Integrated Invasive 

Plant Management for 

the Coos Bay District 

Environmental Assessment 

(revised October 2018) 

(DOI-BLM-ORWA-C000-2017-0003-EA) 

U.S. Department of the Interior 

Bureau of Land Management 

Coos Bay District 

1300 Airport Lane

North Bend, OR 97459

Scotch broom Canada thistle European beachgrass Tansy ragwort & cinnibar 

moth Gorse

COOS BAY

BLM

 DISTRICT October 201

8
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Acronyms and Abbreviations

2

Acronyms and Abbreviations

ACEC Area of Critical Environmental Concern

A.E. Acid Equivalent

A.I. Active Ingredient

ALS Acetolactate synthase

APHIS Animal and Plant Health Inspection 

Service

ARBO II Aquatic Restoration Biological Opinion 

(2013)

BEE With triclopyr, butoxyethyl ester

BLM Bureau of Land Management

CFR Code of Federal Regulation

CWMA Cooperative Weed Management Area

EA Environmental Assessment

EIS Environmental Impact Statement

EPA Environmental Protection Agency

FEIS Final Environmental Impact Statement

FIFRA Federal Insecticide Fungicide 

Rodenticide Act

FLPMA Federal Land Policy and Management 

Act

FONSI Finding of No Significant Impact

FWS U.S. Fish and Wildlife Service

GIS Geographic Information System

GUS Groundwater Ubiquity Score

HUC Hydrologic Unit Code

IARC International Agency for Research on 

Cancer

JMPR Joint FAO/WHO Meeting on Pesticide 

Residues

LD50 Lethal Dose to 50 percent of a 

population

LOC Level of Concern

NEPA National Environmental Policy Act

NISIMS National Invasive Species Information 

Management System

NMFS National Marine Fisheries Service

NPDES National Pollutant Discharge Elimination 

System

NRHP National Register of Historic Places

OAR Oregon Administrative Rule

ODA Oregon Department of Agriculture

ODEQ Oregon Department of Environmental 

Quality

ODFW Oregon Department of Fish and Wildlife

ODOT Oregon Department of Transportation

OWRD Oregon Water Resources Department

Oregon FEIS Vegetation Treatments Using Herbicides 

on BLM Lands in Oregon FEIS (2010)

2007 PEIS Vegetation Treatments Using Herbicides on 

BLM Lands in 17 Western States 

Programmatic FEIS (2007)

2016 PEIS Vegetation Treatments Using Aminopyralid, 

Fluroxypyr, and Rimsulfuron on BLM Lands 

in 17 Western States Programmatic FEIS 

(2016)

pH potential of Hydrogen (measure of 

acidity)

POEA Polyoxyethylenamine, a surfactant 

found in some glyphosate formulations

SHPO State Historic Preservation Office

TEA With triclopyr, triethylamine salt

TEP Federally listed as threatened or 

endangered, or proposed for such listing

TMDL Total Maximum Daily Load

WHO World Health Organization

WQRP Water Quality Restoration Plan
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Changes to the EA and the Finding of No Significant Impact

3 

Changes to the EA and the Finding of No 

Significant Impact

The following edits were made to the EA or Finding of No Significant Impact (FONSI) as a result of public comment 

or new information. Typographical errors have also been corrected, but are not listed below.

Finding of No Significant Impact 

Throughout References to the Proposed Action were changed to reference the selected alternative

Page 3 A line stating that there would be no disproportionate negative health or safety effect to low 

income or minority populations was added. 

Page 5 A line describing western lily being found in forest habitats was removed. The same sentence 

was also deleted from page 90 of the EA. 

Chapter 1 – Purpose and Need

Page 9 The footnote describing that the Tribal Fairness Act conveys approximately 10,000 acres of BLMadministered lands on the Coos Bay District to the Confederated Tribes of the Coos, Lower 

Umpqua and Siuslaw Indians has been deleted as that conveyance is now complete. The District

acres have also been updated to reflect this (see also acres on page 154).

