United States

Department of

Agriculture

Forest Service

Pacific

Northwest

Region

November 1988

Record of Decision

for

USDA Forest Service

Pacific Northwest Region

Final Environmental Impact Statement

Managing Competing and Unwanted Vegetation

November 1988

TABLE OF CONTENTS

INTRODUCTION

General Overview 1

Scope of the Program and Decision... 1

Analysis Process 2

THE DECISION

Identified and Characterized 3

Features of the Selected Alternative 3

Complete Description 4

RATIONALE

Public Comments 7

Highlights of Analysis (Conclusions) 7

Management .Goals 8

ALTER.T\J'ATIVES 9

ISSUES AND RESPONSES 13

PUBLIC INVOLVEMENT AND COMMENTS 15

EXPECTED RESULTS

Introduction. 17

Mitigation Measures 17

Future Public Participation 21

The "E'ive Step Process" 22

Implementation. 24

Moni toring. 24

Working With Cooperators 26

Connection to Forest Plans 26

APPEAL RIGHTS 27

Record of Decision

Managing Competing and Unwanted Vegetation

Final Environmental Impact Statement

INTRODUCTION

General Overview

Managing the National Forests in the Pacific Northwest often requires

controlling vegetation. Examples include brush along roadsides, shrubs in new

tree plantings, and noxious weeds. There are a number of ways to treat these

kinds of competing and unwanted vegetation, such as cutting it with hand tools,

spraying with herbicides, or even plowing it under.

Taken together, all of our activities directed at managing competing and

unwanted vegetation each year constitute a large program. This program can

have significant environmental effects. The public has been especially

concerned about the environmental and human health effects of the use of

herbicides and prescribed fire. Other concerns include our ability to maintain

production of goods and services, and the costs and effectiveness of ourprogram.

We have worked closely with interested members of the public and cooperating

agencies in developing a new vegetation management program and the associated

environmental impact statement (EIS). After carefully considering comments

from the public, scientists, and government agencies on the Draft Environmental

Impact Statement (DEIS) , issued in October 1987, a Final Environmental Impact

Statement (FEIS) was prepared and issued. The Final EIS is the basis for my

selection of a new program of vegetation management.

Scope of the Decision

The decision I am making is to select a Regional program that guides the

management of competing and unwanted vegetation. The program defines a common

Region-wide approach. My decision includes specific requirements that apply to

all vegetation management activities. The decision establishes policy and

direction for subsequent site-specific environmental analysis. Site-specific

projects may be planned individually or in groups. Groups of projects may

include annual programs of work.
Vegetation management activities include: site preparation, conifer release,

fire management activities, range improvements, noxious weed control, wildlife

habitat improvement, recreation and administrative facilities maintenance,

roadside and corridor maintenance, and tree genetics program and research

activities. Activities in National Forest nurseries are excluded, and are

being considered in a separate EIS. Prescribed burning for the primary purpose

of hazard reduction is also excluded.

Methods include the use of herbicides, prescribed burning, manual, biological

and mechanical techniques.

Many of the activities are large programs and have a variety of actions andtasks. 

My decision here pertains only to the portion of each activity that

deals with managing competing and unwanted vegetation.

Site-specific analyses for individual vegetation management projects will be

guided by this EIS and my decisions here. Each site-specific project will be

planned using the process prescribed by the National Environmental Policy Act

(NEPA). and tied to this EIS. as well as to National Forest Land and Resource

Management Plans.

This EIS replaces the 1981 Vegetation Management EIS. Among other items, it

analyzes new standards and guidelines for vegetation management. It also

includes human health risk assessment and worst case analysis. Further, it

considers the plaintiffs' remaining claims for relief in the July 13, 1983,

suit which led to the injunction on the use of herbicides on National Forests

in the Pacific Northwest Region.

Analysis Process

The vegetation management EIS examines alternative ways to address the main

issues and predicts the effects and tradeoffs that would result. The following

steps were included in preparing the environmental study:

Public involvement throughout the process;

Identifying issues and deciding the scope of the decision;

Developing alternatives;

Working with cooperators and special interest groups;

Analyzing effects of the alternatives;

Identifying the preferred alternative(s);

Publishing a Draft EIS;

Receiving and analyzing public comments on the Draft EIS;

Preparation of a Final EIS; and

Selection of a final preferred alternative

This decision is a culmination of that process

2
THE DECISION

I have selected Alternative H.

The Interdisciplinary Team formulated Alternative H in response to comments

from the public on the Draft ElS. This decision is intended to emphasize

the prevention of vegetation management problems. And it reflects my

desire to reduce this Region's reliance on herbicides. It also means that

we will have all tools available for managing competing and unwantedvegetation. 

However, we will prefer the use of non-herbicide methods.

Using herbicides will require special considerations.

The main features of the selected alternative are as follows:

Incorporate some features from all three of the

Draft EIS preferred alternatives. Emphasizes:1} 

protecting human health; 2} promoting long term

health and productivity of forest ecosystems; 3}

meeting goals and objectives of land managementplans.

Philosophy and concept:

Theme: Prevention. 

Reduce reliance on herbicides.

Provide for goods and services at high levels

Manages competing and

unwanted vegetation:

With 

all tools; non-herbicide tools are preferredHerbicide 

use requires special considerations.

Evaluate when vegetation problems are expected.

Act when evidence indicates significant damage or

growth loss will occur.

Time for action:

Project design:

1:

Prevention is preferred: preempt problems.

