in an 

alternative in the DEIS is the complete avoidance of aerial and 

broadcast spraying. We ask that none of the above listed herbicides 

be accepted for use in Region 6 and that both aerial spraying and 

broadcast ground spraying be prohibited for all herbicide 

applications. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

The respective FS risk assessment reviews 

available scientific studies to evaluate the 

environmental and nontarget hazards 

associated with each chemical considered in 

the range of alternatives. Exposures from 

each application method, environmental fate 

and risks are evaluated in the risk 

assessments, synthesized by alternative and 

compared in the Specialist Reports to the 

EIS, and summarized in Chapter 4 of the 

DEIS. 

The rationale for not analyzing in detail an 

alternative that prohibits aerial application 

of herbicides is displayed in Chapter 2.7. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-135 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

More information is needed on clopyralid and sethoxydim for us to 

assess their relative risks. We support avoidance of all the other 

herbicides proposed to be prohibited from use under Alt. B, 

including 2,4-D, Picloram, Dicamba, sulfonylurea herbicides and 

acetolactate synthase-inhibiting herbicides. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

The FS risk assessments review the 

available scientific studies, identify any 

missing information relevant to FS 

applications, and discuss the importance of 

missing information and any additional 

uncertainty factors used in risk estimates to 

account for missing data, 

What is not clear from the EIS document is the manner in which 

herbicide selection and the use criteria of selected products are to be 

actually used. 

The Forest Service will use available 

published information and local experience 

to determine treatment methods. Appendix 

N provides a link to the document, 

“Common Control Measures for Invasive 

Plants of the Pacific Northwest.” This 

document is available on request for those 

without internet access. The document 

contains information about effective 

treatments for known invasive plant species 

across the region. 

Declaring any practice a "Tool of Last Resort" is not an effective 

strategy. We recommend excluding such language from the 

alternative that is selected for adoption. Too often, such language 

actually means that infestations will be studied, and actions delayed, 

until its too late for any tool, even the "tool of last resort" to be 

effective. We noted above that 2,4-D is designated a "tool of last 

resort" in the current direction. Yet, it has not been used for years. 

We had Forest Service resource managers tell us, during the DEIS 

development and review process, that they did encounter situations 

where 2,4-D would have been the best treatment option for certain 

infestations. But, given all of their other duties, they could not jump 

through the additional procedural hoops put in place by the "last 

resort" designation, and so that active ingredient was effectively 

made unavailable to them. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

In Table 2-5 under the Proposed Action it says that additional 

herbicides may be added in the future at either the Forest Plan or 

project level through appropriate risk analysis and NEPA/ESA 

procedures. Further, FS/SERA risk assessments are addressed in 

Chapter 3-90 by the DEIS and the addition of new herbicides is 

addressed in Standard 16. This is confusing. The process of adding 

additional products/herbicides should be discussed further in the 

ROD. We suggest adding a table or diagram to illustrate the analysis 

process and what is required when adding additional herbicides. 

The process for adding additional herbicides 

in the future is discussed in Standard 16: 

“additional herbicides may be added in the 

future at either the Forest Plan or project 

level through appropriate risk analysis and 

NEPA/ESA procedures.” 

Standard 16 - Please consider adding some formulations of 2,4-D to 

the herbicide tool list. Thank you for allowing all application 

methods including aerial application. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-136 

Table 23. Comments and Responses about Standard 16

COMMENT RESPONSE 

Since it appears other EIS documents will tier from this one before 

adoption of new strategies can reach the ground, it does not make 

sense to restrict tools at this level. 

Forest Supervisors always maintain the 

option of adding additional herbicides in the 

future at either the Forest Plan or project 

level through appropriate risk analysis and 

NEPA/ESA procedures. 

Use of 2,4-D should be left in the tool box as a "tool of last resort" 

(see comment 5 [comment 3 in CAET] below) in order to allow 

cooperation with other state and federal agencies that continue to use 

the herbicide. While we agree that there are few if any scenarios 

where 2,4-D is needed over other herbicides, leaving it in the tool 

box until such time as other agencies decide not to use it will 

facilitate better cooperation in weed management. We would not 

anticipate the Forest Service initiating its use, but if a neighboring 

landowner was going to use the herbicide and some drift could be 

anticipated, this would allow spraying to occur up to the boundary 

and/or allow some cost effectiveness decisions to be made. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 

Standard 17: Reduce herbicide use over time

Most respondents, representing preservation and recreation/conservation organizations, a 

federal regulatory agency, and members of the public, supported Alternative B’s commitment 

to a reduction of herbicide use over time. Some questioned how this would be enforced. In 

response to these comments, the Forest Service clarified the objective of reducing herbicide 

use over time and included a decision protocol for the Proposed Action in the FEIS so that 

managers can demonstrate their rationale for use of herbicides over other methods. 

Table 24. Comments and Responses about Standard 17

COMMENT RESPONSE 

Support of Proposed Action Standard #17. Herbicide use as a tool 

should never be singled out as a last resort as in Alternative B. 

Proper integrated vegetation management will always result in 

greater control than any single tool. Restricting the use of a tool may 

mean greater use of another tool that can cause control measures to 

be needed for a greater length of time. Greater use of these other 

tool, such as mowing, burning, exotic animals or insects, and cutting 

or digging can result in undesired results such as species shift, 

wildfires, injury to desirable species, erosion, and degradation of 

water quality. There is a risk to every control tool. The best way to 

reduce chemical use is to use best-known control on established 

invasive plant populations AND improve prevention and early 

detection/rapid response. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-137 

Table 24. Comments and Responses about Standard 17

COMMENT RESPONSE 

An important objective of the proposed alternative is to "reduce 

reliance on herbicide use over time in the Region." (DEIS 2-15) This 

objective is an integral part of the Desired Future Condition: "the 

need for invasive plant treatment is reduced due to the effectiveness 

and habitual nature of preventative actions, and the success of 

restoration efforts." (DEIS 2-14) As currently drafted, there are no 

standards in the proposed alternative to address this objective. 

Language must be added so that this important concept is not 

omitted. 

Standard 17 has been rewritten to help 

contribute to meeting Goal 3 and Objective 

3.2. 

NOAA Fisheries is concerned that the pre-2004 Standard #17a has 

been unnecessarily weakened, causing risks from herbicide exposure 

to listed fish and their habitat to be continually elevated. The pre2004 draft Standard #17a required that herbicide use be reduced over 

time, as consistent with long-term site goals. While that concept is 

found as an objective of the DEIS, and in the No Action alternative 

inventory and monitoring requirements, reference to a reduction of 

reliance on herbicides over time has been removed from the 

Standards. The Objective relates solely to the Goal of protecting of 

human health. NOAA Fisheries is concerned that without a Standard 

specifically designed to reduce herbicide use over time as a means to 

protect ecosystems, this concept will not be implemented in future 

Forest (either individual Forest or sub-Regional) invasive plant 

management actions. Without such assurance, the ESA section 7 

consultation would need to analyze the risk to threatened and 

endangered species and their environment from the standpoint of the 

highest allowable levels of herbicide over the life of the consultation 

rather than based on reduced herbicide use over time. NOAA 

Fisheries recommends reinstating language in the Standards 

acknowledging a reduction in use of herbicides over time. 

Standard language that directs the reduction 

in use of herbicides over time is included in 

Alternative B, Standard 17. 

Standard #17: The Proposed Action has no binding language 

requiring a reduction in the use of herbicides over time, and no 

language encouraging the use of non-chemical methods where 

possible. Chemical herbicides can be a valuable tool in fighting 

invasives; however, they also can have significant detrimental 

impacts, and their use should be minimized whenever possible. We 

support the stronger language in Alternative B, calling for a longterm reduction in the use of chemical herbicides. 

Standard 17 has been re-written for the 

Proposed Action to include language that 

requires the consideration of non-herbicide 

treatments and documentation of the 

rationale for not selecting non-herbicide 

treatments. 

Please continue supporting the US Forest Services' commitment to 

reducing reliance on use of herbicides to combat invasive plants. 

Herbicides used at the lowest effective application rate should be the 

last resort to fight [invasive plant] spread. 

Objective 3.2 addresses the reduction in 

herbicides in the Region over time; plus, 

Standard 17 has been re-written for the 

Proposed Action to include language that 

requires the consideration of non-herbicide 

treatments and documentation of the 

rationale for not selecting non-herbicide 

treatments. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-138 

Table 24. Comments and Responses about Standard 17

COMMENT RESPONSE 

The Forest Service made an excellent decision two decades ago with 

the commitment to reduce herbicide use. This recognition that weed 

invasions are best controlled using techniques that are for the long 

term health of our forests was the right one. Please don't undo a 

great insight. 

It is also very important to reduce reliance on herbicides, as they can 

have profound adverse impacts on various species including humans.

Herbicide use costs money and degrades our forest lands and water 

quality. The Forest Service should commit to reducing herbicide use 

by a measurable amount. 

Objective 3.2 addresses the reduction in 

herbicides in the Region over time; plus, 

Standard 17 has been re-written for the 

Proposed Action to include language that 

requires the consideration of non-herbicide 

treatments and documentation of the 

rationale for not selecting non-herbicide 

treatments. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-139 

Standard 18: The use of adjuvants

Several respondents called for the public disclosure of adjuvants required in Alternative B. 

One respondent said that the Proposed Action was too restrictive: “Limiting adjuvants to ones 

already tested and described in FS documents is backward looking and inflexible.” These 

comments did not result in any substantial changes to the FEIS. 

Table 25. Comments and Responses about Standard 18

COMMENT RESPONSE 

All "inert" ingredients should be publicly disclosed. This concern is addressed in Standard 18. 

Without information on the identity and effect of an herbicide 

formula's "inert" ingredients (which are often toxic in 

themselves and may pose unknown hazards upon combination 

with the formulas "active" ingredients or when in contact with 

fire or water), no knowledgeable assumptions about the full 

risks of that herbicide formula's use can be made and a 

Finding of No Significant Impact or of "acceptable risk" can 

not be made justifiably. Therefore the Forest Service should 

not be allowed to use any herbicide formulas for which the 

"inert ingredients are not disclosed and their potential impacts 

are not analyzed, including, but limited to, Garlon formulas 

("Garlon 5A", "Garlon 4" and "Remedy"). 

Standard 18 accomplishes this goal by 

ensuring that inert ingredients are assessed for 

their potential effects along with active 

ingredients. 

Standard 18: Does this standard require adjuvants to meet the 

same standards that are required for herbicides (FS/SERA 

Risk Assessments)? Is there a process for adding adjuvants in 

the future and how difficult will it be to add new products? 

Adjuvant formulations change frequently and different 

formulations fall in and out of favor. Specific formulations 

can be difficult to obtain at times. If the proposed standard 

requires risk assessments for adjuvants, the DEIS should 

provide a list of approved adjuvants for review. 

Standard 18 requires that only adjuvants and 

inert ingredients that are assessed in herbicide 

risk assessments be used in invasive plant 

projects. These assessments may be updated 

as needed for new adjuvants. 

Treatment and Restoration Standard 18. Limiting adjuvants to 

ones already tested and described in FS documents is 

backward looking and inflexible. For example, Agri-dex, a 

surfactant that came on the market in 2004 has much lower 

toxicity that the widely used LI-700. This limitation prevents 

managers for accessing the best, lowest risk tools available to 

them. There is a need to define the future FS risk assessment 

process to review new products in a timely fashion 

Standard 18 requires that only adjuvants and 

inert ingredients that are assessed in herbicide 

risk assessments be used in invasive plant 

projects. These assessments may be updated 

as needed for new adjuvants. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-140 

Table 25. Comments and Responses about Standard 18

COMMENT RESPONSE 

Changes required so that Forest Plan direction will meet Goal 

3, objective 3.2 and objective 4.2 [add wording in CAPS to 

Standards 12, 18, and 19] 

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

ingredients reviewed in Forest Service hazard and risk 

assessment documents such as SERA, Inc., 1997a, 1997b; 

Bakke, D. 2002. FOR EACH HERBICIDE APPLICATION 

PROJECT CONDUCTED UNDER THIS EIS, PUBLICLY 

IDENTIFY ALL INGREDIENTS IF SUCH DISCLOSURE 

IS EITHER ALLOWED BY THE PRODUCT'S 

MANUFACTURER OR IT THE IDENTITY OF THE 

INGREDIENT IS REQUIRED TO BE DISCLOSED UNDER 

THE FREEDON OF INFORMATION ACT. An important 

part of meeting Goal 3 with respect to herbicide applications 

is for health professionals to have quick convenient access to 

ingredient information so that they can correctly treat any 

patient whose acute or chronic illness may have been caused 

or exacerbated by herbicide exposure. The confidentiality of 

the ingredients in herbicide products is a complex legal issue, 

but Region 6 can easily make a commitment to public 

disclosure of as many ingredients as possible. 

The suggested language was considered but 

not adopted in any alternative. The suggested 

language does not add any substance to the 

standard. Alternative B addresses the spirit of 

the comment and its wording may be selected 

in the final decision. 

Standard 19: Reduce effects to water quality and aquatic biota

Several respondents called for more definitive language in this standard, offering suggestions 

for the specifics of how sensitive situations are identified, how to respond in the event of 

water contamination, and how to avoid impacts to breeding amphibians and other sensitive 

species. Standard 19 was amended in all action alternatives to clarify its intent in response to 

these comments. 

Table 26. Comments and Responses about Standard 19

COMMENT RESPONSE 

Treatment and Restoration Standard 19. Addition to proposed 

action - time applications to limit impact on breeding 

amphibians and other sensitive species. 

Standard 19 in the Proposed Action has been 

re-written to specifically mention amphibians, 

aquatic biota, and terrestrial animals. 

The Proposed Action is better than B. Overall prohibition of 

broadcast spraying in riparian reserves prescribed in Alt B. is 

unacceptable. "Known habitat" is too poorly defined. These 

measures are also already required by the labels and law 

(clean water act) and are therefore redundant. 

Your comment will be considered and the 

rationale for the decision will be published in 

the Record of Decision.

Rely on soil scientists and biologists to identify sensitive 

situations, and weed control and herbicide specialists to 

prescribe treatment methods and which herbicides are 

appropriate for the sites. 

Forest Service Manual 2080.5 already requires 

an interdisciplinary approach for selecting 

treatment methods. See Chapter 2.3. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-141 

Table 26. Comments and Responses about Standard 19

COMMENT RESPONSE 

The statement on p. 2-15 that water should be avoided from 

contamination should state that (1) chemicals will not be 

mixed on National Forests, and (2) any water contamination 

will be cause to immediately close the contract with an 

applicator and assess corresponding damages. 

Standard 15 has been updated in the FEIS to 

address these concerns. Standard 15 now 

requires that projects include an herbicide 

transportation and handling plan to ensure that 

chemical mixing is done in appropriate areas 

and accidental spills are cleaned up promptly. 

The statement on page 4-106 in the second paragraph of the 

"Direct and Indirect Effects" section that "Standard #19 in all 

alternatives would preclude the use of glyphosate 

formulations that could affect fish in riparian areas." This 

language appears to imply that Standard #19 is meant to 

prevent the use of any herbicide in any situation that could 

result in water concentrations that could affect fish. This is 

inconsistent with NOAA Fisheries understanding of how 

Standard #19 was meant to be interpreted. Does this statement

need to be reworded for clarification? 

Standard 19 in the Proposed Action requires 

managers to consider the potential hazards 

associated with herbicides and the sensitivity 

of a site when selecting a particular chemical 

for use. The one formulation of glyphosate 

that may harm fish would be avoided in any 

case where fish may be affected. The 

formulation of glyphosate that may affect fish 

could be appropriate for use away from fish 

bearing streams. 

Changes required so that Forest Plan direction will meet Goal 

3, objective 3.2 and objective 4.2 [add wording in CAPS to 

Standards 12, 18, and 19. To reduce or eliminate direct or 

indirect negative effects to TERRESTRIAL ANIMANS, 

NON-TARGET NATIVE PLANTS, water quality and aquatic 

biota form the application of herbicide, use site-specific soil 

characteristics, proximity to surface water and local water 

table depth to determine herbicide formulation (e.g. use of 

aquatic labeled products), size of buffers needed, it any, and 

application method and timing. MINIMIZE APPLICATION OF 

HERBICIDES AND PROHIBIT BROADCAST SPRAYING IN RIPARIAN 

RESERVES AND IN KNOWN AQUATIC AND TERRESTRIAL 

AMPHIBIAN HABITAT, INCLUDING BREEDING, REARING, AND 

OVERLAND DISPERSAL AREAS. AVOID APPLICATION OF 

HERBICIDES WITH ADVERSE EFFECTS ON AQUATIC SPEICES AND 

AMPHIBIANS. An important objective of the proposed 

alternative is to "protect native plants and animals from 

negative effects of both invasive plants and applied 

herbicides." (DEIS 2-15) In fact, this objective is critical to 

achieving the Desired Future Condition of a "full suite of 

native organisms." As drafted in the proposed alternative, 

Standard 19 fails to provide for protection of important 

components of this "full suite." According to the DEIS, over 

8,000 acres will be treated with herbicides that have a "higher 

potential to harm non-target plants," (DEIS 4-35) almost 

9,000 acres will be treated with herbicides that "could result in 

harmful doses to birds and mammals," (DEIS 4-54) and one 

herbicide is approved that "may harm amphibians." Standard 

19 must require that these Forest Plan amendments address 

these hazards in order to meet Objective 4.2. Also unless the 

management objective of limiting direct and indirect negative 

effects to terrestrial animals and non-target native plants is 

included in this standard, such an objective will not have been 

included anywhere in the entire DEIS. 

Standard 19 in the Proposed Action has been 

re-written to specifically mention terrestrial 

animals, non-target plants, amphibians, and 

other aquatic biota 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-142 

Standard 20: Reduce or eliminate impacts to proposed and listed species and their 

critical habitat

The comments to Standard 20 did not lead to any substantial changes in the FEIS. 

Table 27. Comments and Responses about Standard 20. 

Comment Response 

Standard 20 is already covered by ESA requirements. Standard 20 provides elements specific to 

invasive plant treatment that clarify how 

ESA requirements will be met. 

The Standards do not provide environmental protections 

through the selection of the least impacting treatment 

method or type of herbicide for invasive plant treatments. 

Employing a binding standard regarding the use of 

herbicides with the least toxic effect when all other project 

attributes are equal, could ensure consistency and assurance 

of use of avoidance and/or minimization techniques. 

The complexity of toxicology and balancing 

the risks of invasive plants against the risks 

of treatment precluded the inclusion of a 

standard that requires the “least toxic” 

effect. Project level environmental analysis 

will ensure that herbicide use is appropriate 

and that environment effects are minimized 

to the extent possible. 

Nest sites and post-fledgling areas of the following species 

should be avoided (re: disturbance) during reproductive 

seasons: Bald eagle, Northern spotted owl, Marbled 

murrelet and Snowy plover. (See Table 4-42). 

These design criteria would be established at 

the project scale. 

Standard 21: Buffers

Several respondents suggested modifying the Proposed Action to allow for treatment within 

the 300-foot buffer, if adjacent landowners authorize it. Standard 21 has been re-written in all 

action alternatives in the FEIS to respond to these comments. 

Table 28. Comments and Responses about Standard 21

Comment Response 

Treatment and Restoration Standard 21. Alternative B 

preferred. 

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision 

Proposed Action could preclude cooperative projects with 

private landowners for some treatment options. Allow for 

adjacent landowner cooperation when treating within the 

300 feet boundary. Our suggested change is to make an 

exception to 300 feet buffer for private landowners with 

consent from adjacent property owner or for cooperative 

projects with multiple adjacent ownerships. Allow for 

seamless treatments across ownerships in cooperative 

projects. In many cases the adjacent landowner will want 

the invasive plant treated up to or beyond the ownership 

boundary. 

Standard 21 has been re-written to include 

the language suggested. Decisions on 

buffers for culturally significant plants and 

wildlife resources are most appropriately 

made at the site-specific project level. 

Either the Proposed Action or Alternative B appear 

appropriate, provided that alternative controls are used in 

the buffer areas. These may include mechanical control, 

spot spraying, spraying in off seasons and ground spraying.

Your comment will be considered and the 

rationale for the decision will be published 

in the Record of Decision 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-143 

Table 28. Comments and Responses about Standard 21

Comment Response 

No broadcast spray in riparian or amphibian habitat. No broadcast spray in riparian or amphibian 

habitat is included in Alternative B. 

Riparian buffers analysis needed. The EIS should have 

provided an analysis that separated out riparian buffers. 

Because herbicides are limited in riparian areas to aquatic 

herbicides the affects of all alternatives will be different if 

aquatic herbicides are not used. In addition, the known 

toxicity to fish from common surfactants such as tallow 

amine and nonoxy phenol will be higher if riparian areas are 

buffered from herbicides. Finally, Washington state has a 

protective riparian buffer in place right now, which would 

place constraints on the EIS. 

Standard 19 requires that herbicide 

formulations consider proximity to water 

and other site conditions to ensure that 

aquatic organisms are protected. The 

distance from streams where this would 

apply varies by site. 

Standard 22: Municipal watersheds

No comments specifically addressed this standard. 

Herbicide Use

Many people commented on herbicide use, including comments about specific formulations 

of herbicides. There is substantial overlap between these comments and the comments about 

Standard 16 and about the “merits of alternatives.” 

Commenters expressed opinions both for and against use of particular herbicides. The 

rationale for the final suite of herbicides selected will be in the Record of Decision. 

These comments led to some changes in the wording of the standards. A standard has been 

added to the FEIS to ensure that caution is used when using herbicide mixes. Additional 

information was provided regarding the use of herbicides and the potential for target invasives 

to develop herbicide resistance. 

Table 29. Comments and Responses about Herbicide Use

Comment Response 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-144 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

All potential uses of more than one herbicide mixed together 

(with multiple active ingredients) should be disclosed, 

analyzed for potential effects and be subjected to a risk/benefit 

analysis within the EIS. 

The FEIS includes more information about 

potential use of chemicals. Standard 16 in all 

alternatives has been amended to address 

allowable herbicide mixes. Mixtures of 

herbicide formulations containing specific active 

ingredients may be applied where the sum of all 

individual Hazard Quotients for the relevant 

application scenarios is less than 1.0. This is a 

cautious approach based on the Guidance 

Manual For The Assessment Of Joint Toxic 

Action Of Chemical Mixtures (US Department 

of Health and Human Services, 2004). 

Contrary to EIS assurances that inert ingredients of proposed 

use herbicide formulas pose no significant risk, "The material 

safety data sheet (MSDS) for Garlon 4 (Dow AgroSciences 

2000b) specifies that inhalation exposure to Garlon 4 vapors 

may cause central nervous system effects attributable to 

kerosene." (Profile p.8 - kerosene is an "inert" ingredient of 

Garlon 4). 

The risks potential health effects associated with 

kerosene present in Garlon 4 are analyzed and 

disclosed in the 2003 Triclopyr Risk Assessment.

2, 4-D is another herbicide often used throughout Region 6 

and the use of this extremely toxic compound should be 

immediately stopped throughout the region. This chemical 

has the same active ingredient that was used in Agent Orange 

which is likely to have caused, and is still causing, serious 

health problems to Vietnam Veterans and the people of 

Vietnam. This compound has been shown to have toxic 

effects on pollinators under the typical application system 

(DEIS 4-32). 

The suite of herbicides and treatments available 

is one of the decision points for this EIS – the 

final decision will consider the trade offs 

between cost, effectiveness, and potential 

adverse effects. 2,4-D has not been used in FS 

PNW Region invasive plant management since 

1984. 

2,4-D is assessed by its manufacturer as harmless yet the EPA 

admits it is a carcinogen. But that not enough is known about 

it to really know if it is a tumor growth factor. Again we are 

dealing with unknowns. 

All publicly available data on the health effects 

of 2,4-D were reviewed, and screened for 

relevance. Relevant studies were evaluated by 

independent PhD scientists (toxicologists) to 

derive the weight-of-evidence findings on 2,4-D 

potential health hazards that are used to evaluate 

the human health risks of alternatives in the 

DEIS. The findings and estimated health risks 

are peer-reviewed before final publication. 

It is imperative that your final EIS include studies of the 

herbicides adverse effects supported by research t teams as 

Tyrone B Hayes University of California - Tel: 510-414-2579. 

He wasn't even asked for his study of Atrazine, a very 

important study by the way which would help you make 

informed decisions about that weedkiller foiled into others. 

Neither atrazine nor any closely related 

herbicides (triazines) are proposed for use in 

alternatives considered in the EIS. Thus 

potential effects of atrazine are outside the scope 

of the analysis and are not considered 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-145 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

If the Forest Service is not revealing the "secret" ingredients 

in pesticides and adjuvant formulations, the public can not 

comment fully on the DEIS proposing use of such chemicals. 

The public therefore can not assess the environmental impact, 

or the validity of the statements made in the DEIS, for that 

matter of fact, without full disclosure of all the chemicals in 

the products proposed for use Forest Service is withholding 

critical environmental information in direct violation of 40 

CFR [section] 1500.1(b):40 CFR [section] 1500.1 Purpose.(b) 

NEPA procedures must insure that environmental information 

is available to public officials and citizens before decisions are 

made and before actions are taken. The information must be 

of high quality. Accurate scientific analysis, expert agency 

comments, and public scrutiny are essential to implementing 

NEPA. 

The DEIS followed accepted NEPA protocols to 

address incomplete or unknown information. 

Alternatives were compared and their 

environmental effects estimated based on peerreviewed risk assessments. The risk assessments 

examined EPA Confidential Business 

Information and potential effects of confidential 

formulation ingredients. The risk assessments 

comply with federal regulations that implement 

FIFRA that require that information obtained 

with CBI clearance may not be publicly 

disclosed. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-146 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

The Proposed Action would allow a proven successful control 

treatment of 1% solution of imazapyr, 1 lb ai/acre, well within 

the EPA approved rate.Whitetop, Perennial pepperweed and 

Dyer's woad (Cardaria draba, Lepidium latifolium and Isatis 

tinctoria)- none of the allowed herbicides under Alternative B 

will control whitetop or dyer's woad. Annual mowing, several 

times a year would be needed to manage the weed, and would 

only slow spread. Biological control will likely not be 

available because there are many mustard type crops that bugs 

could cross to and cause economic injury. Dalmatian toadflax 

and Butter&eggs (Linaria dalmatica and Linaria vulgaris)- 

None of the herbicides under Alternative B will control these 

two weeds. Annual mowing will encourage spread by root 

expansion and encourage a lower growth habit unaffected by 

mowing. Biological control will reduce spread after 6 to 7 

years, assuming the bugs are somehow encouraged to move to 

new populations. Bugs tend to stay where released if weed 

population is healthy. Lack of control of Toadflax in the 

Shoshone National Forest has already caused great economic 

loss and environmental loss of wild sheep winter range in the 

Absaroka mountains. The Proposed Action would allow for a 

0.188 lbs ae/acre treatment of imazapyr, only needed one 

time, for initial control with biological control to maintain the 

population at a no impact level. Medusahead, cheatgrass and 

Ripgut brome (Taeniatherum caput-medusae, Bromus 

tectorum and Bromus rigidus) For control under Alternative B 

an annual or biannual treatment of glyphosate or sethoxydim 

every fall and/or spring would be needed to contain the weed 

population. Both these treatments are post-emergence at 

timings when non-target species would be actively growing 

and severely injured by the herbicides. This would cause a 

shift to other weedy plants or severely limit the biodiversity of 

the plant and animal species in the area. It is unrealistic to 

believe these weeds could be hand pulled to a no impact level. 

No biological control is currently available and may not be for 

over 20 years. Fire further encourages the growth of these 

fire-loving invasive plants. The Proposed Action would allow 

for the application of imazapic at 0.023 to 0.188 lbs ai/acre 

that has proven to selectively remove Medusahead, ripgut 

brome and cheatgrass from desired vegetation, allow new 

germination of desirable plants, and give residual control 

which reduces the number of applications needed to limit the 

population to a no impact level. 

More detail on treatments in regards to specific 

invasive plant species was added to FEIS 

Chapter 3 and 4. Appendix N provides a link to 

the document, “Common Control Measures for 

Invasive Plants of the Pacific Northwest.” This 

document is available on request for those 

without internet access. The document contains 

information about effective treatments for known 

invasive plant species across the region. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-147 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

Additional analysis should be done to include 2,4-D on the list 

of herbicides proposed for use with the preferred alternative. 

There are several points that should be reviewed regarding the 

benefits of 2,4-D. 

1. Invasive aquatic weeds have the potential to impact our 

streams, lakes, and reservoirs. Directly impacting several 

federally listed aquatic species. The proposed herbicide 

list contains three chemicals that have an aquatic label, if 

the target weed cannot be controlled by one of these, 

management is essentially impossible. There are several 

2,4-D formulations that are labeled for aquatic 

application. This is by no means implies that 2,4-D will 

control all aquatic infestations but including it on the list 

of chemicals in the preferred alternative will increase the 

likelihood that control can be achieved. 

2. Invasive weed management in the riparian area is a very 

difficult task for several reasons. The proximity to water 

being the foremost. Again the list of proposed chemicals 

contains only three that can be applied to the waters edge. 

Including 2,4-D on the proposed alternative's list will give 

managers another tool to manage riparian infestations. 

3. Many invasive plants can develop resistant biotypes when 

exposed to herbicides. Once this occurs the manager is 

forced to switch to other chemicals for control. Most 

herbicides have a limited target species list. Managing a 

resistant biotype infestation with a limited number of 

herbicides greatly reduce the manager's effectiveness. 

2,4-D is a broad-spectrum herbicide that has a large target 

species list. By including this chemical on the preferred 

alternative herbicide list the manager's options when 

dealing with a resistant invasive weed population will be 

increased. 2,4-D can be very cost effective depending on 

the application rate and target species. With shrinking 

budgets and rising application costs, eliminating a cheap 

herbicide has the probability to reduce the number of 

infestations or acreage treated annually. Including this 

herbicide in the preferred alternative may help those 

managers that may have limited budgets. We by means 

are not trying to say that 2,4-D is a cure all herbicide, it 

has it's limits, drawbacks, and benefits. Our experience 

tells us that the chemical applied does the harm but the 

root cause is always the applicator's choice of chemicals, 

application rates, and timing. We encourage the EIS team 

to include 2,4-D on the list of approved herbicides. We 

feel the local manager needs the largest "weed toolbox," 

including 2,4-D will expand the available "toolbox". 

The management of aquatic invasive plants is 

beyond the scope of this EIS. Riparian invasives 

are likely to be controlled with the three aquatic 

herbicides available in the Proposed Action. 

The EIS acknowledges that herbicide resistance 

varies inversely as more herbicides are available 

for use (Proposed Action and Alternative D). No 

invasive biotypes are known for which 2,4-D is 

necessary for control. 

The Proposed Action avoids 2,4-D because of its 

more risky environmental and human health 

profile, and strong public opposition. 

The rationale for the final decision will be in the 

Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-148 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

The DEIS is lacking needed specific analysis of specific 

impacts of different herbicide formulas and active ingredients 

to water quality and extent of potential water contamination at 

what distance from the application source. 

The DEIS considered herbicide effects on water 

quality from the standpoint of human health as 

well as from the standpoint of aquatic organisms. 

The treatment standards require that site 

conditions including proximity to water and 

beneficial uses of water (e.g. municipal 

watersheds, fish habitat) when determining 

treatment methods. 

The DEIS is lacking needed specific analysis of the combined 

synergistic effects of the use of 1) different ingredients within 

an herbicide formula and 2) different herbicide formulas used 

in the same area over time. 

Section 5.4 of Appendix Q “Human Health Risk 

Assessment” discloses accepted scientific 

principles and analysis for estimating the effects 

of chemical mixtures, including multiple 

ingredients within a herbicide formulation, and 

multiple herbicides applied simultaneously. The 

rationale for estimating cumulative effects of 

mixtures is disclosed. Only in those few cases 

where one ingredient by itself approaches the 

Hazard Quotient for a toxic effect would the 

addition of other ingredients pose a risk of 

exceeding the HQ. 

Each FS/SERA herbicide risk assessment 

analyzes the fate of the herbicide in the 

environment over time. Using decomposition 

rates, residual herbicide concentrations could be 

estimated for cumulative effects estimation at the 

time (at least one complete growing season) of a 

subsequent herbicide application. As there is 

always some decomposition over time, the 

cumulative effects for this last scenario will be 

less than the effects estimated for simultaneous 

application of the same two herbicides. 

The human health and FS/SERA assessments are 

summarized in the EIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-149 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

NOAA Fisheries is concerned that the uncontrolled 

combination of pesticides may pose unintended risks to 

species and their ecosystem. Pesticides in mixtures can 

interact with one another and alter the toxicity by additive, 

synergistic, or antagonistic means. An additive effect occurs 

when the combined effect of several chemicals is equal to the 

sum of individual effects of each chemical as if they were 

alone (Klassen 1986). Synergism, a greater than additive 

effect, occurs when the combined effect of two chemicals is 

greater than the sum of the effect of each agent individually 

(Klassen 1986). Antagonistic effects occur when a mixture 

contains chemicals that interfere with the action of the other 

chemical in the mix. Antagonism occurs with chemicals that 

have different modes of action. When found in mixtures, 

pesticides with similar modes of action generally interact in an 

additive manner (Lydy et al., 2004; Faust et al., 2001; 

Altenburger et al., 2000; Bailey et al., 1997) and occasionally 

in a synergistic manner (Denton, 2002; Forget et al., 1999; 

Pape-Lindstrom and Lydy, 1997). Implications of these 

interactions are not trivial to species or their habitats. 

Organism responses can be misrepresented and 

underestimated (mortality, fecundity, behavior, growth, etc.) 

when analyses are based solely on single pesticides. Without 

addressing mixture toxicity, it is likely that unintended 

negative consequences will occur in some locations affected 

by the proposed action. If the FS proceeds with this 

uncontrolled combination of herbicide tank mixes, then the 

effects of all possible combinations on salmonids and their 

ecosystems should be evaluated through literature searches 

and subsequent data analyses. This approach highly 

complicates the Biological Assessment (BA) and Biological 

Opinion processes under the ESA, and would likely lengthen 

the NEPA and ESA timelines. NOAA Fisheries recommends 

that the FS remove the phrase "or more," and limit the list of 

tank mix options to those combination of formulations that 

have been analyzed in the existing risk assessments and the 

open literature and include that list in the FEIS and ESA BA. 

Additional tank mixes could be employed in the future 

following appropriate NEPA evaluations and ESA section 7 

considerations. 

Please provide a discussion of how potentially millions of 

possible combinations of herbicide mixtures are allowed 

under Standard #16. NOAA Fisheries recommends either 

fully addressing this complex topic, or changing the Standard 

to limit the number of mixtures and formulations to that which 

can be analyzed and discussed. 

The FEIS includes more information about 

potential use of chemicals. Standard 16 in all 

alternatives has been amended to address tank 

mixing. Mixtures of herbicide formulations 

containing specific active ingredients may be 

applied where the sum of all individual Hazard 

Quotients for the relevant application scenarios is 

less than 1.0. This is a cautious approach based 

on the Guidance Manual For The Assessment Of 

Joint Toxic Action Of Chemical Mixtures (US 

Department of Health and Human Services, 

2004). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-150 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

The DEIS is lacking needed specific analysis of which 

herbicide formulas, active ingredients and inerts cause exactly 

what health effects to humans and wildlife species at what 

concentrations. For instance, I had to guess that picloram and 

triclopyr are the herbicides that could exceed EPA thresholds 

for cancer based on the DEIS alone: other health effects are 

even less defined re: which herbicide causes them. 

The disclosure in the EIS is based on complex 

toxicological risk assessments that are difficult to 

summarize effectively. Multiple variables 

combine in risk assessment, not just the herbicide 

used but the specific formulation, dose, method 

of application, and other factors influence the 

results. The authors of the EIS have endeavored 

to clearly disclose the relative risks and hazards 

associated with the proposed herbicides. 

The DEIS raised concerns that drift from glyphosate could 

affect long-term sustainability of lichens and bryophytes. 

Further glyphosate-containing products are acutely toxic to 

animals, including humans. Laboratory studies have found 

that all glyphosate containing products include medium term 

toxicity (salivary gland lesions) long term toxicity (inflamed 

stomach linings) genetic damage (in human blood cells) 

effects on reproduction (reduced sperm counts in rats, 

increased frequency of abnormal sperm in rabbits), and 

carcinogenicity (increased frequency of liver tumors in male 

rats and thyroid cancer in female rats) (Cox 1998). People 

who were occupationally exposed to glyphosate herbicides 

had a threefold higher risk of hairy cell leukemia, a form of 

the cancer non-Hodgkin's lymphoma. In addition, glyphosate 

has been associated with an increase in miscarriages, 

premature births, and attention deficit disorder. We are 

concerned that the human population and the wildlife will be 

exposed to the same health risks. 

The FS/SERA risk assessment for glyphosate 

(2003) identifies the broad susceptibility of nontarget plants to glyphosate. This was discussed 

in DEIS Chapter 4.3. The studies cited in Cox, 

1998 were considered in the FS/SERA risk 

assessment for glyphosate (2003), and 

incorporated into the DEIS effects analysis. 

These studies are evaluated within the context of 

the large body of data on glyphosate effects, and 

where studies appear sound, they are considered 

in developing the lowest NOAEL exposure limits 

and the subsequent characterization of hazard 

and risk in the FS/SERA risk assessment. This 

information would be considered in site-specific 

projects that propose to use glyphosate. 

I submit alarming evidence about the possible effect of 

Round-up increasing the deadly fungus FUSARIUM in soils. 