Page 14 The line stating that the decision to be made would be applicable to lands to be conveyed to the 

Tribes until those lands are conveyed was deleted.

Page 15 The Public Comment Period section was re-written to describe the July public comment period.

Additional information was added to the tribal consultation section to describe an August 2018 

meeting with the Confederated Tribes of Coos, Lower Umpqua and Siuslaw Indians and an 

August 2018 letter from the Coquille Indian Tribe.

Chapter 2 – Integrated Invasive Plant Management and the Alternatives

Pages 28-30 Diffuse knapweed, panic veldt grass, and shiny leaf geranium were added to the list of known 

species on the District. (Shiny leaf geranium was also removed from the potential new invaders 

list on page 33.) The known locations of spotted knapweed were updated. These updates where 

also made on Table D-2 in Appendix D (page 262, 264, 265).

Chapter 3 – Affected Environment and Environmental Consequences

Page 117 Table 3-11, Effects of Herbicides (Wildlife), has edits in the triclopyr and hexazinone sections; a 

line stating that no studies on invertebrates were known was removed from the triclopyr section 

and additional information was added about the risks from hexazinone.

Page 120 Hexazinone was added to the list of herbicides that have some risk to insects.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Changes to the EA and the Finding of No Significant Impact

4 

Page 123 A footnote about (lack of) risk to human health from the broadcast spray of triclopyr was added.

Page 152 Language clarifying that the BLM would not treat traditionally gathered plants was added.

Other Edits

Page 162 The list of reviewers has been updated.

Page 176, 182 A missing reference was added and reference to the Medford Invasive Plant EA was corrected to 

point to their Revised EA (see also footnote on page 9).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Table of Contents

5

Table of Contents

Chapter 1 – Purpose and Need ..............................................................................................................................9

The Need..................................................................................................................................................................10

The Purposes ...........................................................................................................................................................11

Issues .......................................................................................................................................................................11

Issues Analyzed in Detail .....................................................................................................................................12

Issues Not Analyzed in Detail...............................................................................................................................12

Decision to Be Made................................................................................................................................................14

Public Involvement ..................................................................................................................................................14

Scoping ................................................................................................................................................................14

Public Comment Period .......................................................................................................................................15

Consultation.............................................................................................................................................................15

Tribes...................................................................................................................................................................15

State Historic Preservation Office........................................................................................................................16

Endangered Species Act ......................................................................................................................................16

Tiering and Reference..............................................................................................................................................18

Conformance and Consistency with Land Use Plans, Laws, Policies, and Other Decisions.....................................18

Land Use Plans on the Coos Bay District..............................................................................................................19

Other Management Plans on the Coos Bay District ............................................................................................21

Other BLM Direction............................................................................................................................................22

National Policy.....................................................................................................................................................23

Chapter 2 – Integrated Invasive Plant Management and the Alternatives ........................................................... 25

Invasive Plants .........................................................................................................................................................25

Categories of Invasive Plant Infestations.............................................................................................................25

Integrated Invasive Plant Management ..................................................................................................................34

Prevention, Education, and Awareness...............................................................................................................34

Coordination and Cooperation............................................................................................................................35

Planning ...............................................................................................................................................................35

Direct Control Methods.......................................................................................................................................37

The Alternatives.......................................................................................................................................................48

The No Action Alternative – Noxious Weed Management (Alternative 1) .........................................................48

Proposed Action – Invasive Plant Management with ARBO II Consultation (Alternative 2) ...............................51

Invasive Plant Management with Additional Endangered Species Act Consultation (Alternative 3)..................57

Alternatives Considered but Eliminated from Detailed Study.............................................................................70

Ongoing and Reasonably Foreseeable Actions....................................................................................................73

Chapter 3 – Affected Environment and Environmental Effects............................................................................. 78