Design correction to move toward prevention.

Strategy:

2) Human Health: Analyze risk prior to use.

low-risk suitable method.

when necessary.

Select a

Use herbicides only

Minimize by following land management plans and

vegetation mitigation measures. Use site-specific

environmental analysis.

3) Environmental Effects:

4} Tools Available: All tools permitted. Use herbicides only whenother 

methods are ineffective, or will increase

project cost unreasonably.

Consider project cost efficiency along with human

health risks and environmental effects.

5) Budget and Costs:

Support levels of forest commodities at the level

identified in current or future land managementplans.

6) Outputs:

3
Complete Description of the Selected Alternative

Purpose and Theme

The purpose of this alternative is to conduct a Regional vegetation management

program so that it: 1} protects human health; 2} promotes long-term health and

productivity of forest ecosystems; and 3} meets the goals and objectives of

land management plans.

The theme here is to reduce the reliance on herbicides, to continue the

reduction in the use of fire for treating slash, and to support providing goods

and services at high levels.

To achieve its purposes and theme, this alternative emphasizes preventing

vegetation management problems. All methods for managing competing and

unwanted vegetation will be available. Protecting rural communities and

wildernesses from the effects of smoke is a high priority. This alternative

also requires early involvement of the public to help set project goals, assist

in environmental analysis, observe project implementation, and to monitor the

results of projects.

Time for Action

The intent of this alternative is to detect and resolve vegetation management

problems before they cause serious losses or require large correctionprojects. 

This calls for evaluating the need for action when problems areexpected. 

The evaluation should include site-specific surveys and documented

local experience. Then, when the evaluations verify that the expected problems

are likely to occur, action will be taken. This approach will help managers to

detect and control vegetation problems before they cause damage.

At times, results of the evaluation may be inconclusive and managers won't be

sure that serious damage will occur. Managers may then elect to take a "wait

and see" approach. That is, they can defer action until it is clear that a

problem is developing. In some cases, the "wait and see" approach may reveal

that the damage is minimal and that further action is not needed.

4
Project Design

The factors to consider in designing projects include:

Strategy: 

This approach emphasizes the use of prevention and natural processes

to manage competing and unwanted vegetation. It requires creative solutions

that use the biological and technical knowledge gained through monitoring.

Managers will need to anticipate potential vegetation management problems and

take steps to avoid them. When corrective measures are needed, those projects

should be designed to move toward preventive strategies.

The planning stage for any project (such as timber harvest, road constructionor 

range improvement) is the most appropriate time for implementing a

prevention strategy. For example, the site analysis may identify a plant

association known for its potential to compete with crop trees. A harvest

prescription may then include measures to limit the vigor of competingvegetation, 

be designed to reduce the need for subsequent corrective action (in

this case, release), and result in lower overall costs.

Human Health: The evaluation of human health risks, including exposure to

hazardous substances and injuries, is an important factor in designing projects

and in selecting vegetation management methods. All methods that are being

considered will be analyzed prior to use for potential direct and indirect

effects on human health. Herbicides will be used only when necessary.

Selected methods will present low risk when compared to other methods that

could also meet the design criteria.

The protection of recreational and rural residential populations from exposure

to smoke from forestry burning will be given special attention. All means of

smoke management (reduction, avoidance, and scheduling) will be employed asappropriate.

Environmental Effects: Adverse effects will be minimized by using: 1) site

specific environmental analysis; 2) mitigation measures described in this EIS;

and (3) natural processes. The site specific environmental analysis will

address potential environmental effects for proposed projects. They will also

help identify project designs and mitigation measures that will be necessary to

minimize adverse effects. The diversity and integrity of the natural ecosystem

and long-term productivity are major considerations in this process.

Tools Available: Alternative H makes all tools available while working toward

the goal of reducing reliance on herbicides. Using herbicides requires special

considerations to establish their need, assess the risks, and to implement

special mitigation measures. Herbicides will be used only when necessary; that

is, when other methods would not be effective, or their costs would beunreasonable. 

As a part of the site specific NEPA process, responsible

officials will document the criteria they used in establishing the need for

using herbicides.

5
Vegetation treated with herbicides will not be burned for at least one year

following treatment. However, prescribed burning is available, often being the

preferred method for reducing the natural accumulation of dead plant debris,

maintaining ecosystems at a more productive stage of succession, regeneratingdecadent, 

fire-dependent plant communities, and to sanitize disease-infectedstands.

Three specific herbicides (of the sixteen that were evaluated in this EIS' risk

assessment) will not be used: amitrole, diuron, and fosamine. One herbicide,2,4-D, 

will be used only as a last resort. The use of other herbicides

requires using special mitigation measures summarized in this Record of

Decision and detailed in Chapter IV of the EIS.

Amitrole will not be used because there is a high probability for the public

and workers of receiving a toxic dose if exposed to amitrole during routineoperations. 

In addition, there is strong evidence from animal studies that

amitrole has high cancer potency.

Diuron and fosamine will not be used because there is insufficient information

for conducting a full toxicological evaluation for both herbicides. In

addition, limited data suggest that diuron has relatively high toxicity and a

high risk of exposure to the applicator during backpack applications.

With respect to 2,4-D, studies about its cancer causing potential have

conflicting results--some show a positive association with cancer, others donot. 

Although the studies completed to date do not support a conclusion that

2,4-D causes cancer, the question remains unresolved. In reaching the decision

to use 2,4-D as a last resort, I also considered its demonstrated potential for

adverse neurotoxic, reproductive and developmental effects.