(See attachment B- Monsanto's herbicide Roundup linked to 

deadly fungus.) If it can happen in crops it can perhaps happen 

in forests. Please address this in you IPEIS. How will you deal 

with that problem if it arises? 

The FEIS has been amended to acknowledge that 

glyphosate may be an energy source for some 

soil organisms. Forest soils have much healthier 

food webs than agricultural soils so fusarium 

would be less likely to thrive. 

The DEIS shows clear and repeated bias toward the use of 

toxic herbicides and exotic, largely untested biocontrols over 

the protection of plant and wildlife diversity; soil fertility; 

water quality; Endangered, Threatened and Sensitive-listed 

species; rare species; ecological integrity of food webs and 

inter-species relationships and human health. This bias must 

be corrected at the programmatic level or all these values are 

at greater risk due to ill-advised regional direction to Forest 

Service staff. 

The Forest Service attempts to consider and 

resolve public issues in a non-biased manner. 

The fact that public comments to the DEIS state 

that the Forest Service is biased both for and 

against herbicide use would indicate that the 

Forest Service approach is balanced. 

[The] Journal of Pesticide Reform [states:] "Imazapic is 

persistent, damaging crops up to 40 months after the 

application and has chemical properties that make it likely to 

concentrate water." The same page 10, highlighted in yellow, 

states it does accumulate in actively growing tissues! Whoever 

has written up this IPEIS has not done their homework on the 

potential harm of these herbicides and needs to do so in the 

final EIS. 

The studies cited in the cited journal have been 

reviewed and incorporated where appropriate in 

the FS/SERA Imazapic herbicide risk 

assessment. The concerns raised by the 

comments are either not supported by the body 

of scientific literature, or are not expected to 

result from FS invasive plant treatments within 

the scope of this EIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-151 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

Reported half lives for TCP (though its potential effects are 

not disclosed) range from 8-279 days in 15 soil types. "TMP 

is another degradation product although it is found less often 

and in smaller amounts." (Profile p.4) So what are the 

consequences of human and environmental exposure to TCP 

and TMP? Apparently these triclopyr degradation products 

are not even mentioned within the EIS, much less analyzed. 

The FS/SERA risk assessment for triclopyr 

identified any metabolites and degradation 

products of potential toxicological significance 

and the DEIS evaluated their potential risks from 

use of these formulations in FS invasive plant 

treatments that comply with the standards. 

The absence of reported cases of long -term health effects 

from triclopyr does not mean that there are no long-term 

effects. Health effects could be experienced by members of 

the public who had no knowledge that they were exposed to 

triclopyr (eg. who were exposed to spray drift or consumed 

contaminated wild edible plants or meat/dairy products from 

livestock grazing on contaminated forage). Long-term health 

effects are especially hard to trace back to their source. Such 

uncertainties should have been discussed within the EIS. 

Appendix Q, “Report Human Health Risk 

Assessment” displays the estimated potential 

risks to workers and the public, typical and 

worst-case, for the suite of herbicides and 

methods for each alternative. The risks are based 

on Reference doses developed from studies of 

both short and long-term exposures of mammals 

to the herbicides, and incorporates any data 

available from human population studies. The 

long-term studies and human population studies 

are intended to account for long-term health 

effects that may not be immediately expressed or 

detectable. Finally the Reference dose reduces 

the threshold dose for potential for toxic effects 

by at least 99 percent to account for uncertainties 

such as you describe. The Report also discusses 

the potential for effects at even lower doses for 

sensitive individuals in the human population. 

These findings are summarized in the EIS. 

There appears to be no disclosure or analysis of the effects of 

TCP (3,5,6-trichloro-2-pyridinol), a degradation product of 

triclopyr, to human health or the environment. This means 

that triclopyr in any of its formulations should not be used, as 

there is no way to adequately assess the risks of its use 

without this information. 

All relevant data concerning environmental 

consequences, human health and ecological risks 

from FS invasive plant treatment using triclopyr, 

including those of TCP, are analyzed in detail in 

the FS/SERA Triclopyr risk assessment (2003) 

and potential effects were detailed in Appendix 

Q “Human Health Risk Assessment” and 

summarized in the DEIS. 

What are the potential risks to endangered plant and wildlife 

species in Region 6 from the use of triclopyr formulations 

under the alternatives considered? 

Chapter 4 of the DEIS described the risks of all 

herbicides considered including triclopyr to nontarget plants and special status species. 

An article in Aug. 31, 04 Register Guard quotes your botanist 

Jenny Lippert as saying you may need to aerial spray 

herbicide in Eastern Oregon. A June 22, 04 letter from our 

congressman Peter DeFazio states "the U.S. Congress has 

banned herbicide aerial spraying on Federal lands." Please 

make all your staff aware of this legislation. Don't use 

herbicide poisons on our land! 

Congress has not banned aerial spraying on 

National Forest. Herbicide use is subject to many 

environmental laws and policies that tend to 

minimize aerial spraying. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-152 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

I am concerned that your analysis has built in additional safety 

margins on top of theirs [EPA]. You are both federal 

agencies, and USFS should as such accept EPA safety 

calculations, and recognize that these products are safe when 

used as labeled. 

Herbicides used according to EPA approved guidelines 

represent the wisest, most cost efficient way to use public 

funds (tax receipts) for restoring lost and nearly lost precious 

natural resources. 

We recommend the EIS be written in a manner consistent with 

the standards the Environmental Protection Agency (EPA) 

uses in approving a labeled use; not on an individual chemical 

basis. The EIS should allow newly approved EPA chemicals 

to be used on an as labeled basis. 

The Forest Service is required to fully consider 

environmental effects of herbicides, even when 

used as labeled. NEPA requires the Forest 

Service to consider measures to reduce adverse 

effects to the human environment. 

Newly approved chemicals would need to be 

evaluated under NEPA for use on the National 

Forest. The NEPA analysis would tier to and 

incorporate this EIS as appropriate to avoid 

redundancy. 

3-86, "Herbicides may control all types of vegetation, or they 

may kill some types of plants while not affecting other types". 

This document has been written at a scientific level, however, 

the above sentence is accurate, however, could be written to 

sound more scientific/less awkward, i.e. herbicides may be 

non-selective (controlling all types of vegetation), or they may 

be selective, selectively controlling only broadleaf or 

selectively controlling grasses, or very selective in controlling 

only specific broadleaves or grasses. Or the book could insert 

a terminology box (i.e. highlighted in gray on 3-85) to explain 

selectivity. 

This paragraph has been edited to read: “...lower 

concentrations mean smaller amounts of the 

active ingredients are released into the 

environment.” 

Page 3-86 states, "Herbicides may be sprayed from wheeled 

vehicles with hose sprayers or pump-driven booms using an 

array of spray nozzles". This sentence is awkward, suggested 

re-wording. The two most popular methods of applying 

herbicides via ground vehicles are boom sprayers or hand-gun 

sprayers. Typically the sprayer pump is powered by an 

independent gas-powered motor or electric motor. Sprayer 

pumps are mounted on ATV's, 4WD pickups, and larger 

vehicles. 

The FEIS has been corrected in light of this 

comment. 

Page 4-24,Second to last paragraph. "On the other hand, lower 

concentrations mean smaller amounts of toxic substances are 

released into the environment". The word "toxic" seems like a 

biased exaggeration. 

This paragraph has been edited in the FEIS: 

“...lower concentrations mean smaller amounts 

of the active ingredients are released into the 

environment.” 

[Herbicide spraying] endangers surrounding watersheds, 

native plant species, wildlife, and most important the health of 

people living in surrounding communities. Please continue 

your commitment to refrain from spraying in our national 

forests. 

The DEIS discussed why herbicide use is being 

considered for invasive plant management in 

Region Six. However, standards would be 

adopted in all alternatives to protect watersheds, 

native plants and wildlife and human health. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-153 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

I want to urge you not to resort to spraying herbicides in the 

national forests. Herbicides may look like a "quick fix" but in 

reality they only further abuse the forest by harming nontarget species, wildlife, the soil and ground water. For the sake 

of the future health of our forests, please commit to nonherbicide means of controlling invasive plants. 

I live in a highly forested area and would like to think the air I 

breathe and the creek I wade in are free of pesticides. But I 

don't believe it's true. I have neighbors, and what's forested is 

logged occasionally and sprayed too. I worry about the bees I 

take care of and my cat and our quality of life in general as 

part of this beautiful environment that's being unmindfully 

managed in respect to pesticides. Please continue to keep this 

reliance to a minimum. 

The alternatives vary in their response to public 

issues about herbicide use. The DEIS took a 

hard look at the need for and risks involved with 

herbicide use, and concluded that under certain 

conditions, herbicide use is appropriate. 

Rationale for using herbicide would be required 

under the Proposed Action and non-herbicide 

methods would also be tried first under 

Alternative B. 

With respect to the National Forests the use of herbicides is an 

extremely bad idea. I have always noticed that when 

herbicides are used, noxious weeds of certain types tend to 

take over the area sprayed within a few years because no 

herbicide selects for all weeds. The result is that the situation 

in which one is trying to control weeds because less 

controllable. Please do not sacrifice our national forests for 

the sake of very short term gain from herbicide use. 

The wholesale use of herbicides to control invasive plants is 

shortsighted at best. The evidence is abundantly clear that 

pesticides and herbicides lead to long-term environmental and 

health problems. It makes no sense to me to treat one problem 

by causing another. 

The FEIS further discusses the effectiveness of 

herbicides in various situations. While no 

herbicide selects for all weeds, integrated pest 

management and adaptive management can be 

applied to treatment areas to ensure that desired 

conditions are attained. 

None of the alternatives advocate “the wholesale 

use of herbicides.” Rather, an integrated 

approach to prevention and treatment is 

advocated. 

Rare use of aerial spraying needs to be emphasized. As you 

know, aerial spraying is highly ineffective as a target method 

of delivery. Only 13% accuracy has been documented by the 

Forest Service's own research from the days when aerial 

spraying of National Forest was more common in the Pacific 

Northwest. 

Under the Proposed Action, Standard 16 would 

restrict aerial applications for the more powerful 

ingredients of the sulfonylurea group to mitigate 

effects from offsite drift. It also restricts 

triclopyr to selective applications, which will 

also reduce direct effects to woody species. 

Alternative B includes greater restrictions. The 

DEIS acknowledged that without these 

restrictions, effects on non-target species are 

more likely. The DEIS stated that the lack of 

restriction on aerial spraying of the sulfonylurea 

ingredients and glyphosate in Alternative D is 

the reason it has “relatively higher potential to 

harm” non-target species. 

Chapter 4-16: [H]erbicide resistance by invasive weeds can 

be reduced by tank mixing two or more herbicides with 

different modes of action within the plant. Rely on local 

expertise of professional applicators, chemical manufacturer 

representatives, university researchers, and chemical 

distributor representatives. 

Standard 16 has been modified in all FEIS 

alternatives to address the use of herbicide 

mixes. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-154 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

Error: Chapter 3-88 - Imazapyr does not effectively control 

blackberries in the Pacific Northwest. I helped do some of the 

research to get this compound registered and found in tests 

and in field usage that it does not control blackberries. 

Glyphosate, metsulfuron methyl, and triclopyr are very 

effective on blackberries. 

Error: Chapter 3-89 - Metsulfuron methyl "no effects on 

most woody species" Comment: This is not true; 

salmonberry, thimbleberry, elderberry, and blackberries are 

very well controlled. Significant damage will occur to species 

such as willow, vine maples, and others as well. Most 

deciduous tree species are not killed, but may be lightly 

damaged by this product. Most conifers actively growing will 

be heavily damaged or killed with the labeled rates of 

metsulfuron methyl. 

The FEIS has been corrected to incorporate this 

information. 

4.2.2 Background / Social Acceptability and Effectiveness 

Paragraph states management actions should be consistent 

with prevailing social norms. Although people expressed that 

use of herbicides is not socially acceptable, use of herbicides 

is the social norm. Millions of people have their lawns treated 

by Turf companies that use herbicides to control lawn weeds. 

Golf courses and places of business use herbicides for 

maintenance. The majority of food crops are grown with the 

aid of herbicides. County, State and federal agencies use 

herbicides for vegetation management on sewage ponds, 

roadways, etc. Power companies use herbicides to maintain 

power lines to limit power interruption. Railroads use 

herbicides to limit fires from sparks lighting vegetation and 

keep tracks clear. The majority of households have a bottle of 

Roundup or Weed-B-gone in their garage or shed. As much 

as people hate to admit it, use of herbicides is a social norm. 

Herbicide use may be a social norm but the 

public continues to express concern about their 

use on National Forests. These concerns are 

addressed in the EIS. 

4.5.2 Direct and Indirect Effects, Comparison of Alternatives -

Risks to Workers and the Public From Herbicides, Paragraph 

2: The use of streamside no-spray zones would be detrimental 

to an invasive plant control program. Streams are a major 

avenue of invasive plant spread and it is important to eradicate 

invasive plants in this area. As stated throughout these 

comments and the EIS, there are invasive plants that can be 

controlled by no means except an IPM program that includes 

herbicides, for example Japanese knotweed. In this case, 

aquatic approved herbicide formulations (imazapyr, 

glyphosate, triclopyr) should be allowed within any 

streamside no-spray zone. 

The EIS needs to recognize that all noxious weeds need to be 

controlled, even those in riparian areas. Weeds close to water 

are many times most susceptible to spreading quickly. The 

label should be used as the limiting factor in where chemicals 

are used. 

The FEIS has been edited to state that avoiding 

aerial spray in municipal watersheds and using 

aquatic label herbicides near streams would 

protect drinking water. Riparian zones would 

not automatically be off limits to invasive plant 

treatment. The label is one limiting factor among 

others (for example, presence of special status 

species, municipal watershed designation). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-155 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

Herbicide Section Final paragraph referring to Table 3-12. In 

reference to the registered EPA uses, 3 of the proposed 

herbicides have aquatic labels in addition to forestry, right-ofway and rangeland labels. These three are Imazapyr, 

glyphosate and triclopyr. This fact should not be over looked 

because aquatic labels may be needed in several situations for 

control of knotweeds, whitetop, purple loosestrife, water 

milfoil, reed canarygrass and possible others. This fact was 

never clearly addressed. 

Standard 19 requires that site-specific soil 

characteristics, proximity to surface water, and 

local water table depth be considered in 

determining whether to buffer a creek, use an 

aquatic label formulation, or adjust application 

method or timing within riparian areas. Chapter 

3 discussed invasive plants such as knotweed 

that grow near streams. 

Herbicide use. In my experience, these have no value even as 

a last resort. There are a zillion complicated side issues such 

as non-inert inerts, effects on amphibian extinction from 

atrazine etc, and contamination of public drinking water such 

as happens on the upper Willamette NF, but my main issue is 

if Roundup etc really worked - and millions of gallons have 

been applied to our public lands - why are the roadside and 

riparian forest lands still full of Himalayan blackberry, scotch 

broom, and worse? I would like the Final EIS to list specific 

areas where herbicides have in fact restored native plant 

populations. If there are none, then the document should 

specify alternative management techniques that do have 

potential to achieve lasting results. Herbicides in conjunction 

with continuing the disturbances that led to invasive plants in 

the first place. 

The FEIS provides further discussion about the 

utility of herbicides in restoring native plant 

populations. 

Quileute has been applying Monsanto herbicides in the 

Dickey watershed of the Quileute System in Clallam County, 

WA. We have seen initially that native and non-native 

species were impacted adversely. However, the native species 

reseeded from adjacent land, while the knotweed (so far not a 

fertile hybrid, though that may change), remained eliminated. 

So that native regeneration needs to be considered in risk 

analysis. 

Native plant regeneration is included as part of 

the site restoration/revegetation sections of the 

DEIS. Further discussion has been added to the 

FEIS in Chapter 3. 

The dependence on herbicides will disrupt native ecosystems 

and place unnecessary risks on human health. These 

herbicides will impact plant diversity. As DiTamaso (2001) 

points out, continuous broadcast of one or a combination of 

herbicides will select for tolerant plant species. When broadly 

selective herbicides are used, noxious annual plants such as 

cheat grass often proliferate. Population shifts can also occur 

through the repeated use of a single herbicide by reducing 

plant diversity and nutrient availability. "Herbicides are 

designed to kill plants, some damage to non-target plant 

species is probable despite cautious planning and 

implementation." (DEIS 4-23). 

The DEIS explained that due to the nature of 

herbicides, some effect may occur, but mitigation 

measures directed through the standards will 

minimize such effects. DiTomaso suggests the 

use of a combination of herbicides in an 

integrated approach, which was emphasized in 

the DEIS to varying degree by alternative. 

The EIS needs to recognize the particular and inherent risk of 

Riparian Weeds and emphasize that the treatment of nonnative invasives in riparian areas is a top priority because of 

their ability to spread and substantially impact riparian 

function; and also because of their proximity to aquatic 

species (particularly T&E species). Add riparian weeds as a 

priority for treatment to table 3-15 on pg 3-97. 

Riparian species were discussed and designated 

as high priority in Chapter 3 of the DEIS. The 

FEIS expands this discussion. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-156 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

State amount of herbicide use you are planning to use - when, 

where, why & cost. 

These are site-specific questions that would be 

answered in project-scale analysis. The DEIS 

disclosed assumptions about how many acres 

would be treated with herbicide under each 

alternatives, why herbicides would be used, and 

the cost of their use. 

Our concern is that a proposed eradication solution could 

create a new environmental problem. For example, the use of 

herbicides can be just as deleterious to the ecosystem as nonnative invasive species. These agents can kill much more than 

the intended target, "opening the door" for non-native 

organisms. 

This concern is one of the reasons why site 

restoration/revegetation is emphasized in the 

EIS; to reduce the chances for invasion from 

other organisms. 

Acquired pesticide resistance should be considered. The EIS 

should have analyzed a number of plants that are known to 

have become pesticide-resistant. The use of broadcast 

treatments of non-specific chemicals over large areas will 

certainly increase our reliance on stronger chemicals as more 

plants develop resistance. 

Discussion on resistance was consolidated and 

expanded in Chapter 4. 

Non target mortality to plants from herbicides should be 

minimized. Forest Service contract inspectors should be 

required to monitor wind and precipitation every day during 

herbicide applications. The EIS did not provide safeguards 

against non-target mortality from herbicides. This happens 

whenever broadcast herbicides are used along roads, 

particularly if there is wind. 

By requiring that herbicides be applied by or 

supervised by certified pesticide applicators, 

such safeguards will be instituted. Trained 

applicators are aware of such basic precautions 

and are trained to follow EPA labels. Also, 

Standard 19 was designed to guide the 

development of such safeguards. 

Require all National Forest pesticide applications to account 

for pesticides through a clause that ensures the Forest Service 

can determine the actual quantities of herbicides provided to 

contractors. 

Accountability for pesticide use in all NFS 

herbicide applications is provided through 

compliance with agency direction (FSM 2150, 

FSH 2109.14), and with state pesticide reporting 

regulations 

Risk of herbicide spills should be mitigated. The EIS should 

provide mitigation measures that provide safeguards against 

herbicide spills. 

Several of the treatment/restoration standards are 

aimed at reducing the risk of herbicide spills. 

The DEIS implies that over 8,000 acres will be treated with 

herbicides that have a "higher potential to harm non-targeted 

plants," (DEIS 4-35) almost 9,000 acres will be treated with 

herbicides that "could result in harmful doses to birds and 

mammals," (DEIS 4-54) and one herbicide is approved that 

"may harm amphibians." Within the DEIS and most 

specifically the agency's Preferred Alternative, the following 

must be corrected: there is no management objective for 

limiting direct and indirect negative effects to non-target 

animals and non-target native plants. 

Standards 19 and 20 were developed to address 

these concerns. 

The community becomes distraught and divided when 

herbicide use is proposed by the Forest Service. People will 

trust the FS much more if a clear "last resort" policy is 

followed. If the FS is perceived as casually employing 

herbicide people get very upset and that makes our job of 

pulling people together much harder. 

Social acceptability of treatment methods is 

discussed in Chapter 4. Partnerships and 

collaboration are discussed under integrated 

weed management in Chapter 2, background in 

Chapter 4, and in Appendix I. Alternative B 

maintains herbicides as a “tool of last resort”. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-157 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

Additionally, when public land managers resort to use of 

pesticides including herbicides, they create a demand that 

these chemicals be manufactured, transported, stored, and also 

that waste products from manufacturing and use be disposed 

of somewhere. Therefore, communities and ecosystems 

somewhere else are being negatively impacted; the health of 

the neighboring communities of humans to the manufacturing, 

use and disposal of these chemicals are made to suffer health 

effects; and the human environment is significantly affected. 

The use of chemicals - herbicides and adjuvants - on the 

Pacific Northwest Region 6 creates the need for an 

Environmental Impact Statement not only for the locations on 

Forest Service's lands, but also other locations where the 

major federal action of using chemicals on these public lands 

has an additional major federal action of creating the need to 

manufacture the chemicals, transport, distribute, store, and 

ultimately dispose of these chemicals which significantly 

affect the quality of the human environment in communities 

near the manufacturing, transportation of, storage of, and the 

disposal of those chemicals. In short, the demand for 

herbicides and adjuvants by FS Region 6 creates the need for 

an EIS to address the impacts in other locations in addition to 

the FS Region 6 lands pursuant to 40 CFR 1502.3. Where is 

that EIS? 

Chapter 4 of the DEIS displayed the projected 

contribution of FS herbicide treatments (3 

percent) toward the estimated total agricultural 

herbicide use in Oregon and Washington. This 

small fraction is even smaller, when all herbicide 

uses are considered. No evidence is presented 

that the number or production levels of any 

herbicide manufacturing facilities would be 

materially affected by alternatives in this EIS, 

nor does that scenario follow logically from the 

miniscule fraction that the proposed FS action 

would contribute to estimated total production of 

herbicides and any manufacture waste products. 

Waste products from FS herbicide use are 

minimal; good handling practices encourage 

purchase of only the quantity needed, and 

contracts require that that the applicator retain 

possession of all leftover herbicide, for which the 

financial incentive is to use it legally on other 

projects, not to surplus it as waste. 

Project level mitigation is highly variable and often 

inadequate - it can not be used to guarantee lack of significant 

environmental or human health risk impacts - especially as it 

is often not funded and never takes place. Mitigation funding 

needs to be guaranteed. 

The Forest Service is required to implement the 

mitigation measures approved in NEPA 

documents. Required measures are funded as 

part of project implementation. 

The following herbicides should be eliminated because they 

create exposure scenarios that exceed toxicity indices for birds 

and mammals even under Alternative B: clopyralid, 

glyphosate, sethoxydim and triclopyr. (see Table 4-11). 

Exposure scenarios provide a useful tool to 

compare the relative risks of each herbicide. Not 

all exposure scenarios are very plausible in terms 

of actually occurring due to a field application. 

The number and type of exposure scenarios that 

exceed the toxicity indices was used to design 

the standards in each alternative. The ROD will 

outline the rationale for including or excluding 

the particular herbicides chosen. 

How will you avoid contamination of rivers, streams and 

endangered plant species during and aerial spray? Wind 

factors can change upon the instant! Much of the sprays 

ability to perform is lost during aerial sprays so massive doses 

are usually required. 

Project specific plans would outline how 

waterways and habitats would be affected. The 

projects would be required to comply with the 

standards intended to minimize adverse effects to 

non target species, water quality and habitats. 

Doses would not exceed levels analyzed in the 

EIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-158 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

Please put into your final IPEIS a comparison study of all 

herbicides to be used in your plan. The comparison study 

would compare the different science studies on the toxic 

potentials of each chemical so there is no bias in your plan to 

justify using that chemical based solely on the studies given 

by the manufacturer itself on the labs where they have been 

tested that favor the outcome of the company which employed 

it. I submit comparison sheets as an example and they directly 

contradict each other. Please justify in you final IPEIS why 

your plan will favor one study over another. 

Each alternative describes the estimated effects 

for the herbicides included for invasive plant 

treatment on National Forest in Region 6. The 

FS/SERA risk assessments are the basis for the 

EIS effect analyses. The risk assessments 

describe and reference all studies used to develop 

the estimates of effects for that individual 

herbicide and its relevant formulations. 

Newmaster (1999). Further drift from the application of 

triclopyr could affect the sustainability of populations of 

lichens and bryophytes. Normal application rates in aerial 

spraying were found to reduce abundance by 75% (DEIS 4-

28). Triclopyr has also been found to inhibit the growth of 

ectomychorrhizal fungi associated with conifer roots at 

concentrations of 1000 parts per million. Since science has 

shown that nearly if not all trees depend on this symbiotic 

relationship, then the continued use of triclopyr can have 

serious effects on forest health. Triclopyr has much different 

documented toxicity. 

Triclopyr causes an increase in breast cancer, an increase in 

genetic damage such as dominant lethal mutations, an 

increased incidence of reproductive problems, and damage to 

the kidneys. The ester form of triclopyr is highly toxic to fish, 

inhibits behaviors in frogs that help them avoid predators, and 

decreases the survival rate of baby birds. Triclopyr also 

inhibits the growth of mycorrhizal fungi, and with fixation of 

atmospheric nitrogen. Triclopyr is mobile in soil and readily 

contaminates wells, streams, and rivers. The major breakdown 

product of triclopyr (3,5,6-trichloro-2-pyridinol) disrupts 

normal growth and development of nervous systems and 

accumulates in fetal brains. 

The risks associated with various exposure 

scenarios for triclopyr were discussed throughout 

Chapter 4. Standard 16 limits the application of 

triclopyr to selective techniques so that 

application to soils and hence mycorrhizae would 

be minimized. 

 

It would seem that many of the concerns with broadcast 

application of Triclopyr (non-target impacts, public and 

worker safety, etc.) could be addressed through site-specific 

analysis and mitigation at the EA or project level. The 

Proposed Action could provide standards to limit broadcast 

application of Triclopyr. Triclopyr is an important and 

effective herbicide tool for adequate control of many noxious 

weed species and is the preferred choice for many treatment 

prescriptions (i.e. gorse, brooms, butterfly bush, Himalayan 

blackberry, purple loosestrife control) and specific site types. 

Triclopyr has a riparian and aquatic EPA registration. We 

suggest having a means to allow some level of broadcast 

application of Triclopyr even on a limited basis. To minimize 

or avoid adverse impacts at the EIS level, Forest/EA or project 

level, standard 20 in Table 2-4 of the Proposed Action should 

be adopted. The standards should also reduce any associated 

risk to proposed and listed species and their habitat. 

Alternative D allows for broadcast application of 

triclopyr. The Proposed Action restricts such 

use. Your comments will be considered and the 

rationale for the final decision will be described 

in the Record of Decision. The Regional 

Forester may combine standards from multiple 

alternatives in the final decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-159 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

The ROD also needs to clarify or define what spot treatment 

means regarding Triclopyr application; the only indication 

was the example in Chapter 4-70. From this statement a spot 

treatment is a backpack, directed stem spray or OHV method 

of application. Spot spray or directed application could also be 

made with a spot spray boom, handgun and other application 

method that directs the application to the intended target. 

The list of “approved” spot application methods 

has been amended in the FEIS to clarify that the 

intent is to allow triclopyr application methods 

that minimize non-target exposures. 

Although more recent studies are noted to be detailed in 

SERA (1996), the methodology for these studies and their 

results are not disclosed in either the current EIS or the 

Herbicide Information Profile, making it difficult or 

impossible for the public and other decision-makers to reach a 

knowledgeable conclusion re: the health risks of triclopyr use. 

The Herbicide Information Profiles, herbicide specimen labels 

(not included in the EIS or provided otherwise for public 

review) and Material Safety Data Sheets are not disclosed in 

the EIS or otherwise made available to the public for most of 

these herbicide formulas. 

The risk assessments were available on request 

and are currently posted on the website 

(www.fs.fed.us/r6/invasiveplant-eis) 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-160 

Table 29. Comments and Responses about Herbicide Use

Comment Response 

Known potential impacts of triclopyr formulations not 

discussed within the EIS include their potential to leave 

residues in meat and milk (through livestock grazing and hay 

production) that may exceed EPA standards (profile p.3), 

potential damage to broadleaf crops, potential spray drift to 

non-target areas (ibid), the potential to inhibit the germination 

of soil-stored native plant or crop seed at higher 

concentrations, greater adsorption of triclopyr in soils that are 

alkaline with low organic matter (as in much of eastern 

Oregon, Eastern Washington and Idaho), triclopyr's long 

persistence in soils (75-81 days in W. Oregon, Norris et al. 

1989 - for half lives, and detectable triclopyr residues in soil 

477 days after "treatment"!) 

Other potential impacts and relevant residue transport/vectors 

not disclosed or analyzed for triclopyr within the EIS include 

its capacity to leach into groundwater, which exceeds the EPA 

threshold for solubility, the ability of the metabolite TCP to 

persist in groundwater (Profile, p.4), triclopyr's detection in 

runoff in western Oregon 9 months after application, detection 

of trace amounts of triclopyr in some samples of southern 

Oregon airsheds, release of toxic hydrogen chloride and 

phosgene from burning of vegetation sprayed with triclopyr 

formulations Garlon 3A (hydrogen chloride only [illegible?]), 

Garlon 4 and Pathfinder II (both), 68% of triclopyr having 

been recovered intact in smoke under smoldering conditions, 

possible contamination and injury of nontarget broadleaf 

plants via "very small amounts of spray" and clippings used as 

mulch that are contaminated with triclopyr, triclopyr having 

been found in berries 6 days after spraying, & TCP having 

been detected in root crops following application of an 

insecticide that also degrades to TCP. (Profile, p.5). 

All relevant data concerning environmental 

consequences to human health and the 

environment from FS invasive plant treatment 

using triclopyr are analyzed in detail in the 

FS/SERA Triclopyr risk assessments (2003 and 

1996) and potential effects were summarized in 

the DEIS. Identified potential risks resulted in 

restriction of certain applications of triclopyr in 

the Proposed Action and Alternative B. 

Public Notification of Herbicide Use

Commenters expressed concern that the DEIS did not include a standard for public 

notification. In response, the Forest Service modified all action alternatives to include 

Standard 23, which requires that Forests create a plan for public notification and signage if 

they are using herbicides. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-161 

Table 30. Comments and Responses about Public Notification of Herbicide Use

Comment Response 

To reduce public exposure, however, posting warning signs 

where spraying is done for either applications would be 

helpful. Using dates on the signs as to when the application of 

these sprays is no longer harmful. 

The EIS should have considered whether to allow a greater 

degree of protective signage. We recommend providing 

warning signs for all pesticide applications, for at least two 

times the expected half-life. 

How will you warn people that an area has been treated with a 

certain pesticide or herbicide? 

This concern is addressed through the addition of

Standard 23 to all action alternatives, requiring 

that Forests create a public information plan with 

notification and signage responsibilities (See 

Chapter 2). 

Merits of the Alternatives

Many people commented about the merits of the DEIS alternatives in total or about the merits 

of elements of the alternatives. The set of comments below require no specific response at 

this time. The Regional Foresters will consider these comments and document her rationale 

for the selected alternative in the Record of Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-162 

Many people suggested that elements of multiple alternatives be combined for maximum 

effectiveness. They noted that if prevention standards in Alternative B were combined with 

the Treatment Standards in the Proposed Action or Alternative D, the overall result would be 

more effective than any single alternative currently considered. The FEIS includes sufficient 

discussion about each standard to support a final decision that blends standards from multiple 

alternatives. 

Table 31. Comments about Merits of the Alternatives

Comment 

I support the proposed action and particularly like the emphasis on prevention. I believe the proposed action 

provides adequate and reasonable guidance for on the ground action by the Forest Service on Forest Service lands.

When you incorporate the high costs for herbicide treatments (Table 4-33, which incidentally seem excessively 

high from my experience), and the fact that you can treat a much greater area effectively in the short time window 

available annually for many of these weeds, Alt D looks far better. Table 4-34 shows what you can do with fixed 

dollars for each treatment method, again favoring Alt D. 

I believe that Alternative A is unacceptable. The local USFS personnel in Yakima County know that they need to 

use modern weed control technologies to fight invasive plants. But they are currently unable to use these methods 

under current policies. 

Considering the 4 proposed alternatives, it seems the "No Action" alternative could not accomplish the desired end 

and to not make best use of the people, expense and planning already expended and in place. It is unnecessarily 

passive and management restrictive. 

[Idaho State Department of Agriculture] supports the adoption of the Proposed Action. ISDA supports the USFS in 

efforts to efficiently manage noxious weeds. Control of noxious and invasive weeds within the Pacific Northwest 

Region will benefit the quality of the wilderness and the human environment. 

The proposed action recognizes the importance of early detection and rapid response in the treatment of newly 

detected noxious weed infestations. We believe rapid response to be the most effective means of exercising 

control while limiting effort, which must be expended to the smallest possible area. Significant portions of the 

forest within our county are being overrun with noxious weeds because there is not current mechanism to allow 

for early response. Currently, the time required to conduct a site specific analysis poses a true threat to forest 

health because the intervening time often allows noxious weed to gain a foothold. Once established, these 

population are much more difficult to effectively control. In our county weed control, we have found that the 

earlier the response, the greater the likelihood of achieving long-term success in controlling or even eradication 

of noxious weed populations. 

We also support proposed action C because it allows limited use of herbicides. While we are sensitive to public 

concern over widespread use of herbicides such as 2-4D, such as it proposed in alternative D, we also recognize 

that it is unlikely that an effective control program can be implemented without treatment with some herbicide. 

Alternative C identifies the following advantages It proposes use of herbicides only as a measure of "last resort"; 

It avoids the use of the most controversial of herbicides; It avoids the fallacy that manual or mechanical 

treatment alone is always sufficient to control or contain noxious weeds; It is a cost effective and culturally 

acceptable alternative. 

We also object to alternative B, which proposes additional restrictions on grazing, ATV and recreational access 

and road maintenance activities within the forest. Such proposals are offensive to the custom and culture of the 

citizens of the county and threaten the economic livelihood and well being of the citizens of this county. They 

should also be considered as a last result when all other efforts have failed. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-163 

Table 31. Comments about Merits of the Alternatives

Comment 

I am extremely opposed to the use of toxic herbicides 2,4-D and 2,4,5-T-since they have been proven to 

adversely impact all wildlife and to pollute the streams and rivers, salmon and to stay in the environment for a 

lasting negative impact on people. These chemicals have been proven to cause cancer and I for one am 

extremely opposed to any further destruction of out ecosystems. There are no invasive weeds that warrant the 

use of such toxic methods. 

The Nature Conservancy believes this thorough draft addresses the key issues in a frank, professional manner. Its 

treatment of the real risks of chemical and biological control treatments is excellent, and provides a good basis for 

the selection and use of herbicides and other methods described in the Proposed Action. There are also provisions 

in this EIS to support adequate and appropriate monitoring to detect change due to management actions. This draft 

EIS takes into consideration potential off-target impacts, especially health and safety issues when using herbicides, 

and we believe that the Proposed Action strikes the right balance in guarding against the risks to human and 

environmental health from these methods, and the risks of a failed invasive plant management program. The 

Nature Conservancy strongly supports the Proposed Action to provide direction and tools to protect National 

Forest lands from invasive plants in the Region. 

I find that the FS alternative is unlikely to adequately protect Public Lands from the continuing invasion and 

expansion of alien plants. Specific standards...that would provide improved protection from invasive plants are 

provided in the Restore Native Ecosystem Alternative (Alternative B). Thus, I strongly urge the Forest Service to 

adopt them in lieu of those provided in the Proposed Action since they are more likely to reduce the spread of alien 

invasive species on public lands. 

4.6.2 Costs of Invasive Plant Treatment Pg 4-94 "Significant potential effects" Bullet points; It should be 

emphasized and understood that the costs (dollars, time, inconveniencies) of the proposed prevention measures will 

be far less cost than paying the price of allowing invasive plant establishment, including cost of control, cost to the 

environment and wildlife, and spread to neighboring land. "Pay now or Pay later" applies here and the cost-benefit 

ratio is highly weighted towards greater benefit with the proposed Alternative B prevention measures. 

A mix of Purposed Action and Alternative B is needed to have an effective management program. One goal of the 

management plan is to reduce herbicide use. The most effective way to reduce herbicide use is to promote 

extensive prevention practices at the cost of multiple use and by putting more responsibility on those that work and 

play in the forest. A combination of the Proposed Action and Alternative B will be most effective in meeting these 

goals. From Table 2-4 Action Alternatives Standards the most effect combination is implementing Proposed 

Action standards 3, 11, 12, 13, 14, 15, 17, 18, and 19 as is, with Alternative B standards 1, 2, 4, 6, 7, 9, and 10 as 

is. Standards that need revision are discussed separately. 

The No Action alternative is unacceptable. It does not allow for control of numerous invasive weeds that can 

reduce biodiversity, cause irreversible economic and ecological damage, in addition to being a source of 

contamination to surrounding land, costing land owners, both public and private, countless millions of dollars in 

suppression costs alone, with no hope of eradication. 

Considering your stated objectives of reducing the rate of spread of invasive plants within Region Six, increasing 

the effectiveness of invasive plant management and protecting human health and the environment, the no action 

alternative which represents no change from the current direction is unacceptable. 