Determination of Effects in this Environmental Analysis ........................................................................................78

Invasive Plants .........................................................................................................................................................79

Invasive Plants Issue 1 .........................................................................................................................................79

Invasive Plants Issue 2 (Not Analyzed in Detail) ..................................................................................................83

Invasive Plants Issue 3 (Not Analyzed in Detail) ..................................................................................................85

Background: Potential Effects to Non-Target Organisms........................................................................................85

Native Vegetation....................................................................................................................................................87

Native Vegetation Issue 1....................................................................................................................................87

Native Vegetation Issue 2 (Not Analyzed in Detail)...........................................................................................100
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Table of Contents

6

Native Vegetation Issue 3 (Not Analyzed in Detail)...........................................................................................102

Fish and Aquatic Organisms...................................................................................................................................103

Fish and Aquatic Organisms Issue 1 (Not Analyzed in Detail) ...........................................................................103

Wildlife...................................................................................................................................................................105

Wildlife Issue 1...................................................................................................................................................105

Wildlife Issue 2 (Not Analyzed in Detail) ...........................................................................................................111

Wildlife Issue 3 (Not Analyzed in Detail) ...........................................................................................................112

Human Health........................................................................................................................................................121

Human Health Issue 1 (Not Analyzed in Detail).................................................................................................121

Human Health Issue 2 (Not Analyzed in Detail).................................................................................................125

Human Health Issue 3 (Not Analyzed in Detail).................................................................................................127

Human Health Issue 4 (Not Analyzed in Detail).................................................................................................127

Soil .........................................................................................................................................................................129

Soil Issue 1 (Not Analyzed in Detail) ..................................................................................................................129

Soil Issues 2 and 3 (Not Analyzed in Detail).......................................................................................................130

Water Quality ........................................................................................................................................................135

Water Quality Issue 1 ........................................................................................................................................135

Air Quality..............................................................................................................................................................148

Air Quality Issue 1 (Not Analyzed in Detail).......................................................................................................148

Air Quality Issue 2 (Not Analyzed in Detail).......................................................................................................148

Fire.........................................................................................................................................................................149

Fire Issue 1 (Not Analyzed in Detail)..................................................................................................................149

Archaeological and Cultural Resources .................................................................................................................150

Archaeological and Cultural Resources Issue 1 (Not Analyzed in Detail) ..........................................................150

Traditional and Cultural Uses (Native American Interests) ...................................................................................152

Traditional and Cultural Uses Issue 1 (Not Analyzed in Detail) .........................................................................152

Environmental Justice............................................................................................................................................153

Environmental Justice Issue 1 (Not Analyzed in Detail).....................................................................................153

Socioeconomics.....................................................................................................................................................154

Socioeconomics Issue 1 (Not Analyzed in Detail) ..............................................................................................154

Socioeconomics Issue 2 (Not Analyzed in Detail) ..............................................................................................155

Socioeconomics Issue 3 (Not Analyzed in Detail) ..............................................................................................156

Socioeconomics Issue 4 (Not Analyzed in Detail) ..............................................................................................156

Implementation Cost.............................................................................................................................................157

Implementation Cost Issue 1 .............................................................................................................................157

Recreation..............................................................................................................................................................160

Recreation Issue 1 (Not Analyzed in Detail) ......................................................................................................160

Recreation Issue 2 (Not Analyzed in Detail) ......................................................................................................160

Consultation and Coordination.......................................................................................................................... 162

List of Preparers.....................................................................................................................................................162

Review Opportunity...............................................................................................................................................162

Glossary............................................................................................................................................................. 163

References......................................................................................................................................................... 174

Appendix A – Protection Measures.................................................................................................................... 183

Appendix B – The Herbicides, Formulations, and Adjuvants.............................................................................. 228

Appendix C - Herbicide Risk Assessment Summaries ......................................................................................... 244

Appendix D - Invasive Plant Infestations............................................................................................................ 259