There are, in addition, special mitigation measures required when herbicides

are used. These mitigation measures are identified in the E18.

The use of all tools and methods requires operator safety training and proper

protective gear. The Forest Service will coordinate vegetation management

activities with its cooperators. In addition, all contracts will provide forworker 

education and safety, including the use of protective clothing, at a

level equivalent to that specified for Forest Service employees.

~ Forest managers will continue to evaluate and monitor tools and intensity of

application. Methods used will continue to change based on new research,

analysis of completed projects, improvements in technology and public need.

Outputs: 

Vegetation management activities will be those required to support

the production of forest goods and services at a level approximating those of

the applicable land and resource management plans.

Budget and Costs: The costs of the activities will vary, but will be within

the budgets that can be reasonable expected. In selecting vegetation

management methods for projects, human health risks, environmental effects,

project-specific decision criteria, and cost-efficiency will be considered.

6
RATIONALE

I considered three main areas of information in reaching the decision for

Alternative H:

What the public told us.

What we learned from the analysis.

The resource management goals for the Pacific Northwest Region.

The Public

Of 

course different people have different ideas about how we ought to manage

competing and unwanted vegetation. But from listening to people at meetings

and in reading their comments to the Draft ErSt we heard several main messages

-People want us to conduct our program so that it doesn't pose a health

threat to the people who use National Forest land, to the people who

work there, or to neighbors.

-The 

public wants us to continue providing goods and services at a high

level.

People expect us to protect the forest environment --in fact, our

program should promote the long term health and productivity of the

forest ecosystem.

Public responses to the draft tended to favor four alternatives; relying on

Forest Plans (Alternative B); emphasizing prevention and natural processes

(Alternative D); restricting some herbicides (Alternative E); and an

alternative that was submitted to us as part of the responses to the DEIS,

producing a high level of goods and services (Alternative B+). The selected

alternative (H) was developed using the main concepts of B, D, E, and B+.

The Analysis

Our analysis was one of the most extensive we have ever undertaken. It covered

a broad range of programs and activities, as well as technical details of

economics, timber yields, and herbicide information. The main things we

learned from our analysis were that:

We do not have to sacrifice timber production to assure human health,or 

vice-versa.

The health risk of most of the herbicides we analyzed can be managed,

and can be made acceptable. We do not have to eliminate their use to

protect human health.

7
Resource Management Goals

We manage competing and unwanted vegetation so that we can meet basic resource

management goals: grow new trees, keep roads open and safe, control the spread

of noxious weeds, and other multiple use objectives. In other words,

vegetation management is not a program with its own end. It supports

production of goods and services in many program areas. In reaching mydecision, 

I looked for an alternative that would enable us to meet the goals

and objectives of our land and resource management plans as much as possible.

Conclusion

This decision, like most, is aimed at satisfying several different needs.

In this case, I was looking for a balance of responding to the public

heal th concerns, using new knowledge gained from our analysis, and meeting

basic resource management goals. Often a decision has to trade-off or

sacrifice advantages in one area for those in another. But in this case, I

believe that I was able to meet the needs of all major concerns by

selecting Alternative H.

8
THE ALTERNATIVES

There were eight alternatives for this decision. The first seven were

presented in the Draft Environmental Impact Statement. These came from the

issues that the public helped us formulate, and were the heart of ouranalysis. 

The following is a brief description of each of those alternatives,

including Alternative H, which was developed in response to public comments and

built from elements of existing alternatives, and others that were considered

but not analyzed.

A summary description of each of the alternatives follows.

Alternative A

This alternative was designed to eliminate all risk associated with the use of

herbicides in managing competing and unwanted vegetation. Other effective and

efficient techniques are to be used. This is the "no herbicides" choice.

Alternative A approximates the current vegetation management program, carried

into the future. Herbicides are not currently available as a management tool,

due to the U.S. District Court injunction of 1984.

Alternative B

All effective and efficient techniques for managing competing and unwanted

vegetation are available, consistent with the direction provided in applicable

land and resource management plans. This was used as a reference alternative.

The management of competing and unwanted vegetation specified in this

alternative approximates the direction in current and in proposed ForestPlans. 

The Fiscal Year 1989 program serves as the reference for budgets,

outputs, and vegetation management activities for all alternatives.

Alternative B was one of three preferred alternatives (along with D and E) in

the Draft EIS.

Alternative 

C

The vegetation management approach here is one of "no action" unless public

safety is clearly and directly threatened. For example, hazard trees will be

removed from campgrounds, and roadside brushing will be done to maintain safe

travel, but virtually all of the vegetation management normally associated with

forest management will not be done. Some resource production objectives may

not be met.

There is virtually no active intervention to manage competing and unwanted

vegetation in Alternative C. Only situations that pose a direct threat to

public safety will trigger action to suppress unwanted vegetation; and, in

these cases, neither herbicides nor fire will be used.

9
This alternative is the "no action" alternative required by regulation (40 CFR1502.14). 

While it serves an important analytic role, it is also an

alternative that could be implemented if it were selected. However, it is a

dramatic departure from the manner in which the National Forests have

historically been managed.

Public involvement will occur infrequently, primarily because of little or no

vegetation management activities. If a vegetation management project isproposed, 

NEPA guidelines will guide the public involvement efforts. I am

identifying Alternative C as the environmentally preferred alternative in theEIS.