Clearly, No Action is unacceptable. The current and past direction of noxious weed control on national forests in 

the Pacific Northwest has been plagued by a lack of effective control techniques, insufficient preventative practices 

and inadequate regional coordination. While local USFS personnel in many places are well intentioned and hard 

working, the most effective weed control technologies are too often made unavailable to them. In our view, the 

many inadequacies of the current direction made the DEIS process necessary. Given all of the effort that's been 

put into this process by your staff and the many interested stakeholders, let's not end up back where we started. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-164 

Table 31. Comments about Merits of the Alternatives

Comment 

Use of the limited herbicides under Alternative B will require annual maintenance treatments or overly high 

herbicide rates per acre, resulting in plant shifts to only tolerant plant species or opening the area to other invasive 

weeds that may not be able to be controlled with the limited control options. Allowed mechanical alternatives 

would require continued disturbance of the site and need annual treatment. These practices will also result in plant 

shifts to species that can tolerate continued use of these other control methods. 

Weeds that have already been shown to trend towards a monoculture, under the No Action alternative are listed 

below. In addition these invasive plants cannot be eradicated under Alternative B without abusive rates of the 

allowed herbicides or continued mechanical maintenance treatments (only delaying spread, not controlling the 

weed). Japanese, Himalayan, Giant knotweed (Polygonum cuspidatum, polystachyum, sachalinense)- needed 

control method under Alternative B is 5ml injection/stem of triclopyr or glyphosate resulting in greater than 2500 

lbs ai/acre herbicide, greatly exceeding label rate of a maximum of 7 lbs ai/acre. Mechanical control or fire results 

in further spread and encourages re-sprouting. 

.Quick, decisive, and proper management be it chemical, mechanical, cultural, or biological on these small 

infestations have the greatest potential to achieve positive results. But, the first step in any weed management 

program is to have the proper tools available at the ground level. Alternative D creates the largest "tool box" 

available to the local manager. We support Alternative D knowing that the main difference between it and the 

Preferred Alternative is the approved chemical list. Specifically, 2,4-D and Dicamba are included in the 

Alternative D list and not in the Preferred Alternative. 

I support the USFS efforts to come up with an invasive plant eradication strategy. I support the Proposed Action 

plan with the exception that 2,4-D is not one of the tools available. Since federal tax dollars are not endless, 2,4-D 

use would stretch the number of treated acres since it is very cost effective on several species of weeds.2,4-D has 

been used for over 60 years now and it has been re-registered with the US EPA recently. This re-registration 

shows that it has satisfied the regulatory agency that it is not a hazard to the applicators, general public, and the 

environment when used according to label directions. Please include 2,4-D as a tool in this important control 

effort! 

The King County Noxious Weed Control Board supports the proposed action C , supplemented by additional 

features from other Actions 

All of the proposed standards from alternative B should be included in the agencies final decision. 

The point of this EIS should be to raise the bar so that all of the different National Forests in our region are doing 

the same things. Therefore, the more precautionary standards listed in Alternative B: standards 1, 6, and 8, should 

be adopted. 

Alternative B is overly prescriptive and does not recognize multiple use values. 

Alternative D is underdeveloped and therefore does not provide reasonable alternatives for more site-specific 

(forest or district) control but falls out as an obviously uneducated alternative (i.e. no corollary standards offered 

for Standards 4 and 11). 

I feel that the Preferred Alternative (Alternative C) probably provides the best balance of strategies to prevent the 

spread of invasive plants while also providing effective strategies to treat and control existing infestations. 

The Tri-State Weed Management Area fully supports the adoption of the Proposed Action. It provides a balanced 

option by providing needed tools along with guidance for protection of sensitive resources and concern for 

sensitive issues. We would like the team to reconsider the exclusion of the entire suite of 2,4-D formulations as a 

herbicide tool in this alternative. This herbicide is one of the most effective tools in the treatment of white top and 

other weeds found on the east side of the Region. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-165 

Table 31. Comments about Merits of the Alternatives

Comment 

In conclusion, the Oregon Invasive Species Council strongly supports the Proposed Action within the DEIS. If 

implemented with adequate resources to field programs, and within the context of coordinated resource 

management plans, the programs enabled by this DEIS will dramatically improve natural resource management in 

our National Forests, and in so doing, will benefit the health of the larger landscapes across Oregon. 

This draft EIS takes into consideration potential off-target impacts, especially health and safety issues when using 

herbicides, and we believe that the Proposed Action strikes the right balance in guarding against the risks to human 

and environmental health from these methods, and the risks of a failed invasive plant management program. 

We believe that the Proposed Action will work to preserve biological diversity and environmental quality, and will 

also protect agriculture and economic interests by directing resources toward the prevention, early detection and 

early treatment of invasive plant infestations. The Proposed Action will also allow necessary flexibility in 

management treatment options to individual National Forests. 

We especially appreciate the emphasis in the DEIS on adopting and implementing prevention guidelines and 

recommendations which will work to reduce the continued transport and proliferation of invasive species by 

limiting the pathways of invasion. Without strong prevention, the invasive plant threat will continue to proliferate 

beyond our control. 

The active ingredients dicamba and 2, 4-D as listed in Alternative D, should be added to the list of approved 

chemicals because they control many invasive plant species and are more cost effective to apply. According to 

Table 4-4, an additional 10,000 acres could be treated annually using these methods. The additional 10,000 acres, 

along with the projected rate of spread (4%-6%) of the Proposed Action, could mean control of 420,000 acres in 14 

to 18 years compared to 21 to 32 years as listed in Table 4-5. We feel that the benefits of adding these two 

chemicals to the list far outweigh the potential risks associated with using them, and urge their inclusion in the 

final decision. Both 2,4-D and Dicamba are useful products for invasive plant management. These herbicides can 

improve efficacy of other herbicide treatments, are used to manage resistance, may be the preferred herbicide in 

certain treatment prescriptions, and are safe products when used properly. Standard 20 in Table 2-4 of the 

Proposed Action should also reduce any associated risk to proposed and listed species and their habitat. Some 

examples of why these chemicals are important include: Early season treatment of rush skeletonweed followed by 

late season application of Picloram is a preferred treatment option and is one of the few effective treatments for 

skeletonweed control. Extending treatment windows: Many species are difficult to control or even stop from 

seeding after reaching certain stages of phenology. Growth regulating herbicides, synthetic auxins, like 2,4-D and 

Dicamba when added to tank mixes can significantly improve mid and late season control of certain species (e.g. 

knapweed control at late bud to bloom stage). Improving efficacy: the use of 2,4-D in tank mixes have been shown 

to greatly increase the percent of control of hard to control species. For example, tank mixing Sulfometuron methyl 

with 2,4-D increases efficacy when treating white top and perennial pepperweed. Managing herbicide resistance: 

having multiple herbicides for specific species and site types enables superior rotation of herbicides to manage 

plant resistance. 

We support the USFS Proposed Action because of its strong prevention, inventory and restoration components as 

well as the broad array of treatment options. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-166 

Table 31. Comments about Merits of the Alternatives

Comment 

The diverse habitat, distinct vegetation management/restoration projects, and broad geographic area overseen by 

the Forest Service, juxtaposed with 107 identified weed species on Forest Service lands require effective treatment 

options. Alternative D would provide the greatest flexibility for an individual Forest/Ranger District to develop 

efficacious and cost-effective weed control strategies at the local level by maximizing available weed control tools 

(i.e. twelve herbicides). Specific concerns regarding the safety of using 2,4-D and dicamba would be adequately 

addressed through the local planning process and NEPA if a Ranger District identified those products as essential 

to a successful weed control program. In addition, Alternative D would preserve the integrity of how herbicides are 

applied on Forest Service lands by deferring to their individual, federal product label. Unnecessary, self-imposed 

restrictions on application techniques, as outlined in the Proposed Action, may create future situations in which the 

safest, most effective, cost efficient, and environmentally sound method is precluded by the IPEIS. Again, specific 

concerns regarding application techniques would be addressed by the federal product label and through the local 

planning process and NEPA. With the IPEIS, the Forest Service is at a critical bureaucratic crossroad. It is 

imperative that the agency does not repeat the past mistake of preemptively tying their land managers' hands by 

selecting the Proposed Action and limiting effective weed control tools and techniques. We strongly urge the 

Forest Service to adopt Alternative D in the final IPEIS. 

The [Crooked River] WMA supports the proposed action outlined in the Invasive Plant Draft EIS; it provides a 

good mixture of tools for prevention, treatment and restoration of weed sites. However, a few areas in the Action 

Alternative Standards should be discussed more in depth. Discussions on prevention, Standard Number 1, should 

address conditions that allow the spread of invasive plants, including management decisions that degrade healthy 

ecosystems. Standard 2 should require the cleaning of light vehicles as they are just as likely as heavy equipment to 

have traveled through weedy areas and carry weed seeds/parts into work areas. Standard 4 should require the use 

of weed free hay on all NFS lands. While this standard is harder to enforce, it is much more effective in preventing 

the spread of noxious weeds. Trailheads, staging areas and corrals should be monitored annually and kept weed 

free. Standard 16 should include use of 2,4-D. This chemical is widely used on lands neighboring NFS lands. The 

EIS should also provide a mechanism for implementing early detection and rapid response measures. 

The Region has a big job ahead. A combination of the Proposed Action and Alternative B will best accomplish 

that job. 

After reviewing the proposed action alternatives, we are endorsing Alternative D. The flexibility of planning and 

operational duties may reduce costs and time while improving communication for a more sustainable and 

achievable eradication of noxious species. It is our understanding that the main difference between the Preferred 

Alternative and Alternative D is the list of approved chemicals, specifically the inclusion of 2,4-D and Dicamba 

herbicides. 

The inclusion of the [2,4-D and Dicamba] herbicides [in Alt D] would be beneficial to increase the number of 

"tools" for eradication, prevention of spreading and curbing established plants while deterring the introduction of 

invasive species. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-167 

Table 31. Comments about Merits of the Alternatives

Comment 

Additionally, I feel the Proposed Action should be further amended as follows: Standard 16-Herbicides. Adopt the 

standard from Alternative D. This is in line with the State Weed Board's comments, but they did not specifically 

mention the inclusion of Dicamba in the "tool box". I feel strongly that both 2,4-D and Dicamba be included in the 

list of available herbicides. Both are relatively inexpensive and effective on a wide variety of noxious weeds, 

either alone or in combination with other products. I think the tables listing the potential harmful effects of these 

products on human health, wildlife and water quality are misleading and exaggerated. Just because the EIS team 

lists them as having a higher potential to cause human, animal or environmental harm than the other products 

included in the Proposed Action still does not mean that they are likely to cause harm when used according to 

product labels. They need to be considered in perspective. Dr. Allen Felsot, noted area toxicologist, points out in 

his lectures that being able to detect a substance (in water, soil, air, skin, etc) does not mean that it is at a level that 

is harmful. I believe that all twelve of the herbicides that were reviewed should be included in the "tool box" for 

use. I understand that public perception is a concern, but each Forest should be allowed to make the determination 

of which products to use based on need and local public concern. I do not believe that the use of 2,4-D or Dicamba 

on the Colville district would be a public concern, but it may well be that the Okanogan district, for example, 

would choose not to use these products based on the current public climate surrounding their use. 

Thirty thousand acres will be "treated annually" by the Proposed Action (DEIS 4-15), but the Proposed Action 

makes no commitment to altering practices that are causing and exacerbating invasive species introduction, 

establishment and spread on those thirty thousand acres, let alone the hundreds of thousands of PNW Forest acres 

on which invasive species are spreading and which won't be "treated." 

The Proposed Action promises to continue the kinds of management practices (e.g. logging, grazing, roadbuilding, off-road vehicle use) that cause invasive plants to spread. I predict that invasives will soon eclipse 

uncharacteristic wildfire as the number one threat to native ecosystems and public wildlands. The Forest Service 

must do all it can to prevent the introduction, establishment, and spread of invasives--this means no more "business 

as usual" coupled with false promises of "mitigation" or "restoration." 

Alternative B is vastly superior to the Proposed Action because "B" wisely applies the precautionary principle to 

avoid those management actions that lead to the spread of invasives. A strategy of prevention is far more effective 

and inexpensive than a strategy of mitigation and restoration, which are so far largely unproven in effectiveness 

and highly costly. 

[The DEIS states:] "For herbicide treatments assuming Worst-case (maximum application rates and exposure 

factors) there would be six worker exposures with HQ=2-10 and five worker exposures with HQ>10. One 

exposure (picloram) would result in a cancer risk probability of 2 in one million, exceeding the EPA cancer risk 

threshold of 1 in one million." [This is a] reason not to use picloram. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-168 

Table 31. Comments about Merits of the Alternatives

Comment 

EPA supports an Integrated Pest Management (IPM) approach and the use of non-herbicide solutions as much as 

possible. We also recognize that herbicides are a necessary tool for invasive species control and may, in some 

cases, be the only effective tool available. The risk assessments for the herbicides proposed for use under the 

alternatives are based on studies that provide a model for assessing risk. The shortcomings of these risk 

assessments are: (1) the exposure that has been studies is not likely to approximate the level that might be expected 

in the natural environment. Plants and animals are usually exposed to pesticides and other toxics in pulses rather 

than at constant levels; (2) the endpoints studied may represent the most toxic effect of a pesticide. For example, 

the studies required for effects on pesticides on non-target plants does not include the potential effects on flowering 

or reproduction and this has important implications for the plant community as well as for animals that may require 

these plants for food. For most animals the toxiological endpoint studied is generally lethality so that potentially 

important effects are often not considered; and (3) synergistic effects that may arise from exposure to more than 

one pesticide or from a pesticide plus a natural stressor (disease, drought, etc.) are not well studied or understood. 

These uncertainties mean that the model for assessing risk to non-target organisms may not be very accurate. Some 

of these testing and modeling limitations are discussed in the DEIS. It is important here, however, to emphasize 

that the challenge is to account for these uncertainties explicitly as decisions are made regarding the management 

of noxious weeds. Alternative B comes closer to incorporating the precaution needed. We recommend that these 

precautions be embedded in the thought process for making decisions, regardless of whether or not they are 

incorporated as action requirements. Where herbicides are being used, we recommend the Forest Service review 

progress on an annual basis toward reducing reliance on herbicides. 

The Wallowa County Stockgrowers generally supports the proposed action (Alternative C) of the Pacific 

Northwest Region Invasive Plant Program, preventing and Managing Invasive Plants Draft Environmental Impact 

Statement with the following exceptions. Specifically we support the expansion of the available chemicals and the 

inclusion of aerial application. 

NEDC prefers alternative B to the other alternatives listed because it requires more restricted herbicide use. The 

Forest Service predicts that under Alternative B, the native plants may not be adequately protected against invasive 

species. However, the Forest Service does not consider the increased protection native plants will receive as a 

result of the some of the limitations set forth in this alternative. For instance, under the proposed action, the Region 

6 forests will continue to allow vehicles to drive cross-country 300 feet out from either side of a road. It is 

extremely likely that these vehicles will have driven through invasive species infestations before contacting native 

plant populations. Because Alternative B does not permit this practice, spread of invasive species will be reduced. 

Notwithstanding the protective functions inherent in Alternative. B, NEDC prefers the alternative because it does 

not give individual project managers as much discretion as they are given in the other alternatives. 

NEDC strongly suggests that the Forest Service avoid implementation of Alternative D, as it poses the most risk to 

non-target plant species. By permitting use of 2,4-D and more aggressive aerial spraying, the Forest Service 

increases the native plant populations will be harn1ed. Without implementing a monitoring program required by 

NFMA, the Forest Service may not become aware of the damage until native plant populations are significantly 

reduced. In addition, as the Forest Service points out, pollinators may be effected by the application of 2,4- D, 

which in turn will impact the vitality of the native species populations. NEDC does not believe that the Forest 

Service should implement a plan that permits use of a chemical that has the potential to reduce pollinator species 

populations, which in turn reduces viability of native plant populations when the goal of the project is to increase 

native plant species numbers. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-169 

Table 31. Comments about Merits of the Alternatives

Comment 

The No Action alternative is not preferable in this case because it includes the use of several chemicals that pose 

significant risks to non-target plant species. Specifically, as the Forest Service notes in the DEIS, Picloram 

threatens off site damage to plant communities. NEDC is also concerned about the use of triclopyr in the No 

Action alternative because the chemical is known to severely impact the survival of lichens and bryophytes. The 

Forest Service should pay' particular attention to the effects on non-vascular species, as they playa vital role in 

maintaining forest health and diversity. The use of 2,4-D in the No Action alternative is also of great concern to 

NEDC. In its description of Alternative D, the Forest Service explains that 2,4-D can harm native plant populations 

directly and indirectly through pollinators. Because the Forest Service provides little data on the effects of 2,4-D, 

but admits that use of the chemical can harm rare plants, its use should be limited. 

The Proposed Alternative provided by the Forest Service should not be implemented because the Forest Service 

does not propose to require that the more harmful chemicals be used in very limited circumstances, 'The DEIS 

suggests that the "toolbox" Will allow it use of more potent herbicides to treat highly aggressive species. Nowhere, 

however, does the Forest Service prohibit use of such chemicals to treat less aggressive species. By permitting the 

use of discretion to determine which chemical to use in a particular situation, the Forest Service does not provide a 

strict standard with which individuals must comply. NEDC does not believe that the Forest Service has done 

enough to merely suggest that more harmful chemicals may be used more sparingly under the Proposed 

Alternative. For instance, although the Forest Service has taken a step to limit the use of Triclopyr, NEDC remains 

concerned that the Forest Service intends to use a product that is known to cause serious harm to nonvascular plant 

species. "Spot spraying," if not carefully done can impact surrounding species. In addition, the Forest Service does 

not do enough to 1imit the use of aerial spraying. "Standard 16 restricts aerial applications for the more powerful 

ingredients of the sulfonylurea group to mitigate effects from offsite drift." DEIS at 4-34. NEDC does not believe 

that aerial spraying should be employed using any of the listed herbicides because all can harm or kill non-target 

plant species. Because the proposed alternative permits use of aerial spraying and does not establish specific 

standards to be adhered to by those who implement the plan, the Forest Service should not select this alternative. 

NEDC opposes the Proposed Action and finds inadequate support for it in the Pacific Northwest Region Invasive 

Plant Program DEIS. The DEIS does not require sufficient monitoring to ensure forest health and leaves too much 

discretion to forest managers to use a host of chemicals and management techniques that pose a risk to humans, 

plants, animals, and long-term ecosystem health. 

I favor the Proposed Action interspersed with several standards from Alternatives B and D. Standard 7 - I 

recommend adopting the standard from Alternative B. An annual inspection combined with pre-use treatment can 

more effectively stop new infestations. Standard 9 - I recommend adopting the standard from alternative B on road 

closures. Standard 10 - Use the standard from Alternative B off highway vehicles need to be regulated. Each year I 

inspect roads and trails up the Little Naches and Naches Rivers drainage system, invasive plants keep moving 

deeper into the forest along these off road trails. This is caused by weeds being attached to vehicles and dragged 

further up the trails. Standard 16 - On herbicide use I think adopting the standard from Alternative D should be 

used. As an example: There are several small infestations of tansy ragwort on the Little Naches River drainage. 

Being able to use a product like 2,4-D would most likely eradicate this weed. Being able to use 2,4-D in areas 

where off road vehicles are used would help in the control of invasive plants. 

We favor the Proposed Action with the following changes: Standard 2 - There are invasive weeds present in some 

Forest Service sites that are not found (or found in limited quantities) in surrounding areas. The spread of invasive 

weeds needs to be halted both to and from Forest Service lands. Vehicles need to be cleaned before entering and 

[emphasis] before leaving National Forest System lands. Standard 7 - Adopt Alternative B. Annual inspections 

are critical to weed control. Standard 10 - Adopt Alternative B. OHV should be restricted to road use to help 

control the spread of invasive weeds. Standard 16 - Adopt Alternative D. 2,4-D and dicamba are valuable tools to 

use against some weeds. Forest Service personnel should have option to use them. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-170 

Table 31. Comments about Merits of the Alternatives

Comment 

For the most part we support the Proposed Action. It addresses the issues and goes a long way toward attaining the 

desired future conditions identified. We do favor, however, certain provisions of Alternative B as outlined in 

Table 2-4 Chapter 2-18Standard 6 - While grazing is not an issue in the Metolius Basin it is in parts of Region 6. 

The prevention practices in Alt B are sound and should be incorporated in the final Proposed Action. Livestock 

movement patterns can disturb ground and transport invasive weeds. They should be controlled wherever invasive 

plants are a problem. Also passive restoration (rest rotation and retirement) is essential and effective in restoring a 

vigorous native plant community. Standard 9 - Non-essential roads should be closed or decommissioned anywhere 

in the forest and absolutely in areas where noxious weeds are present. We can think of no reason to maintain nonessential roads particularly where they could contribute to the spread of invasive species. Standard 10 - The 

provision in Alt B to prohibit cross-country use of OHVs is common sense in any effort to control invasive plants. 

They both disturb ground and transport seeds. 

A strong reason for support of a modified Proposed Action, with 12 herbicides (addition of diflufenzopyr and a 

reduced rate dicamba) is to reduce herbicide applications and encourage greater diversity of desirable plant species. 

A greater number of approved herbicides mean the correct herbicide can be used that best fits the treatment site 

and invasive plant treatment, minimizing environmental impact. The better the fit of the herbicide to the site and 

the invasive plant and other control methods (IPM), the fewer herbicide applications will be needed. For example, 

control of Dalmatian toadflax can be accomplished with one application of the selective herbicide imazapic plus 

bio-control, with recovery of the plant community starting the spring after fall herbicide treatment. Bio-control 

alone requires approximately 5 to 7 years for adequate control if the bio-control is suited for the ecosystem, 

delaying the recovery of the plant community and allowing spread during the biological control establishment 

years. Herbicides in Alternative B and D are not effective on Dalmatian toadflax meaning annual herbicide 

treatment to reduce spread, biological control or an annual manual or mechanical treatment that will cause a shift 

in the plant community and still not result in control of the toadflax. The treated Dalmatian toadflax site will 

recover the fastest to the desired plant community with the combined application of imazapic (Proposed Action) 

plus bio-control. 

The last assumption following Table 4-6 "The most viable treatment options available combined with the most 

reduction in seed introduction or spread should most effectively reduce infestation size and rate of spread" should 

be given the greatest weight. This statement suggests that prevention methods in Alternative B must be coupled 

with the IPM control methods in the Proposed Action (with modifications proposed above for standard #16) to 

result in the greatest reduction in spread. 

Issue l seems to pit emphasis of prevention against emphasis of treatment of current infestations. We submit that 

you cannot separate prevention from treatment and that both must be emphasized i.e. you need to treat the 

infestations currently on the forest to control and prevent further spread as well as carry out all other prevention 

standards. 

We would encourage the Regional Forester to find that a modified action incorporating the more aggressive 

elements of the alternatives in Alternative D as well as some of the more restrictive elements of Alternative B 

would best meet the underlying need for action.(1.3 Decision to be made) 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-171 

Table 31. Comments about Merits of the Alternatives

Comment 

We favor the Proposed Action (Alternative C), amended with several of the most promising elements of 

Alternatives B and D. Here are the ways in which we recommend you amend Standards and improve the Proposed 

Action: Standard 7 - Inspection and treatment of gravel pits and similar material sources. Adopt the standard from 

Alternative B. We are concerned that merely requiring inspection of such materials "before use" may allow such 

inspections to occur during seasons when infestations are less detectible and/or weeds are harder to identify. 

Annual inspection, combined with pre-use treatment, can more effectively prevent new infestation in areas where 

materials are used. Standard 9 - Road closures. Adopt the standard from Alternative B. While we are not anxious 

to see forest roads closed, local resource managers should have this option available if their analysis indicates that 

a particular route poses a high risk of spreading noxious weeds .Standard 10 - Regulation of off-highway vehicles. 

Adopt the standard from Alternative B. Unrestricted use of such vehicles poses many threats, including the spread 

of noxious weeds. Many other activities have long been regulated on national forests. It is time that forest-use 

regulations "caught up" with the proliferation of OHVs in recent years. Standard 16 - Herbicides. Adopt the 

standard from Alternative D. We do not want to see an effective, affordable and selective active ingredient like 

2,4-D made unavailable to local resource managers. It is not true that USFS land managers in the Pacific 

Northwest have not used 2,4-D in recent years because they haven't needed it. The material was effectively made 

unavailable due to its designation as a "tool of last resort." 

A combination of the Alternatives would seem to be the best way to address the current situation. No Action is not 

acceptable, as it perpetuates the spread of invasives. 

If Region 6 were to adopt the prevention measures of Alternative B while also adopting the treatment measures of 

the Proposed Action, the Forest Service would be expressing at least a modicum of respect for the reality of the 

invasive species problem. 

An adaptive management approach is intended, which we support, but a preventive approach, as advocated in 

Alternative B, is not fully embraced by the Preferred Alternative C. We agree it is important to eradicate and/or 

substantially control invasives and we agree that "there may be instances where it is prudent to conduct a project 

that has a short-term adverse effect, in order to provide a long-term beneficial effect to the habitat" (p.4-129). Yet 

considering the imperiled condition of so many species, and the risks, uncertainties, and unknowns and associated 

with use of chemicals, a great deal of precaution should be exercised in any aggressive treatment program using 

herbicides, including efforts to prevent additional need for their use. We believe that Alternative B or a modified 

Alternative C can provide for both of these needs. Consequently, we support the precautionary and preventive 

methods exhibited in Alternative B or, if Alternative C is selected, we recommend that several of the 

precautionary/preventive standards from Alternative B be incorporated. Many of these standards are prudent, 

easily doable, and they would further curb the rate of spread, which we believe is essential. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-172 

Alternatives Considered But Eliminated from Detailed Study

Many respondents stated that the “Restore Native Ecosystems Alternative” should not have 

been eliminated from detailed study. Others stated that the “No Herbicides” alternative 

should not have been eliminated from detailed study. A third alternative that some people said 

should not have been eliminated from detailed study is stopping all ground disturbing 

activities that are causes of invasive plant spread. None of the comments addressed directly 

the reasons the Forest Service provided for dismissing these alternatives from detailed study. 

Table 32. Comments and Responses about Alternatives Dismissed from Detailed Study

COMMENT RESPONSE 

I write to urge the PNW Region to adopt the Restore 

Native Ecosystems alternative. This alternative 

incorporates many of the leading elements of invasive 

species management: 1)block invasion pathways, 

2)manage land use to avoid creation of invasive favoring 

conditions, 3)eradicate, contain and suppress weed 

infestations using the minimum chemical methods and 4) 

protect sensitive habitats and species. The provisions of 

the Restore Native Ecosystems alternative are a 

reasonable and necessary component to any successful 

weed management strategy. 

The undersigned organizations contend that the RNEA 

prescribed a scientifically based and practicable program 

for addressing and solving the extensive invasive plant 

problems that exist in Region 6 of the Forest Service. 

The "Restore Native Ecosystems" alternative submitted 

by a coalition of citizens and citizen groups merits serious 

attention and adoption by the FS as the least ecologically 

harmful and least risky to human health of any alternative 

described and obviously includes careful consideration of 

the full range of prevention strategies, native plant 

restoration practices, revegetation, monitoring, 

evaluation, coordination with the Native tribes and public 

education needed as well as a framework for prioritizing 

different weed control/eradication means using a 

precautionary approach. Yet this detailed alternative was 

dismissed by the Forest Service from further 

consideration, apparently for being too outside the FS's 

"business as usual" narrow frame of reference to be 

deemed feasible. 

The DEIS explained that the “RNEA” alternative 

was dismissed from detailed study because 

certain components were not reasonably feasible 

or viable, or duplicative of the alternatives 

considered in detail. However, many of the 

main concepts from RNEA, (e.g., proceeding 

experimentally and cautiously, favoring nonchemical over chemical treatments, reducing the 

amount of herbicide use over time, and reducing 

conditions that favor invasive plants) were 

incorporated into the action alternatives, 

particularly Alternative B. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-173 

Table 32. Comments and Responses about Alternatives Dismissed from Detailed Study

COMMENT RESPONSE 

We also believe that the USFS did not adequately 

consider the viable alternatives that are available. 

Specifically, the USFS fails to adequately consider nonherbicide management techniques. Options such as hand 

pulling or mowing, which could be of a benefit to the 

economy and long term forest health are not even 

considered. 

The DEIS fails to take the requisite "hard look" and 

consider the full range of alternatives that could be used 

to prevent and manage invasive plants in that there is no 

alternative considered that does not use herbicides and 

bio-controls while still using prevention methods and 

mechanical and manual means of control--despite many 

comments from the public expressing concern over the 

use of herbicides. The 1988 Noxious Weed FEIS was 

found to inadequately address important herbicide 

concerns, so this EIS must remedy that failure by fully 

disclosing known herbicide impacts and data gaps within 

the EIS itself and fully addressing significant concerns 

regarding the use of herbicides. This suggests the need to 

include a "No Herbicide Use" alternative and consider its 

adoption in good faith. Without a "No herbicide use" 

alternative, there is inadequate disclosure of the relative 

merits and reduction of impacts from other potential 

approaches. 

NEDC believes that the Forest Service did not adequately 

consider the viable alternatives available to it. 

Specifically, it fails to adequately discuss the impacts and 

effectiveness of non-herbicide management techniques. 

Non-herbicide treatments are allowed in all 

alternatives and would be integrated, where 

effective, into site-specific projects. Manual and 

mechanical treatment alone have not effectively 

addressed the current invasive plant problem. 

Section 3.3 stated: “Treatment methods 

emphasized in this EIS include manual, 

mechanical, biological, cultural, prescribed fire, 

and herbicides.” Several pages were devoted to 

the non-chemical treatment methods. 

The DEIS considered a “no herbicide use” 

alternative and explained why it was eliminated 

from detailed study: “large populations of 

certain invasive species can only be effectively 

controlled with herbicides... The purpose and 

need of this EIS includes making new practices, 

technologies, and chemical formulations of 

herbicides available for use on National Forests 

lands in Region Six...Making additional 

herbicides available for use by National Forests 

will increase available options for controlling 

invasive species while protecting native plant 

communities and environmental quality. 

National Forests will still be required to do sitespecific environmental analysis before using 

herbicides. By making additional herbicides 

available, it does not mean that Forests will be 

choosing to use herbicides over other types of 

control methods.” 

That the "Restore Native Ecosystems" Alternative was 

rejected without the incorporation of many of the 

concerns and suggestions is very troubling and 

discouraging for those who are promoting collaborative 

efforts such as the planning team in the Blue Mountains. 

The Forest Service has made a good faith effort 

to include viable portions of the RNEA into 

Alternative B and will continue to work with the 

public to implement good ideas that are within 

and outside the scope of this EIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-174 

Table 32. Comments and Responses about Alternatives Dismissed from Detailed Study

COMMENT RESPONSE 

Headwaters supports the Restore Native Ecosystems 

Alternative (RNEA) which was prepared by a coalition of 

citizens and citizen groups. Reading the alternative in 

full (Appendix L) we can only conclude it is a shame for 

the agency to not give this alternative full consideration. 

Furthermore, we do not believe there is a legally valid 

justification for dismissing it from detailed study. The 

RNEA is a comprehensive, well thought out alternative 

that was feasible enough to have the agency incorporate 

many of the main concepts into the other action 

alternatives. It remains disconcerting for organizations 

like Headwaters who periodically submit alternatives for 

consideration only to have their alternative be dismissed 

by phrases like, "beyond the scope of this EIS," 

particularly when it appears that the proposal is designed 

explicitly to address the identified purpose and need. The 

RHEA deserves to stand alone as an alternative to be 

considered fully with a realistic effort to determine if its 

adoption would best meet the stated project goals. 

The DEIS explained specific reasons why 

portions of the RNEA were outside the scope of 

this EIS. The Forest Service has made a good 

faith effort to include viable portions of the 

RNEA into Alternative B and will continue to 

work with the public to implement good ideas 

that are within and outside the scope of this EIS.

Our concern is that endangered species will all be 

"adversely affected" by the plan as proposed. We request 

an alternative where no herbicides are used. 

Invasive plants themselves may harm 

endangered species, as well as invasive plant 

treatments. The DEIS considered an alternative 

that would not have used herbicides but 

determined that a non-herbicide alternative 

would not meet the underlying need for action. 

The DEIS stated that some invasive plants that 

infest or can be expected to infest National 

Forests in Region Six can only be effectively 

controlled with herbicides. Non-herbicide 

treatments are allowed in all alternatives and 

would be integrated, where effective, into sitespecific projects. Alternative B minimizes 

herbicide use compared to the other alternatives. 

It represents a restrictive approach to herbicides 

that addresses the underlying need for action and 

is within the scope of this EIS. 

 

The DEIS did not consider an alternative that would not 

allow herbicide use, timber cutting and removal, livestock 

grazing, off-road vehicle use, pile-and-burn or "jackpot" 

burning, post-clearcut slash burning, and other activities 

that disturb ecosystems and provide an opening for 

invasive plants to colonize wherever risk is determined to 

be significant, thus the analysis failed to uphold 

provisions of the National Environmental Policy Act 

requiring consideration of an adequate range of 

alternatives. 

The DEIS explained that the alternative of 

prohibiting certain land uses and activities was 

considered but eliminated from further study. 

Prohibiting these multiple-use activities would 

be inconsistent with current laws governing the 

management of National Forest System lands. 

We recommend that a No Herbicide Alternative be 

chosen. If this is not considered, there should at least be a 

ban on aerial spraying and broadcast spraying due to the 

countless problems that are associated with drift. 

The DEIS explained why a No Herbicide 

Alternative would not address the purpose and 

need. The DEIS discussed concerns associated 

with herbicide drift and included mitigation 

measures to reduce likelihood of harm. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-175 

Table 32. Comments and Responses about Alternatives Dismissed from Detailed Study

COMMENT RESPONSE 

Strongly opposed to aerial spraying of herbicides. All 

options contain such spraying, which doesn't seem like an 

adequate range of alternatives has been prepared. 

The DEIS stated that a “no aerial application 

alternative” would not meet the underlying need 

for action, which includes making new practices, 

technologies, and chemical formulations of 

herbicides available for use on National Forests 

lands in Region Six. The DEIS explained that 

aerial application may be necessary in some 

locations (Hell’s Canyon being the best 

example), because of scale, topography and/or 

access. In these rare cases, aerial application of 

herbicides is the only effective control method. 

However, the action alternatives include 

standards that would apply to aerial spraying, for 

instance, such spraying would be prohibited in 

municipal watersheds 

All of the alternatives are associated with plausible 

scenarios that exceed the toxicity indices for birds and 

mammals that eat grass or insects, acres treated that 

exceed a LOAEL, and herbicides that may aversely affect 

amphibians." (p.4-44). Why were no alternatives 

considered for adoption that would avoid these significant 

harms? 

No viable alternatives exist that address the 

purpose and need would eliminate all plausible 

scenarios for adverse effects to animals. Under 

all alternatives, to reduce or eliminate direct or 

indirect negative effects to water quality and 

aquatic biota from the application of herbicide, 

site-specific soil characteristics, proximity to 

surface water and local water table depth would 

be used to determine herbicide formulation (e.g. 

use of aquatic labeled products), size of buffers 

needed, if any, and application method and 

timing. Site-specific project design (e.g. 

application rate and method, timing, wind speed 

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

would be required to mitigate the potential for 

adverse disturbance and/or contaminant 

exposure. These standards are intended to reduce

risk of actual harm to species. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-176 

Inventory, Monitoring and Adaptive Management

Several commenters queried how the invasive plant program would be monitored. Broad 

scale monitoring would occur via existing large scale efforts, such as Pacfish/Infish Biological 

Opinion (PIBO), the Forest inventory and Analysis Network (FIA), and the Forest Health 

Monitoring plots. Site-specific monitoring would occur at the Forest and project level. 

Progress will be tracked via the NRIS/Terra database. 

Table 33. Comments and Responses about Inventory, Monitoring and Adaptive Management

Comment Response 

Monitoring-how will this be accomplished? What's funding like for 

implementation monitoring? 

Monitoring occurs at both the 

regional and Forest level. Funding is 

allocated annually to complete this 

work 

We fear that if one application of herbicide is ineffective, more will be 

applied and damage could be done through unexpected cumulative 

effects. We question that you have state of the art effectiveness 

monitoring in place to truly curb these chemical alternatives if they begin 

to do more harm than good. Ecosystems are complex and simple answers 

are known to be often wrong. 

Invasive plant projects would be 

monitored to ensure that treatments 

are effective and adverse effects are 

mitigated as planned. The DEIS 

acknowledged the complexity of 

invasive plant management in Region 

6. The Proposed Action requires 

rationale be provided for herbicide 

use and includes an objective for 

reducing use. Alternative B further 

requires a commitment to using other 

non-herbicide methods before 

resorting to herbicides. 

One element of the PDCs important to defensible NEPA and ESA 

processes is the development of a monitoring plan. Without the inclusion 

of a monitoring program the FS and consulting agencies will have no 

basis to evaluate how the Standards will be applied in the field or whether 

they will be effective. Passing this responsibility to the sub-Regional 

level loses effectiveness gained at the broad-scale, risks loss of 

consistency, and incurs increased cost and added complexity. This could 

translate into increased risk from the invasive plant management program 

on ESA listed species and their habitats. NOAA Fisheries reiterates its 

recommendation that an interagency monitoring program focusing on 

invasive weed treatment, PDC compliance, and effectiveness be 

developed and incorporated into both the FEIS and ESA BA. 

The Regional NRIS/Terra database 

and existing large scale monitoring 

efforts, such as PIBO (Pacfish/Infish 

Biological Opinion) monitoring, the 

Forest inventory and Analysis 

Network (FIA), and the Forest Health 

Monitoring plots are relied on for the 

broad-scale perspective. Site-specific 

monitoring would occur at the Forest 

or project level. See Appendix M for 

more information. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-177 

Table 33. Comments and Responses about Inventory, Monitoring and Adaptive Management

Comment Response 

Appendix M (Inventory and Monitoring Plan Framework) of the DEIS 

does not incorporate several important concepts contained in the No 

Action alternative. The No Action alternative states that "...Forests are 

currently required to address...projected need for vegetative management 

by method, over the next three to five years...how the projected need for 

treatment can be reduced, and identify the steps that can be taken to 

reduce the reliance on herbicides and prescribed burning...review 

progress on an annual basis toward reducing reliance on herbicides and 

prescribed burning..." These concepts were originally included in the 

preferred alternative, and then subsequently dropped from the Standards. 