Appendix E - Prevention .................................................................................................................................... 271
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Table of Contents

7

Tables

Table 1-1. Listed Species on the Coos Bay District ......................................................................................................16

Table 1-2. Endangered Species Act Consultation ........................................................................................................16

Table 2-1. Summary of Known Invasive Plant Sites.....................................................................................................27

Table 2-2. Summary of Invasive Plants Documented in NISIMS by Infestation Size ...................................................31

Table 2-3. Invasive Plants Documented on Neighboring Lands but Not Known to Occur on the District...................32

Table 2-4. Biocontrol Releases within the Coos Bay District Boundary.......................................................................39

Table 2-5. Herbicide Information ................................................................................................................................41

Table 2-6. Herbicide Characteristics............................................................................................................................43

Table 2-7. Guide for Herbicide Rotation......................................................................................................................45

Table 2-8. Annual Treatment Summary (2012-2017)..................................................................................................50

Table 2-9. Annual Treatment Plan...............................................................................................................................54

Table 2-10. Treatment Key (All Alternatives) (treatments ordered by preferred treatment method) .......................59

Table 2-11. Comparison of the Alternatives, Treatment Methods..............................................................................70

Table 3-1. Treatment Effectiveness under the Alternatives........................................................................................79

Table 3-2. Specific Species, Locations, and Extent1 .....................................................................................................80

Table 3-3. Plant Communities, Management Areas, Invasive Plants, and Species Affected.......................................88

Table 3-4. Special Status Plants Threatened by Invasive Plants..................................................................................89

Table 3-5. Effects of Herbicides on Native Vegetation and Special Status Plants .......................................................96

Table 3-6. Summary of Effects (Native Vegetation Issue 1) ........................................................................................99

Table 3-7. Special Status Fungi Known or Suspected to Occur on Coos Bay BLM.....................................................101

Table 3-8. Aquatic Special Status Species within the Coos Bay District.....................................................................103

Table 3-9. Summary of Effects (Wildlife)...................................................................................................................110

Table 3-10. Wildlife Special Status Species, Birds of Conservation Concern, and Game Birds Below Desired 

Conditions..................................................................................................................................................................112

Table 3-11. Effects of Herbicides (Wildlife) ...............................................................................................................115

Table 3-12. Human Health Herbicide Risk Summary, Public .....................................................................................121

Table 3-13. Effects of Herbicides (Human Health).....................................................................................................122

Table 3-14. Human Health Herbicide Risk Summary, Workers .................................................................................126

Table 3-15. Soil Order Properties and Extent............................................................................................................129

Table 3-16. Fate of Herbicides in Soils.......................................................................................................................133

Table 3-17. Median Saturated Hydraulic Conductivity (Ksat) Values for BLM land within the Analysis Area...........135

Table 3-18. Selected Characteristics that Affect the Fate of Herbicides ...................................................................136

Table 3-19. Effects of herbicides available under all alternatives(Water) ................................................................142

Table 3-20. Effects of herbicides available under the Proposed Action and Alternative 3 (Water)..........................145

Table 3-21. Effects of herbicides available only under Alternative 3 (Water)...........................................................146

Table 3-22. Summary of Effects (Water) ...................................................................................................................147

Table 3-23. Coos Bay-Administered Lands by Historic Fire Regime Group ...............................................................150

Table 3-24. Ground Disturbing/Non-Ground Disturbing Actions..............................................................................151

Table 3-25. Direct Costs of Invasive Plant Treatments, by Gross Acre ......................................................................157

Table 3-26. Average Direct Cost of Treatments.........................................................................................................158

Table 3-27. Summary of Effects (Implementation Cost Issue 1) ...............................................................................159

Figures

Figure 2-1. Gross and Net Treatment Acres ................................................................................................................26

Figure 2-2. Western Snowy Plover Habitat Restoration Areas (North Spit and New River)........................................49

Figure 2-3. Water Basins on the Coos Bay District ......................................................................................................74
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Table of Contents

8

Figure 3-1. Relationship between Area Occupied by Invasive Plant Species and Time...............................................84

Figure 3-2. Bureau Sensitive Species Treatment Conditions.......................................................................................86

Maps

Maps are located in a separate downloadable file available on the ePlanning website or at the end of this printed 

document.