Alternative D

The key to this alternative is the integration of natural ecosystem processes

into managing competing and unwanted vegetation. Here, vegetation management

emphasizes the implementation of the philosophy of having the least impact on

the natural environment while producing products and amenities for human use.

The implementation of the alternative will involve early preventive measures,

monitoring of sites, and frequent evaluations of conditions and practices.

Vegetation is managed to avoid the need for corrective measures; however,

correction, if needed, is done in a way to least alter natural ecosystems andprocesses. 

Herbicides under this alternative are available as a last option.

It requires the consideration of the health of those ecosystems as seen in

conditions such as growth and diversity.

This alternative places an increased emphasis on early involvement of the

public in environmental analysis procedures, and on carrying this participation

through to project implementation and monitoring.

Alternative D was one of three preferred alternatives (along with B and E) in

the Draft EIS.

Alternative E

This alternative is designed to reduce the risks of herbicide use to the

public, and to reduce the risk of herbicide use and manual vegetation

treatments to forest workers. No aerial application of herbicides ispermitted; 

specific herbicides are prohibited; and additional safety

requirements for workers are imposed.

Herbicides reviewed by the Forest Service are permitted, except 2,4-D,amitrole, 

diuron, and fosamine. "Brown and burn" techniques are not used.Bromacil, 

2,4-DP, and simazine will not be applied using backpack techniques.Special 

safety considerations apply for the use of all herbicides. Alternative

E was one of three preferred alternatives (along with B and D) identified in

the Draft EIS.

10
Alternative F

This alternative is designed to manage competing and unwanted vegetation

without the use of prescribed fire for silvicultural purposes. All other

effective and efficient techniques of vegetation management are available.

The burning of logging slash would be allowed only to reduce wildfire hazard.

Off-site residue utilization would be encouraged in place of burning, and

burning of chemically treated vegetation would be prohibited.

Prescribed fire will not be used to treat logging slash for site preparation.

Burning of logging slash will be allowed only for protection purposes, and then

only if no other vegetation management tool will achieve the sam~ hazardreduction. 

The Fuel Appraisal Process will be used to determine whether or not

slash will be treated to reduce wildfire hazard. Prescribed fire may be used

for treating natural fuel accumulations for reducing wildfire hazard, wildlife

habitat improvement, and range improvement.

Use of herbicides is allowed.prohibited. Burning of chemically treated vegetation will be

Alternative G

This alternative manages competing and unwanted vegetation aggressively, to

maximize production of resources for human use. All techniques for managing

vegetation are available. This is the choice that stresses maximum production

of goods and services for human use.

Alternative H

The theme here is to reduce the reliance on herbicides, to continue the

reduction in the use of fire for treating slash, and to support providing goods

and services at high levels.

To achieve its purposes and theme, this alternative emphasizes preventing

vegetation management problems. All methods for managing competing and

unwanted vegetation will be available. Protecting rural communities from the

effects of smoke is a high priority. This alternative also requires early

involvement of the public to help set project goals, assist in environmentalanalysis, 

observe project implementation and to monitor the results ofprojects.

Alternative 

H is the preferred alternative identified in the Final EIS.

11
Other 

Alternatives Considered

Several 

other alternatives were suggested and considered, but not studied by

the Interdisciplinary (10) Team as fully as the final eight alternatives.

Alternative Responding to Oregon Air Quality Legislation: One alternative

examined how the Forest service would conduct its programs in light of possible

new legislation for air quality in the State of Oregon. However, the specific

provisions of the law were not yet available and the alternative would have

been highly speculative. And, the alternatives that were considered in detail

do address the effects of various levels of prescribed burning on air quality.

Alternative for Maximizing Employment: This alternative would have stressed

the use of labor-intensive practices in managing vegetation. However, initial

analysis showed that it would require larger budgets than could be reasonably

expected, and the remaining alternatives do cover a substantial range of joblevels.

Alternatives With Unlimited Budgets: During early analysis the ID Team

proposed a "subalternative" for each of the original action alternatives.

Each subalternative was the same as its original except that it assumed

unlimited budgets would be available to do whatever was needed in implementing

that alternative. However, after analyzing the data from each National Forest

on both sets of alternatives, it became evident that the Forest's vegetation

management programs would not significantly change when they assumed that

budgets would not be constraining. The ID Team then discontinued analysis and

presentation of these subalternatives. In their present form, Alternatives A,

D, E, F, and H represent the most reasonable and likely balance of costs and

work (outputs) that would be expected, given their respective themes.

"Current" Situation Alternatives: The ID Team at first considered two separate

alternatives to reflect a "current" situation. Two were needed because current

could mean either 1) before the injunction (1984) when herbicides wereavailable, 

or 2) really current, where the injunction prohibits our use ofherbicides. 

However, these situations are already represented in Alternatives

A (no herbicides) and B (rely on land management plans), and they were

eliminated from separate consideration.

12
ISSUES AND RESPONSES

During the early phase of this environmental impact analysis, the public helped

us to identify the important issues. We then used those issues to outline the

scope of the decision, form the alternatives, raise questions for analysis and

eventually to focus our thoughts and discussion for selecting the preferredalternatives.

What follows is a brief summary of the original seven main issues that emerged

during early public participation, and how my decision for the selected

alternative responds to each of them.

Human Heal th

Many people are concerned about the safety of herbicides used in vegetationcontrol. 