NOAA Fisheries requests that these concepts be added back into the 

preferred alternative. 

Objective 3.2 (Proposed Action and 

Alternative B) and Standard 17 

(Alternative B) include the concepts 

of reducing herbicide use. Standards 

in the Preferred Alternative require 

that managers document their 

rationale for using herbicides over 

other methods. 

No inclusion of follow-up/follow-through for management 

recommendations after herbicide use. This has been the largest single 

limitation to effective invasive plant treatment on R6 National Forest 

lands where I have worked. Areas are herbicide-sprayed, 60 to even 95% 

effective. But there is no effective follow-up planning for residual weeds 

that will simply reinfest sprayed areas. This is the time to use strategic 

handpulling. This follow-up would improve site-specific effectiveness, 

as well as to decreasing the repeat need for economically and 

ecologically expensive reapplication of herbicides. Some of this followup is/will be done at the project level, but, unfortunately, this is not so in 

many cases. Inclusion of this language and guidance at the EIS level 

would provide direction for resource managers, especially those who are 

just beginning to focus on the significant problems and complexities of 

weed management. 

Maintenance of initial treatments 

would likely be necessary and manual 

treatments may be used in areas 

where herbicides may have been used 

at one time but are no longer needed 

because the surviving invasive 

population is small enough to 

maintain by hand. This would be 

addressed in site-specific treatment 

plans. Adequate guidance is included 

in the Proposed Action to ensure 

managers would not repeat 

ineffective or unnecessary herbicide 

treatments. 

Until you can measure and report on herbicide use, you cannot 

meaningful claim to have a program to reduce pesticide use. The US 

Forest Service should follow these protocols. 

Information on annual herbicide and 

pesticide use on National Forest is 

collected and disclosed in monitoring 

and accomplishment reports. 

In regards to the No Action alternative early detection comment, for the 

above weeds [Japanese, Himalayan, Giant knotweed (Polygonum 

cuspidatum, polystachyum, sachalinense), Whitetop, perennial 

pepperweed and dyer's woad (Cardaria draba, Lepidium latifolium and 

Isatis tinctoria), Dalmation toadflax and butter&eggs (Linaria dalmatica 

and L. vulgaris), Medusahead, cheatgrass and Ripgut brome 

(Taeniatherum caput-medusae, Bromus tectorum and Bromus rigidus)] 

and numerous others (Russian knapweed, field bindweed, leafy spurge), 

it will not matter how early the population is detected, unless it is found 

within the first month of establishment, which is unrealistic to expect. 

Deep rooted perennial species, such as all listed above except annual 

grasses, are difficult to control and would need to be pulled or dug up 

before root systems were too large. Any root fragments will result in reestablishment of the weed. The annual weeds must be detected before 

seedheads are developed and studies have shown that even after clipping 

cheatgrass 12 times, it still produces a seedhead. 

An early detection/rapid response 

strategy is required under the 

National Invasive Species Strategy 

(link to electronic version of this 

document in Appendix S). While this 

requires diligence, it is a technique 

supported by many in the field of 

invasive species management. 

On Forest Service land the public, FS staff, and contractors must be able 

to unambiguously ascertain from objective criteria provided by the final 

EIS when standards are met or not met; in the latter case there must be 

enforcement remedies specified and implementable in a time scale 

applicable to invasive species situations. 

The standards were designed to 

provide implementable criteria for 

invasive plant projects. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-178 

Table 33. Comments and Responses about Inventory, Monitoring and Adaptive Management

Comment Response 

8. Chapter 2 page 11: Sometimes process can kill the goose that laid the 

golden egg. In certain areas, no inventory is needed. You need to get out 

there and kill the weed because it has clearly taken over. Be careful to not 

design something wherein one size is deemed to fit all, in terms of 

process, or you may lose ground and time, critically. An example is 

knotweed, a scourge of the RMZ, which clearly starts upstream and 

moves downstream. It carpets the entire RMZ and because it is not 

dependent on aquatic environments, moves laterally, as well. We have 

found that if you start upstream and move downstream systematically, 

and get it laterally where it has spread that way, you can successfully 

eliminate it in a watershed. For some watersheds with major invasion, no 

inventory is needed and would just waste time, because everyone with 

eyes can see where the problem is. Mapping is good where the weeds are 

"here and there," not where they have taken over the local flora entirely. 

Again, design your protocol to fit the obvious and the subtle, so you don't 

lose valuable time with the obvious situation. If you must inventory all 

things first (we hope things are not that rigid), then include things like 

flyovers and highlighting areas of aerial maps, as acceptable protocol, so 

it can be done quickly for what would show up so readily that way. The 

weeds are not waiting while you map the obvious. 

We recognize the urgency of this 

issue and the trap of “analysis 

paralysis”. The alternatives are 

intended to streamline the invasive 

plant project planning process to the 

extent possible while complying with 

NEPA and other environmental laws. 

The DEIS also needs to have more provisions to guide and support USFS 

monitoring and research so that this problem can be better understood 

and dealt with. 

Monitoring for this EIS relies on 

existing sources, Regional 

NRIS/Terra database and existing 

large scale monitoring efforts, such as 

PIBO (Pacfish/Infish Biological 

Opinion) monitoring, the Forest 

inventory and Analysis Network 

(FIA), and the Forest Health 

Monitoring plots for the broad 

perspective. Site-specific monitoring 

will occur at the Forest or project 

level. See Appendix M for more 

information. 

Monitoring should be done in areas where no treatment is accomplished 

as well as where treatment is accomplished. This covers both weed free 

for new infestation areas as well as rates of spread when treatments are 

not accomplished for budget or policy reasons. 

The Forest Inventory and Analysis 

Network (FIA) or the Forest Health 

Monitoring plots can be used to track 

the spread or reduction in spread of 

the most dominant invasive plants in 

treated or untreated areas. 

Monitoring accountability should be restated. Several key components of 

accountability should be required for controlling invasive species 

infestations. Monitoring should include three critical components during 

invasive species management projects: (1) measurement of the extent of 

invasive species populations;(2) measurement of the effectiveness of 

treatments; and (3) measurement of non-target effects, e.g., incident 

tracking and measurement of environmental consequences on non-target 

ecosystems from chemical treatments. 

These components are appropriately 

monitored at the site-specific project 

level. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-179 

Table 33. Comments and Responses about Inventory, Monitoring and Adaptive Management

Comment Response 

Monitoring - We believe that any monitoring plan should be reasonable 

and capable of being implemented. Any requirement to monitor every 

treatment project at all monitoring levels is unreasonable. We believe 

that a systematic monitoring plan should be designed where 

implementation monitoring of standards can be done fairly easily, 

treatment and restoration monitoring can be done at different levels at 

different intensities, and environmental effects monitoring should be 

done in statistically sound sampling protocol. Implementation 

monitoring should be done at least once a year at each district conducting 

invasive plant control projects. We do have concern that the same level 

of treatment and restoration effectiveness monitoring being required on 

every project will become an onerous task and take time away from other 

activities or not be implemented in a truly useful manner for adaptive 

management. The monitoring plan should require full effectiveness 

monitoring at selected sites and a scaled down version at the remaining 

sites. Full monitoring should be done for a sample of related treatments 

on similar land types. To be a truly adaptive management monitoring 

program, it should be implemented across multiple National Forests and 

coordinated with other federal, state, and county agencies. Thus, the 

question of "which treatment methods, separate or in combination, are 

most successful for specific invasive species" can be answered more 

systematically. The remaining questions on weed distribution and need 

for follow-up treatment can be assessed much more quickly. The same 

issue arises for environmental effects monitoring. Unless the treatment is 

in a highly sensitive area, a sampling protocol across multiple federal, 

state, and county agencies should be coordinated so that you are not 

trying to monitor every project for environmental effects. 

We recognize the urgency of this 

issue and the trap of “analysis 

paralysis.” Monitoring in this EIS 

relies on existing sources, our 

Regional NRIS/Terra database and 

existing large scale monitoring 

efforts, such as PIBO (Pacfish/Infish 

Biological Opinion) monitoring, the 

Forest inventory and Analysis 

Network (FIA), and the Forest Health 

Monitoring plots for the broad 

perspective. Site-specific monitoring 

will occur at the Forest or project 

level. See Appendix M for more 

information. 

Address in your final IPEIS what places in our National Forests have 

been sprayed for noxious weeds and what the weed situation is at present.

Chapter 3 of the DEIS addresses the 

current situation relative to invasive 

plant management to the level of 

detail appropriate for a programmatic 

document. 

The Forest Service should implement a monitoring program to ensure 

that any unexpected impacts on non-target plant populations are 

identified immediately and are remedied. The National Forest 

Management Act (NFMA) requires such monitoring. Monitoring "at 

intervals established in the plan, implementation shall be evaluated on a 

sample basis to determine how well objectives have been met and how 

closely management standards and guidelines have been applied." 36 

C.F.R. [section] 219.12(k). 

NEDC is concerned with the Forest Service's failure to require 

monitoring to determine the short and long term impacts of management 

techniques it proposes. The Forest Service should also create a 

monitoring program to ensure long term ecosystem health. 

Monitoring in this EIS relies on 

existing sources, our Regional 

NRIS/Terra database and existing 

large scale monitoring efforts, such as 

PIBO (Pacfish/Infish Biological 

Opinion) monitoring, the Forest 

inventory and Analysis Network 

(FIA), and the Forest Health 

Monitoring plots for the broad 

perspective of how ecosystem health 

is affected by management or lack of 

management. Site-specific 

monitoring will occur at the Forest 

and project level. See Appendix M 

for more information. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-180 

Implementation Funding 

Commenters expressed that invasive plant programs should be funded. Funding decisions are 

beyond the scope of this NEPA document and no changes were made to the FEIS in response 

to these comments. 

Table 34. Comments and Responses about Implementation Funding

Comment Response 

Our contact with and observations of the national forests in southern 

Oregon indicate they are operating with minimum staff and budgets. 

Implementing an alternative from this IPEIS would be irresponsible if the 

agency does not have sufficient funding or staffing to carry out the required 

treatments, goals and objectives. If the past 15 years is an indication of 

what's in store budget wise for this program, we would say the prevention 

and management of invasive plants is in trouble. Do not implement this 

program unless full funding is assured. 

I do not have a solution for funding because I feel Taxes and fees are 

already to high and with the federal government's deficit spending I do not 

foresee Congress providing more funds for the Forest Service to further 

implement the Invasive Plant program and the Fee Demo doesn't provide it 

either. 

And a sufficient budget will require the commitment of management at all 

levels, including the Chief's office and USDA. A serious shortfall in one 

year will set the program back several years. 

Management direction to Forest 

Plans. Projects would be funded 

on a case-by-case basis. Some of 

the direction can be implemented 

without funding. The EIS 

describes the effectiveness of the 

alternatives given current budgets. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-181 

Cost of Treatment

The comments about cost of treatment were generally framed as questions about how 

treatment costs were figured and presented in the DEIS. Some people stated that the 

estimated costs of herbicides were too low, given the adverse effects that may result. Others 

said the estimated costs were too high, given personal experiences with herbicides on nonfederal lands. The relationship between cost and effectiveness was also questioned. 

In response to these comments, the EIS was supplemented to address how need for recurring 

treatment might increase the years estimated to control invasive plants under each alternative. 

Table 35. Comments and Responses about Cost of Treatment

COMMENT RESPONSE 

..the economics need to be reviewed to more closely align 

with costs experienced by non-federal agencies. 

An economic analysis that more closely aligns 

with costs experienced by non-federal 

agencies would not be appropriate because 

federal agencies operate under different 

policies, laws, controls, etc. that require 

different operational procedures and 

subsequently incur different costs. 

I realize that in many cases, herbicide use is perceived as 

the most cost effective solution. However, I believe that 

this cost-effectiveness is only short term, at best and 

short-sighted, at worst. The additional costs come as 

health detriments to ecosystems and those exposed to 

herbicides. 

Effectiveness in meeting the purpose and need 

and effects from herbicides on human and 

ecosystem health are discussed throughout 

Chapter 4. The monetary costs of treatment 

are discussed separately. Long-term 

prevention measures are a major component 

discussed throughout the DEIS. 

Sensible, non-chemical strategies will save the Agency 

money. Social and environmental externalities such as 

endangered species and water quality issues, will cost 

public much more in the long-term even if these items are 

not included by current accounting practices. 

Non-chemical treatment strategies are allowed 

under all alternatives. Effects from herbicides 

on the physical, biological, and social 

environment are discussed throughout Chapter 

4. The monetary costs of treatment are 

discussed separately. Long-term prevention 

measures are a major component discussed 

throughout the DEIS. 

We do not believe the agency has presented adequate data 

to show that non-chemical techniques are routinely more 

expensive than herbicides. 

Cost of both chemical and non-chemical 

treatments is discussed in Chapter 4. 

Estimated costs of a one-time, per acre 

treatment, show that in many cases nonchemical treatments are less expensive than 

chemical treatments. 

What is estimated money cost of the Proposed Action as 

compared with Alternatives B and D? 

There are many variables including future 

budgets, new or expanding invasive plant 

infestations that make it difficult to estimate 

the total cost of an alternative. Rather, the 

alternatives are compared by the estimated 

total acres treated per year based on current 

budget estimates (see Chapter 4). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-182 

Table 35. Comments and Responses about Cost of Treatment

COMMENT RESPONSE 

Thus, if the DEIS bases its analysis on an assumed 100 

[percent] successful treatment rate, this assumption needs 

to be supported by relevant scientific data according to 

the requirements of 40 CFR 1502.24. If the assumption is 

something less than 100[percent] treatment rate, then the 

DEIS should show the scientific support for whatever the 

estimated successful treatment rate is for each alternative. 

It would appear likely that each alternative would have a 

different successful treatment rate, as much of the DEIS 

analysis is based on trying to balance the different 

effectiveness levels of the alternatives. The outcome of 

such calculations could significantly change the estimates 

on Table 4-4 for the number of years needed for each 

alternative to achieve control- and by association, the 

total cost of each alternative. For instance, in the 

calculations for "years needed for each alternative," the 

Forest Service assumes a constant rate of spread over 

time. The Forest Service should take into account the 

strong emphasis on prevention in Alternative B, which 

will reduce the rate of annual spread in the future.. As a 

general matter, the Forest Service appears to miscalculate 

acres treated under the plan. It divides the estimated cost 

per acre (which varies depending on treatment employed) 

into the estimated total invasive plan budget. Should the 

Forest Service also take into consideration the 

administrative costs rather than just assuming that every 

dollar will be used for treatment? 

The cost of treatment is based on a weighted 

average cost per acre of treatment likely for 

each alternative, based on the treatments 

methods allowed. The differences in average 

cost are from the differences in allowable 

herbicides and the degree of emphasis on nonherbicide methods. This provides a basis from 

which to compare alternatives. However, the 

actual costs will fluctuate, based on site 

characteristics, objectives and other factors. 

As noted, the DEIS analysis of years to control 

is based on an assumption that each acre of 

treatment equals an acre of control. The FEIS 

has been supplemented to address how need 

for recurring treatment might increase the 

years estimated to control invasive plants 

under each alternative. 

Since it is assumed that reapplication 

requirements, opportunities to use multiple 

treatment types, and administrative costs 

would be similar amongst the alternatives, this 

analysis adequately discloses the relative costs 

and effectiveness of each alternative. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-183 

Table 35. Comments and Responses about Cost of Treatment

COMMENT RESPONSE 

We ask that this section [4.6] be revised based on the 

following considerations. Most generally, the cost 

analysis fails to account for the true long-term costs of 

implementing each alternative. Because the analysis 

simply assumes a constant annual cost for each 

alternative (as Table 4-33 does for per acre herbicide 

application) the analysis does not reflect the reality that 

the long-term cost will not be determined simply by 

annual costs, but by the number of years that the 

respective annual costs will be incurred -which, in turn, is 

the total number of years needed to "control" the invasive 

plants. The problem, however, is that the DEIS's 

projection of the number of years needed for each 

alternative to control the invasive plants, given in Table 

4-4 Years to Control at Current Funding Levels, has little, 

if any, scientific data to support the estimates. In order to 

make such year estimates accurate, it would seem that the 

DEIS must account for the fact that the effectiveness of 

each alternative will fluctuate from year to year. In other 

words, from a practical perspective, the number of new 

acres treated each year by each alternative will fluctuate 

based on the prior's year's effectiveness rate: if a proposed 

action would treat 30,000 acres annually, but would only 

be 50 [percent] effective, then only another 15,000 acres 

of new land (not 30,000) can be treated each successive 

year because 15,000 acres of last year's area will have to 

be re-treated. Looking at it from another angle, a method 

that is 80 [percent] effective but costs $70 per acre may 

be cheaper over the long-term than a method that is only 

50[percent] effective but costs $60 per acre (so if all you 

compare is the per acre cost, then the analysis is 

misleading and incomplete). Incorporating an 

"effectiveness factor" into the analysis is necessary to 

make the results credible because it would let the public 

know how many acres of actual control each alternative 

offers The DEIS seems to assume (or at least does not 

clarify otherwise) that each alternative will provide 100 

[percent] successful annual treatment (i.e., no retreatment necessary). This is potentially true, but it is 

highly unlikely. 

Recurring treatments may be necessary to 

fully eliminate invasive plants at a given site. 

However, it is not always necessary to fully 

eliminate invasive plants to meet site 

objectives. Chapter 3 of the DEIS provides 

information on integrated invasive weed 

treatment techniques that would be applied in 

all alternatives. 

The cost of treatment is based on a weighted 

average cost per acre of treatment likely for 

each alternative, based on the treatments 

methods allowed. The differences in average 

cost are from the differences in allowable 

herbicides and the degree of emphasis on nonherbicide methods. This provides a basis from 

which to compare alternatives. However, the 

actual costs will fluctuate, based on site 

characteristics, objectives and other factors. 

As noted, the DEIS analysis of years to control 

is based on an assumption that each acre of 

treatment equals an acre of control. The FEIS 

has been supplemented to address how need 

for recurring treatment might increase the 

years estimated to control invasive plants 

under each alternative. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-184 

Effectiveness Preventing and Reducing Invasive Plants

Several respondents questioned the assumptions and methodology used to determine how well 

each alternative would prevent/reduce the spread of invasive plants. Many people asked for 

clarification and supplementation of this section of the document. Some people expressed 

disagreement with the conclusions presented in the DEIS. 

The analysis was revisited in response to these comments and updated results are in Chapter 

4.2. 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

4.2.3 Direct and Indirect Effects-The thinking in paragraph 3, 

percent spread rate under Alternative B is flawed. Although new 

introductions are reduced, spread from already established 

invasive plant populations in greatly increased due to the lack of 

effective available control tools. Spread rate in Alternative B 

should at least equal, if not exceed the spread rate of the Proposed 

Action. 

The analysis for effectiveness has been 

reevaluated based on this and similar 

comments and updated results are in 

Chapter 4.2. 

Table 2-6 - Numbers for Alternative B are poorly thought through, 

showing a smaller percent of spread yet a longer time to control. 

Weeds spread at an annual rate of 8% to 12% dependant on the 

species. With less acres treated, greater spread will occur. The 

majority of prevention methods sited were effective to reduce new 

invasions from outside the forest. Spread of established invasive 

plant populations within the forest are not adequately accounted 

for because spread of invasive weeds is not solely through humane 

intervention. With reduced control tools and continued natural 

process (plant reproductive part movement by wind, water, 

through scat or on animals, etc) spread of established populations 

would be greater than 3 to 4%. The reduction in control methods 

would result in a greater annual rate of invasive spread in 

Alternative B as compared to the Proposed Action. 

Natural processes are important factors 

in the spread of invasive plants. These 

are described in Chapter 3. Natural 

processes are included as an assumption 

in the analysis for effectiveness. The 

analysis for effectiveness has been 

reevaluated based on this and other 

similar comments and updated results 

are in Chapter 4.2. 

The following weeds [Japanese, Himalayan, Giant knotweed 

(Polygonum cuspidatum, polystachyum, sachalinense), Whitetop, 

perennial pepperweed and dyer's woad (Cardaria draba, Lepidium 

latifolium and Isatis tinctoria), Dalmation toadflax and 

butter&eggs (Linaria dalmatica and L. vulgaris), Medusahead, 

cheatgrass and Ripgut brome (Taeniatherum caput-medusae, 

Bromus tectorum and Bromus rigidus)], in addition to other 

annuals and deep rooted perennials, would not be controlled within 

a 3 to 5 year management plan even if detected early without a 

comprehensive approved list of herbicides such as allowed in the 

Proposed Action. At best, spread of these species would be 

delayed under the No Action alternative and Alternative B. 

Additional information regarding 

difficult to control species has been 

incorporated into Chapter 4.2 of the 

FEIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-185 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

4.2.5 Methodology Table 4-6 Relative Ranking of Prevention 

Effectiveness by Alternative 

In addition to the above comments, Natural vectors of spread 

appear to be extremely under estimated for Alternative B. The 

literature I am familiar with states that invasive plants can 

naturally spread 5 to 20% without intervention by man. Not being 

familiar with the 1999 USDA FS report by Stemming I have to 

assume the 8 to 12% he determined was also natural spread. Or at 

least assume the 8% is natural spread and the 12z5 includes 

intervention by man. Therefore, in Alternative B, assuming only 

20,000 acres (4.7%) are successfully treated, and assuming no new 

infestations, meaning 400,000 are left non-treated and spreading at 

a natural rate of 8 to 12% equals a minimum spread of 7.6% 

(420,000-20,000=400,000*8%=32,000/420,000=7.6%), double the 

3% to 4% estimated in the EIS. Using this same type of reasoning 

for the Proposed Action, 30,000 acres successfully treated and 

390,000 acres spreading by natural vectors gives a minimum 

spread of 7.4%(420,000-

30,000=390,000*8%=31,200/420,000=7.4%). This allows for 840 

acres of new introductions to equal the 7.6% spread allowed in 

Alternative B. With early detection/rapid response action in the 

Proposed Action, new introductions should be kept below 840 new 

invasive plant acres. This would mean the Proposed Action would 

give a greater or equal reduction in spread as compared to 

Alternative B. 

Natural processes are important factors 

in the spread of invasive plants. The 8-

12 percent spread rate estimate in the 

1999 USDA FS report represents more 

than these natural processes. Active 

management and human induced 

disturbance ground disturbance and 

transport has been occurring on the 

National Forests for decades. It is 

virtually impossible to separate out the 

factors that cause or contribute to the 

introduction, establishment and spread 

of invasive plants. Rate of spread is 

complicated by many factors and varies 

by species. The estimates in the FEIS 

have been reevaluated and updated. 

If we look carefully at the Current Direction and No Action 

Alternative sections in the IPEIS we see there has been no 

assessment of specific guidance on a regional basis nor is any data 

available to measure the yearly success or failure of 

accomplishments or treatments for each forest. Without this 

information there is no way to compare alternatives or prove the 

inadequacy of the current direction. Furthermore, the IPEIS lacks 

an analysis of any operational results from previous invasive plant 

treatments and fails to describe the effects of using various 

treatment tools since l989. 

The alternatives, including No Action 

are compared and evaluated for 

effectiveness in Chapter 4.2. Other 

landowners and other land managers 

already commonly use the tools 

proposed in the alternatives. Numerous 

scientific studies conducted by state, 

federal and university scientists support 

the efficacy of these tools for treatment 

of invasive plants. These studies are 

synthesized into operational 

recommendations in the PNW Weed 

Control Handbook (OSU 2002). 

The problem here is that there is no data in the IPEIS showing the 

inadequacy of the current management direction as to which 

preventive measures worked and which didn't. Neither are we 

provided with any data showing the success of the new herbicides 

now proposed for use. Our observations show that private lands 

are having the same invasive plant problems as are occurring on 

federally managed lands (some to a greater extent) even with 

extensive herbicide availability and use. 

Studies on the effectiveness of 

prevention have been reviewed and 

synthesized in the PNW white papers 

(Appendix D). The EPA evaluates 

effectiveness of new herbicides. This 

information has been synthesized into 

operational recommendations in the 

PNW Weed Control Handbook (OSU 

2002). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-186 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

Table 4-4 (and related table 4-5) contain data that appear to 

suggest that the preferred alternative will most rapidly achieve 

"control" of invasives in the Pacific Northwest. These tables, 

which appear to show that Alternative C contains the Goldilocks 

"just right" combination of prevention and restoration, were a 

factor in the choice of Alternative C. Unfortunately, there is no 

data in the DEIS to support the numbers presented in these two 

tables. Therefore the choice of Alternative C is arbitrary and 

capricious, and violates both the Administrative Procedures Act 

and the Data Quality Act. 

 We are highly skeptical of the claim that the very limited 

resources allocated by the Forest Service to prevent the spread of 

invasive species in the Preferred Alternative will result in a 

reduction in the rate of spread of 50%, as presented in table 4-4. 

In fact, even if all the measures we propose in our second 

comment were adopted, we would be skeptical of such an 

optimistic claim. 

The tables equate "acres treated" with acreage that has been 

"controlled," but there is a high probability that aggressive 

treatments, such as herbicide use and soil cultivation, will not 

control invasives. The disturbed habitat, empty of canopy cover, 

which such treatments create, is exactly the sort of environment in 

which invasive species thrive. There is no data presented in the 

DEIS relating to the effectiveness of various treatment methods in 

actually controlling invasives. The definition of control is suitably 

vague that it includes the possibility that many areas will need to 

be treated annually, greatly decreasing the potential acreage 

covered over time. Such data must be gathered as part of the 

adaptive management process that the proposed rules do not 

require. 

The FEIS discussions of the 

alternatives’ effectiveness have been 

edited to respond to this and similar 

comments. No data exists to precisely 

predict the results of each alternative. 

Rather, invasive plant specialists 

devised an analysis methodology that is 

applied consistently to each alternative 

so that objective comparisons can be 

made. In this methodology, specialists 

used relative values to predict how 

much prevention practices would 

actually reduce the rate of spread. Acres 

of treatment were indeed equated with 

acres of control as a means of arriving 

at a relative value for “years to control” 

for each alternative. This value is not 

intended to be precise but is intended to 

help managers and the public evaluate 

the relative costs, effectiveness and 

effects of each alternative. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-187 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

The DEIS fails in its analysis of the effects of the treatments that 

may be used to combat invasive plants. Evidence exists, for 

example, that herbicides may create conditions more hospitable to 

invasive species than were present before the chemicals were used. 

McDonald and Everest of the USFS Pacific Southwest Research 

Station found that cheatgrass populations, not observed in the 

study plots at the beginning of a study (McDonald, Everest. PSWRN-419-Web. 1996) exploded in an herbicide-treated plot (at 

743,667 plants per acre with 22 percent foliar cover) where it was 

6 times greater in number of plants and more than 7 times greater 

in foliar cover than in the control plot (130,300 plants per acre, 3 

percent foliar cover) two years after treatment. Of particular 

interest is that this study was done to consider the most effective 

means of reducing bearclover, another possibly high priority threat 

in R6 (we'd know whether bearclover is high priority if the DEIS 

had made the required analysis), comparing mulch, herbicide and 

control plots. McDonald and Everest found that the cheatgrass 

was colonizing bare ground. George Harper of the Canadian Forest 

Service found similar dynamics in comparable ecological 

conditions to many parts of R6 in British Columbia. As he notes in 

his Brush River Brushing Trial site project report (EP1179 

http://www.for.gov.bc.ca/research/forprod/fordyn/projects/ep1179/

ep1179.htm), "Total number of plant species present varied 

considerably over all plots, independent of treatment. Total 

number of species are higher in glyphosate than in other treatments 

due to the ability of invading plant species to colonize on exposed 

sites. The initial reduction of shrub and herb cover of naturally 

occurring species following herbicide application probably allows 

for the establishment of such 'invaders." That herbicides appear to 

be a disturbance factor that actually encourages invasive species to 

colonize and spread in herbicide-treated areas clearly must be 

analyzed in the EIS. 

Chapter 4.3 and Appendix J, The 

Effects of Non-Herbicide Methods of 

Invasive Plant Treatment on Wildlife, 

Fish and Plants disclose that treatment 

of invasive plants by any method may 

lead to the introduction of other 

invasive species. Natural vectors are 

always a factor in re-invasion of sites. 

That is why site restoration/revegetation 

was highlighted as an important tool 

(DEIS Chapter 3.3.2). 

A mechanical-treatment-based alternative which also considers 

ORV use, grazing, and logging, along with appropriate and viable 

road closures could have a substantial impact on the spread of 

invasive plants. On the other hand, even the most chemicallyintensive response to invasive species that fails to take into 

account the root causes of plant propagation will fail to succeed. 

Thus estimates of effectiveness of mechanical-treatment-based 

response seem to be down-played, while estimates for the 

chemically-intensive alternative seem to be over-exaggerated. 

Mechanical treatment is an important 

tool in an integrated approach to the 

treatment of invasive plants (see DEIS 

Chapter 3). Appendix J, The Effects of 

Non-Herbicide Methods of Invasive 

Plant Treatment on Wildlife, Fish and 

Plants provides additional information. 

A significant number of invasive plants 

cannot be effectively treated by 

mechanical methods because of their 

physiology and reproductive nature. 

[Chapter 2-29-table 2-6, Proposed Action](How can you determine 

number of years until invasive plants may be controlled. No real 

data to prove this assumption, please provide your data in this 

evaluation! 

This determination is an estimate used 

for the purpose of comparing 

alternatives. It was based on the 

methodology presented in the DEIS 

Chapter 4.2. This section has been 

supplemented in the FEIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-188 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

Please give an example of where in your forest programs herbicide 

applications have worked permanently so no further application is 

needed and native vegetation has recovered itself with or without 

human assistance. 

Herbicide use on National Forest is 

limited under the Mediated Agreement; 

effectiveness of this use is in FEIS 

Chapter 4.2. 

You haven't addressed the 'resistance' factor plants acquire towards 

herbicides. How are you going to deal with that reality? How long 

do you plan to use these chemicals? Do you have any deadlines? 

What about the possibility of developing 'superweeds' as is the 

case with farmers now having to contend with across our nations 

farmlands? 

The discussions about herbicide 

resistance have been supplemented in 

Chapter 3.3 and 4.2 in the FEIS to 

respond to this comment. 

[Section 4.2] Additionally, the DEIS fails to consider possible 

ways to integrate some of Proposed Action into Alternative B so 

that the absurd results predicted would not occur. For example, if 

there was no way to get local native seed, and seeding was 

essential, then perhaps alternative B could allow reseeding with a 

non-persistent exotic in order to prohibit re-growth of the invasive 

species. The DEIS claims that alternative B would lead to 

herbicide resistance because some types of herbicides require 

multiple treatments. However, the DEIS fails to recognize that 

although alternative B has fewer herbicides it still has a variety of 

herbicides and thereby can, like the preferred alternative, treat with 

a diverse combination of herbicides to prevent resistance. 

Alternative B, like the proposed Action, also allows for 

consideration of additional herbicides. 

Alternative B was developed to respond 

to issues and suggestions received 

during scoping, including those 

received from coalition of citizen’s 

groups. Alternative B lacks the variety 

of herbicides necessary to treat some of 

the more aggressive species known in 

Region Six. A blended alternative that 

integrates the elements of multiple 

alternatives may be selected with 

rationale provided in the Record of 

Decision. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-189 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

[Section 4.2] Reliance on broad assumptions and generalized 

statements provides inadequate information for public comment. 

The comparison of the effectiveness of each alternative is full of 

such assumptions. The focus on cost analysis fails to take into 

consideration the effectiveness of each treatment option. If it is 

much more expensive but much more effective over time to use 

hand removal than to have to repeatedly treat with herbicides this 

should be considered. The limited explanations for how numbers 

were calculated limits the effectiveness of the tables used 

comparing the various alternatives. For example, explanation for 

the creation of Table 4-6 comparing prevention effectiveness 

states: "following the above assumptions, the team evaluated every 

standard for individual contribution to reducing spread, and then 

evaluated these standards as a group for each alternative. 

Prevention effectiveness was ranked for each group of standards 

based on effectiveness in reducing invasive plant seed introduction 

and survival." What does this mean? How did the team "evaluate"? 

How were the standards ranked? This lack of identification of 

methods or data used to generate Table 4-6 makes the Table seem 

unrealistic. Likewise, the explanation for Table 4-4 is only that 

"given the projected rates of spread and annual treatment area 

estimates described above, the years to control invasive plants was 

calculated." How was the calculation done? Does acres treated 

actually mean there is no more invasive species present? 

Throughout the section on comparing the alternatives similarly 

lack sufficient explanation of the methods or data used to generate 

them giving the overall impression that the Tables are designed 

solely to support the preferred alternative. 

The effectiveness of the alternatives is 

based on the number of tools and 

prevention strategies per alternative. 

The more combinations available for 

the diversity of species in Region Six, 

the more effective the alternative. 

Integrated weed management principles 

apply to the selection of method, but the 

more methods available, the more likely 

their effectiveness. 

A more expensive treatment is not 

necessarily more effective. Treatments 

under all alternatives would be designed 

to address specific site and species 

characteristics and include a 

combination of methods, not just 

herbicide. 

The discussions about effectiveness and 

alternative comparison tables have been 

updated in the FEIS Chapter 4.2. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-190 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

[Section 4.2] The projected treatment acreage seems implausible. 

The sole explanation about the comparative effectiveness of the 

different proposed alternatives is that "the annual treatment 

acreage is based on current budgets and the costs of various types 

of chemical and non-chemical treatments." The cost of treatments 

says nothing about the effectiveness of a particular treatment and 

whether or not the acres treated were treated successfully. What is 

meant by treatment? Does that mean that an area has no more of a 

particular invasive species? Does it mean that an area has been 

sprayed by an herbicide but not that the herbicide was effective? 

Isn't whether or not an alternative is effective over time in 

restoring vegetation that is resistant to invasive species more 

important than whether the alternative can "treat" more acreage? 

The projected treatment acreage seems to be nothing but a smoke 

screen! Nothing in the analysis shows any real attempt to evaluate 

the long-term effectiveness of the different alternatives. 

Effectiveness in restoring vegetation 

resistance to invasion is one of the most 

important aspects of this program. That 

is why site restoration/revegetation is 

discussed in Chapter 3 as a treatment 

method. Effective treatments would be 

designed to address site objectives, 

which vary based on the biology of the 

invasive species and the site conditions. 

Acreage is a useful factor for 

comparing effectiveness of alternatives 

because the more acreage of 

propagating individuals that have been 

eradicated, the more reduction in 

spread. Cost is related to effectiveness 

in that the greater the cost per acre, the 

fewer acres that can be treated. Fewer 

acres treated means more acres 

available of plants that can produce 

seeds and/or expand vegetatively. This 

equates to less long-term improvement 

in restoration of native or desirable 

vegetation on Forest Service lands as 

well as adjacent lands where natural 

vectors may move propagules. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-191 

Table 36. Effectiveness Comments and Responses about Preventing and Reducing Spread of 

Invasive Plants

COMMENT RESPONSE 

[Section 4-2] The comparison of the various treatments fails to 

address the effectiveness of each treatment option focusing instead 

on the number of tools available and cost and acreage "treated." 

While there is no doubt that these factors are important in 

determining the how many acres of invasive plants may be killed, 

there are other factors that were not discussed. In dismissing 

Alternative B, the DEIS emphasizes that it has the fewest possible 

herbicides however it does not discuss the effectiveness of these 

herbicides nor the effectiveness of non-herbicide methods. 

Specifically, there is not a thorough discussion or documented 

evidence of how effective each of the tools available is in (a) 

treating the targeted species; and (b) contributing to recovery of 

native vegetation that is resistant to repeated waves of invasive 

species (and sprayings).. Perhaps some target species are best 

treated by hand removal and some are best treated by only one 

spraying of X herbicide whereas the use of Y herbicide would take 

multiple sprayings in one year. Moreover, a focus on "treatment" 

(i.e., killing) of invasive plants does not address the effectiveness 

of herbicides in promoting native vegetation recovery. 

Table 4-2 is ineffective because it does not discuss all of the 

potential herbicides that may be used. Furthermore, the comments 

are vague. For example, the DEIS states that "Formulations of 

these herbicides may be useful on some aggressive species that 

have not been effectively treated by other methods or herbicides" 

What aggressive species does the Forest Service? What other 

methods have been tried first and have failed? 

Chapter 4-2 has been expanded in the 

FEIS to address these and similar 

comments. The effectiveness of 

herbicides in promoting native 

vegetation recovery is discussed in 

Chapter 4.3. 

Every invasive plant species and 

situation is likely to require a different 

combination of treatments. Numerous 

scientific studies conducted by state, 

federal and university scientists support 

the efficacy of these tools for treatment 

of invasive plants. These studies are 

synthesized into operational 

recommendations in the PNW Weed 

Control Handbook (OSU 2002). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-192 

Effects on Non-Target Species and Native Plant Communities

Respondents expressed a wide variety of opinions about this section. Some stated that the 

analysis of effects to non-target plants from herbicides was overstated: “Potential for off-site 

drift from aerial applications has been greatly reduced over the last 10 years. New application 

equipment along with lower gallon per acres and drift control surfactants has resulted in very 

accurate aerial spray applications. This greatly reduces risk to non-target species.” A state 

agency expressed that “The toxicity to bees seems to be greatly exaggerated as well for most 

of the formulations considered.” 