Map 1-1. Land Administration

Map 2-1. Invasive Plants Documented in NISIMS

Map 2-2A. Routes of Invasive Plant Spread: Recreation Sites and Waterways

Map 2-2B. Routes of Invasive Plant Spread: Ground Transportation Network

Map 2-2C. Routes of Invasive Plant Spread: Utility Corridors and Water Developments

Map 3-1. Depth of Ground Water

Map 3-2. Saturated Hydraulic Conductivity
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

9

Chapter 1 – Purpose and Need

The Coos Bay District manages approximately 311,942 acres of public lands located primarily in Curry, Coos and 

Douglas Counties with smaller portions in Josephine and Lane Counties1 (see Map 1-1; maps are located at the end 

of this printed document or in a separate downloadable file, available on the Bureau of Land Management (BLM) 

ePlanning website). The District is proposing to update its 

existing integrated noxious weed management program on 

these lands. The District currently controls noxious weeds 

following existing BLM policy and direction and a district-wide 

1997 Integrated Noxious Weed Program on the Coos Bay 

District Environmental Assessment (EA) and Decision Record, 

using a range of methods including manual (hand-pulling), 

mechanical (mowing, string trimmers, discing), biological 

control agents, targeted grazing, competitive seeding and 

planting, prescribed fire, and herbicides (primarily glyphosate, 

but also limited amounts of 2,4-D, dicamba, and picloram).

The District proposes to update and expand this program by:

• Broadening the scope of the program to include terrestrial invasive plants as well as noxious weeds;

• Increasing the herbicide active ingredients2 available for use; and,

• Using additional non-herbicide control methods, including weed barrier mats and propane torch spot 

treatments.

The proposed updates to the 1997 plan allow the use of treatment methods that are generally more selective, 

provide better control, and have fewer adverse environmental effects. The additional herbicides are generally 

effective at lower rates, control a wider range of invasive plants species, decrease the potential for herbicide 

resistance, and can be used to make associated non-herbicide methods more available and more effective (USDI 

2010b:19-25). Allowing the treatment of all invasive plants permits the District to protect resources threatened by 

species that are not listed as noxious weeds. This would better align the program with the principles of integrated 

pest management: protecting, maintaining, and restoring ecologically diverse and properly functioning native plant 

communities on public lands (USDI 2008a).

The additional herbicides, and their use on all invasive plants, were addressed in:

• The 2007 Final Programmatic Environmental Impact Statement (2007 PEIS) and Record of Decision for 

Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States (USDI 2007a, b).

• The 2010 Final Environmental Impact Statement (Oregon FEIS) and Record of Decision for Vegetation 

Treatments Using Herbicides on BLM Lands in Oregon (USDI 2010a, b).

• The 2016 Final Programmatic Environmental Impact Statement (2016 PEIS) and Record of Decision for 

Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron (USDI 2016a, b).

 1 Approximately 3,740.5 acres of the Coos Bay District are administered by the Medford District. The effects of BLM’s invasive 

plant program on these acres were analyzed in the Medford District’s 2018 Integrated Invasive Plant Management Revised EA

(USDI 2018a). 2 The herbicide active ingredient (e.g., glyphosate) is the part of an herbicide formulation or product (e.g., RoundUp) that 

destroys, repels, desiccates, or otherwise controls the target plant. In this EA, herbicides are referred to by their active 

ingredient name rather than their product names. A full list of current product names that can be used on BLM-managed lands 

can be found in Appendix B.