And the effects of smoke from prescribed burning has also emerged an

an important health issue along with the need to evaluate the health effects of

using non-chemical methods of managing vegetation.

My decision emphasizes the importance of assuring human health for workers

and the public. It includes specific and detailed mitigation measures

designed to protect human health.

Public Participation

Members of the public asked to be included throughout the development of the

Draft Environmental Impact Statement. They wanted to continue participation and

information sharing after the decision has been made. Additionally, members of

the public asked for participation in site-specific, project level planning;

and for readable, clear analyses and documents.

I am committed to a decision process for vegetation management that

includes full and ongoing public participation and information sharing;

public participation in site-specific, project level planning; and

readable, clear analyses and documents. I am directing the line and staff

officers of the Region to do likewise.

Social 

and Economic Effects

Many Forest activities directly support jobs in some sectors and indirectly inothers. 

The vegetation management program will have economic effects, and

effects on social cohesion and the well-being of communities.

The selected alternative emphasizes social and economic well-being by directing

that vegetation management activities be conducted to meet all the goals and

objectives of Forest Land Management Plans, including the production of goods

and services at planned levels.

13
Cost and Benefit Analysis

People are concerned about the costs and benefits of the methods used in

managing vegetation, and that money and resources be wisely managed and put to

the highest and most beneficial use.

Alternative H requires that project decisions be guided by cost efficiency aswell 

as human health risks and environmental effects.

Environmental Effects

The public has been consistently concerned about the physical and biological

effects from applying vegetation management techniques. This concern focuses on

long term health and productivity of forest ecosystems.

My decision emphasizes the use of natural processes and includes detailed

mitigation measures for protection of environmental quality. In addition,

both the FEIS and this Record of Decision require specific new procedures

for conducting vegetation management programs that are considering the use

of pesticides: early site-specific analysis, a five-step project design

process, and formal monitoring. Taken together, these new procedures

directly address the need to minimize environmental effects.

Effectiveness of Techniques

There are a number of methods used in managing competing and unwantedvegetation. 

People want us to be sure that we use methods and techniques that

will achieve desired results.

My decision provides for the use of all tools with the exception of three

specific herbicides. The decision also directs that early planning.

detailed site specific analysis and integrated pest management be conducted

for all projects.

Interagency Coordination

Many agencies have a shared interest in vegetation management that overlaps

with Forest Service responsibilities. It is important to coordinate withnational, 

state, and local interests in developing programs for management.

Joint Forest Service/cooperator planning is required for all vegetation

management projects conducted by cooperators on National Forests. I am

also directing that line and staff officers of the Region assure that

provisions of this EIS and my decision are incorporated in all relevantagreements, 

special use permits, easements, cooperative resource managementplans, 

memoranda of understanding, and work plans.

14
PUBLIC INVOLVEMENT AND RESPONSE TO PUBLIC COMMENT

The public has been actively involved in developing this decision. The issues

relating to vegetation management have long been of concern to many people.Over 

the past years, interaction with interested and concerned people on

vegetation management issues was often controversial and full of conflict. The

result of that era was a court injunction in 1984, prohibiting the use of

herbicides until further analysis was completed by the Forest Service.

In developing the new program for vegetation management, it was important to

work to change these previously conflict-charged relationships with individuals

and organizations into collaborative relations.

We therefore set high goals for participative public involvement-by working

with people early and continuously in the process. Cooperative relations with

state and national agencies were further developed. Expert technical and

scientific review were included in the strategy designed to involve everyoneinterested.

We began by conducting scoping meetings to set public involvement objectives

for people who had high interest. During these meetings we identified and

developed the best strategies to incorporate public participation in the

vegetation management decisionmaking that would be forthcoming. These key

players included individuals who were spokespersons for their respectiveorganizations, 

and who had an interest in working toward mutually acceptable

solutions after the 1983-84 litigation.

During the course of the initial meetings, a variety of strategies for

involving the public throughout the development of the EIS were worked out.

They included:

-Periodic requests for participation in our planning process mailed to

all interested parties.

-Northwest Coalition for Alternatives to Pesticides (NCAP) and

Oregonians for Food and Shelter (OFS) providing leadership in

coordinating involvement of the segments of the public they represent.

-Issue workshops for the Forest Service hosted by NCAP and OFS.

-Environmental and business community work groups assisting the Forest

Service Interdisciplinary Team.

-A special outreach program to Forest Service employees.

-Contacts and close coordination with other interested organizations

and agencies.

Throughout the development of the Draft and Final ErS, people were kept

informed and provided opportunities for feedback.

15
During this EIS process, many public involvement activities have taken place:

-We published seven "Requests for Participation" with information on

progress and current status.

We held two issue workshops

Three working groups (NCAP, OFS, and Oregon Society of American

Foresters) worked for over twelve months with the Interdisciplinary

Team.

Forest Service employees received all mailings and participated inspecial 

briefings.

-Over 

a hundred other organizations were contacted and invited to

participate in the analysis. Many of them did.

The Draft EIS was released on October 15. 1987. According to NEPA regulations,

a 45-day public comment period is required for the Vegetation Management DraftEIS. 

We decided on a longer. 90-day review because of the broad scope and

complexity of this particular document. A 30-day extension was granted in

January 1988. bringing the total review time to 120 days--October 15. 1987.

through February 15. 1988.

We received over 5,000 responses to the Draft EIS from 29 states and BritishColumbia. 