Other respondents stated that the effects were more significant than the analysis disclosed. 

For instance, one Environmental Advocacy Organization stated “The long half-lives of some 

of the chemicals discussed in the DEIS increase the likelihood that there will be harmful 

cumulative impacts on the native plants community.” Most of the comments about effects on 

non-target species related to herbicide use, however the point was made that non-chemical 

invasive plant treatments may also affect native plant communities. 

Substantial changes were made to Section 4.3 of the EIS to respond to these comments. 

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

Fish and Plants provides detailed information about non-herbicidal effects to non-target plants 

and other environmental components. In addition, Standard 23 was added to ensure that 

people do not inadvertently harvest medicinal plants that have been affected by herbicides. 

Table 37. Comments and Responses about Effects on Non-Target Plant Species

COMMENT RESPONSE 

4-25, third paragraph, last sentence. "In arid regions, wind erosion if 

treated soil could also result in damage to non-target plants". 

Sentence is missing key words or the order is wrong, probably a 

mistake in copying and pasting. Suggested rewrite: n arid regions, 

treated soil can be moved off-target from wind erosion and could 

result in damages to non-target plants. Or on the next page under 

Metsulfuron methyl and Sulfometuron ethyl there is a statement that 

could be modified "In arid regions, wind erosion could also result in 

damage to non-target species" 

The FEIS Chapter 4.3 has been edited to 

correct the sentence about arid regions 

and wind erosion. 

One obvious concern is that harvesters of Medicinal Plants, which 

are also considered Noxious Weeds, could end up making medicine 

out of poisoned plant material. Another possibility is that other 

personal or commercially-harvested plants of medicinal, food, or 

other value in the vicinity of noxious weeds could inadvertently be 

contaminated with chemical herbicides. 

These concerns are addressed through 

Standard 23 in the FEIS in all alternatives, 

requiring that Forests create a public 

information plan with notification and 

signage responsibilities (See FEIS 

Chapter 2.5). Site-specific project plans 

would consider the usefulness of target 

and adjacent nontarget species and 

incorporate strategies that protect human 

health and the environment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-193 

Table 37. Comments and Responses about Effects on Non-Target Plant Species

COMMENT RESPONSE 

The toxicity to bees seems to be greatly exaggerated as well for most 

of the formulations considered. These conclusions appear to be 

counter to those in SERA documents as well. Given the potential 

doses calculated for a direct spray scenario, the risks are generally 20 

to 100 times under most toxic endpoints for bees. The differential 

toxicity effects are not consistently presented, the uncertainty in the 

calculations is not presented. This uncertainty is particularly 

important when actual usage is to be considered. The reference 

documents do not seem to support the statement in the EIS. 

One herbicide (2,4D) was found to pose a 

risk to bees at typical application rates. 

Two other herbicides (glyphosate and 

triclopyr) pose a risk at the highest labeled 

application rates. These results are based 

on FS/SERA risk assessments that 

incorporate the best available scientific 

information and have been peer reviewed. 

Uncertainty of this analysis was addressed 

in DEIS Chapter 4.3. 

4.3.3 Direct and Indirect Effects Herbicide Effects on Non-target 

Plants Acetolactate Synthase (ALS) Inhibitors 

Correction: Chlorsulfuron, metsulfuron methyl and sulfometuron 

methyl are NOT relatively "new" herbicides. Although the 

technology for these herbicides have been more recently developed 

than the Synthetic auxin herbicides, these herbicides have been 

researched for over 20 years and available commercially since the 

1980s. This is legally NOT considered a new herbicide. 

The statement about “new” herbicides in 

FEIS Chapter 4.3 has been corrected to 

respond to this comment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-194 

Table 37. Comments and Responses about Effects on Non-Target Plant Species

COMMENT RESPONSE 

Non-herbicide treatments can cause substantial harm to non-target 

plant and plant communities. This should be a significant enough 

issue to address. Repeated mowing or grazing can substantially 

harm non-target plant and substantially change, shift plant 

communities and reduce biodiversity beyond natural regeneration. 

Prescribed fire can also substantially harm non-target plant and 

substantially change plant communities greater than changes caused 

by using the best-fit herbicide correctly. For example, Medicine 

Bow National Forest has currently restricted prescribed burns in 

areas prone to cheatgrass invasion because of the lack of ability to 

control the cheatgrass with an aerial herbicide application. 

Disturbance and foot traffic from hand pulling can substantially harm 

non-target plants. This section appears to assume herbicide will be 

used incorrectly. Under Alternative B best-fit herbicides will not be 

available. 

Inadequate Consideration of Each Alternative [Section 4.3] First, the 

Forest Service fails to adequately consider the environmental 

consequences of each alternative proposed, as is required by NEPA. 

"Section 102(2)(C) [of NEPA] requires that an impact statement 

contain, in essence a detailed statement of the expected adverse 

environmental consequences of an action, the resource commitments 

involved in it, and the alternatives to it." Kleppe v. Sierra Club, 427 

U.S. 390,401-02 (1976). The FS admits that non- herbicide 

treatments can also harm native plant species but explains that "the 

impacts are not substantial and are not a significant issue." DEIS at 

4-22. The effects of these treatments are said to be located in the 

analysis files. The agency cannot simply assert that the impacts are 

not significant and then fail to back that assertion with findings~ By 

not providing its analysis to the public, the Forest Service makes it 

impossible for NEDC members and other members of the public to 

effectively comment on each alternative. The Forest Service has not 

made its analysis of the impacts of non-herbicide treatments 

available to the public in violation of NEPA. To satisfy NEPA's 

public disclosure requirements, "the public [must] receive the 

underlying environmental data from which a Forest Service expert 

derived her opinion." Idaho Sporting Congo V. Thomas, 1.37 F.3d 

1146, 1150 (9th Cir. 1998). NEDC asks that the Forest Service 

provide this analysis in a more accessible form. 

The effects on non-herbicidal treatments 

on non-target plants are discussed in 

Appendix J, The Effects of Non-Herbicide 

Methods of Invasive Plant Treatment on 

Wildlife, Fish and Plants. These effects 

are not the focus of the EIS; these effects 

are not controversial and would be similar 

in all alternatives. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-195 

Table 37. Comments and Responses about Effects on Non-Target Plant Species

COMMENT RESPONSE 

4.3.5 Methodology Paragraph 6, Discussion on herbicide persistence: 

One element to choosing the correct herbicide is evaluating the 

herbicides selectivity, for both post and pre treatments. If a 

persistent herbicide is needed, such as for control of cheatgrass, 

common crupina, medusahead or other annuals, and revegetation or 

release of desirable plant species is also desired, the weed 

management team should choose a herbicide that has persistence 

towards controlling the weed and is selective enough to allow the 

desired species to germinate. For the invasive plant species example 

sited above, imazapic would be a better choice over sulfometuron 

methyl. These annual invasive species are extremely sensitive to very 

low rates of imazapic, while native perennial grass and forbs are 

highly tolerant to medium to high rates of imazapic. Imazapic 

persists long enough in the soil to give long-term control of the 

annual species, yet is selective enough to allow germination of many 

native grass and forbs. This gives non-target plants a chance to 

establish and out compete the annual invasive weeds once the 

herbicide is degraded. Both the invasive plants and non-target plants 

have a similar sensitivity to sulfometuron methyl. This results in less 

selectivity and will not allow germination of the desirable species for 

the same length of time as the invasive annual plant. Careful 

selection of the right herbicide "tool" will show persistence as a 

benefit rather than a risk. 

More discussion was added to the FEIS 

Chapter 4.3 regarding herbicide 

resistance. 

Table 2-6 is very misleading and the "Numbers of herbicides 

included in each alternative that have a relatively higher potential to 

harm non-target plants" versus the "Acres of annual herbicide 

treatment . . ."has flawed reasoning (Section 4.4.3). This portion of 

the chart should be disregarded because it does not take into 

consideration the short-term "potential harm causing herbicides" 

versus the long-term potential harm of doing nothing using other 

control methods or using an inadequate herbicide for a prolonged 

period of time. For example: If only the herbicides allowed under 

Alternative B were available for use, annual treated acres of 

glyphosate would need to be higher to compensate for the lose of 

herbicides allowed under the Proposed Action. Application of 

glyphosate would be 3 to 10 times the number of applications needed 

to control weeds that herbicides in the Proposed Action are more 

effective on. Therefore, without these other herbicides available, 

glyphosate annual acres would need to be increased above the 2031 

acres predicted to accomplish the containment (control) of 20,000 

acres. 

More discussion was added to the FEIS 

Chapter 4.2 regarding how effectiveness 

of each alternative was determined. 

Table 3-14 Summary of Treatment Methods Herbicides. Potential for 

off-site drift from aerial applications has been greatly reduced over 

the last 10 years. New application equipment along with lower 

gallon per acres and drift control surfactants has resulted in very 

accurate aerial spray applications. This greatly reduces risk to nontarget species. In addition, low volume applications (2 to 5 gallons 

of mix per acre) can be made where a large majority of spray is 

intercepted by the target canopy foliage, allowing remnant vegetation 

to quickly recover under the treated canopy. 

The DEIS addressed the potential effects 

of herbicide drift. The standards 

associated with all alternatives require 

that “application rate and method, timing, 

wind speed and direction, nozzle type and 

size, buffers, etc.” be designed to mitigate 

the potential for adverse disturbance 

and/or contaminant exposure due to drift. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-196 

Table 37. Comments and Responses about Effects on Non-Target Plant Species

COMMENT RESPONSE 

Table 4-8 Summary of Effects by Measuring Factors 

The sentence "Any short-term adverse effects would be largely offset 

by the long-term benefits to native plant communities from 

protecting them from invasion of invasive plants." should be 

emphasized. A point that has not been well covered is the quick 

recovery of plant communities to properly used herbicides in IPM 

programs. Use of a herbicide not only will facilitate recovery of the 

natural state of the treated area, but will also stop the potential harm 

to yet un-invaded natural plant communities. 

Additional discussion regarding beneficial 

effects of effective invasive plant 

treatments is in FEIS Chapter 4.3. 

Lacking an analysis of the impacts over the long-term that may be 

expected from the use of various herbicides on non-target plant 

species composition and abundance, and lacking adequate guidance 

for which herbicides and other treatment options are suited or not 

suited for various ecological conditions common within the R6, the 

DEIS cannot serve as an appropriate tiering document for future 

decisions regarding invasive species within Region 6 as it is 

currently written. 

Adequate analysis for selection of 

alternative is in this programmatic EIS. 

The EIS provides alternative suites of 

standards that will direct herbicide use, 

and discloses their relative effects. The 

EIS also provides guidance on what 

herbicides are appropriate for a variety of 

invasive plant species and situations. 

The DEIS is lacking needed specific analysis of how each herbicide 

affects specific native plants - including non-listed plants and the 

potential for large scale degradation or elimination of more common 

native plant communities in areas sprayed (particularly relevant to 

broadcast and aerial spraying, also potentially to water-borne 

transmission to non-target riparian plants). 

More information about effects on nontarget plants has been added to the FEIS 

Chapter 4.3. Effects on specific nontarget plant species of concern would be 

further addressed in project level analysis. 

What beneficial plants that are food to wildlife will also be affected 

by the herbicides lessening the availability of food, which is the very 

reasoning you use to justify the use of herbicides to get rid of 

noxious invasive plants? Herbicides will play the same role as 

noxious weeds do in eradicating plant food sources for wildlife. Plus, 

they will poison wildlife and the surrounding plant and insect and 

aquatic life as well. Again - is the cure worse than the problem? 

The EIS discusses the relative toxicity of 

the herbicides considered for use in the 

alternatives. The standards for herbicide 

use would ensure that important wildlife 

habitat is protected during treatments. 

Site-specific analysis would be required to 

compare the need for action against the 

potential effects. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-197 

Effects on Worker Health and Safety

Comments about worker health and safety focus on both herbicidal and non-herbicidal 

treatment methods. These comments did not lead to substantial changes in the FEIS. The 

FEIS clarifies that the analysis of effects on worker health and safety is not intended to 

compare human health risks from manual/mechanical treatments against effects from 

herbicide treatment and characterize one as great and the other as insignificant. 

Table 38. Comments and Responses About Worker Health and Safety

Comment Response 

Despite a well-defined list of the possible injuries that can occur in 

manual invasive plant removal scenarios the DEIS does not predict 

in any way how frequently such injuries normally do or would occur. 

The DEIS states that, "data on accidents related specifically to 

invasive plant treatment is not available." DEIS at 4-61.In the 

absence of this data the DEIS alternatively considers in table 4-16 

how much acreage will be treated manually and mechanically in each 

proposed alternative and how many "worker days of exposure" (days 

necessary to treat the specified number of acres) each alternative 

entails. Although useful for comparing the amount of manual labor 

proposed in each alternative, this data alone does not provide for 

even a rough assessment of what risk to human health manual and 

mechanical labor poses in each alternative. There is currently an 

absence of data and agency failure to obtain the required 

information. If the Forest Service assumes that Alternative B will 

require more acres of mechanical and manual treatment for the first 

few years, it should also consider that the acres treated will be 

reduced as prevention measures become effective in controlling 

invasive species. Despite the inadequate data the DEIS claims that 

"the potential for cumulative risks to workers from non-chemical 

treatments methods is great." DEIS at 4-83. This claim is not only 

unsupported but requires an inferential leap. Given that manual and 

mechanical laborers treating invasive species will be working on 

rough terrain with dangerous tools for x amount of days on y amount 

of acres, it does not necessarily follow that cumulative health risks 

are great. The DEIS nonetheless treats the claim as conclusive fact, 

using it as a basis for comparison against the degree of cumulative 

hazards to human health that arise out of herbicide treatments. 

Following the comparison the DEIS finds that "[t]he potential for 

cumulative human health effects from repeated herbicide exposures, 

resulting from herbicide use proposed in th[ e] DEIS is insignificant" 

DEIS at 4-83. This conclusion is unreliable not only because it stems 

from a comparison with a mere theory but also because it fails to 

consider that many of the very hazards presented in the manual and 

mechanical treatment scenario are equally likely in herbicide 

treatment scenarios. Any backpack spraying for example, will also 

be done on difficult terrain, with a risk of exposure to dangerous 

plants, animals, insects and adverse weather. These identical risks are 

irrationally deemed "great" in one instance but "insignificant" in the 

other. 

The DEIS used the indicator of annual 

worker days to compare the risks to 

workers from the projected use of 

manual/mechanical methods among the 

alternatives. The greater the acreage 

treated manually, the greater the potential 

exposure. The relative risks associated 

with each of the alternatives are not likely 

to change over time (Alternative B would 

always include relatively more acreage 

treated manually than other alternatives). 

The risks to workers from manual and 

mechanical treatments versus herbicide 

treatment are not “equally likely.” While 

some risks are inherent to all “woods 

work”, manual and mechanical treatments 

are associated with injuries that are 

cumulative in nature, such as skeletalmuscular strains associated with repeated 

bending and pulling activity, and carpal 

tunnel syndrome associated with use of 

vibrating hand-held machinery such as 

chain saws. These cumulative injuries are 

not associated with herbicide application. 

The statement that worker health effects 

from repeated herbicide application are 

not expected to trigger significant effects 

is based on the toxicology of the 

herbicides proposed for use and the fact 

that they do not bioaccumulate. 

The DEIS analysis was not intended to 

compare human health risks from 

manual/mechanical treatments against 

effects from herbicide treatment and 

characterize one as great and the other as 

insignificant. The FEIS has been edited 

to clarify this point. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-198 

Table 38. Comments and Responses About Worker Health and Safety

Comment Response 

When comparing worker risks of herbicide use vs. manual methods, 

I believe you do an in adequate job on assessing manual hazards. 

From my own experience, I know they can be considerable. Even 

the J Herbert Stone Nursery (USFS) has banned hand weeding 

because of the physical strain - and this is in open fields. I believe 

that you could find data on this issue for woods workers from state 

accident agencies. 

Exposure, expressed as acres treated with 

manual methods, is directly proportional 

to risk of an accident actually occurring 

and provides meaningful comparison of 

alternatives. 

For aerial spraying (now proposed in the new action alternatives) 

"typical" health risks to project workers has now been bumped up 

from "low" to "moderate", as has the risk to workers for right of 

way/broadcast foliar spraying, for which "upper" risk levels are now 

"high". What do "moderate" and "high" risks to workers mean in 

this context? Permanent impairment? Chronic breathing difficulty? 

Reproductive disorders resulting in deformed children? Cancer? 

Premature death? 

The derivation and meaning of 

“moderate” and “high” risks are described 

in Ch. 4.5.2, and are based on a calculated 

“Hazard Quotient” (HQ). The HQ is the 

ratio (comparison) of estimated dose for 

FS applications, compared to EPA 

reference doses (RfD). The development 

of RfD from toxicity tests is more fully 

described in Appendix Q, “Human Health 

Risk Assessment.” 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-199 

Herbicide Risk Assessment and Human Health Effects

Several comments were received about the DEIS reliance on herbicide risk assessments to 

characterize potential effects to worker and public health. Some people questioned the 

objectivity of the risk assessment specialists. The Forest Service response is to explain that 

FS/SERA risk assessments incorporate all known scientific information about herbicide 

effects and are peer reviewed, thus, these represent the best available information for use in 

the EIS. 

The FEIS contains supplemental discussion about interpretation of risk assessments, effects 

on sensitive people, and the adjuvant NPE in response to these comments. 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

Where are you getting your herbicide data from? What labs? FS/SERA herbicide risk assessments review 

the entire body of relevant scientific 

literature. 

[The DEIS states:] "For NPE, only the typical exposure rate for 

each of the typical and maximum-labeled rate is analyzed for 

human health risks." Why is maximum exposure to maximum 

application rate not considered for NPE? 

The maximum exposure/maximum 

application rate will be recalculated for NPE 

in the FEIS. 

Spraying is only temporary and harms too many innocents, 

including humans. Asthma is on the rise. I now have it from 

orchard spraying. Our lungs are sensitive organs. Please - no 

pesticides. 

The rationale for selecting herbicides for 

treatment over other methods will be 

disclosed and documented in project 

environmental assessment. The DEIS 

described why herbicides are necessary as 

the only known method to effectively control 

certain invasive plant species. Standards in 

all alternatives require that National Forests 

inform people so that they may avoid 

exposure to herbicides in the vicinity of 

treated areas during and after application. 

I believe the statement from Section 4.5.4, Cumulative Effects, 

paragraph 3 "The potential for cumulative human health effects 

from repeated herbicide exposures, resulting from herbicide use 

proposed in the EIS is insignificant." should be more boldly stated 

since it is a major concern identified in the scoping comments. 

The cumulative effects of repeated herbicide 

use are discussed throughout these comment 

responses and the EIS. 

Bakke, 2003 is listed as an unpublished report in the IP DEIS 

Bibliography. This is not the case. This report has been published 

for over a year and is now cited as USDA 2003 and the full citation 

is "USDA Forest Service. 2003. Human and Ecological Risk 

Assessment of nonylphenol polyethoxylate based (NPE) 

surfactants in Forest Service herbicide applications. Pacific 

Southwest Region." It has not, however, been published in a 

scientific publication or been peer reviewed. 

The NPE Risk Assessment was peer 

reviewed by Dr. Patrick Durkin and Dr. Gary 

Diamond, whose qualifications are described 

on page vi of the assessment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-200 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

As a citizen concerned about environmental degradation, my own 

health and the destruction of wildlife, I strongly urge you to find 

alternatives to the use of pesticides to deal with invasives. I am 

worried about contamination of the wild mushrooms that I and 

countless others enjoy eating. 

The FEIS uses FS/SERA risk assessment 

scenario of consuming berries that have been 

sprayed as the scenario for consumption of 

contaminated plant material. The scenario is 

described in Appendix Q “Human Health 

Risk Assessment”. The scenario estimates 

doses from consuming residues on directly 

sprayed fruit. This scenario would represent 

the doses from consuming sprayed wild 

mushrooms. Estimates of hazard quotients 

for each herbicide, typical and worst-case 

scenarios from eating berries were displayed 

in Appendix Q. Experience from forest tree 

nurseries indicates herbicides do not 

otherwise affect fungi (Hildebrand, personal 

communication, 2005). 

The proposed action specifies that only adjuvants (e.g. surfactants, 

dyes) and inert ingredients must be reviewed in Forest Service 

documents such as SERA, Inc., 1997a, 1997b, and Bakke, D. 2002. 

In this light, the sections concerning the use of nonylphenol 

polyethoxylates (NPE) and nonylphenols (NP) seed to misrepresent 

the conclusions drawn by these references. The stated concern is 

from the toxicity and/or carcinogenicity of ethylene oxide. 

Ethylene oxide is one of the reagents used to produce NP and NPE 

and some low level of residue may be present. The SERA 

reference indicates residue levels from <3.6 to 12.2 PPM. NP or 

NPE both have surface action potential and these compounds may 

be added as formulation inerts. Members of this chemical family 

area included in US EPA Inert List III Table. NPE is listed as an 

herbicide in the body of the EIS. In Table 4-7, Chapter 4-31 the 

presence of NPE as an inert component has been misrepresented 

(SERA 1997b). This group of surface action agents listed a 

polyethoxylates are more properly described as alkylphenol 

ethoxycarboxylates or phosphates. Similar compounds are also 

used in the form of acids, salts or esters of the basic chemical 

groups. The alkyl group can vary from 1 carbon to many. The 

ethoxylated portions are a chain of ethoxy units, from 1 to 10 units 

in length. The ethoxylated portion does not metabolize to ethylene 

oxide but as two (2) carbon unit, most likely an alcohol, than 

further degraded to carbon dioxide and water. If the chemical form 

were a ketone, the metabolic fate would be removal as carbon 

dioxide. The alkyl chain attached to the phenol will be cleaved, 

generally 2 units at a time, then each 2 carbon unit converted to 

carbon dioxide and water. The initial microbiological action 

appears to be the cleavage of the phenolic ring followed by the 

previously described metabolic steps. In short the projected 

concentrations of ethylene oxide or polyethoxylates are not likely 

to meet the levels as listed in the EIS. This section clearly conflicts 

with the SERA documents that were apparently utilized in the 

preparation of the EIS. 

The DEIS incorporated the peer-reviewed 

analysis of the range of relevant studies on 

effects of NPE from the FS risk assessment. 

NP will be studied further and incorporated 

into an updated risk assessment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-201 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

The EIS should clearly explain the models used for risk 

assessments and how they relate to potentially real situations. As it 

is, the DEIS leaves the reader to wonder about the methods of risk 

assessment and the reality of their conclusions. A stronger effort 

should be made to communicate the biological significance of the 

predicted risks (population level). 

The disclosure in the EIS is based on 

complex toxicological risk assessments that 

are difficult to summarize effectively. 

Multiple variables combine in risk 

assessment, not just the herbicide used but 

the specific formulation, dose, method of 

application, and other factors influence the 

results. 

The IDT applied the FS/SERA risk 

assessments to the alternatives considered in 

detail in the EIS. The use of exposure 

scenarios to quantify risks to non-target 

organisms is described in the risk 

assessments for each herbicide. Further 

detail about the processes and calculations 

used to produce dose and risk estimates are 

in Preparation of Environmental 

Documentation and Risk Assessments 

(SERA 2001c). 

NPE degradates and other EDs have shown a pronounced tendency 

to exert influence on the endocrine system at different times in the 

life cycle of all living things. Since the IP DEIS proposes to apply 

herbicides and surfactants during the breeding season for most 

species at risk, it is imperative that this be incorporated into the IP 

DEIS risk assessment. The importance of understanding timing as 

a risk assessment parameter is that it once again dispels the risk 

assessment methodology incorporated in the IP DEIS. The concept 

of acceptable dose levels (those below the threshold NOAEL x 

100) are only appropriate if a) the most sensitive time for exposure 

is the tested exposure period and b) these studies are long term 

chronic or multi-generational studies to identify "later in life" or 

trans-generational effects. Since nonylphenol has shown itself to 

produce effects in the very low ppb range during the 

developmental stage of most organisms that have been tested, this 

would place the risk quotient multiplier in the ppt, which in turn 

would place all species at serious risk from exposure. 

The DEIS incorporated the peer-reviewed 

analysis of the range of relevant studies on 

effects of NPE from the FS risk assessment. 

 NP will be studied further and incorporated 

into an updated risk assessment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-202 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

The IP DEIS has failed to properly analyze the potential acute, 

chronic and cumulative effects from both endocrine and nonendocrine effects. The IP DEIS does not even present a clear 

explanation of the analytical route used in the risk assessment 

analysis of these effects from NPE based surfactants, other than to 

mention that standard methodology is incorporated. 

The IP DEIS is deficient in it's analysis of the risk of endocrine 

effects from the use of NPE surfactants. In fact, the IP DEIS does 

not even offer analysis for endocrine effects except a brief mention 

of public concerns about estrogenic effects to aquatic species. The 

(Wildlife RA) does little better, as basically it merely passes on 

misinformation found in USDA 2003. 

The IP DEIS is flawed in it's assessment of risk from nonendocrine disruption mediated toxicity, similar to failings found in 

the DEIS concerning EDCs. Scientifically unrealistic threshold 

levels are used to establish levels of risk. 

The FS risk assessment for NPE follows the 

methodology outlined in SERA, 2001 (cited 

in DEIS bibliography). The FS risk 

assessment analyzed the range of relevant 

scientific studies on the hazards of NPE, 

metabolites, and impurities including these 

possible effects and established a Reference 

Dose, based on the most sensitive effect with 

applied uncertainty factors. The RfD was 

determined to account for the risk of any of 

the potential effects cited in this comment. 

Any multiple herbicide mixtures for which the effects have not 

been disclosed and analyzed in this EIS should not be used by the 

Forest Service, as there is no opportunity for the public or decision 

makers to assess the risks of their use. 

The potential for synergistic effects from 

herbicide use in the alternatives was 

summarized in DEIS Chapter 4.5. A more 

detailed analysis of the potential for 

synergistic effects from the herbicides 

proposed for use and methodologies for 

assessing the potential effects of chemical 

mixtures is found in the FEIS Appendix Q 

“Human Health Risk Assessment”. This 

analysis is based on FS/SERA herbicide risk 

assessment. Standard 16 now addresses the 

use of herbicide mixes. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-203 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

Inadequate Testing: Herbicide safety evaluations for wildlife and 

humans are conducted by the herbicide manufacturing corporation, 

which has a vested interest in selling their product -- a clear case of 

the fox in the henhouse. Thus potential impacts of herbicide 

formulas may be understated or undisclosed. Toxicity testing is 

also generally for "active" ingredients only, not for the synergistic 

collective effect of combining two or more active ingredients in an 

herbicide formula or for the combined effect of "active" and toxic 

"inert" ingredients, again understating the danger of a formula's 

use. Further, there has been little or no testing for impacts of 

herbicides on native plant species, native wildlife, native 

pollinators, amphibians or humans directly. Usually genetically 

dis-similar crop plants, domesticated lab animals, honey bees, etc. 

are used, whose metabolism may differ considerably from nontarget wild species and humans at risk. 

This analysis is based in detailed reviews of 

relevant scientific literature for each 

herbicide in the respective FS/SERA 

herbicide risk assessment. The DEIS adopts 

the US-EPA process for acceptable risk 

(RfD’s); however, the underlying FS/SERA 

herbicide risk assessments review the entire 

body of relevant scientific literature (not just 

tests submitted to EPA for pesticide 

registration) to develop comprehensive and 

protective RfD’s. Both acute and chronic 

RfD’ s are estimated and used to identify the 

most-sensitive effect RfD for calculation of 

the Hazard Quotient for herbicide 

applications associated with DEIS 

alternatives. In establishing RfD’s, the risk 

assessments apply uncertainty factors for 

intra and interspecies variability in 

physiological responses and adopt the most 

conservative realistic approach to best 

encompass the possible ranges of variability 

for long-term exposures/doses. The 

potential for synergistic effects from 

herbicide use in the alternatives is 

summarized in DEIS section 4.5.4. A 

detailed analysis of the potential for 

synergistic effects from the herbicides 

proposed for use and methodologies for 

assessing the potential effects of chemical 

mixtures is found in the FEIS Appendix Q 

“Human Health Risk Assessment”. 

The updated SERA information is from 1996. Why aren't more 

recent toxicity studies included in the EIS and analyzed? The 

SERA 1996 risk assessment also used a different approach - "in 

which the estimated level of exposure is divided by some estimate 

of acceptable exposure (the RfD)." This approach and its 

ramifications are not explained further. How are the estimates of 

"acceptable exposure" derived? Why was the method of 

comparing predicted levels of human exposure to known highest 

dose levels for which animals showed no observable effect 

(NOEL) abandoned? 

All FS/SERA herbicide risk assessments 

used to estimate effects for this DEIS have 

been updated since 1996 to incorporate new 

studies, regulations, and information. The 

RfD is calculated from the NOAEL, with 

uncertainty factors for inter and intraspecific variation already incorporated into 

the final RfD value. This process is 

described in the FEIS Appendix Q “Human 

Health Risk Assessment”, and in greater 

detail in the individual risk assessments and 

in SERA background documents (SERA, 

2001). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-204 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

There are some differences between the old FEIS toxicity data 

evaluation and the newer SERA (1996) risk assessments on which 

this EIS relies for updated toxicity data that are not discussed in the 

EIS and are not adequately explained in the Herbicide Information 

Profile for triclopyr. On p.9 of the Profile it is noted that: "The use 

of the newer NOEL of 0.5 mg/kg/day reduces the margins of safety 

cited in the FEIS by a factor of five." This seems to be a 

significant difference and reflects new scientific data indicating 

greater hazards for triclopyr (and other herbicides?) yet later the 

Profile assures us that "-the qualitative expression of risk for both 

workers and the general public is reasonably consistent between 

the FEIS and the updated (1996) risk assessments". 

All FS/SERA herbicide risk assessments 

used to estimate effects for this DEIS have 

been updated since 1996 to incorporate new 

studies, regulations, and information. The 

risk assessments and specialist reports have 

been available upon request from the EIS 

staff. 

There is no disclosure in the Profile of the results of studies 

mentioned that measured actual worker doses of herbicide 

formulations in typical forestry applications although the SERA 

1996 bumped up all application methods from "negligible" to 

"low" to "moderate risk" for workers (backpack sprayers were 

already rated at "moderate" risk)- a change based on what 

information? What does this change mean to the worker? 

The IPEIS categorizes risk based on 

estimated Hazard Quotient ( the relationship 

of the predicted dose to the RfD for the most 

sensitive effect), with a threshold of 1 for 

concern. The DEIS describes how HQ that 

exceed one are categorized, and how 

categories are interpreted for effects analysis 

of alternatives on DEIS page 4-65. 

I question the assumptions of your use of Reference Dose. Since 

RfD is an estimate of the daily dose that can cause no health effects 

over a lifetime, this means there could be exposure at this level 7 

days a week, year after year. This is not realistic for real-world 

herbicide application, which is focused on the growing season. To 

exceed the RfD occasionally during a spray season should not 

imply the risks shown. These products would be used as labeled 

under this weed program, and the science shows that they are safe. 

I believe your analysis should conclude this as well. 

Both acute and chronic RfD’ s were 

estimated and used to identify the mostsensitive effect RfD for calculation of the 

Hazard Quotient for herbicide applications 

associated with DEIS alternatives. This 

comment only applies when the most 

sensitive dose RfD is a chronic RfD. The 

FS/SERA risk assessments use peerreviewed evaluation of all scientific studies, 

based in US-EPA protocols to establish 

chronic RfD’s. The risk assessments 

acknowledge the uncertainties in intra and 

interspecies variability in physiological 

responses and adopt the most conservative 

realistic approach to best encompass the 

possible ranges of variability for long-term 

exposures/doses. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-205 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

How strange it is that the collective memory of the Forestry 

Department is so shortlived. Remember the hundreds of babies 

born with Emphaliceil in Guerneville in Sonoma County, 

California 1976 and 77 from a pesticide spill. Most only survived a 

short time. Remember A Bitter Fog, the book about pesticides and 

herbicides in the Five Rivers area of Oregon causing cancers, 

deformed infants, miscarriages. Is this human toll meaningless now 

because it was twenty five years ago and we were not the same 

people made of the same substances as our immediate ancestors. 

Do not do this to us again! Keep pesticides out of our forests. 

All alternatives in the DEIS estimate 

maximum realistic doses of each herbicide 

and other substances of toxicological 

concern. If those doses exceed the 

respective reference dose based on the dose 

for the most sensitive effect found in 

laboratory animals tests, with a reduction in 

the maximum allowable dose of at least 99% 

for uncertainty in interpreting lab animal 

studies to human responses in natural 

settings. FEIS Appendix Q “Human Health 

Risk Assessment” describes this mitigation 

process in detail. 

To further reduce the risk of human 

exposures from invasive plant herbicide 

treatments, notification and signing would 

be required to advise forest users of area 

with current and recent herbicide 

applications. These measures would 

minimize the risk of anyone receiving a dose 

from our operations that will cause or 

contribute to adverse health effects. 

As a chemically-sensitive person with Chronic Fatigue Syndrome, 

my health is harmed by contact with pesticides such as 2,4-D and 

others. When I go camping or visit national forests for daytrips, I 

do not want to be forced to return home immediately due to a 

negative reaction to pesticides being used in our public places. 

Headaches, nauseas, light-headedness, dizziness and extreme 

weakness are some of my symptoms that are exacerbated or 

brought on by exposure to pesticides, including breathing them as 

they off-gas from the leaves of treated plants. Although other 

people may not be so sensitive as I am, it is likely that they are 

experiencing negative health effects also, just not as noticeable. 

The FEIS has been amended to state that 

unusually sensitive individuals may 

experience effects even when they receive a 

dose that is less than the Reference Dose for 

the most sensitive health effect. This section 

also discusses any known or anecdotal 

effects reports for all herbicides for sensitive 

individuals and possible hypersensitive 

effects. Standards in the alternatives would 

require that National Forests inform people 

so that may avoid exposure to herbicides in 

the vicinity of treated areas during and after 

application. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-206 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

We cannot continue to accept the risks associated with herbicide 

use while our mothers, brothers, sisters and friends are dying from 

environmental-contamination-induced cancers. Please find other 

ways to prevent/manage invasives. 

The rationale for selecting herbicides for 

treatment over other methods will be 

disclosed and documented in project 

environmental assessment. The DEIS 

described why herbicides are necessary as 

the only known method to effectively 

control certain invasive plant species. A 

comparison of the DEIS alternatives, and the 

finding of no expected serious health effects 

to workers and the public from the proposed 

action are located on DEIS pages Chapter 4-

82-83. 

Standard 23 in all action alternatives require 

that National Forests inform people so that 

they may avoid exposure to herbicides in the 

vicinity of treated areas during and after 

application. 

Although I am not entirely opposed to herbicide use, I am very 

concerned about indiscriminate and continual use of herbicides. 

Both known and not-yet-known environmental and human health 

side-effects from herbicide use are under-estimated by government 

agencies, the chemical industry, and public members as well. In 

your own DEIS known and potential herbicide side-effects are 

down-played or not even mentioned. 

The DEIS described the potential effects and 

risks from alternatives for invasive plant 

management. A detailed synthesis of human 

health risks is available in the FEIS 

Appendix Q “Human Health Risk 

Assessment”. Details of the review of 

scientific studies and reported health effects 

for each herbicide are found in the FS/SERA 

herbicide risk assessment. 

The National Data Quality Act (DQA) and FIFRA mandate that 

relevant information be provided to determine a cost-benefit 

analysis for herbicides in this proposal. The lack of such a costbenefit analysis, coupled with the exclusion of information on 

proprietary studies, should be cause to fail the requirement for 

disclosure under NEPA. We recommend that use the DQA and 

FIFRA to analyze the number of lives that will be lost due to 

glyphosate treatments on National Forests due to contraction of 

non-Hodgkin's lymphoma, which has been positively linked to 

glyphosate. 

The risk assessments do not indicate that 

glyphosate use projected for the alternatives 

would cause any loss of human life. The 

DEIS described the costs (environmental 

consequences) and benefits (effectiveness in 

meeting the purpose and need) of the 

alternatives. 

Though not listed as carcinogens, NPE and degradates have shown 

the potential to cause mutations and deformities and are suspected 

of producing cancer effects through both endocrine and nonendocrine mediated pathways. These concerns should be addressed.

The FS analyzed the range of scientific 

studies on the hazards of NPE, metabolites, 

and impurities. The Reference Dose (RfD) is 

based on the most sensitive potential effect 

with applied uncertainty factors. The RfD 

was determined to account for the risk of any 

of the potential effects cited in this 

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

Appendix A-207 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

 "Estimated Health Risks to the Public" (whatever those risks may 

be in physical manifestations) go up from "negligible" to "low" 

(completely undefined terms) for dermal exposure to sprayed 

plants & "lower" risk exposure to contaminated fruit. What does 

this mean in quantifiable terms and what are the specific health 

risks involved? 

Quantifiable estimates of health risks for 

these effects are displayed and described in 

the FEIS Appendix Q “Human Health Risk 

Assessment” and associated tables. The 

specific health risks are identified for the 

RfD for each individual herbicide or NPE in 

the respective FS/SERA risk assessment. 

These results have been summarized in the 

EIS. 

It is also important to challenge the assumption that U.S. EPA 

standards of "acceptable risk" for human health effects are not 

based on any kind of popular democratic consensus, but are 

determined in-house by agency staff. 