Invasive plants are nonnative aggressive plants with 

either the potential to cause significant damage to 

native ecosystems, cause significant economic 

losses, or both.

Noxious weeds are a subset of invasive plants that 

are County-, State-, or federally-listed as injurious to 

public health, agriculture, recreation, wildlife, or 

any public or private property.

Thus, the term “invasive plants” includes noxious 

weeds in this EA (Oregon FEIS – USDI 2010a).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

10

A 1984 U.S. District Court injunction, amended in 1987, had limited the BLM to using only four herbicides and 

restricting their use to noxious weeds only (USDI 2010a:3). This injunction was amended following completion of 

the 2010 Oregon FEIS and Record of Decision permitting the use of additional herbicides and targeting additional 

species once site-specific National Environmental Policy Act (NEPA) analysis was completed.3 These analyses must 

be tiered to the Oregon FEIS, the 2007 PEIS, or subsequent analysis4 at the national or state level.

This EA examines the environmental effects of BLM’s proposal to expand and update its integrated weed 

management program at a site-specific scale within the District. It will replace the Coos Bay District’s 1997 

Integrated Noxious Weed Program on the Coos Bay District Environmental Assessment (USDI 1997).

The chapter starts with a Need section, followed by a Purposes section, which briefly specifies the underlying 

purpose and need to which the agency is responding with its alternatives in Chapter 2. Following that, an Issues

section presents the issues that will guide the analysis in Chapter 3. The Decision to be Made section presents how 

the District Manager will determine a decision, as well as the scope of that decision. The Public Involvement

section describes the scoping and public comment periods, and the Consultation section describes specific 

consultation requirements that occur with regards to Tribes, cultural resources, and federally listed species. The 

Tiering and Reference section describes programmatic NEPA and the Resource Management Plan that this EA tiers 

to, as well as other documents that the EA references. The last section of this chapter, Conformance with Land Use 

Plans, Laws, Policies, and Other Decisions, presents other direction that guides the analysis or decision.

The Need

Species of terrestrial invasive plants on the District have been mapped on over 18,000 gross5 acres (over 2,000 net 

acres) in over 19,000 separate known locations6

, with individual locations ranging from a few plants to a 251-acre 

site (net) of Himalayan blackberry (Rubus armeniacus). In addition, there are tens of thousands of acres of 

unmapped invasive plants known on the District; for example, European beachgrass (Ammophila arenaria) is 

estimated to occupy over 1,500 acres. Despite the efforts of the existing noxious weed program, noxious weeds7

are continuing to spread at an estimated rate of 10 percent per year (USDI 2010a:595).

For some noxious weed species such as Canada thistle (Cirsium arvense), neither non-herbicide methods nor the 

four herbicides currently available on the District provide effective control. The existing program also does not 

have an effective method for selectively8 controlling a host of other invasive plants that are not noxious weeds, 

such as wild radish (Raphanus species), false dandelions (Hypochaeris species), big quakinggrass (Briza maxima), 

ripgut brome (Bromus rigidus), or reed canarygrass (Phalaris arundinaceae).

Herbicides that are more selective are available to treat invasive plants. These herbicides are effective at lower 

quantities and pose less environmental and human health safety risk9 than the herbicides the BLM is currently 

authorized to use (USDI 2010a:80 and others). Furthermore, if these additional herbicides could be used on the 

 3 In addition, the injunction states that BLM shall not aerially spray herbicides west of the Cascade crest and shall not spray 

herbicides for the production of livestock forage or timber production.

4 Such as the 2016 PEIS.

5Gross acres are the area of land defined by drawing a line around the general perimeter of the infestation; the net acres are 

the actual acres of canopy cover of the plants. 6 Summarized on Table 2-1 in Chapter 2. 7 Noxious weeds are a subset of invasive plants that are County, State, or federally listed as injurious to public health, 

agriculture, recreation, wildlife, or any public or private property.