The responses came from individuals, organizations, associations,

elected officials, and state and Federal agencies. The majority werewell-reasoned, 

thoughtful letters and became valuable contributions to theFinal 

EIS.

About 74,000 individual comments came from the letters (an average of 15

comments per letter). Eighty six percent of these comments came from formletters, 

that is, the same 15 comments, 3,000 times. Fourteen percent of the

comments came from individually written letters. Although responses came from

29 states, most were from Oregon (4,100 responses) and Washington (600responses).

Some people addressed broad, sweeping issues while others commented on specifictechnical 

points. Still others did a good job of editing. Most of the

responses were submitted by individuals acting on behalf of themselves or theirfamilies. 

The next largest groups of respondents were conservation andenvironmental 

groups, timber industry businesses, associations/unions and

county officials.

The main messages from the public comments were that:

-The presentation of human health material in the Draft EIS was too

technical and difficult to understand.

People could not determine local effects of the alternatives.

There could (and should) be one alternative that both protects human

health and supports production of goods and services at plan levels.

16
As part of our committment to working closely with people in the planningprocess, 

we responded to the letters we received. We assured them that we

received their response, thanked them for participating, acknowledged the

points they made, and explained how we would be using their response to develop

the final document.

We then set about using the full range of public comments to develop the Final

ErS. We developed a new, plain-language summary of the human health analysis.

This summary now appears as a new appendix (The Characterization and Managementof 

Risk), and the text from that summary replaces discussions about human

health risk in the ErS. We conducted additional analysis to show local,

Forest-by-Forest timber harvest and economic effects. And finally, we

developed a new alternative, drawing features from Alternatives B, D, E, andB+, 

as suggested by members of the public.

Finally, 

the FEIS shows how we used public comments in two ways. First, the

most substantive comments, and our response to each, are listed in Appendix I.Second, 

at the beginning of each chapter in the FEIS we have highlighted

comments that suggested the biggest changes, and how the FEIS responds to thecomment.

EXPECTED RESULTS

Introduction

As a result of our analysis, the public's participation, my selection of

Alternative H and the whole EIS process, I am expecting a number of changes in

the way we conduct our vegetation management program. It is important for both

the public and our employees to be clear about those changes. This section

presents a summary of them.

Mitigation Measures

We developed mitigating measures to reduce, avoid, minimize, rectify, or

compensate for impacts on the environment which might result from vegetation

management activities.

The measures reflect Federal and state laws; existing direction found in Forest

Service Manuals and land management planning documents; past experience; and

current research. It is important to understand that the mitigating measures

are specific to methods, not to the alternatives. Whatever method is used

under any alternative, the mitigating measures associated with that method will

be followed. Below are highlights from the mitigation measures which are

developed in detail in Chapter IV of the EIS.

17
For 

All Methods:

-Conduct scoping and environmental analysis for each proposed project.

-Use written silvicultural prescriptions, prepared or approved by a

Certified Silviculturist.

-Use a site specific diagnosis that meets Forest Service Handbook

standards (2409.17), and treatment needs (2409.26c).

-Prepare a human health risk management plan for each project

-Provide training and quality control at regional, forest, and district

offices.

-Adherence to all state and Federal laws.

-Adherence to Forest Service health and safety handbook.

For Biological, Cultural, and Grazing Methods:

Biological control agents will be used only in cooperation with

appropriate Federal and state agencies.

Inform dowr:stream water users that could be affected directly.

Evaluate genetically-adapted seedling use to natural diversity of

forest and range ecosystems at the Regional genetics program level.

-Protect resources from grazing impacts using the guidelines under FSM

2200 Range Management and FSM 2500 Watershed Management

Strict control of livestock near wetlands and riparian areas

For Manual Methods:

-Analyze worker health and injury risks.

For Mechanical Methods:

Tractors on steep (35 percent and greater) slopes prohibited.

Tractors prohibited on critical soils

Tractors prohibited on erodable soils in municipal watersheds

Tractors limited to low-impact operating periods.

Leave buffers along streams, lakes, and wetlands.

No slash piling in stream flood zones.

18
For 

Using Herbicides:

Notify downstream water users and adjacent landowners

The herbicides amitrole, diuron, and fosamine will not be used in the

Region's vegetation management program.

The herbicide dalapon will not be used in roadside vegetation

management nor in any other situations where its use could result in

exposure to the public either through routine operations or accidents.

-Female 

workers (either Forest Service employees or contract workers)

will not be used in backpack spray or hack and squirt operations

involving the application of 2,4-D, glyphosate, dicamba, tebuthiuron,

triclopyr, simazine, or bromacil.*

Female workers (either Forest Service employees or contract workers)will 

not be used as mixers or loaders in atrazine or bromacil

applications.*

Female workers (either Forest Service employees or contract workers)will 

not be used in dalapon applications.*

The herbicide atrazine will not be applied aerially.

-Diesel oil will not be used in herbicide applications except as an

adjuvant (not to exceed 5 percent of the spray mixture).

Kerosene will not be used in herbicide applications, except as an

inert ingredient in the ester formulation of triclopyr.

Follow herbicide label instructions.

Use herbicide formulations that contain only inerts that are

recognized as generally safe by the Environmental Protection Agency

(EPA) , or are of a low priority for testing by EPA. Use of other

inerts (identified by EPA as a high priority for testing, or those

that have been shown to be hazardous) requires full assessment of

human health risks incorporated into the NEPA decision-making process.