The DEIS adopts the US-EPA standards for 

acceptable risk (RfD’s); however, the 

underlying FS/SERA herbicide risk 

assessments review the entire body of 

relevant scientific literature (not just tests 

submitted to EPA for pesticide registration) 

to develop comprehensive and protective 

RfD’s. The EPA standards were developed 

through regulatory rulemakng to implement 

legislation approved by the legislative and 

executive branches of the federal 

government. 

The surfactant NPE is not the only additive associated with specific 

risks to human health contrary to the DEIS statement on p. 4-62. 

Kerosene and ethanol are other known additives of herbicides 

proposed for use that are associated with known human health 

risks. 

NPE is an adjuvant that may be added to 

various formulations of herbicide, and it is 

the only adjuvant considered in the DEIS 

that is classified by US-EPA as an Inert of 

Known Toxicity (“List 1”). The other 

compounds mentioned are inert ingredients, 

pre-incorporated into specific herbicide 

formulations; none are on EPA Lists 1 or 2. 

The known toxicity of publicly-identified 

inerts is analyzed in the “Adjuvants” section 

of each FS/SERA herbicide risk assessment. 

The overall toxicity of the formulation 

encompasses and discloses any toxicity 

attributable to the inert(s) acting in 

combination with the other herbicide 

formulation ingredients. The FEIS clarifies 

this distinction. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-208 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

We are concerned about the potential for endocrine disruption and 

synergistic effects from herbicide use; the DEIS does not appear to 

plan to avoid these effects despite their potential severity. 

The potential for synergistic effects from 

herbicide use in the alternatives is 

summarized in the DEIS section 4.5. A 

detailed analysis of the potential for 

synergistic effects from the herbicides 

proposed for use and methodologies for 

assessing the potential effects of chemical 

mixtures is found in the FEIS Appendix Q 

“Human Health Risk Assessment”. This 

analysis is based in detailed reviews of 

relevant scientific literature for each 

herbicide in the respective FS/SERA 

herbicide risk assessment. 

The potential for endocrine disruption is 

analyzed in each herbicide risk assessment, 

as a distinct effect or as a contributor to 

reproductive or systemic health effects. 

NPE surfactant is the only compound for 

which a potential for endocrine effects has 

been identified. The Reference dose for 

NPE incorporates uncertainty factors to be 

protective from estrogenic and reproductive 

effects in FS applications. 

[Page 4-74 states] There are no exposure scenarios for drinking 

stream water contaminated by drift for any herbicide in this 

alternative that exceed the Rfd. (What does this mean? Where's the 

science to possibly back up this assumption?) 

The underlying methodologies for 

estimating drift from DEIS herbicide 

applications are described in: “Preparation 

of Environmental Documentation and Risk 

Assessments” (SERA, 2001; cited in DEIS). 

The methodologies used to quantify the 

concentration of a particular herbicide 

expected in a described typical forest stream 

from drift and runoff is described in Section 

4.2-Exposure Assessment of each FS/SERA 

herbicide risk assessment. Every risk 

assessment received a scientific peer review 

incorporated into its estimates of dose and 

risk, including stream contamination from 

drift. 

Please address in final IPEIS, contrary to the IPEIS draft which 

states no long term health effects will ensue. Please clarify how is 

light of submitted papers that pesticides and herbicides apparently 

are accumulative, you can still derive no long term health effects 

will ensue - Chapter 4-22. Indirect and Direct effects. 

Studies of the metabolism of each herbicide 

and of NPE, including any tendency to 

bioaccumulate in humans are analyzed in 

“Pharmokinetics and Metabolism” section of 

the FS/SERA risk assessment, which is the 

basis of the DEIS effects analysis and the 

Specialist report: Human health Risk 

Assessment. Only NPE was found to 

bioaccumulate and the potential for longterm effects from NPE exposure is described 

in the risk assessments. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-209 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

In addition to making unfounded comparisons to reach desired 

conclusions, the DEIS makes an unsatisfactory attempt to answer 

scientific questions concerning the likelihood and severity of 

various herbicide exposure risks. The DEIS provides a number of 

helpful tables and explanations that layout risk assessment but 

despite these expansive efforts, the science remains insufficient and 

questionable. The DEIS acknowledges for example that it chooses 

a "threshold for serious risks of potential health effect based on 

professional judgment rather than EPA regulations." DEIS at 4-65. 

This threshold is defined as a hazard-quotient greater than 10. The 

hazard quotient is calculated as estimated dose/ RfD, the RfD being 

the reference dose or EPA target level. These equations indicate 

that the threshold set out in the DEIS is 10 times the EPA target 

level. That is an alarmingly high allowance. Granted, the scenarios 

in which an exposure would cross the threshold are limited but the 

threshold is nonetheless disturbing because its excess is justified 

only by unsubstantiated "professional opinion". There is no 

assurance of "professional integrity, including scientific integrity" 

as required by 40 CFR 1502.24. In an undefined "professional 

opinion.” 

Both components of the Hazard Quotient 

(RfD and projected dose from FS 

applications) are based on peer-reviewed 

scientific analysis and displayed to public 

review in the FS/SERA risk assessments. 

The projected doses assume various 

circumstances for each application scenario, 

including in max-max projections a number 

of worst-case assumptions such as 

.maximum hours worked, or 100% body 

exposure (i.e. naked), and maximum 

herbicide application rates. 

EPA does not categorize risks that exceed a 

HQ of 1. The EIS team adopted as 

administrative guidance a threshold HQ of 

10 to enable the decision-maker and the 

public to distinguish risks that would be 

readily mitigated at the project level to 

below the EPA threshold of concern, from 

risks that would require extreme scrutiny 

and effort to achieve mitigation and could be 

considered for region-wide prohibition or 

mandatory mitigations in this programmatic 

EIS. 

For many of the herbicides, the only HQ’s > 

1occur for worst-case assumptions that 

would not occur in FS operational 

applications in compliance with state federal 

and agency law and direction. 

Project environmental analysis will need to 

address whether the HQ exceeds 1, and 

adopt project-specific mitigations or 

refinement of analysis to ensure that worker 

and public health will be protected in realworld applications. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-210 

Table 39. Comments and Responses about Herbicide Risk Assessment and Effects on Human Health

Comment Response 

The assessment that human health effects will be insignificant in 

the case of herbicide treatments is also based on the questionable 

rationalization that "the quantities of herbicide proposed for use in 

DEIS alternatives is further diminished in significance of their 

contribution to potential significant cumulative health effects in the 

context of all herbicide use in the analysis area." DEIS at 4-84. The 

DEIS claims that the use of additional herbicides as proposed 

would only amount to roughly 3 [percent] of the total herbicides 

used against invasive plants in Oregon and Washington: This drop 

in the bucket" rationale does not automatically negate the dangers 

of the proposed herbicide treatments especially when taking into 

consideration the NEPA standard that "cumulative impacts are the 

impacts resulting from "past, present, and reasonably foreseeable 

future actions regardless of what agency (Federal or non-Federal)" 

takes the action. 40 CFR 1508.7. In assessing cumulative impacts it 

is essential to take into account all contributors. It is unscientific 

and illogical to conclude that the proposed herbicide use will not 

notably impact human health simply because other individuals and 

agencies use herbicides too. Additionally the 3 [percent] statistic 

appears to be unreliable based on the DEIS' previous claim that the 

"overwhelming majority of the weed control work occurring off 

National Forest system lands is with herbicides" but that "an 

accurate accounting of the total acreage of invasive plant treatment 

for all land ownerships is unavailable." The limited information 

that is available is "based on informal discussions with state and 

county agriculture and weed personnel". DEIS at 4-1. The DEIS 

does not establish a clearly defined basis for the claim that the 

proposed herbicide use is "insignificant" compared to all the other 

anti-invasive herbicide use. 

The human health effects analysis disclosed 

the reasons why the risks of herbicide use in 

the Proposed Action are not significant, 

especially in light of the legal and ongoing 

use of herbicides off National Forest across 

the two-state region. There is no evidence 

that the additional use of herbicides as 

proposed would trigger significant 

cumulative effects. 

The direct and indirect effects vary between 

the alternatives; for instance, Alternative D 

poses the greatest potential hazard to human 

health effects of all the alternatives. 

However, the cumulative effects of all the 

alternatives are similar because of the use off

National Forest is so much larger and does 

not vary between alternatives. 

The FEIS has been edited to clarify that 

there are no significant differences in 

cumulative effects between alternatives. 

What data and methodologies are used to calculate RfD’s? The DEIS adopts the US-EPA process for 

acceptable risk (RfD’s); however, the 

underlying FS/SERA herbicide risk 

assessments review the entire body of 

relevant scientific literature to develop 

comprehensive and protective RfD’s. Both 

acute and chronic RfD’ s are estimated and 

used to identify the most-sensitive effect 

RfD for calculation of the Hazard Quotient 

for herbicide applications associated with 

DEIS alternatives. In establishing RfD’s, 

the risk assessments apply uncertainty 

factors for intra and interspecies variability 

in physiological responses and adopt the 

most conservative realistic approach to best 

encompass the possible ranges of variability 

for long-term exposures/doses. This 

information was in the DEIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-211 

Effects on Wildlife

Several commenters questioned conclusions in the DEIS wildlife effects analysis. Others 

accepted the DEIS conclusions, and expressed opinions about the merits of the alternatives 

given the wildlife analysis. The FEIS contains additional discussions and clarifications to 

respond to these comments. 

Table 40. Comments and Responses about Effects on Wildlife

Comment Response 

I oppose the potential impacts to wildlife: "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, and 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 malformities or impacts to amphibians, 

which are exposed in the event herbicides enter water" (DEIS, p.1-

11) 

The DEIS disclosed these potential effects of

herbicide use. However, the DEIS also 

stated that adherence to the proposed 

standards would reduce the risk of these 

effects actually occurring 

Issue no. 3 should be about treatments, not just application of 

herbicides. In fact the EIS does go on to analyze treatments, but 

only in a haphazard and incomplete fashion, generally nonquantitative. The August 10, 2004 Specialist's Report, "The Effects 

of Non-herbicidal Methods of Invasive Plant Treatment on 

Wildlife, Fish, and Plants", by Bautista, Mazzu and Robbins gave 

more details in analyzing a number of non-chemical methods, but 

these seem to have been borrowed primarily from the old 

Vegetation Management EIS, as witnessed by the use of the same 

old categories. Furthermore the specialist's report was incomplete, 

and deserved to be much more thorough. The National 

Environmental Policy Act is explicit about requiring analysis 

sufficient to make a reasoned decision. The boiling down of issues 

was done in an inappropriate manner likely to bias decisions and 

failing to meet the requirements of NEPA for a disclosure 

document. Because non-chemical alternatives were not analyzed or 

were insufficiently analyzed, the decision and the choice of 

alternatives are biased and baseless. 

The effects of non-chemical treatment on 

wildlife, fish, and non-target plants were not 

identified as key issues for analysis. These 

effects would not change regardless of 

alternative selected. NEPA requires that 

agencies focus the disclosure on issues of 

significant concern to the public. 

Appendix J, The Effects of Non-Herbicide 

Methods of Invasive Plant Treatment on 

Wildlife, Fish and Plants is published with 

FEIS to address concerns about wildlife 

effects from non-herbicidal treatment 

methods 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-212 

Table 40. Comments and Responses about Effects on Wildlife

Comment Response 

Birds and mammals that eat grass or insects and are most 

susceptible to herbicide impacts make up a large part of the forest 

food chain and a base of biological productivity - herbicide impacts 

to these species are a large problem and should have been analyzed 

in detail and avoided through specific measures. 

A detailed, quantitative analysis of estimated 

exposure and potential risk to birds and 

mammals that eat grass or insects was 

conducted for all herbicides, to the extent 

permitted by available data (see Appendix P, 

“Summary of Herbicide Effects to 

Wildlife”). The evidence and findings from 

this report are in the EIS. Standards 19 and 

20 contain direction to reduce or avoid 

adverse effects to wildlife, including birds 

and mammals that eat grass or insects. 

Specific protection measures will be 

designed at the project scale, where site 

information and species presence can best be 

evaluated. 

In the proposed alternative you’re using more herbicide and the 

number for harmful doses is less even though more herbicides will 

be used! Please explain in IPEIS final how you arrived at this 

figure? 

The FEIS Chapter 4 contains additional 

explanation of how the herbicide suite 

included in each alternative influences the 

number of exposure scenarios that exceed 

the NOAEL or LOAEL in relation to 

number of acres projected to be treated with 

herbicide. Compared to the No Action 

alternative, the Proposed Action projects 

more acres treated with herbicide each year, 

but fewer exposure scenarios that may result 

exceed the NOAEL or LOAEL. This is due 

to the availability of herbicides in the 

Proposed Action that have little or no 

potential to result in a harmful dose to 

wildlife. Acres treated with those herbicides 

do not contribute to the potential number of 

scenarios exceeding the NOAEL or LOAEL. 

In addition, the Proposed Action projects 

many fewer acres treated with picloram, no 

use of Dicamba, and restricted use of 

Triclopyr compared to No Action, so the 

number of scenarios exceeding NOAEL or 

LOAEL is lower for the Proposed Action, 

even though the projected number of acres 

treated is higher (see Tables 4-12 and 4-13 in 

the DEIS). 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-213 

Table 40. Comments and Responses about Effects on Wildlife

Comment Response 

Please address what science you are using to determine the effects 

of wildlife. How do you know PREY will not be exposed. That is 

an unproved assumption. Have you tested 'the Prey'? How can you 

know the effects when such a massive aerial and ground 

application of herbicides has never been used before? Have you 

tested 'prey' from previously treated areas where herbicides have 

been used? And the wildlife? Your broad statements are not based 

in fact. Where is the data to support your statements? 

The DEIS analysis assumed that prey will be 

exposed and quantitatively estimates, when 

possible, the dose received by the prey and 

transferred to the predator (further 

discussion in Appendix P, “Summary of 

Herbicide Effects to Wildlife”). Published 

literature from peer-reviewed journals was 

reviewed that, 1) measured population 

changes for common prey species (see for 

example, Cole et al. 1998; Lautenschlager 

1993; Sullivan et al. 1997, 1998), or 2) 

measured the amount of herbicide absorbed 

by various species of wildlife and prey after 

field applications of herbicide (e.g. Newton 

et al. 1984). These sources of information 

were used to characterize risk to animals that 

eat fish, small mammals, or insects. 

Your IPEIS states on Chapter 4-122 -129 state that "indirect effects 

from herbicides used are not likely to occur because the herbicides 

considered in this EIS do not accumulate or concentrate up the food 

chain.” The science differs from the science of researchers such as 

Dr. Tyrone Hayes - UC Berkeley. [Atrazine] accumulates enough 

that frogs develop multiple sex organs in low doses and there is no 

Atrazine free environment. 

The FS is not considering the use of atrazine 

or any other triazine group of herbicides. 

The effects of atrazine are beyond the scope 

of this EIS. 

[Section 4.4] The Forest Service fails to adequately compare the 

toxicity of each recommended treatment (or chemical, or 

whatever). Both NEP A and the ESA contain strong science and 

disclosure requirements. 16 U.S.C. [section] 1536(a)(2)(requiring 

that agencies use "best scientific and commercial data available." 

"Agencies shall ensure professional integrity, including scientific 

integrity" in all discussions and analyses in the DEIS. 40 CFR 

[section] 1502.24. The Forest Service fails, to explain why the 

chemicals it chooses to use are necessary. In section 4.7.2 the 

Forest Service discusses the effect of Glyphosate concentration in 

water. Concentration of this chemical in water is shown to have a 

harmful effect. However this chemical is included in all 

alternatives. Is this chemical really necessary in controlling 

invasive species of plants. 

The herbicides included in the Proposed 

Action were selected to comprehensively 

address invasive plant species known in the 

Region. The FEIS describes the control 

methods appropriate for a variety of target 

species and site conditions. Alternative D 

includes 2 additional herbicides that to 

decrease the costs and increase the 

effectiveness of herbicide use as compared 

to the Proposed Action. Alternative B 

includes herbicides that were suggested by a 

coalition of citizen’s groups interested in 

prevention and management of invasive 

plants on National Forest. The herbicides 

that would be approved in Alternative B 

have greater social acceptance and are less 

persistent in the environment. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-214 

Table 40. Comments and Responses about Effects on Wildlife

Comment Response 

Amphibians are also at increased risk for severe long term harm. It 

has been stated in the DEIS that Glyphosate could put amphibians 

at a huge risk of severe decline if a large amount were to 

accumulate in water ways were amphibians are present. The Forest 

Service states in section 4.4.2 that exposure scenarios for all 

chemicals have not been created for amphibians in the Forest 

Service/SERA risk assessment. The Forest Service chose to use 

fish as a surrogate to amphibian reactions. The Forest Service does 

not include language as to why it chose fish as an appropriate 

surrogate or why it has failed to do proper scientific research on the 

effects of the chemicals on amphibian populations. It is extremely 

important that the Forest Service assess all scenarios including 

those involving amphibian populations. Again the Forest Services 

is obligated under the ESA to use the best science available to them 

and to present to the public the best information regarding the 

possible effects of the chemicals used in the proposed action. 16 

U.S.C [section] 1536(a)(2). The Forest Service has clearly failed to 

fulfill its obligations. Also, if there is no other pertinent studies, the 

Forest Service must carry out their own tests, unless it can be 

shown that the cost of obtaining such information is too exorbitant, 

which it has not included. 

The FEIS includes further explanation of 

why fish are used as a surrogate for 

amphibians in assessing potential effects of 

herbicides to amphibians. 

Quantitative exposure scenarios can only be 

done if adequate toxicity data exists to 

support the scenario. If there is no 

amphibian exposure scenario for an 

herbicide, it is because there was insufficient 

data on amphibians to support the scenario. 

In this case, toxicity to fish was used as a 

surrogate to characterize risk to amphibians. 

Potential risks to amphibians are discussed 

qualitatively based on published, peerreviewed literature in Appendix P, 

“Summary of Herbicide Effects to Wildlife.”

It is not feasible to obtain more precise 

information for various amphibian species 

prior to making a decision regarding the 

management of invasive plants. This would 

require many different laboratory tests, each 

one of which is costly, and after the tests are 

concluded there would be significant delays 

while the results are peer-reviewed and 

published. In the meantime, we know that 

invasive plants are adversely affecting 

wildlife habitat and in some cases 

contributing to the extirpation of rare 

amphibian species at specific sites. The 

uncertainty regarding potential effects of 

herbicides to amphibians was one factor, 

which led us to develop Standards 19 and 

20, which require consideration of sitespecific conditions to develop treatment 

projects and require measures that will 

reduce exposure to rare amphibians and 

other wildlife. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-215 

Table 40. Comments and Responses about Effects on Wildlife

Comment Response 

The DEIS also fails to adequately assess the science used in regards 

to the herbicides~ potential to harm wildlife and aquatic species. 

We are forced to extrapolate data from lab animals kept in specific 

conditions to the effects that herbicides might have on wild free 

ranging wildlife. The science is inadequate because it fails to show 

that there are vastly different environmental effects that cannot be 

adequately assessed from lab conditions. The science used does not 

assess behavioral or feeding patterns or other patterns of known 

wildlife in the proposed project area thereby reducing the validity 

of the information. The DEIS does not adequately address the 

needed scientific data and fails to ensure the "scientific integrity" of

the data it used for the conclusion reached as required by NEPA. 40 

CFR 1502.24. 

The influence of animal behavior or feeding 

patterns on the likelihood of exposure was 

disclosed in Chapter 4.4 of the DEIS. 

Incomplete and unavailable information, 

uncertainty and the infeasibility of obtaining 

more species-specific information was also 

discussed. 

The DEIS disclosed that the best science 

available was used in herbicide risk 

assessments. The numerous site-specific 

conditions that influence the likelihood that 

non-target animals would be exposed to 

herbicide (e.g. topography, weather, 

vegetation type, animal species presence, 

behavior, feeding patterns, etc.) would be 

evaluated at the project level when and 

where a treatment is proposed. 

The DEIS also list a variety of ways that the Forest Service can 

avoid some of the potentially harmful effects of the herbicides on 

the wildlife and amphibian populations. It makes generalized 

statements about attempts to avoid spraying herbicide at certain 

times of years, or on certain areas or when and where specific 

herbicides can be used. It is stated that it can lower the impact of 

adverse effects by management directions. However, the DEIS 

does not address how these factors may lower adverse effects on 

animals. Simply because the Forest Service does not broadcast 

herbicide sprays when herbivores or amphibians may be more 

vulnerable does not eliminate the effects that the herbicides will 

have on them in the long term. Also, it fails to point to specific 

times of years the Forest Service proposes to lower herbicide 

spraying and only generalizes ideas to lower risk. The management 

directives are so vague that they fail to provide any real assurance 

that the Forest Service can avoid actual adverse effects on the 

proposed project site. Also, no other alternatives are presented 

making the Forest Service's claim that there are additional choices 

to minimize risk unsubstantiated. The Forest Service must be more 

concrete in informing the public about the methods it will use to 

minimize risk. 

The methods listed lower the potential for 

adverse effects by decreasing the likelihood 

of animals being exposed to the herbicide. If

an animal is not exposed to the herbicide, it 

cannot be directly affected by it. 

Specific protection measures, such as 

determining the time of year an application 

would occur in a particular project area, 

must be designed at the project level, where 

site conditions, species presence, invasive 

plant species present, and methods of 

treatment to be used are best evaluated. It is 

not feasible or practical to try to dictate 

specific project design features that could be 

used on all forests within the two-state 

region. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-216 

Table 40. Comments and Responses about Effects on Wildlife

Comment Response 

The DEIS also makes generalized statements that the short term 

adverse effects will be largely offset by the long term benefits to 

species from protecting habit from loss due to invasive plants. 

However, if we look at the science currently available in the DEIS, 

the Forest Service provides us with a list of potential long term 

effects that the herbicides it's proposing to use will have on the 

overall population. For example, triclopyr, an herbicide the Forest 

Service proposes using, albeit in small doses, still has the potential 

to cause mortality in birds at acute levels and decreased eggshell 

thickness at chronic levels. The mortality of not only adult birds 

but the potential problems associated with weakened bird shells 

could have a long-term impact on the survival of specific bird 

species in the area. It could also potential cause a decline in 

endangered bird species that might be affected such as the northern 

spotted owl or the snowy plover. Small declines in endangered 

populations could have enormous impacts on the long term survival 

of the entire population. 

The FEIS Chapter 4 includes a more detailed 

discussion of the relationship between 

“hazard identification” and the 

characterization of risk. Potential mortality 

and decreased eggshell thickness represent 

the “hazard identification” portion of risk 

assessment. The hazard that any chemical 

may pose must be evaluated in terms of 

potential for exposure to the hazard 

identified (usually in terms of dose 

received). Triclopyr that is broadcast 

sprayed has some potential to cause adverse 

effects, but only to the specific individuals 

exposed in the treatment area, and then only 

if a specific exposure scenario actually 

occurs in the field. Triclopyr does not 

persist in the bodies or animals, nor is it 

passed up the food chain, so only the 

individual exposed is likely to experience 

the adverse effect. The low likelihood that 

the exposure scenarios would occur as 

modeled, the typical application methods 

used for triclopyr, the potential to reduce 

exposure through application method and 

timing, and the influence of animal behavior 

and seasonality, are just a few factors that 

modify the potential for exposure and serve 

to reduce actual risk. This will reduce the 

number of individuals exposed. So, while a 

potential for an adverse effect to occur 

remains, the plausibility is low. Some 

individual birds might be adversely affected, 

but the likelihood that a project would 

adversely affect many individuals and 

therefore influence a population is extremely 

emote, due to the hazard-reducing factors 

mentioned above. 

In addition, Standard 20 for all alternatives 

requires projects to be designed to reduce or 

eliminate adverse effects to proposed and 

listed endangered species. This is relatively 

easy to accomplish and effective, further 

ensuring that any adverse effects that do 

occur would be limited to a few individuals, 

and not influence an entire population. 

These potential effects would also only 

occur after consultation with the U.S. Fish 

and Wildlife Service has been completed for 

the proposed project implementation. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-217 

Table 40. Comments and Responses about Effects on Wildlife

Comment Response 

The Forest Service indicates that cumulative adverse effects of 

herbicides on wildlife are not likely. It states that the herbicides 

examined in the DEIS do not build up in the animal's body and are 

not passed up the food chain. However, the Forest Service does not 

cite where it got this information. It also concludes that the adverse 

effects would just occur in a "small number" of animals, instead of 

populations of animals. What constitutes "a small number" would 

need to be defined. 

The FEIS Chapter 4 contains a reference to 

the Forest Service/SERA risk assessments as 

the source of information regarding 

bioconcentration and elimination of each 

herbicide. The FEIS Chapter 4 has also been 

corrected to reflect that adverse effects 

would occur to individual animals rather 

than populations. 

The invasive species DEIS fails to adequately review the impacts 

of the proposed herbicide use on wildlife and aquatic species. The 

DEIS proposes in several areas there is limited exposure to wildlife 

from the spraying either aerially or by ground spraying because of 

an inferred belief that wildlife with large home ranges will only be 

in the area for a short amount of time thereby limiting there 

exposure to potentially harmful herbicides. However, the DEIS 

fails to point to any scientific research to indicate that the area 

exposed to the herbicide is or is not preferred habitat for many 

species. The amount of exposure to wildlife depends largely on 

uncontrollable factors such as food supply, weather, and behavior 

patterns. The DEIS fails to do any scientific research into animal 

behavior in the affected areas which may indicate greater risks to 

wildlife in the proposed project area than is evident by the science 

used in the DEIS. Without such information the Forest Services' 

scientific conclusions that wildlife will only have limited exposure 

is inaccurate. In effect, the Forest Service fails to ensure that it is 

managing fish and wildlife habitat to maintain viable populations 

of existing native and desired non-native species as required by the 

National Forest Management Act. 36 C.F.R. [section] 219.19. 

The analysis of potential impacts to wildlife 

and aquatic species in the DEIS is conducted 

at the forest plan scale, and as such, is a 

general discussion of potential effects. The 

numerous site-specific conditions that 

influence the likelihood that non-target 

animals would be exposed to herbicide (e.g. 

topography, weather, vegetation type, animal 

species presence, behavior, feeding patterns, 

etc.) must be evaluated at the project level 

when and where a treatment is proposed.. 

Also, the target species for treatment 

projects (invasive plants) do not provide 

preferred habitat for wildlife or aquatic 

species, reducing the likelihood for exposure 

to herbicides. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-218 

Effects on Land Uses

Some commenters expressed that the DEIS should be supplemented to clarify how the 

proposed standards would affect grazing, recreation, timber management and other land uses 

and activities. In response to these comments, the FEIS includes further discussion about risk 

to human health if an area is subjected to wildfire after herbicides are applied. The FEIS also 

provides further discussion about the weed-free mulch requirements. The standards related to 

weed-free mulch and feed were also modified. 

Table 41. Comments and Responses about Effects on Land Uses

COMMENT RESPONSE 

Please know that Minerals and Mining are important to the West 

as are the products of mining, Antimony, Gold, Silver, Stibnite, 

and etc. Weed removal should not hinder Mining. 

The DEIS disclosed that the Forest Service 

does not anticipate that weed removal 

(treatment) will hinder mining activities. 

It is important that any adopted plans not unreasonably interfere 

with the historic uses that were recognized as acceptable when 

areas were designated as wilderness, such as the use of livestock. 

The DEIS disclosed that statutory direction 

provided by congress is not affected by this 

proposal. No Forest Service regulations or 

policies for Wilderness Areas are affected. 

Allotment management plans would be 

required to address invasive plant prevention 

in all alternatives. 

The Final EIS should compare the estimated annual acreage driven 

on by equipment that operates off-road for operations authorized 

or conducted by the Forest Service (for which equipment-cleaning 

is required) and estimated acreage driven off-road by recreational 

vehicles (for which no equipment-cleaning is required). 

Such acreage estimates are not available as 

data to base them on does not exist and is not 

reasonably attainable. See Chapter 4 for 

calculation of costs to heavy equipment work. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-219 

Table 41. Comments and Responses about Effects on Land Uses

COMMENT RESPONSE 

I am disappointed in the limited data and disclosure of the effects 

on fire and fuels management from the proposed action. On the 

one hand, the DEIS states that fuels management projects are 

expected to increase considerably in number, scale, and 

complexity; however, the document does not adequately analyze 

all the likely effects of those anticipated projects in aiding the 

introduction, establishment, and spread of invasive plants. The 

FEIS needs much more analysis and disclosure on the role of 

suppression actions in the spread of invasives. In particular, some 

of the potential effects of the spread of invasive plants that need to 

be fully analyzed in the FEIS include: 1. current and anticipated 

future changes in fire regimes and condition classes (FRCC) due to 

invasives 2. predicted changes in rate of spread, fireline intensity, 

fire severity, and fire effects from changes in FRCC 3. increase in 

suppression costs and health and safety risks to firefighters from 

changes in FRCC 4. risks to fuelbreak effectiveness and 

maintenance costs due to invasives 5. risks to firefighters' health 

from herbicide-treated vegetation burning during wildfires and 

/or prescribed fires 6. role of suppression actions such as spraying 

chemical retardants or constructing firelines with mechanized 

equipment such as bulldozers in the introduction, establishment, 

and spread of invasive in wildlands 7. empirical evidence of the 

effectiveness of spraying vehicles 8. data on the validity of socalled "weed-free" mulch used in post-fire rehab actions, and the 

risk to spread of invasive from post-fire rehab actions. At a 

minimum, though, in order to make the FEIS legally sufficient 

under NEPA, more data, analysis, and disclosure of the items 

listed above must be included in the document. 

The level of detail requested is not necessary 

to evaluate the merits and effects of the 

alternatives. Invasive plants are not known to 

have a significant effect on fire behavior, but 

the EIS acknowledges that fire suppression 

can affect the spread of invasive plants. 

The DEIS recognized that fuels management 

projects within Regional Six are increasing 

due to action to reduce fire hazard. Chapter 3 

discussed how these types of projects might 

become a mechanism for spread of invasive 

plants. All action alternatives would require 

that prevention be considered when planning 

these projects. At the fuels project level, 

mitigation measures would be applied and 

effects monitored. Washing equipment is a 

logical method that results in fewer invasive 

plant seeds brought in to disturbed areas. 

The FEIS includes further discussion about 

risk to human health if an area is subjected to 

wildfire after herbicides are applied. 

The FEIS also provides further discussion 

about weed-free mulch requirements. 

[Section 4.67] The analysis on the impacts of proposed road 

closures for Alternative B is incomplete. The document does not 

identify which roads (or road sections) would be closed, or if the 

closures would be temporary (i.e., until weeds are under control in 

certain areas) or permanent. Under 40 CFR 1502.22, the DEIS 

should disclose the nature of unknown data or the vagueness of 

assumptions based on incomplete information. How can the DEIS 

make conclusions about the impacts of lost forest access, and the 

associated cost of lost access, when neither the location nor the 

duration of the closures is presented? As analyzed, the conclusions 

about lost access and associated higher transportation costs are so 

vague that they lack enough substance for the public to evaluate or 

offer comments or alternatives. More information on the extent of 

the closures is needed. 

Current status of access management and road 

closures are discussed in Chapter 3. Road 

analysis would identify roads that are 

contributing to the spread of invasive plants 

and recommend how to best manage access to 

reduce this spread. This programmatic EIS 

would not directly lead to any specific road 

closures. The DEIS disclosed that the 

standards in Alternative B would tend to lead 

to more access restriction than the standards in 

the other alternatives. 

[Section 4.67] The DEIS seems to conclude that the impacts of 

grazing on the spread of weeds is already addressed in the 

individual grazing management plans and so no additional 

measures are needed as part of this DEIS. No scientific support or 

other information for this conclusion is given. Does this mean that 

there are uniform and effective measures to control weeds from 

grazing disturbances in all parts of Region 6? Please provide the 

scientific basis, according to 40 CFR 1502.24, on how these 

grazing plans are controlling weeds in ways that meet the purpose 

and need of this DEIS. 

Current direction on invasive plant 

management related to livestock grazing is 

discussed in Chapter 2. The affected 

environment related to livestock grazing is 

discussed in Chapter 3. Standard 6 in all 

action alternatives requires that invasive plant 

prevention measures be incorporated into 

annual operating instructions and grazing 

allotment management plans. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-220 

Table 41. Comments and Responses about Effects on Land Uses

COMMENT RESPONSE 

As a small organic farmer in a residential area very close to the 

forests I'm always greatly concerned about drift of pesticides. I'm 

very grateful to the forest representatives who, in the past some 

years, have seen fit to notify me when spraying is to occur, and to 

then back pack spray near the area. 

Stop spraying carcinogenic herbicides on our public lands! By 

spraying these poisons you're causing cancer and other diseases in 

humans, especially the forest workers who spray this stuff.- You're 

poisoning berry pickers, mushroom harvesters, etc.- You're 

contaminating our watersheds, drinking water, salmon fisheries, 

and the soil.- The drift from spraying contaminates and can ruin 

certification for Organic farmers like myself. 

These concerns are addressed through the 

addition of Standard 23 to the FEIS in all 

alternatives, requiring that Forests create a 

public information plan with notification and 

signage responsibilities (See FEIS Chapter 2).

How will landowners be affected? I own 40 acres in E. 

Washington next to Dept. of Natural Resources land and a 5 acre 

pond I do not want contaminated with herbicides. Outline in Final 

IPEIS how landowners can protect their land from potential 

spraying operations. 

This decision would not affect Dept. of 

Natural Resources lands. Adjacent lands 

would be considered when planning projects. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-221 

Effects on Soils

Respondents expressed concern that the analysis of effects to soils was not adequately 

disclosed. For example, one Environmental Advocacy Organization stated, “The DEIS is 

lacking needed specific analysis of details about the toxicity of individual herbicides to soil 

organisms, information about studies considered in the risk assessment, modeling of 

individual herbicide movement, and specific information about herbicide properties such as 

persistence, absorption to soil, and solubility in water.” 

These comments did not lead to substantial changes in the FEIS. Appendix J, The Effects of 

Non-Herbicide Methods of Invasive Plant Treatment on Wildlife, Fish and Plants has been 

included in the FEIS to answer numerous questions about the effects of non-herbicidal 

treatment methods. 

Table 42. Comments and Responses about Effects on Soils

COMMENT RESPONSE 

The conclusion that sedimentation will be increased by invasive 

species applies more so to treatments with herbicides, which add to 

existing sedimentation by removing ground cover. 

The difference between sedimentation 

from invasive plants and sedimentation 

from the treatment of invasive plants 

(including the use of herbicides) is the 

amount of time that soil is exposed to 

precipitation or wind that could instigate 

erosion. Under an integrated plan, new 

and varied vegetation will be growing in 

as little as one season. When invasive 

plants are growing, generally no other 

vegetation protects the soil during seasons 

when the invasive plant is dormant, and 

this effect persists as long as the invasive 

plant dominates. This information is in 

the FEIS Appendix J, The Effects of NonHerbicide Methods of Invasive Plant 

Treatment on Wildlife, Fish and Plants. 

The paper by Lacey (1989) cited on p. 3-28 correlated with bare 

ground exposure. The observed effects due to knapweed were 

probably directly due to bare ground, and only indirectly due to 

weeds. Yet the EIS describes this reference as a conclusion that 

removing weeds will solve the problem of erosion, when removing 

the weeds would make the situation worse. 

The point of the Lacey reference is that 

spotted knapweed is associated with more 

ground exposure than native vegetation. 

Native vegetation would be encouraged in 

areas where invasive plants are treated to 

increase ground cover in the long term. 

Removing the knapweed would increase 

bare ground in the short term. This 

information is in the FEIS Appendix J, 

The Effects of Non-Herbicide Methods of 

Invasive Plant Treatment on Wildlife, 

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

Appendix A-222 

Table 42. Comments and Responses about Effects on Soils

COMMENT RESPONSE 

Despite the DEIS's assertion to the contrary, (p. 4-105), soil 

organisms are not important to the "human environment" only 

because they can affect soil productivity. What about more subtle 

changes to soil ph or nutrient levels that could lead to displacement 

of native plants by exotics or to changes in species composition on 

the site? What about consequent impacts to other species and the 

food web? 

The DEIS considered effects on pH, 

nutrient levels, and all the organisms in 

the complex (and fascinating) food web 

found in soil as part of “soil productivity”. 

General statements about picloram's and sulfometuron methyl's 

toxicity to soil microorganisms (EIS p. 4-103) do not give any 

indication of the nature, extent or severity or potential ramifications 

(to native plants, food webs, human health, etc.) of potential 

contamination of different Region 6 soils by these chemicals under 

each of the alternatives. For example, what are the physical longterm direct and indirect results of "substantial" "microbial inhibition" 

from sulometuron methyl at typical forestry application rates? 

Obviously more specific information answering this question should 

be possible to extrapolate, given these statements, which must be 

based on some field or laboratory study/studies. Likewise, with 

picloram's known toxic effects to microorganisms at "low levels", 

what does it mean for the ecosystem and human health, exactly, that 

toxic effects can last "some time" after application? 

The risk assessments addressed the 

nature, severity, and potential 

ramifications of herbicide contamination. 

Generally, effects are inferred from 

effects to soil productivity. In all cases, 

effects to soil productivity were shortlived. This could be due to a change in 

the soil ecosystem, where other organisms 

take over for organisms killed by the 

chemical, or it could be that the chemical 

concentration dropped and organisms 

survived. In some instances, it may be 

desirable to have an herbicide that persists 

in soil long enough that further treatment 

won’t be necessary. Also, changing the 

vegetation from invasive plants will 

change the soil food web, though this is 

considered a benefit to the ecosystem. 