8 Non-selective herbicides can be used to treat any plant species; however, that can make it difficult to target an invasive plant 

species growing among desirable species. Selective herbicides control specific plant species, while leaving neighboring desired 

plant species unaffected.

9 Risk is defined as the likelihood that an adverse effect (such as skin or eye irritation, leaf damage, mortality, etc.) may result 

from a specific set of circumstances.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

11

Coos Bay District, it is estimated that the efficacy of BLM’s invasive plant treatment would improve from 60 

percent under the No Action Alternative to 80 percent under the Proposed Action (USDI 2010a:136).

In addition, there are invasive plants on neighboring (non-BLM-managed) lands that may spread to BLM-managed 

lands at any time. Adverse effects of invasive plants include resource loss or degradation of ecosystem function 

including displacement of native vegetation; reduction in habitat and forage for wildlife; loss of habitat for 

federally listed and other Special Status species; reduced water quality; and reduced wilderness and recreation 

values (USDI 2010a:7). Invasive plant infestations are also responsible for economic losses. A 2014 Oregon 

Department of Agriculture (ODA) report estimates that 25 of Oregon’s noxious weeds cost the State an estimated 

83.5 million dollars a year (ODA 2014). While much of this loss is to agricultural areas, invasive plants on BLMmanaged lands may spread to adjacent non-BLM-managed lands, increasing control costs for affected landowners 

and degrading land values. For the past several decades, the BLM has participated in cooperative invasive plant 

control efforts with other private, governmental, and non-governmental entities, such as adjacent timber owners, 

the Oregon Department of Agriculture, and the Coos, Coquille, and Curry Watershed Associations. However, the 

BLM’s current inability to use herbicides commonly used on adjacent lands results in less effective control and 

coordination challenges.

Executive Order 13112 (February 1999, amended December 2016) requires Federal agencies to “(i) prevent the 

introduction of invasive species; (ii) detect and respond rapidly to and control populations of such species in a costeffective and environmentally sound manner; (iii) monitor invasive species populations accurately and reliably; 

[and] (iv) provide for restoration of native species and habitat conditions in ecosystems that have been invaded...”

All of the foregoing factors indicate that there is a need for a more effective invasive plant control program.

The Purposes

The District proposes to update its existing noxious weed management program to more effectively—

• Control invasive plants to protect native ecosystems and the flora and fauna that depend on them.

• Cooperatively control invasive plants so they do not infest or re-infest adjacent non-BLM-managed lands.

• Provide a range of direct control methods that allow individual treatments in varying conditions to have 

more effective control of invasive plants.

• Prevent treatments from having unacceptable adverse effects to applicators and the public, to desirable 

flora and fauna, and to soil, air, and water.

• Improve treatment effectiveness, so resource and economic losses from invasive plants are reduced.

Each of these purposes is addressed by one or more of the issue statements listed below and they are used to 

guide the effects analysis in Chapter 3. Additional background information for each of these purposes can be found 

in the Oregon FEIS (USDI 2010a:9-12).

Issues

The issues identified during internal (BLM) and external (public) scoping were used to guide the effects analysis in 

Chapter 3.

Issues are analyzed when—

● Analysis is necessary for making a reasoned choice from among the alternatives in determining:

o How well the proposed action or alternatives responds to the purpose and need, or

o If there is a meaningful difference between alternatives with respect to the issues analyzed;
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

12 

● Analysis is necessary to determine the potential for significant environmental effect.

Several issues identified during internal and external scoping were considered but not analyzed in detail in this EA. 

In general, the issues not analyzed in detail in this EA have already been addressed in documents to which this EA 

tiers and a) there is not enough difference between the alternatives relative to the issue for additional analysis to 

aid the decision-maker and b), there is negligible likelihood of significant effects due to the requirement to 

implement Protection Measures (see Appendix A, Protection Measures). In the list below, the issues are framed as 

questions. Further information about the following issues (both those analyzed in detail and not analyzed in detail) 

is included in Chapter 3.