Protective clothing will be worn by all workers (both Forest Service

employees and contract workers) involved in herbicide mixing, loading,

backpack applications, and hack-and-squirt applications.

* Research studies, including both laboratory studies of animals and studies ofhuman 

populations, demonstrate the potential for gender-specific adverse healtheffects. 

The intent of these measures is to prevent females from coming in

direct contact with the herbicides in question. These measures will not be

used as a basis for sex des crimination and will not be used as a factor of

consideration in hiring, promotion, or any other personnel action. Females, or

any employees not wanting exposure to these herbicides will be given alternatework 

assignments that do not involve direct contact with herbicides. There are

many assignments, even in herbicide operations, that do not involve direct

contact with herbicides.

19
Public notification will be used for all applications where there is apotential 

for public exposure, requesting that people who know or

suspect that they are hypersensitive to herbicides contact the Forest

Service office proposing the project to determine appropriate risk

management measures.

Workers (both Forest Service and contract) who know that they are

hypersensitive to herbicides will not be used for applicationprojects. 

Workers who display symptoms of hypersensitivity to

herbicides during application will be removed from the project.

-Take precautions against accidental leaks.

-Do not prepare mixtures or clean equipment where ground water could be

contaminated.

-Control spray to prescribed boundaries.

-Leave buffers along streams, lakes, and wetlands

-Determine appropriate management of streamsides along dry Class IV

streams.

-Use pilot vehicles when transporting mixes.

-Exposure monitoring will be conducted required for all herbicide

application projects. Pertinent details will be documented, including

herbicides used, land areas treated, dates and times of applications,

people involved, and mitigation measures followed.

-Monitor 

and assure effectiveness of mitigation measures during spray

operations.

-Follow Forest Service Manual Direction (2150) for conducting projects.

-Meet Forest Service Handbook standards as follows:

a. Chapter 2109.11 for planning projects, and for storing,

handling and transporting herbicides.

b. 

Chapter 2109.13 to define worker training and experience

requirements.

c. 

FSH 6709.11, Chapter 9 to identify worker safety

requirements.

Individual National Forests will develop detailed guidance for

projects as part of project environmental analysis.

Use licensing and training to maintain applicators' knowledge of

chemical application techniques emphasizing proper procedures.

-Post material safety data sheets at storage facilities.

-Avoid skin contact with diesel oil and kerosene.

20
For Using Prescribed Fire:

-Avoid excessive consumption of litter and duff.

-Reduce fuel consumption on steep (60 percent) slopes.

-Leave 

unburned buffers along streams.

-Protect air quality, following all state and local regulations.

-Avoid smoke intrusion into state-identified sensitive areas.

-Use the best available technology to reduce smoke.

-Comply with Oregon State Implementation Plan prohibitions.

-Comply with Washington State Smoke Management Plan and Implementation

Plan.

Vegetation treated with herbicides will not be burned for at least oneyear 

following treatment.

Future Public Participation

Another expected result is that I am committed to a decision process for

vegetation management that includes full and ongoing public participation

and information sharing; public participation in site-specific, project

level planning; and readable, clear analyses and documents. I have

directed the line and staff officers of the Region to do likewise.

Environmental Analysis and the "Five Step Process"

When environmental analysis is conducted for vegetation management

projects, additional emphasis will be given to five aspects of the

established analysis and decisionmaking process.

These five aspects of the NEPA process--the "five steps" discussed here--focus

attention on the site-specific ecological features of the competing or unwantedvegetation. 

It requires that we carefully examine when action is needed,

design and conduct the project carefully, and provide for follow-up on (and

learning from) the project.

21
"Five Steps" in Managing Competing and Unwanted Vegetation

SITE ANALYSIS

What's there? What's likely to happen? What are Forest Plan goals?

SELECT STRATEGY

When to act? What strategy to use?

DESIGN PROJECT

Incorporate specific requirements, mitigation, risk management plans,

and reporting and training requirements. Use only permitted tools.

Include Forest Plan standards and guidelines.

ACTION

Do the work.

MONITOR

Successful project? What was learned? More work needed?

These five steps are familiar to many as the scientific management method.

Others know them as the analytical steps used in integrated pest management.

They are commonly used in silvicultural prescriptions, and are partly

documented in the Timber Stand Improvement Handbook (FSH 24og.26c'. They are

intended to provide Forest-level direction in implementing the vegetation

management portion of any of the nine vegetation management activities covered

by this EIS, and described in detail in Appendix G.

Environmental analysis is not a rigid process. Sections may be done in various

order and some parts done several times. The "five step process" is readily

compatible with environmental analysis. Many items evolve and are developed

within "scoping" , where the scope of the action, its context, and further

analyses are examined. The following figure illustrates how the five-step

process fits within environmental analysis.

22
How the Five Step Vegetation Management Process

Fits within Environmental Analysis

ENVIRONMENTAL ANALYSIS ("The NEPA Process")* VEGETATION MANAGEMENT PROCESS

Site Analysis

Site Analysis, Select

Strategy

Design Project

Design Project

Design Project

Design Project

Scoping

-identify the action

-identify agencies and responsible

official

-look for issues

-explore possible effects and

existing direction

-assess public participation needs

and make contacts

-identify skills needed

-convene interdisciplinary team,

identify cooperators, assign

tasks

-expand public involvement as

appropriate

-plan for an orderly analysis

(analysis criteria, issues,

alternatives, other analysis,

public involvement)

Site Analysis, Design

Project

Collect Data Site Analysis

Interpret Data Select Strategy

Design Project, Site

Analysis

Develop Alternatives

Site Analysis, Select

Strategy

Estimate Environmental Consequences

Evaluate Alternatives Select Strategy

Identify Preferred Alternative(s) Select Strategy

Documentation (as appropriate)

Decision Select Strategy

Implementation Action

Monitor

Monitoring

* Adapted from Exhibit 3. FSH 1909.15.06

23
Implementation: 

Site-Specific Analysis

All tools--manual, mechanical, burning, biological, herbicides, and

no-action--are appropriate responses under Alternative H. Each NationalForest, 

however, will actively look for opportunities to reduce their past

reliance on herbicides.