The DEIS is lacking needed specific analysis of details about the 

toxicity of individual herbicides to soil organisms, information about 

studies considered in the risk assessment, modeling of individual 

herbicide movement, and specific information about herbicide 

properties such as persistence, adsorption to soil, and solubility in 

water (as reported to be within individual risk assessments but not 

disclosed or analyzed fully within the DEIS--see p.4-105, DEIS.) 

Herbicide effects to soil organisms were 

analyzed. The disclosure of effects to 

soil biota is based on the concept that 

healthy soil biota are needed for 

productive soil, so negative effects to soil 

biota would be expressed as unproductive 

soil. 

The DEIS is lacking needed specific analysis of differential impacts 

to soil microorganisms according to which soil types are affected 

(arid vs. moist, clay vs. sand, high organic content vs. low organic 

content or alkaline, etc.) by different herbicides. What is not very 

persistent or mobile on the west-side may be very persistent and 

mobile through soils on the east-side but no distinction is made in the 

DEIS between east- and west-side typical and worst-case scenarios 

for herbicide persistence in soils or herbicide mobility through soils, 

surface water and ground water, leading to wider-spread 

contamination of soils, water tables, surface water (eg. via run-off in 

arid flash flood-prone areas) and plants. 

The DEIS is lacking needed specific analysis of assessment of sitespecific scenarios given use of particular formulas proposed on 

particular soil types with specific native plant and wildlife 

associations to give examples of possible results of herbicide use in 

concrete form for better understanding of risks posed. 

Site-specific soils analysis would be part 

of project level planning. Standard 19 

requires that site-specific soils 

characteristics be considered in treatment 

method selection. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-223 

Effects on Aquatic Organisms

Many commenters expressed that the DEIS disclosure of effects to aquatic organisms needed 

to be reinforced with additional information. The FEIS has been supplemented in response to 

these comments. In particular, the FEIS addresses concerns expressed by the National 

Oceanic and A Administration (NOAA) Fisheries Department, the agency responsible for 

consultation on anadromous fisheries listed under the Endangered Species Act (ESA). 

The FEIS clarifies that no direct effects on aquatic organisms would be expected from the 

invasive plant treatment program, however, invasive plant treatments have the potential to 

indirectly affect riparian areas, the aquatic food chain, and water quality. 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

Finally, protections for sensitive riparian areas are a necessary 

component of any IWM strategy. Amphibians and fish are 

typically more sensitive to chemical exposure and given the 

presence of numerous sensitive and ESA listed species in those 

taxa in the PNW Region, the protection of riparian areas that serve 

as habitat for those species is warranted. 

It should come as no surprise that herbicides kill more than plants. 

What guarantee can you give me that every applicator will keep 

them out of the watersheds, wetlands, and endangered fish 

habitats? You can't. Salmon are struggling to survive and WA 

States spends millions of dollars on salmon recovery-don't let one 

Agency destroy the good work of fish and wildlife people. 

Standards 19 through 22 are designed to 

reduce risks to riparian areas. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-224 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

In the aquatic "cumulative effects" section, on page 4-107, the first 

sentence of the section states that FS lands in Region 6 are 

typically upstream from other herbicide applications. The second 

sentence states that FS use of herbicides is typically a small 

percentage of the total herbicide use within a given watershed, and 

references the SERA risk assessments. These statements should be 

further supported with Federal and non-Federal application rates. 

The SERA risk assessments were developed at a national scale, 

where many National Forests have discontinuous ownerships. In 

addition, the geographic scale of "watershed" is not clear. In 

Region 6, most FS ownerships tend to begin at the top of drainage 

basins, extending downstream to boundaries with non-Federal 

lands (where FS ownerships do become more discontinuous). The 

NEPA analysis would be more complete to state that in headwater 

streams and many 5th, 6th, and a few 4th field hydrologic unit 

code (HUC) watersheds, FS land ownership is at or near 100 

percent. In these watersheds, herbicides are typically only applied 

by counties (roadside applications) and the FS for invasive plant 

control. The relevance of this clarification is that many 5th, 6th, 

and a few 4th field HUC watersheds in Region 6, the FS will have 

considerable discretion over the type, extent, and location of 

herbicide application, and ESA listed salmonids will be present in 

many of these watersheds. Therefore, aquatic cumulative effects 

analysis should be conducted in a manner that addresses these 

scale and discretion issues, as well as a realistic assessment of 

applications expected from Federal and non-Federal landowners. 

The DEIS explained that use of the 

herbicides that are considered in the 

alternatives is widespread in the two-state 

region. Application rates and annual acreage 

sprayed were discussed in DEIS Table 4-1, 

Basis For Cumulative Effects Analysis. 

Watersheds with high proportions of federal 

ownership are subject to far less chemical 

exposure than watersheds with a high 

proportion of non-federal lands. The small 

proportion of federal use to non-federal use 

provides a yardstick to help evaluate the 

significance of differences between 

alternatives. 

This programmatic EIS does not 

contemplate any site- specific actions. At 

the project scale, proposed use of herbicides 

would be quantified and risks within 

specific HUC’s will be more precisely 

addressed. 

NOAA Fisheries does not agree that NOEC levels obtained in 

acute toxicity studies represent actual concentrations where no 

data exist for sub-lethal effects. In many cases NOEC levels from 

acute toxicity tests (or derived from LC50 values) may represent 

the best information available. Those data, however, should not be 

considered as definitive documentation of the absence of sublethal effects, but rather a reduced risk of lethality. The effects on 

aquatics would benefit from a more rigorous explanation of sublethal effects that examines the current understanding of the 

limitations of using NOEC levels from acute toxicity tests (and 

extrapolations of NOEC from LC50) 

The DEIS provided the methodology for 

herbicide risk assessment as it pertains to 

fish. (p. 4-108). The DEIS stated that the 

NOEC values that were derived directly 

would most likely cover concerns for sublethal effects, however if NOEC values are 

derived from mortality studies, then 

concerns regarding sub-lethal effects would 

not be fully addressed. NOEC values from 

mortality studies were used when no other 

data was available. 

Calculation/definition of the "concentration of concern" is defined 

in the aquatic analysis section as equal to the "no observable effect 

concentration" (NOEC), and that in some cases the NOEC was 

estimated using LC50 values. It is stated on page 4-108 of the 

DEIS that "...there are sound statistical reasons for this approach," 

(using LC50 values to estimate NOEC) and SERA, 2003-

clopyralid is cited as the source. NOAA Fisheries was not able to 

locate the statistical reasoning within the cited document. NOAA 

Fisheries recommends that this section be expanded to include the 

full citation. 

The statement referred to the “sound 

statistical reasons” for using an LC50 to 

estimate risk of acute mortality, not for 

using an LC50 to estimate a NOEC. The 

FEIS has been updated to eliminate 

confusion. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-225 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

NOAA Fisheries is concerned that the analysis of aquatic effects 

of herbicide use within the DEIS is overly limited by the modeling 

results contained in the SERA risk assessments. The DEIS states, 

in several places, that the only herbicide formulation that could 

result in negative (e.g. page 4-105) or lethal (e.g. page 1-14) 

effects to fish is one formulation of glyphosate. Yet, NOAA 

Fisheries expects that numerous herbicide application and 

exposure scenarios will occur that were not modeled in the SERA 

risk assessments, and for which no discussion or analysis of these 

scenarios is present. For example, the situation of additive toxicity 

risk occurs when application of several different herbicides takes 

place within a watershed, and the effect that is likely to accrue to 

the aquatic community is not adequately addressed. In addition, 

the influence of simultaneous manual and mechanical vegetation 

treatments on herbicide delivery resulting from accelerated erosion 

of herbicide-sorbed soil particles should also be part of this 

discussion. There should also be some discussion of possible 

effects caused by herbicide exposure that is expected to occur 

when the project design will be well outside of what is modeled in 

the SERA risk assessments. For example, helicopter application to 

large infestations in remote areas may affect herbicide delivery and 

exposure for a considerable distance beyond the SERA modeled 

impact area. While quantitative modeling results may not be 

available for this application method, a qualitative discussion of 

effects pathways, vulnerable aquatic species and life stages that 

may be present, and possible consequences is feasible and 

appropriate, and, hence, should be disclosed. NOAA Fisheries 

understands that the above-mentioned project scenarios, which are 

more complex or extensive than those modeled in the SERA risks 

assessments, would tier to the Standards amendments proposed in 

the DEIS during the individual Forest or sub-regional invasive 

weed management projects. However, it would be preferable if 

the DEIS aquatic analysis more thoroughly combined the results of 

the modeling contained in the SERA risk assessments with other 

specific information when analyzing all potential treatment 

scenarios. 

The aquatic effects analysis has been 

clarified to respond to this comment. The 

SERA risk assessments represent the best 

available information. The interpretation of 

the risk assessment results is based on 

professional judgment. While the risk 

assessments do not necessarily predict the 

actual effects of herbicide use, they indicate 

the relative risk and severity of potential 

effects. The alternatives take the risk 

assessments into consideration in the 

selection of herbicides and standards for 

their use. At the project scale, the actual 

amount of herbicide use proposed can be 

specifically analyzed and adjustments made 

if the risk assessments indicate a cause for 

concern. The additive effect of multiple 

substances used in a watershed would be 

analyzed at the watershed scale when 

projects are proposed. It is not possible to 

completely analyze the potential effects of 

every possible combination at this Regional 

scale. A standard has been added to the 

FEIS requiring specific evaluation of 

mixtures at the project level prior to use. 

The actual effects are expected to be lower 

than those estimated in the SERA modeling 

because the standards require managers to 

reduce the risk of adverse impacts when 

selecting appropriate treatment methods. 

The inherent uncertainty of risk assessments 

is addressed in the document. Plausible 

exposure scenarios outside SERA risk 

assessments are not likely. The exposure 

scenarios used include herbicide entering 

water through erosion and run off, so 

potential risks from herbicide-sorbed soil 

particles are already accounted for. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-226 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

On page 4-128, the first two sentences of the third paragraph under 

"Direct and Indirect Effects" appear to be contradictory. The first 

sentence states that indirect effects to ESA-listed aquatic species 

would include changes to "...their riparian areas, food chain, and 

water quality." The second sentence states that "invasive plant 

treatment will not remove or degrade suitable habitat for any listed 

species." NOAA Fisheries agrees at least in part with the first 

sentence (there could be other indirect effects not mentioned), but 

the second sentence appears to be inconsistent with the first, and 

deleting it is recommended. Invasive plant treatments clearly have 

the potential to alter suitable habitat. The last sentence in the third 

paragraph on the following page makes the correct point - that 

adverse effects to listed species may occur, but the intended 

tradeoff is short-term adverse effects for long-term benefit. 

The first full sentence on page 4-129 is [deleted word] inconsistent 

with the statement that indirect effects to ESA-listed aquatic 

species would include changes to "their riparian areas, food chain, 

and water quality." It is true that the herbicides proposed for use in 

the DEIS do not tend to bioaccumulate or biomagnify, but that 

does not mean that other indirect effects will not occur, such as 

those stated above. 

The FEIS has been edited for clarity and 

accuracy in response to this comment. No 

direct effects on aquatic organisms would be 

expected from the invasive plant treatment 

program. Invasive plant treatments have the 

potential to indirectly affect riparian areas, 

the aquatic food chain, and water quality. 

However, if work is done according to 

standards proposed in the EIS, these effects 

are unlikely to result in significant adverse 

effects. Site-specific analysis will address 

the potential for these effects to occur, and 

mitigation will be applied at the project 

level to minimize any actual effect. 

Please provide some discussion of the influence of surfactants and 

other adjuvants on herbicide (i.e. active ingredient) toxicity to 

aquatic flora and fauna. This would include adding a discussion of 

how active ingredients toxicity endpoints are typically modified by 

surfactants and other adjuvants added to make formulations. 

The risk assessments included evaluation of 

the influence of surfactants on toxicity to 

aquatic organisms. When surfactant toxicity 

was a concern, analysis in the risk 

assessment was conducted using toxicity 

data from formulations that contained 

surfactant (e.g. SERA 2003 Glyphosate, p. 

4-39). Standard 18 requires that only 

formulations that have been evaluated in 

risk assessments may be used. 

Public comments expressed concern over potential effects of 

herbicide application to aquatic species (salmonids as well as other 

aquatic flora and fauna) and riparian area function. In addition, 

public concerns were raised about the fact that ESA listed salmon 

are present on a large portion of streams within National Forest 

lands within Region 6. Given those public concerns, NOAA 

Fisheries that "effects to aquatic systems" be considered as an 

"issue" within the DEIS. This could help consolidate effects and 

capture issues highlighted in this letter. 

The effect of herbicides on aquatic organism 

is an issue analyzed in the EIS. It is not a 

key issue because the effects do not vary 

significantly between alternatives. The 

evidence for the importance of effects to 

aquatic biota to the process can be found in 

the standards, goals, and objectives. 

Additionally, analysis continues as part of 

the ESA consultation process. 

The "uncertainty" discussion on page 4-108 touches on the topic of 

effects to aquatic fungi and unicellular organisms but dismisses 

effects as "...likely to be transient and localized" without 

supporting discussion or citations. NOAA Fisheries recognizes 

that this discussion stems from the FS SERA risk assessments, but 

does not believe that the modeling contained in the assessments 

fully appreciates the complexity and subsequent aquatic effects of 

projects that could result form implementation of the Proposed 

Action. 

The FEIS contains additional information 

about the effects on aquatic organisms. 

Effects on aquatic fungi and unicellular 

organisms are not well understood, however 

no data indicates there is a significant 

potential effect from the types of treatments 

contemplated. The SERA risk assessments 

considered exposure scenarios in both 

flowing and standing water. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-227 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

The aquatic cumulative effects analysis beginning on page 4-107, 

provides no discussion of the potential effects of herbicides to 

aquatic plants (macrophytes, phytoplankton, submerged aquatic 

vegetation, etc.) and the associated effects to the aquatic 

community (macroinvertebrates, zooplankton, fish, etc.). 

However, on the same page, two paragraphs before the 

"cumulative effects" section, seven herbicides contained within the 

Proposed Action are identified as potentially affecting aquatic 

plants. This contradiction should be removed. In addition, a 

general discussion of how mixtures of selective and non-selective 

herbicides (and their additives, to the degree known) might affect 

aquatic ecology should be provided. 

The aquatic cumulative effects section of the 

FEIS contains additional information about 

the effects on aquatic organisms. The 

characterization of an herbicide as 

“selective” or “non-selective,” has no 

relevance to potential effects to aquatic 

ecosystems, as these indistinct categories 

pertain to their effects on terrestrial target 

species. The potential effects of surfactants 

and active ingredients to aquatic plants and 

animals are discussed in the FEIS, 

supporting documents, and project files. 

Recent research conducted by NOAA-Fisheries has documented 

the startlingly significant impact of poor water quality on salmon 

recovery efforts in small urban streams. A number of agencies 

have found that streams, particularly those in developed areas, can 

carry a witch's brew of chemicals, including pesticides, herbicides, 

hydrocarbon compounds, heavy metals, and pharmaceuticals. This 

unnatural cocktail can make it impossible to recover salmon and 

steelhead dependant upon small urban streams, even where 

significant money has been spent to restore the stream 

characteristics more typically of interest (e.g., geomorphologic 

features such as pools, large woody debris, meanders, and riparian 

vegetation; and such water quality parameters as temperature, 

dissolved oxygen, and sediment). The same concerns must be 

considered with respect to increased use of herbicides (and other 

chemicals) on national forest system lands. Intensive field and 

laboratory studies by NOAA-Fisheries on Longfellow Creek near 

Seattle, WA, demonstrated surprisingly large effects on several life 

stages of coho salmon from degraded storm water in urban 

streams. The culprit appears to be the oil, grease, pesticides and 

other pollutants carried in storm water gurgling off streets, parking 

lots and roofs. Healthy, "ocean-bright" adults suffered significant 

pre-spawn mortality after entering the creek. Up to 85% of the 

total adult females in the run died before spawning, after initially 

exhibiting a loss in their ability to orient to the current and a loss 

of equilibrium. Preliminary testing of embryos exposed to 

unfiltered creek water showed a dramatic tendency to develop 

problems during development of their vascularization network, 

with a significant number of embryos failing to develop any blood 

vessels to the mid-brain. Modeling the effects of the adult prespawn mortality and embryonic fatalities on population dynamics 

in an otherwise healthy population of a size typical to many 

smaller tributary streams (i.e., approximately 300-600 individuals) 

produced preliminary results indicating that those two factors 

alone likely would lead to population extinction in 30-50 years. 

Pesticides can significantly impact fish survival and fitness. Many 

common insecticides block a brain enzyme called 

acetylcholinesterase (AChE), which hydrolyzes the 

neurotransmitter acetylcholine. 

The conditions discussed in this comment 

are unlikely to be affected by any of the 

alternatives. The use of herbicides to treat 

invasive plants is unlikely to contribute 

significantly to urban stream pollution 

because 1) the extent of herbicide use on 

National Forest is insignificant compared to 

the amount of use on private lands near 

urban streams; 2) monitoring of Forest 

Service herbicide use projects in the western 

U.S. has demonstrated that very few projects 

result in the inadvertent introduction of 

herbicides into adjacent waterways 

(Wofford et al. 2001, Rashin and Graber 

1993) and 3) most herbicides considered in 

this EIS would have only transient presence 

in the aquatic ecosystem. 

No insecticides are considered for use in this 

EIS so the discussion of AChE effects from 

insecticides is beyond the scope of the 

document. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-228 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

Chapter 4-we don't see a discussion of potential impact on insect 

larvae in the hyporheic zone (fish food). Perhaps a word or two on 

whether they are impacted or not would be helpful. 

Data on effects to insect larvae in the 

hyporheic zone is lacking. A summary of 

potential effects of each herbicide to aquatic 

invertebrates, based on available data, was 

included in the DEIS. 

I really hate to see the repeated heavy use of herbicides, the 

residue of which can negatively affect the natural balance under 

which our forests have thrived over the eons. I'm thinking 

particularly of our bird & fish populations, in particular the Coho 

salmon. 

Consultation with regulatory agencies has 

been initiated as required by the Endangered 

Species Act. Effects on special status 

species are discussed in the EIS. 

Furthermore, riparian zones should be off-limits to herbicide 

treatments or in compliance with Aquatic Conservation Strategies 

of the Northwest Forest Plan. 

Standards are proposed in all alternatives to 

ensure aquatic ecosystems are protected. 

The ACS does not require that riparian 

zones be off limits to herbicide treatments. 

The risk of adverse effects to riparian zones 

from invasive plants would be balanced with 

the risk from treatments at the project level. 

No herbicide should be used in or near water or riparian areas or 

near or within the high water mark of rivers, streams, irrigation 

canals and reservoirs. Even glyphosate, assumed to be one of the 

safest herbicides for riparian application poses known toxicity 

risks to fish and amphibians. 

None of the alternatives eliminate all 

herbicide use within riparian areas because 

some invasive plants, capable of degrading 

riparian habitats, can only be treated 

successfully with herbicides. Aquatic label 

herbicides can be used in riparian areas with 

minimal risks to aquatic species. This was 

carefully considered in the risk analyses and 

addressed in the proposed management 

direction. 

One formulation of glyphosate, applied at the highest application 

rate, could negatively affect fish. (DEIS 4-105). Which 

formulation? Negatively affect fish to what extent and which fish 

species? Enough to eradicate a species population or contribute to 

an up-listing trend? Is the use of the highest application rate 

possible either unintentionally or through an accidental spill? 

What is the threshold rate of application for negative effects? For 

lethal effects? Most critically, why is no alternative designed to 

avoid use of this glyphosate formula and thereby avoid these 

negative effects to fish? By not analyzing such issues in detail, 

public and decision-maker's knowledge of risks at stake is 

impaired and choices are not made obvious or available that could 

lead to a better decision. The NEPA process is intended to lead 

decision-making results that prevent potential environmental harm, 

not just mention a risk in passing. 

The FEIS has been supplemented in 

response to this comment. The formulation 

of glyphosate that could negatively affect 

fish is any formulation that includes POEA 

surfactants. With enough exposure 

(concentration and length), this formulation 

can be lethal to fish, thus a large chemical 

spill could harm listed fish. 

Alternative formulations of glyphosate that 

do not contain this surfactant are readily 

available and are labeled for aquatic use. 

These formulations are much less toxic to 

fish and may be used near streams. (See 

Standard 19.) 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-229 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

[Section 4.4] The Forest Service states that the concentration of 

several different chemicals (chlorsulfuron, dicamba, imazapic, 

imazapyr, metsulfuron methyl, picloram, sulfometuron methyl, 

triclopyr, and 2,4 D) could all reach harmful levels. The different 

alternatives include a different number of these haIn1ful 

chemicals, with Alternative B only using one of the above named 

chemicals and only treating the smallest percent of the riparian 

areas. However, the Forest Service concludes that even with the 

difference with respect to number of chemicals used and areas 

treated between the four alternatives, there would be no significant 

difference in the levels of risk to aquatic organisms. This 

conclusion does not follow logically because it only makes sense 

that the alternative that uses the least amount of chemicals on the 

smallest area of land would pose the least threat[.] 

Clarification has been added to the FEIS 

that the exposure scenarios that generated 

the list of herbicides that may adversely 

affect aquatic plants do not account for such 

factors as application method, timing, and 

site-specific conditions. Standard 19 

requires consideration of these factors to 

eliminate or reduce potential adverse effects 

for all alternatives. Alternative B has less 

potential for adverse effects in riparian 

areas, but all alternatives estimate minimal 

treatment within riparian areas, so potential 

adverse effects are not expected to vary 

significantly between alternatives. 

In section 4.4.1, the Forest Service states that many of the invasive 

plant treatment sites are less, than one acre in size. However, in the 

discussion of each alternative the total acres of projected treatment 

areas greatly exceed this number. Alternative B, which calls for 

the least amount of treatment with herbicides, calls for 2,539 acres 

treated annually. In addition, the Forest Service states that the 

spraying of these 2,539 acres poses only a negligible risk to 

wildlife in relation to the 24.9 million acres in the project area. The 

same conclusion was reached in the other three alternatives as 

well. This, conclusion however does not accurately measure risk. 

Instead, the cumulative effects of herbicide spray on the wildlife 

living in the area to be treated must be examined. The Forest 

Service again states in section 4.4.4 that a three percent increase in 

land treated with these herbicides in the project area will not cause 

a significant increase in adverse effects to wildlife. However, the 

animals that live exclusively in the areas treated with herbicide 

need to be considered. If the Forest Service fails to consider this, 

these animals run a high risk of being adversely affected. 

Direct, indirect and cumulative effects from 

invasive plant management on wildlife are 

discussed in the EIS. The total acres of 

herbicide use are for the entire two-state 

region. No animals are known to live 

exclusively in areas inhabited by target 

invasive plants. 

The Forest Service also has not included any information as to the 

likelihood of one of the worst-case scenarios to occur. Within the 

DEIS the Forest Service generalized that it is unlikely that a worst 

case scenario accident would occur but it does not adequately 

present any estimation has to how unlikely that specific scenario 

actually is. When the Forest Service discuss alternative D it 

includes a statement regarding the potential for a huge mortality in 

amphibian populations if an accidental spill were to occur due to 

the lethal dose of 2,4-D an herbicide proposed for use in 

Alternative D. It fails, however, to calculate the possibility that an 

accident is likely to occur. It is important that the Forest Service 

assess all potential occurrences when it works on a proposed 

action that could have serious consequences for large populations 

of aquatic species. 

Accidental spills are unpredictable and their 

likelihood was not quantified. Standards are 

proposed to reduce the risk and severity of a 

spill. The potential for adverse effects to 

wildlife is one reason certain herbicides 

would not be approved for use in the 

Proposed Action and Alternative B. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-230 

Table 43. Comments and Responses about Effects on Aquatic Organisms

Comment Response 

Also not discussed in the EIS is the moderate to high toxicity of 

triclopyr BEE (eg. Garlon 4) to aquatic species, based on test 

results for toxicity to frog tadpoles, trout, salmon, bluegill and 

daphnia, at least four of which exist as native species in Region 6 

that could be affected (see Profile, p.6). The lack of tests for acute 

and chronic toxicity of triclopyr to wildlife mammals was also not 

considered in the EIS. (Profile p.6). 

The toxicity, dose/response data, and 

potential for exposure of triclopyr BEE to 

aquatic organisms were assessed in the 

SERA 2003-triclopyr. The risk assessments 

used data from laboratory tests and field 

studies. The DEIS accurately reported the 

results of the triclopyr risk analysis. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-231 

Effects on Species Listed under the Endangered Species Act

Several commenters mentioned the Endangered Species Act (ESA) and effects on listed 

species. In response, the FEIS clarifies the difference between anticipated adverse effects 

from project implementation and the “likely to adversely affect” determination required by 

the ESA. Some factual corrections were made to the FEIS analysis in response to comments. 

Table 44. Comments and Responses about Effects on Species Listed Under The ESA

Comment Response 

Why is the Forest Service not considering specific herbicide 

application restrictions to protect TES species as the EPA 

requires? (See p.4-110, last par.) 

Standards 19 and 20 provide appropriate 

management direction at the Regional Scale. 

Design criteria would be developed at the 

project scale protect special status species 

that may be affected by specific projects 

The Invasive Plant DEIS incorrectly states that Arabis 

macdonaldiana (protected under the Endangered Species Act) is 

not likely to be affected because its habitat (on ultra-mafic soils) 

is not prone to the introduction of invasive species. This may 

not be correct if the habitat is subject to disturbance such as fire 

or off highway vehicles. 

The ESA determinations are subject to the 

biological assessment and opinion process. 

Site-specific consultation documents would 

more accurately reflect threats at the project 

scale. 

A biological assessment should have been completed and 

incorporated within the DEIS. 

NEDC is particularly concerned about the potential impact on 

rare plant species mentioned in the DEIS. DEIS at 4-35. The 

DEIS lists 14 federally listed plant species. The Forest Service 

requested a list of threatened or endangered plants and animals 

pursuant to Fish and Wildlife Service regulations, but the agency 

does not discuss whether it completed formal or informal 

consultation, as required by the Endangered Species Act. 16 

U.S.C. [section] 1536(a)(2); 50 C.F.R. [section] 401.12. The 

agency notes that invasive species are currently adversely 

affecting threatened and endangered plants and animals, but 

makes no determination whether the invasive species plan itself 

will affect these species. DEIS, 3-52. Further, the Forest Service 

fails to determine the effect of the plan on critical habitat. 50 

C.F.R. [section] 402.12(f). Failure to complete at the very least a 

biological assessment, if not a biological opinion due to the 

duration and potentially wide-ranging effects of this proposal, 

violates the Endangered Species Act. 

The biological assessment (BA) is a 

consultation document required under the 

Endangered Species Act. It is on a different 

timeline than the EIS, by definition, a 

preferred alternative must be identified 

before a BA can be completed. Thus, the 

BA was not complete by the time the DEIS 

was available for comment. However, 

information relevant to the NEPA process 

from the BA was in the DEIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-232 

Table 44. Comments and Responses about Effects on Species Listed Under The ESA

Comment Response 

It is clearly stated in the Invasive Species Plan DEIS that the 

Forest Service is lacking available research into listed species 

under the ESA. The uncertainty regarding herbicide exposure or 

proximity of disturbance prevents the Forest Service from 

making any determination regarding the effects of the proposed 

project on the listed species. The ESA requires that the best 

available scientific and commercial data be used to assess the 

impacts of the proposed project on these sensitive species. 16 

U.S.C [section] 1536(a)(2). The Forest Services is required to 

show that it has used the best science available to them including 

surveying the area for the species that are of particular concern, 

studying the impacts that use of herbicides could have on 

habitats and systems of the listed species, and the overall impact 

to the species themselves. The Invasive Species Plant DEIS fails 

to do any of the above and therefore has not followed through 

the requirements under the ESA. 

The DEIS properly used and identified the 

best science available for assessing risk to 

wildlife, including federally listed and 

proposed species. Analysis in the DEIS was 

conducted at a scale appropriate to the scale 

of the decision to be made (e.g. the plan 

level). Appropriate determinations 

regarding potential effects to listed species 

were made, supported by scientific 

information, and reviewed by consulting 

agency personnel. 

There are major concerns that endangered fish species are all 

listed as "likely to be adversely affected" by the proposed action.

We should not risk our forest health to an onslaught of 

chemicals with such telling facts as all endangered fish species 

are listed as "likely to be adversely affected" by the proposed 

alternative. 

We are very concerned that all federally listed aquatic species 

are "Likely to be Adversely Affected" (Table 4-45) and that 

habitat for all commercially important fish species may be 

adversely affected (Table 4-47)! We are also concerned that 

almost all sensitive-listed fish species may have individuals 

adversely affected. We are not satisfied that this would not lead 

to a trend toward federal listing. (re: Table 4-46). 

The FEIS clarifies the difference between 

anticipated adverse effects from project 

implementation and the “likely to adversely 

affect” determination required by the ESA. 

Actual adverse effects during project 

implementation are expected to be rare, 

therefore adverse effects will be minimal. 

However, even one adverse effect for one 

future project results in the “likely to 

adversely affect” determination statement. 

The frequency and scale of adverse effects 

anticipated is further discussed in the 

Biological Assessment. This determination 

statement is appropriate at the Regional 

scale because all alternatives have potential 

to affect listed and sensitive species. 

However, at the project scale, potential 

effects will be more precisely analyzed and 

adverse effects will be avoided or 

minimized as required by Standards 19 and 

20. The risk of adverse effects to fish and 

other wildlife from invasive plants would be 

balanced with the risk from treatments at the 

project level. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-233 

Table 44. Comments and Responses about Effects on Species Listed Under The ESA

Comment Response 

The Draft EIS does discuss negative impacts of riparian weeds 

on the threatened aquatic plant Howellia aquatilis, but no 

mention is made of likely, severe, direct impacts caused by 

infestations of aquatic, invasive weeds. If this species is to 

remain viable, then such infestations need to be prevented and/or 

detected early enough that appropriate management techniques 

can be implemented. 

Aquatic invasive plants are beyond the 

scope of this EIS because: 

 1) The purpose and need is focused on the 

need for invasive plant management within 

upland and riparian areas; the need to 

manage aquatic plants is not as evident 

within Region Six; 

2) The conditions, treatments and issues are 

different for aquatic invasive species; 

3) The Forest Service does not have 

expertise in dealing with aquatic invasive 

species; 

4) Aquatic invasive species are managed by 

the States. 

Aquatic invasives are addressed on a caseby-case basis by individual National Forests 

as needed via coordination with state and 

other agencies with expertise and 

responsibility in this area. 

The habitat type listed for Howellia aquatillis in Table 3-8 is 

"vernal wetlands." This term is not generally not used on the 

west coast and thus needs clarification. The more commonly 

used term is "seasonal wetland." Use of the term "vernal 

wetlands" could lead to confusion with a unique type of wetland 

found only on the west coast of the US, the vernal pool. Vernal 

pools are seasonal, depressional wetlands that occur under the 

Mediterranean climate conditions of the west coast. They are 

covered by shallow water for variable periods from the winter to 

spring, but may be completely dry for most of the summer and 

fall. Vernal pools are underlain with bedrock or a hard clay layer 

that helps keep water in the pool. They are home to a suite of 

unique plants and animals many of which are rare endemics. 

Corrections have been made to this table in 

FEIS Chapter 3. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-234 

Cumulative Effects

This set of comments relate to how cumulative effects were addressed in the document. Most 

of the comments questioned whether repeated use of the same or different herbicide 

formulations might accumulate in the human body or in the ecosystem. 

These comments resulted in further explanation supporting the conclusion that the herbicides 

considered for use in the alternatives do not bioaccumulate. 

Table 45. Comments and Responses about Cumulative Effects

COMMENT RESPONSE 

Cumulative effects about fire. There should include a 

statement about multiple disturbances in the same place, 

i.e., fire and salvage will increase invasive plants more 

than either alone. 

The DEIS addressed this in Chapter 3.1.2 

under the section entitled, “The Role of 

Disturbance in Invasion.” 

The EIS should have analyzed cumulative effects on 

streamside vegetation. Cumulative effects analysis is a 

requirement of NEPA and riparian areas get the highest 

use of both wildlife and recreationists. 

The DEIS discussed the effects of invasives 

and invasive plant treatments on riparian 

habitats and aquatic organisms in several 

places in Chapters 3 and 4. 

Cumulative effects need to be fully analyzed re: the 

multiple exposures and multiple herbicide exposures 

possible across multiple ownership boundaries for farranging federally and state-listed species. (see p.4-121) 

Chapter 4-55: "Even the highest use estimates of 

herbicide from Alternative D would amount to only about 

three percent of the total acres treated with herbicides in 

Oregon and Washington." As our experience now 

shows, the use of the proposed chemicals, including 2,4-

D do not currently exhibit any direct adverse wildlife 

effects in the Pacific Northwest. Therefore, a 3% 

increase in use will not increase any adverse effects. 

Cumulative effects are discussed throughout 

Chapter 4 of the EIS. Potential effects from 

off National Forest do not vary between 

alternatives. The likelihood that animals 

would also be exposed to chemicals used on 

National Forest is low because the extent of 

treatment proposed in all alternatives is 

comparatively small (estimated at 3 percent or 

less of total acres of herbicide use). 

Application of Standard 20 at the project scale 

would reduce the risk of cumulative exposure 

on and off National Forest. 

[The DEIS states:] "Herbicide exposure from invasive 

plant projects is unlikely to add to, or accumulate with 

herbicide exposures from other projects." Why not? 

Each herbicide was evaluated for its ability to 

accumulate within the bodies of exposed 

animals by reviewing the bioconcentration 

factor and the time required to eliminate an 

administered dose. No herbicides considered 

in the DEIS are stored in fatty tissue, they do 

not accumulate up the food chain, and they are 

eliminated from the body very rapidly (often 

within hours of exposure). Since an exposed 

dose is eliminated from the body within hours 

of exposure, the likelihood that another 

exposure would occur to that animal before 

the herbicide is eliminated is remote. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-235 

Table 45. Comments and Responses about Cumulative Effects

COMMENT RESPONSE 

The DEIS also fails to address the cumulative impacts of 

repeated herbicide use, Forest Service use of herbicides 

on top of private herbicide use and herbicide use impact 

in combination with other impacts to wildlife and native 

plants (especially Endangered, Threatened, Sensitive and 

rare species) or to human health and drinking water and 

crops (affected by accidental spills, worker and public 

exposure, toxins leaching through soils into the water 

table and aerial spray drift contamination, etc.) 

The cumulative effects analysis considers use 

of herbicides on and off National Forest. 

The DEIS is lacking needed specific analysis of chronic 

and long-term effects of repeated use of herbicide 

formulas in the same area over time--especially 

cumulative effects on native plant, insect, amphibian, 

aquatic and terrestrial wildlife populations and soil 

fertility and productivity over time--including use of 

multiple formulas over years. For instance, the DEIS 

acknowledges planned annual use of herbicides in 

riparian areas but does not analyze the effects from 

annual application as opposed to single, one-time 

application. 

The cumulative effects of repeated use of 

herbicides are discussed in Chapter 4. If an 

area needs re-treatment, herbicides would no 

longer be active in the soils. The herbicides 

considered in the alternatives do not 

bioaccumulate or remain active in the soil over 

a period of years. 

Based on the information provided, we [EPA] are rating 

the DEIS as EC-2 (Environmental Concerns-Insufficient 

Information). The Forest Service has done a good job of 

organizing and presenting information on this complex, 

multi-dimensional subject. Generally, the DEIS discloses 

the uncertainties and shortcomings of the state of 

knowledge about invasives control, particularly via 

chemical means. In light of the uncertainties, the DEIS 

may not adequately support some of the stated 

conclusions regarding lack of effects from herbicide 

treatments, such as soil productivity, and the cumulative 

effects over time resulting from continued herbicide 

applications. 

Precise impacts cannot be predicted at this 

programmatic scale. In light of uncertainties, 

the Forest Service has taken a cautious 

approach to the use of herbicides. This caution 

is demonstrated through selection of 

herbicides and strict standards for their use. 

The effects analysis considers worst case 

scenarios, management direction that would be 

adopted in the Forest Plans would tend to 

reduce the actual effects. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-236 

Table 45. Comments and Responses about Cumulative Effects

COMMENT RESPONSE 

[Section 4.3] In addition to failing to provide scientific 

data to support its conclusions, the Forest Service also 

fails to consider the cumulative impact herbicide use will 

have on non-target plant species. Cumulative impacts are 

the impacts resulting from "past, present, and reasonably 

foreseeable future actions regardless of what agency 

(Federal or non-Federal)" takes the action. 40 CFR 

1508.7. Herbicides have been used historically by the 

Forest Service (the No Action alternative would simply 

work as a continuation of its herbicide intensive historical 

management techniques) and by landowners. The long 

half-lives of some of the chemicals discussed in the DEIS 

increase the likelihood that there will be harmful 

cumulative impacts on the native plants community. For 

instance, glyphosate has a half-life of between 3 and 130 

days, according to a fact sheet prepared for the U.S. 

Department of Agriculture and the Forest Service. 

(Available at infoventures.com). Picloram has a half-life 

of 30 to 90 days, according to the same source. Both of 

these chemicals are part of the proposed alternative. To 

comply with NEPA, the Forest Service must take steps, 

including consideration of the persistence on each 

chemical in the environment, to consider the cumulative 

impacts that these chemicals will have on non-target plant 

communities. The Forest Service cannot simply consider 

the impact of one application of an herbicide on a 

particular species. 

The DEIS considers cumulative effects 

adequately to determine the effects of 

alternative management direction. The 

evidence based on detailed risk assessment 

does not support a conclusion that “there will 

be harmful cumulative impacts on the native 

plants community.” 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-237 

Table 45. Comments and Responses about Cumulative Effects

COMMENT RESPONSE 

Cumulative Impacts [Section 4.2] This section fails to 

adequately consider the cumulative impacts of each of the 

alternatives. Wouldn't alternative B for example better 

address potential cumulative impacts of road construction 

than the proposed action? 

If the decorative use of invasive plants by people living 

adjacent to the forest will impact the effectiveness of the 

alternatives, why do none of the alternatives consider 

public education on the effect of invasive species on 

forest health? 

 What about the cumulative impact of continued use of 

the same herbicides or the use of multiple herbicides? 

Doesn't the cumulative impact depend on types of 

herbicides used? How would the preventive measures of 

Alternative B reduce cumulative impacts of repeated 

sprayings? 

The DEIS acknowledged that Alternative B 

has the greatest potential to reduce the spread 

of invasive plants. Closing or 

decommissioning roads, minimizing the 

construction of new roads and minimizing the 

improvement or widening of existing roads are 

viable means of preventing invasive plants 

because these measures would reduce ground 

disturbance and eliminate the potential for 

vehicles to spread seed. 

The DEIS addressed public education as a 

Forest Plan objective in all alternatives. 

Public education programs are not subject to 

NEPA. 

The DEIS addressed the effects of repeated 

use of herbicides. It disclosed that Alternative 

B would result in fewer potential direct, 

indirect and cumulative effects to human and 

animal health from herbicides. The DEIS also 

disclosed that Alternative B would reduce the 

rate of spread, and therefore the amount of 

acreage needing treatment. The FEIS further 

discusses the cumulative effectiveness of 

Alternative B, finding that: Alternative B is 

the most effective in the use of prevention 

standards to reduce rate of spread, but the 

limited number of herbicide options would 

makes control of the current infestation 

impossible without a significant reduction in 

the rate of spread (50% or more). It is 

unlikely that the suite of prevention standards 

proposed in Alternative B would have a 

greater impact on the spread of invasive 

plants. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-238 

Table 45. Comments and Responses about Cumulative Effects

COMMENT RESPONSE 

The DEIS works around weak science again when it 

states that "[b ]ecause of data gaps: [risk] assessments 

rely heavily on extrapolation from short-term effects to 

conclusions about long-term effects." DEIS at 3-94. Such 

extrapolation is the basis for the conclusion in the DEIS 

that the risk of cumulative effects on human health is 

negligible because "most of the [proposed] herbicides do 

not bioaccumulate in humans... and they persist in the 

environment for a relatively short time (generally less 

than I year)." DEIS at 4-81. The vague terms like "most," 

relatively" and "generally" in this statement, undermine 

the scientific thrust and the "explicit reference by footnote 

to the scientific and other sources relied upon for the 

conclusions in the statement" required by NEP A. 40 CFR 

1502.24 appears to be lacking. Absolute certainty is 

impossible but the need for more than assumptions and 

limited extrapolation as to the cumulative effects is 

necessary in such a situation where repeated sprayings of 

herbicides in varying combinations are projected to last a 

minimum of 18 years depending upon the chosen 

alternative. DEIS at 4-17.The DEIS is too quick to 

conclude that the impacts of the proposed herbicides on 

human health will be "insignificant." It relies heavily on 

unreasonable comparisons to other unreliable issues and 

not heavily enough on scientific data. 

Use of risk assessments is not considered 

weak science. The DEIS acknowledged the 

uncertainty in risk assessment and 

extrapolation, however no other viable 

approach exists. 

The rationale behind the cumulative human 

health effects analysis is clearly disclosed and 

does not rely on unreasonable comparisons or 

unreliable issues. The agency used accepted 

scientific practices to analyze the risks 

associated with the alternatives. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-239 

Partnership, Coordination and Public Education

Many people expressed interest in collaborating with the Forest Service in addressing the 

invasive plant problem in the Northwest. Commenters recognize that the weeds do not 

respect political boundaries and landowners and agencies must work together to be successful. 

The Forest Service welcomes opportunities to work with groups such as those mentioned in 

these comments. Public information programs, publications, and other educational efforts 

would complement all alternatives in the EIS. The Forest Service strongly endorses and 

supports partnerships and collaboration and agrees that coordination with states, tribes, other 

landowners, and others will be necessary for success of the projects developed and 

implemented under any alternative. Educational programs are not subject to NEPA and are 

thus not the specific focus of the analysis. The decision whether or not to employ volunteers 

(or others) to accomplish work is also not subject to NEPA. 

Table 46. Comments and Responses about Partnership, Coordination and Public Education

Comment Response 

Even though the Oregon Department of State Lands (ODSL) 

may technically have jurisdiction over navigable waters 

within the state, the US Forest Service has typically not 

recognized the state of Oregon's claims to submerged lands, 

which lie within National Forest boundaries. Further, the 

ODSL must do a navigability study before ownership can be 

asserted or denied. ODSL currently has no funds specifically 

identified or allocated for aquatic weed removal. These lands 

and, thus, the aquatic habitat they provide appear to be in 

limbo as far as coordinated management of aquatic weeds. 

Treatment of aquatic weeds is outside the 

scope of this EIS (see Chapter 1, what is not 

included). Aquatic invasives would be 

addressed on a case-by-case basis by 

individual National Forests as needed via 

coordination with state and other agencies 

with expertise and responsibility in this area. 

Even though the proposed action in this Draft EIS applies only 

to on the ground actions on Forest Service lands, I am 

somewhat concerned about the Forest Service going it alone 

on this document since one of the most critical factors in the 

war on invasive plants is coordination between all affected 

agencies at all levels of government and the public. As 

pointed out in the document, invasive plants are unaffected by 

property lines. Implementation will certainly require 

consultation, cooperation, and coordination among various 

agencies and the public. It could even be confusing to the 

public that some agencies have noxious weed programs while 

others have invasive plant programs. 

I hope it is not meant to be a comprehensive plan for halting 

invasive plants on Forest Service lands because it is not. Most 

notably it does not discuss Forest Service interagency efforts. 

FEIS Appendix I addresses the Regional 

strategy for supporting invasive plant 

management on State and private lands. Goal 

5 for all action alternatives would expand 

collaborative efforts between the Forest 

Service, our partners, and the public to share 

learning experiences regarding the prevention 

and control of invasive plants, and the 

protection and restoration of native plant 

communities. 

The Forest Service will continue to work with 

other agencies and groups to educate and 

communicate with the public and reduce 

confusion. 

Section 4.2 of the DEIS specifically discussed 

interagency efforts, partnership and 

collaboration. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-240 

Table 46. Comments and Responses about Partnership, Coordination and Public Education

Comment Response 

There should be a single interagency "noxious weeds hotline" 

or website so the public can report invasive plant occurrences 

because the eyes of all public employees are not enough when 

it comes to trying to track the spread of invasive plants. 

Education and notices at trailheads can make more people 

aware of the problem. Even going as far as putting leaflets on 

windows shields can go a long way in helping with the 

education of invasive weeds. 

Public education into this problem and how weeds are spread 

is an important aspect. 

Similarly the F.S needs to educate "users" as to the factors that 

encourage invasive weeds on Nat. Forest Lands. 

The Forest Service welcomes opportunities to 

work with groups such as those mentioned in 

these comments. Public information programs, 

publications, and other educational efforts 

would complement all alternatives. 

Educational programs are not subject to NEPA 

and are thus not the specific focus of this EIS. 

It is important that all governmental agencies address this 

problem on an ongoing cooperative basis i.e. the National 

Forest, BLM, Indian Reservation Lands, county, city 

government as well as the National Park system. If weeds are 

not controlled in all areas it makes a patchwork system of 

control ineffective. 

Working with neighbors is an important part of the program. 

These may be private landowners with inholdings, county 

weed control authorities and state weed control authorities 

(Washington State Noxious Weed Control Board and the 

Oregon Department of Agriculture). 

Goal 5 for all action alternatives would expand 

collaborative efforts between the Forest 

Service, our partners, and the public to share 

learning experiences regarding the prevention 

and control of invasive plants, and the 

protection and restoration of native plant 

communities. 

Uniform policies need to be implemented on all national 

forests within the region and the individual forest plans need 

to be updated for the use of effective herbicides. The region 

will have to instruct and review to make sure this will be 

done. Again, private, state/county, and federal land 

landowners or agency representatives need to join hands and 

co-operatively work together. 

Remember the general public is a major source of the problem 

in the spreading of invasive weeds on private land. Private 

landowners shouldn't have to pay the price when their lands 

are open for use by the general public. Federal grants, 

partnership funding, etc. should be used to provide funding for 

many projects on private lands being used by the public. 

Many of these lands join one another. You fight a losing battle 

if only one party is involved in treatment of these invasive 

weeds. 

The DEIS acknowledged the value of 

standards that would be applied consistently 

across the region. Goal 5 for all action 

alternatives would expand collaborative efforts 

between the Forest Service, our partners, and 

the public to share learning experiences 

regarding the prevention and control of 

invasive plants, and the protection and 

restoration of native plant communities. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-241 

Table 46. Comments and Responses about Partnership, Coordination and Public Education

Comment Response 

Establish educational programs (pamphlets, signage) targeted 

at OHV users enabling them to be more aware of the impact 

they cause would also be key in preventing further infestations 

and habitat degradation. We suggest developing these 

materials with input form the targeted audience. Information 

should be posted at trailheads and staging areas re the 

importance of cleaning your boots, clothing and coats of pets 

and livestock. The same for OHV staging areas and 

campgrounds. 

Education of the workforce and the public and 

effectively working with neighboring 

landowners in all aspects of invasive plant 

management are among the goals common to 

all action alternatives. These programs are not 

subject to NEPA. 

Locally, a weed pull that started with coffee for all and ended 

with free lunch was extremely successful in terms of number 

of weeders and amount of weed pulling. If there's any way the 

Forest Service could use volunteers in such a manner, it might 

make it less likely that chemicals would be used. 

Volunteer resources such as the Youth Conservation Corps, 

the boy scouts and girl scouts, interested non-profit 

organizations, local community groups and others including 

appropriate high school and college class field trip 

opportunities should be suggested with contact information by 

state and local area to aid in finding adequate numbers of 

people for the manual labor involved. Otherwise 

overburdened resource managers are not likely to take the 

time to familiarize themselves with the specific control 

parameters of the invasive plants or to find adequate labor to 

consistently do manual control. 

The FS is already involved in many [collaborative efforts]. 

Perhaps instead of focusing on expansion of efforts, FS should 

play a more active part in those efforts already existing. 

Please focus on implementation of higher priority strategies 

on national forest lands. At present, many collaborative 

efforts have holes in their agreed upon strategies where Forest 

Service lands require active treatment. 

The Forest Service welcomes opportunities to 

work with groups such as those mentioned in 

these comments. Development of volunteer 

programs and local partnerships would 

complement all alternatives. These programs 

are not subject to NEPA and are thus not the 

specific focus of this EIS. 

Also, back in your collaboration paragraph (see right above), 

you do mention states. It would seem good to have a program 

that coordinates with state (and state-governed private) forest 

lands, as well. And let us not forget tribes with major timber 

holdings right on their reservations, like Yakima or Quinault. 

Let us not have a crazy quilt of plans that go back and forth 

with land ownership. The weeds don't respect political 

boundaries. We look at Par. 2.5 wherein the service will likely 

make an internal response to "Under what circumstances and 

management restrictions should herbicides be used to treat 

invasive plant infestations?" If you make that decision 

unilaterally, you may drag heels or take a course of action that 

adversely impacts adjacent or downstream lands. That is an 

illustration of how it becomes imperative to have a viable 

working relationship with neighboring entities. 

Coordination with Native American tribes, 

other federal and state agencies, neighbors and 

other groups and individuals will be necessary 

for success of the projects developed and 

implemented under any alternative. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-242 

Table 46. Comments and Responses about Partnership, Coordination and Public Education

Comment Response 

The proposal to use state contracting authorities is a recipe for 

poor compliance. The state does not have either the ecological 

expertise or the authority to control contractor spraying on the 

National Forests as described in the EIS, other than to require 

that label directions be followed. Furthermore, the Department 

of Agriculture (DOA) offices are located many miles from the 

Forest, and it is unlikely that the myriad problems associated 

with controversial projects will be resolved in a timely 

manner. While there is some merit in the idea to use DOA 

authority for investigations and enforcement, as stated in the 

EIS, the proposal to transfer and dilute your authority to lower 

state standards is not a good idea. Instead, what is really 

needed is oversight authority that insures interagency 

compliance. 

The Forest Service would retain primary 

responsibility to comply with applicable laws, 

regulations, policies, standards and guidelines. 

None of the alternatives would “dilute Forest 

Service authority” or “lower standards.” 

To improve the overall effectiveness of the proposed action, it 

should include cooperation with state departments of 

agriculture, county weed control programs and weed districts 

to address statewide and local invasive plant issues. It should 

also reference state listed noxious weeds. 

The emphasis on working cooperatively with local, state, and 

other federal programs must remain strong regardless of the 

alternative selected. 

Efforts on prevention and education are included in Appendix 

I. We recommend strengthening the alternatives by explicitly 

including these and other efforts. A large number of 

publications are available from Noxious Weed Boards, etc., 

that could probably be cooperatively distributed without the 

need to develop new materials. Information on invasive plants 

can be provided in visitor centers, at trailheads and other 

locations. 

The Forest Service strongly endorses and 

supports partnerships and collaboration. 

Coordination with Native American tribes, 

states, other landowners, and other agencies 

will be necessary for success of the projects 

developed and implemented under any 

alternative. 

It [the proposed action] doesn't discuss education and public 

involvement. Education of all Forest Service employees, and 

the public, in invasive plant identification is very important. 

There has been a knapweed infestation in the Asahel Curtis 

picnic area on the Mt. Baker-Snoqualmie NF for several years 

but nothing has been done even though Forest Service 

employees walk through the knapweed, possibly daily, to 

empty trash cans and perform other maintenance. The picnic 

area is used by many people as a rest area, so it is acting as a 

seed distribution site. 

This comment acknowledges the need for 

education and raising awareness of Forest 

Service employees as well as others to prevent 

spread of invasive plants. This should occur 

regardless of alternative selected. Training of 

employees is not subject to NEPA and thus is 

not the focus of this EIS. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-243 

Tribal Concerns

A spokesperson for Native American tribes reviewed the EIS and commented about the way 

tribes were discussed. These comments led to corrections in references to Native American 

tribes in the FEIS. Native American tribes are considered as important partners, neighbors, 

and stakeholders in invasive plant management on National Forest lands. The tribes were not 

referenced in some important places in the DEIS; this inadvertent omission has been corrected 

in the FEIS. 

Table 47. Comments and Responses about Tribal Concerns

Comment Response 

Chapter 1 Page 15. In conflict with later sections (fortunately, 

see paragraph on 3-71), this paragraph on tribal/treaty rights 

fails to mention the off-reservation treaty rights of the tribes 

with Stevens Treaties-most of Western Washington and large 

areas of Eastern Washington. The off-reservation rights and 

ownership in fish, plants, and wildlife are derived from the 

treaty as well (and are legally alive and well), but are not part 

of trust lands (a special category of land comparable to a 

reservation even if not contiguous), so not covered by the 

paragraph on 1-15. We are attaching a map that is a little out 

of date (some tribes have since negotiated larger areas through 

evidentiary hearings); however, it illustrates well just how far 

the off-reservation rights extend beyond the relatively small 

reservations or trust property. Note that there is a huge 

overlap of tribes' ceded areas (with treaty rights) with USDA 

FS lands. The federal courts consider the forest service lands 

to be "open and unclaimed" for purposes of tribal exercise of 

off-reservation treaty rights. This page 1-15 paragraph occurs 

before that of page 3-71 and makes the first impression. Few 

will know it is wrong and will begin reading with the thought 

that tribal rights are limited to reservation and trust lands. We 

are very concerned about distribution of misinformation. It is 

so hard to undo. This misperception must get corrected in the 

EIS. However, to educate the non-tribal readers, it would be 

good to flag that correction with a comment in your cover 

letter to the EIS. 

The FEIS Chapter 3 was revised to address 

this concern. 

Chapter 2, page 5: In Table 2-2, your IPM strategies do not 

appear to include tribal planning pursuant to EO13175. It 

looks as if once again, tribes are lumped with the general 

public (see first bullet). Yes, tribes are smaller governments, 

but they have treaty rights and such preliminary involvement 

is the law. Remember that tribes have local biological 

knowledge, as well. They are often experts in local plant life; 

perhaps, in some circumstances, beyond the local FS 

expertise. Tribes also have expertise in the local fishery and 

wildlife issues, and can help greatly in planning actions 

regarding herbicides. Consulting them in a timely fashion 

(before general public action) can only benefit both parties, 

even if this were not the law (but it is). 

Native American tribes are considered as 

important partners, neighbors, and 

stakeholders in invasive plant management on 

National Forest lands. The FEIS has been 

revised to address this concern. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-244 

Table 47. Comments and Responses about Tribal Concerns

Comment Response 

Chapter 3, page 1, definition of "weed," as a plant growing 

where not "wanted," even when native. Not wanted by whom? 

Only the landowner? Remember those tribal off-reservation 

rights. We have a real problem with this one. If a culturally 

important and increasingly rare plant like bear grass grows 

where someone does not want it, would you authorize 

removal? For a document of this magnitude, we suggest you 

find a better definition. Something needs to be added about 

exceptions, in your developing protocol. Landowners must not 

be autocratic about this. 

The term “weed” is defined in comparison to 

“exotic,” “alien,” “non-native,” “invasive 

plant,” and “noxious weed” to help the reader 

better understand the meanings behind the 

words and how terms are used or misused. 

This EIS is an invasive plant program , thus 

the strategies and analysis are based on the 

given definition for “invasive plant” and not 

that of “weed.” Tribal consultation would 

occur at the site-specific treatment level to 

ensure that culturally important plants are 

considered. 

Chapter 3, page 3-71. This Treaty Rights paragraph is 

politically correct and the rest of the document needs to be in 

line with it. [How did you get such disparity? Different 

authors?] However, also recognize, technically (as you do in 

other parts of this DEIS), that invasive plants don't just 

"influence" fish/wildlife "behavior". In some cases, they can 

ultimately severely harm it by killing the RMZ or replacing 

food preferences. We would change "influence" to "impair" or 

"harm" or something stronger. And change "behavior" to 

"population numbers." More than behavior is impacted. 

Wording adjustments have been made in the 

EIS to address these concerns. The disparity 

was inadvertent. 

Table 3-11 on off-reservation rights. Just a legal technicality, 

but you may want to rename the table as "Tribes and Offreservation Rights," rather than "Tribes and Treaty Rights" 

because, e.g., Colville's off-reservation rights are by Executive 

Order, not Treaty. Not sure why you have "of the Quileute 

Reservation" after the name "Quileute Tribe." To our 

knowledge, that is added language. What is the source? Also, 

typo: delete "Tribe" in number 28, as an extra word. 

Wording adjustments have been made in the 

EIS to address these concerns. Tribal names 

were provided by the Regional Tribal 

Government Staff Assistant. 

Chapter 2 Page 16, Objective 5.2: How can you talk about 

collaboration with federal, state, local and private land 

managers, and leave out tribes, when talking about native 

plants? We find it amazing that the FS would talk things over 

with cities, however small, but not tribes. (Or did the drafters 

think tribes were "local governments" and thereby covered? 

Local governments are subsets of the state, and tribes are not 

subsets of the state.) 

Native American tribes are considered as 

important partners, neighbors, and 

stakeholders in invasive plant management on 

National Forest lands. The DEIS 

inadvertently left off mention of the tribes. 

This oversight has been amended in Chapter 2.

Chapter 2, Page 16, Par. 2.4.2: Are the drafters of this DEIS 

aware of other monitoring protocols out there, developed by 

REO with the tribes, for example, and even local MOU’s 

(such as with Olympic National Forest and Quileute), 

regarding monitoring? This DEIS needs to be sure it 

integrates with such other documents appropriately. 

The drafters of the DEIS were aware that other 

monitoring protocols and agreements exist. 

This was addressed in DEIS Appendix M 

under “Assumptions.” 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-245 

Table 47. Comments and Responses about Tribal Concerns

Comment Response 

Chapter 1 page 9: There are references throughout the 

document to scoping with tribes. We frankly do not recall a 

time when the FS came out to our tribe [Quileute Indian 

Tribe] and said that the agency was about to do a DEIS on 

weeds, and ask our opinion. We got the CD ROM in its 

completed form. As required under Executive Order 13175, 

preliminary consultation is required, for actions of federal 

agencies that can impact tribes. Please recognize: Tribes are 

not members of the general public. Mostly around 1855 in 

Washington State, the US took quite a sizeable package of 

land, from which it later benefited hugely, in the case of each 

western Washington tribe. In return, besides the relatively 

small and exclusively held reservations, tribes reserved (this 

means kept as part of the trade; these interests never passed to 

the US) off-reservation rights to natural resources, including 

wildlife and vegetation of cultural and/or subsistence value. 

All court cases we have seen include the federal forests in 

these off-reservation lands wherein tribes have legal (treaty) 

rights to the living resources (not just fish). These offreservation rights make the applicable and affected Stevens 

Treaty Tribes co-owners of these resources (depending on the 

particular forest concerned). Because of 1) the co-manager 

relationship and 2) the EO 13175, tribes need to be brought in 

at the earliest planning stage. This is a co-tenancy; all cotenants must be involved in the planning stage, before general 

public viewing. 

The emphasis on working cooperatively with local, state, and 

other federal programs must remain strong regardless of the 

alternative selected. 

Native American tribes are considered as 

important partners, neighbors, and 

stakeholders in invasive plant management on 

National Forest lands. Native American 

tribes of the Pacific Northwest were sent 

initial project scoping letters during August of 

2002. Follow up contacts where pursued by 

the Invasive Plants EIS Team in July and 

August of 2003. Additional efforts to include 

tribes in invasive plant treatment efforts that 

may tier to this EIS are currently being 

pursued. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-246 

Glossary

One invasive plant professional reviewed the glossary and suggested several changes. These 

changes were generally adopted in the FEIS. 

Table 48. Comments and Responses about the EIS Glossary

Comment Response 

Glossary: "Fungi" are not usually classified as "plants" these days, except by 

members of the public or authors for field guides for that audience, re 

mushrooms and bracket fungi. You may want to be taxonomically more up to 

date. This is not a document for the general public, right? 

The FEIS glossary has been 

updated in response to this 

comment. 

Glossary: "Zooplankton" definition is more properly stated as "tiny aquatic 

animals that provide an important source of food for fish." So many other 

animals depend on them, too; not just fish. 

The FEIS glossary has been 

updated in response to this 

comment 

Glossary: Here and there are singular definitions for plural words and plural 

definitions for singular words. One area is "Enzymes" and see also 

"Controls". 

The FEIS glossary has been 

updated in response to this 

comment. 

Glossary: Some rhetorical fixes, such as changing "is" to "are" in line 6 of 

Allotted Lands ("acres are"). Under "Mitochondria", change "this" to "that" 

for the definition to make sense. 

The FEIS glossary has been 

updated in response to this 

comment 

Glossary: You do not define "plant", even though you use terms for agents 

that kill "plants" and refer to them under "Flora" and "Threatened Species". 

This is a tough one, but do you want to make a definition for this DEIS 

purpose only, and then say so? The popular conception includes mushrooms 

and fungi. Do you want to exclude fungi et al. from a plant definition and say 

why? You need to come up with something re "plants", and explain the 

exclusions or inclusions. 

The FEIS glossary has been 

updated in response to this 

comment. 

Glossary: "Mollusks". Fifty percent of your example does not have a 

calcareous exterior, and of those, slugs (no shell) are gastropods along with 

the snails. As you must know, Mollusca has a huge number of no-shell 

representatives (we think of not only of slugs, but also octopi, squids, and 

nudibranchs, for starters), so "usually" with respect to shells is probably not 

accurate, when speaking of mollusks overall (which you must be, since you 

refer to squids). Why not restate it as a "Phylum (major taxonomic group) of 

unsegmented, invertebrate animals, some types having a calcareous external 

shell; representatives in the USDA FS include snails, slugs, and clams." 

The FEIS glossary has been 

updated in response to this 

comment. 

Glossary: "Sink" The DEIS discusses a biological sink wherein native bird 

species could be lured to nest, with negative impact, in areas of strong 

presence of certain non-native plants. You may want to add that to your 

definition here. 

The FEIS glossary has been 

updated in response to this 

comment 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-247 

Miscellaneous Other Comments

The following set of comments did not fit neatly into any other category and were placed 

together in this miscellaneous category. In general, these comments generated explanations 

but no substantive changes to the EIS. 

Table 49. Miscellaneous Other Comments and Responses 

Comment Response 

I am concerned that you have structured your alternatives with 

a bias against 2,4-D. 

The Forest Service attempts to consider and 

resolve public issues in a non-biased manner. 

The fact that public comments to the DEIS 

state that the Forest Service is biased both for 

and against herbicide use would indicate that 

the Forest Service approach is balanced. 

Site Restoration/Revegetation Paragraph 4. Discussion on the 

definition of 'local'. A point that is left out as a negative in 

utilizing genetically similar seed is the genetic inferiority of 

the plant. More diverse genetics will result in more robust 

plants. More genetically similar populations run a greater risk 

to losing the entire population to a single disease or ecological 

change. Greater diversity in the genetics would allow a 

greater chance of the plant species to adapt to changes in the 

ecosystem, such as those caused by invasive plants. 

Direction on the use of native materials 

follows draft national policy. Discussion on 

genetically similar seed can be found in 

Chapter 3 of the EIS or the FEIS Appendix J, 

The Effects of Non-Herbicide Methods of 

Invasive Plant Treatment on Wildlife, Fish and 

Plants. 

Your draft mentions cost transfer to users of National Forest 

lands, including grazing adjustments, feed specifications, and 

vehicle access restrictions. I believe that is the only just way 

to protect these lands from invasive plants. It would not be fair 

to allow these users to shift costs to others-such as to me or to 

my grandchildren's generation-for the harm caused by users' 

activities. As an occasional visitor to National Forest lands, 

including "wilderness," I don't mind paying taxes to support 

agency efforts to prevent invasive plants from spreading. 

Your comments will be considered and the 

rationale for the decision will be published in 

the Record of Decision. 

Chapter 2 Page 3: Despite earlier remarks in your text, we 

think it would clarify the headings to also call "No Action" in 

Table 2-1 "Alternative A", underneath or above "No Action", 

and to call "Proposed Action" also "Alternative C". It is 

particularly jarring to the reader presently, since you show B 

and D after C on the table. Someone should be able to look at 

the table and get the picture at a glance and as the columns are 

headed presently, they cannot. 

The reference to Alternative A as No Action 

and Alternative C as the Proposed Action was 

intended to explain why other action 

alternatives are B and D. The tables in the EIS 

generally refer to No Action, Proposed Action, 

Alternative B and Alternative D. The order of 

alternatives in the tables may vary depending 

on the information presented in the table. 

Table 2-6 re Environmental Effects. We hope someone will 

have the expertise to review this table adequately. It makes 

some pretty sweeping conclusions; however, we are not 

saying they are wrong. We just think they need external 

review. 

The DEIS comment process allows for 

external parties, including agency 

representatives and invasive plant 

professionals, to review our findings and 

conclusions. Appendix A demonstrates that 

the Forest Service has considered and 

responded to all substantive comments about 

the effects analysis. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-248 

Table 49. Miscellaneous Other Comments and Responses 

Comment Response 

The Forest Service should [revise] the components of the 

Alternative B, better incorporates ICBEMP science, such as 

"Source Habitats for Terrestrial Vertebrates of Focus in the 

interior Columbia Basin: Broad-Scale Trends and 

Management Implications" and includes many more 

protection measures. The [revision] should evaluate a wide 

range of restoration-type alternatives that will serve to 

effectively protect vegetation communities from weed 

invasion. 

The DEIS provides direction on restoration in 

order for more site specific techniques to be 

considered at the Forest level during sitespecific NEPA 

A description of so-called "Experimental herbicide trials 

conducted by EPA" (p. 1-5), which was exempt from this 

EIS, should be given so that there is no doubt of when or 

where such experiments are or are not occurring. 

Herbicide testing occurs as part of EPA’s 

program of work and is beyond the scope of 

this EIS. No herbicide trials would occur on 

National Forests in Region Six. 

The EIS did not provide the monetary value of benefits of 

weed control to compare with the costs, otherwise known as a 

risk-based, or cost-benefit, analysis. While the EIS is 

commendable for the use of risk-based analyses for herbicidal 

risk to safety, the same standard of cost-benefit analysis is not 

applied to the costs versus benefits of control and prevention 

of invasive plants. This leaves the decision-maker's choice of 

alternative up to creative guesswork. 

Why is there no risk/benefit analysis in the EIS weighing the 

benefits of herbicide use against the risks? This should be 

done for each individual herbicide and its formulations so that 

decision-makers and the public can evaluate the "pros" and 

"cons" of using each herbicide and formula proposed for use. 

The effects of invasive plants on ecosystems 

were discussed at length in the DEIS Chapter 

3, demonstrating that action is needed to 

control these plants. The effectiveness of each 

alternative in reaching objectives was also 

considered. This analysis was partly based on 

herbicide formulations that would be 

approved. 

The costs of the prevention and treatment 

standards were discussed both in monetary and 

other terms. The monetary and non-monetary 

effects of the alternatives will be considered in 

the decision making process. 

The cost, relative effectiveness, and potential 

adverse impact of various herbicides would 

also be considered in project-level analysis 

that can incorporate site-specific information. 

The EIS should describe incentives for managers to actually 

control weeds, otherwise what is to prevent contractors from 

merely going out into the forest and randomly spraying 

herbicides and calling it a job well done? 

The EIS describes the goals for invasive plant 

management. Projects would be evaluated 

regarding their contribution to reaching goals 

and objectives. Thus, random spraying would 

not be approved because it would not 

contribute to goals as well as careful, targeted 

treatments. 

The EIS should have analyzed the production of dust 

produced from bare soil caused by herbicide treatments. Bare 

soil with adsorbed herbicides has the potential to increased 

after herbicide use, and later becoming inhaled, particularly 

during spring thaws. Without this analysis, there will be no 

way of knowing whether inhaling herbicides is impacting 

wildlife and human health. Furthermore, this is a type of 

translocation that is technically illegal for certain restricteduse pesticides like Picloram. We recommend against using 

picloram and other leach-prone pesticides for this reason. 

Each FS/SERA herbicide risk assessment 

evaluates inhalation toxicity and estimates 

exposure from liquid drift and/or vapors. The 

risk assessment estimates the range of 

proportions of the applied herbicide that might 

be present in wind-blown dust. For all the 

herbicides considered, the potential dust 

inhalation exposures are much lower than 

exposures to off-site drift from ground 

applications; therefore the potential risks to 

non-target organisms are adequately 

encompassed in analysis of risks from drift. 
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-249 

Table 49. Miscellaneous Other Comments and Responses 

Comment Response 

The Okanogan National Forest conducted a ten-year $1.5 

million program to "reduce noxious weeds". The EIS does not 

propose a weed control solution that would substantially 

change the way of doing business. The business of weed 

reduction began with a map of weed infestations, which was 

essentially a map of Okanogan National Forest Roads. Even 

though the map was poorly drawn and contained many weedfree areas, the next step was to give the map to a local 

contractor and require them to spray a 10-foot wide shoulder 

for every inch of the roads, regardless of whether there were 

weeds or not. This resulted in miles of completely native and 

sometimes riparian areas being indiscriminately treated, at 

great waste to the public, and great cost to the Forest's image. 

A better goal would have been to manage for ecosystem 

integrity. In that case a poorly drawn map of weed infestations 

would not necessarily result in indiscriminate herbicide 

spraying, but instead with a restoration program that 

considered a suite of ecosystem management tools. 

The FEIS desired condition statement is not 

simply to reduce noxious weeds. Rather, the 

focus is on ecosystem integrity as shown in the 

italicized portion of the statement: “ In 

National Forest lands across Region Six, 

healthy native plant communities remain 

diverse and resilient and damaged ecosystems 

are being restored. High quality habitat is 

provided for native organisms throughout the 

region. Invasive plants do not jeopardize the 

ability of the National Forest to provide goods 

and services communities expect. The need 

for invasive plant treatment is reduced due to 

the effectiveness and habitual nature of 

preventative actions and the success of 

integrated treatment/restoration efforts.” 

The statement on p. 3-1 that, "The effects [of] sic invasive 

plants should be changed to the effects of treatments. 

The commenter apparently misinterpreted the 

sentence. Chapter 3 is about the effects of 

invasive plants on other resources; effects of 

alternative treatment standards are discussed 

in Chapter 4. 

This thorough DEIS addresses all of the key issues in a frank, 

professional manner. Its treatment of the real risks of 

chemical and biological control treatments is excellent, and 

provides a good basis for the selection and use of herbicides 

and other methods described in the Proposed Action. 

The rationale for the final decision will be in 

the Record of Decision. 

The phrase "tool of last resort" needs to be carefully defined in 

the EIS. 

The FEIS defines “tool of last resort” in the 

glossary. 

Furthermore, when the Forest Service applies herbicides on 

public land where the public is present (even at some distance 

from the application), the Forest Service is, in fact, performing 

an illegal test by exposing the public (testing) in direct 

violation of 7 USCA [section] 136j:7 USCA [section] 136j. 

Unlawful acts (a) In general (2) It shall be unlawful for any 

person-(P) to use any pesticide in tests on human beings 

unless such human beings (i) are fully informed of the nature 

and purposes of the test and of any physical and mental health 

consequences which are reasonably foreseeable, and(ii)freely 

volunteer to participate in the test; The Environmental 

Protection Agency (EPA) collects Pesticide Incident Reports, 

but according to Dr. Karl Arne of EPA Region X, nothing is 

typically done with them. So the injury caused by public land 

managers of the non-consensual exposure, which is a form of 

illegal testing, is compounded by the insult of not reviewing 

the harm done so that it will not be repeated! 

These concerns are addressed through the 

addition of Standard 23 to the FEIS in all 

alternatives, requiring that Forests create a 

public information plan with notification and 

signage responsibilities (See FEIS Chapter 2).
Preventing and Managing Invasive Plant Final Environmental Impact Statement April 2005 

Appendix A-250 

Table 49. Miscellaneous Other Comments and Responses 

Comment Response 

Another significant impact of an inadequate range of 

alternatives is the disproportionate impacts to American 

Indian and Hispanic people. No choice or mitigation is 

offered to eliminate this environmental justice discrimination. 

This is unacceptable. Allowing more toxic herbicides and 

more harmful methods of application to be used (eg. backpack 

sprayers, aerial spraying) increases this injustice and may 

lower effectiveness of later mitigation. (See pp. 4-133-135) 

The section on Environmental Justice 

discusses that there may be disproportionate 

effects to American Indians and Hispanic 

people, however no discernable differences 

between alternatives were found at the 

Regional Scale. There is a range of 

alternatives in terms of human exposure 

scenarios; the Proposed Action and 

Alternative B have fewer harmful scenarios 

than No Action. 

It is unclear whether the full text of alternative B has been 

made available in tables 2-4, 2-5 and 2-6. The exact wording 

of the management direction can be key to whether it is 

enforced and is critical to informed decision-making on this 

EIS. 

The full text of standards were included in the 

DEIS. These have been edited in the EIS to 

respond to public comments. 

Please compare the harm of herbicides to the harm of noxious 

weeds in such a case as a frogs in the final EIS. Evaluate why 

the weed is more important to exterminate that the potential 

harm the herbicide will produce in frogs and other wildlife 

potentials ie animals, and insects as well as fish. If the weed is 

less dangerous than what the herbicides will potentially harm 

then it is better to leave the weeds alone until other methods 

can apply. 

The Record Of Decision will consider the 

risks and benefits of the alternatives and 

provide rationale for the final decision. The 

harm of noxious weeds is discussed in Chapter 

3. The harm of noxious weed treatment is 

discussed in Chapter 4. The relative risk of 

these effects occurring would be considered in 

decision making at all levels. 

Solution? Employ Permaculturitsts into your program to help 

you evaluate the best methods available in eradiating invasive 

plants without the use of pesticides and herbicides. One of the 

most renouned Permaculturists in the world is Sepp Holzer of 

Austria. He can be contracted at krameterhof@aon.at. Another 

Permaculturists is Richard Huhnel in Sandpoint Idaho. His 

number is 208-255-2440. Permaculturists have an uncanny 

ability to understand relationships between plants, animals, 

insects and their compatibility with one another. Please 

address the advisability of using Permaculturists in your final 

IPEIS. An example of the above would be, for example, 

removal of knapweed in a certain area and re-seeded with 

Vetch, which is highly competitive with knapweed. Vetch is 

also beneficial to soils and good foraging for animals. Along 

with Vetch would be other native seeds thrown into the mix so 

they all help each other. 

The scientists and ecologists involved with the 

development of this EIS are familiar with the 

philosophy and principles of permaculture and 

plant ecology. 

I hope it is not meant to be a comprehensive plan for halting 

invasive plants on Forest Service lands because it is not. Most 

notably it does not discuss Forest Service interagency efforts. 

Section 4.2.of the DEIS specifically discussed 

interagency efforts, partnership and 

collaboration. FEIS Appendix I addresses the 

Forest Service’s Regional strategy for 

supporting invasive plant management on 

State and private lands.