Herbicides will be employed only when necessary to meet management objectives.

This means that herbicides may be used only when other methods would be

ineffective (will not meet prescription objectives) or would increase project

cost unreasonably.

I 

expect site-specific environmental, biological, sociologic, and economic

factors to be considered in the development of projects.

The following elements are basic for site analysis, selection of strategy, and

design of any vegetation management project:

-Management objectives, required mitigation measures, and anticipated

resource outputs;

-Potential risk of adverse human health effects, for both workers and

the public;

-Risk of unacceptable environmental damage;

-Project feasibility, which is defined by logistical considerations, as

well as the availability of money, people, time, and equipment; and,

-Potential for development of preventive strategies through pest

habitat modifications or the complementing of natural ecosystems and

processes.

During implementation of the vegetation management program, each National

Forest will provide guidance for project planners and prescriptionists. When

treatment options are relatively equal based on the factors considered, the

non-chemical option will be selected. The appropriate resource staff in the

Regional Office, as well as Forest Pest Management, will assure that there is a

consistent understanding of the intent of the herbicide use policy and that the

major factors considered are similar on all National Forests.

Monitoring

When we begin to implement this program we will need to keep track of what

we do and how well we are doing.

The discussion below describes three categories of monitoring.

24
Program Monitoring

We will need to assure ourselves that we are in fact following the selected

alternative and that we are managing our program the way that it is outlined in

this Record of Decision. Key questions for program monitoring will be:

-Are we reducing our reliance on herbicides?

-Is the public being informed and involved in our program?

-Are we preventing vegetation management problems and the need for

large correction projects?

Are we supporting the production of goods and services?

Are human health risks being managed well?

Project Management Monitoring

Project managers will need to collect the information and maintain recordsshowing:

Use of the NEPA process with emphasis on the "five-step" process as

outlined in this Record of Decision.

-Adherence to all appropriate mitigation measures.

-Use of a project risk management plan.

Project Effects Monitoring

Project managers will also monitor their projects and record the results to

address questions like:

-Were the project objectives achieved?

-Were 

the mitigation measures effective?

-What were the short-term (and long-term) vegetative effects of the

project?

What lessons were learned that could be applied to other projects?

To achieve the monitoring outlined above, I am expecting that we will conduct

management reviews of vegetation management programs and activities. Forest

Supervisors will be conducting vegetation management activity reviews on theirForests. 

Regional Staff Directors will collect basic information summaries to

address program monitoring questions.

25
Working With Cooperators

Those who hold easements, rights-of-way, special use permits, and other

rights of use on National Forest land will need to work together with

Forest Service representatives to implement Alternative H and the Record of

Decision for their vegetation management programs. Both cooperators and

the Fores t Service will be doing more analysis and planning to develop

vegetation management programs for these lands than in the past. I see

this as being a joint effort between cooperators and the Forest Service.

Each will have a role in developing projects, analyzing effects, and

selecting alternatives.

Both parties should work together in the scoping and analysis for projectproposals. 

Generally, the cooperator will provide data and recommendalternatives. 

Completing the environmental analysis process will normally be a

Forest Service responsibility. The cooperator will then implement the selected

alternative, including all mitigation and monitoring requirements.

The coordination and involvement of the cooperator, the public and the Forest

Service is critical to the successful implementation of projects on theselands.

Ties to Forest Plans

Forest plans are now being developed for each National Forest in the Region.

The Plans assume, as do current plans, that all methods of managing vegetationwill 

be available. However, the final decisions represented in this document

could affect the Forest Plans. New vegetation management procedures and

mitigation measures could change the way lands and resources would be managed

on a National Forest.

The decisions from this EIS will be incorporated into Forest Plans. This could

be done in one of several ways, depending on the stage of development each

Forest Plan is in. Changes can be incorporated 1} as a Revised Proposed Forest

Plan and its Revised DEIS; 2) incorporated in the Forest Plan and its FEIS; or

3) as an amendment to a Forest Plan already in effect.

26
APPEAL RIGHTS

This decision is subject to appeal pursuant to 36 CFR 211.18 (published in theFederal 

Register, Volume 48, No. 63, FR 13425, March 31, 1983). Notice of

appeal must be in writing and submitted to the reviewing officer:

James F. Torrence, Regional Forester

USDA Forest Service

Pacific Northwest Region

319 S.W. Pine Street

P.O. Box 3623

Portland, OR 97208-3623

The notice of appeal must be filed within 45 days of the date of thisdecision. 

An appeal will not automatically stop implementation. A stay, if

granted, stops initial implementation of the decision while appeal is

considered on its merits. A request for stay must accompany the notice of

appeal to be considered.

December 8, 1988

Date

27

* 

u.s. GOVERNMENT PRINTING OFFICE: 1988-691-059/80,706 REGION NO. 10