Issues Analyzed in Detail

Invasive Plants

• Issue 1: How does the availability of additional herbicides under each alternative affect treatment 

effectiveness for individual invasive plant species?

Native Vegetation

• Issue 1: How would treatment methods affect unique plant communities in Areas of Critical 

Environmental Concern (ACECs) and other areas with Special Status plant species?

Wildlife

• Issue 1: How would mechanical and herbicide treatment methods affect the western snowy plover?

Water Quality

• Issue 1: How would herbicide use affect the quality of surface water and groundwater used for domestic 

water supply? 

Implementation Cost

• Issue 1: How would the increased availability of herbicides to treat European beachgrass in western 

snowy plover habitat restoration areas under Alternative 3 affect treatment costs at the North Spit and 

New River?

Issues Not Analyzed in Detail

Invasive Plants

• Issue 2: How would invasive plant treatments under each alternative affect the spread rate of invasive 

plants?

• Issue 3: How would climate change affect the spread of invasive plants?

Native Vegetation

• Issue 2: How would invasive plant treatments, especially herbicides, affect Special Status and edible 

fungi?

• Issue 3: Even though herbicides would not be used for timber production, would more effective invasive 

plant treatments indirectly decrease or increase timber harvest volume or quality?

Fish and Aquatic Organisms 

• Issue 1: How would invasive plant treatments in riparian areas affect aquatic organisms or their habitat, 

including riparian vegetation?
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

13 

Wildlife

• Issue 2: How do invasive plants affect wildlife?

• Issue 3: How would contact with or ingestion of herbicides affect wildlife species, especially Special Status 

wildlife species?

o How would treatments affect birds (Special Status species, migratory birds, birds of conservation 

concern, and game birds below desired conditions) that may use potential treatment areas, 

especially during the nesting season? 

o How would herbicide treatments affect insects such as the Mardon skipper?

o How would herbicide use affect pollinators, especially Special Status pollinators?

Human Health

• Issue 1: What are the effects to human health from incidentally coming into contact with herbicides used 

on BLM-managed lands?

o What are the human health effects to people who regularly consume or come in contact with 

contaminated vegetation, water, or wildlife? How would herbicide use affect the health of 

people gathering, handling, ingesting plants, fish, or wildlife, or handling fossils or artifacts that 

are in or near the area of herbicide use? What are the human health and safety hazards to those 

harvesting and consuming special forest products, such as greenery, herbs, berries, and 

mushrooms?

o What are the human health hazards to susceptible members of the public (including children, 

pregnant women, the elderly, sick people, and those with chemical-sensitive conditions)

associated with herbicide applications?

o What are the human health effects of herbicides applied near natural springs, private wells, and 

irrigation sources?

• Issue 2: What are the hazards to workers treating invasive plants?

• Issue 3: What are effects to human health of mixing two or more herbicides? Are these combinations 

more toxic than herbicides used individually?

• Issue 4: What are effects to human health of using glyphosate, which the International Agency for 

Research on Cancer (IARC) recently declared a cancer hazard and California lists as cancer causing and 

may be linked to non-Hodgkin lymphoma and leukemia?

Soil

• Issue 1: Would invasive plant treatments lead to increased soil compaction and erosion?

• Issue 2: How do herbicides break down and move through soils?

• Issue 3: Do herbicides affect soils?

Air Quality

• Issue 1: How would the alternatives affect air quality?

• Issue 2: How would the alternatives affect climate change, including greenhouse gas emissions and 

carbon storage?

Fire

• Issue 1: How would the treatment of invasive plants affect fuel loading?

Archeological and Cultural Resources

• Issue 1: How would treatment of invasive plants affect historic and prehistoric cultural sites?

Traditional and Cultural Uses

• Issue 1: How would the treatment of invasive plants affect plant resources used by Native Americans for 

medicinal, subsistence, ceremonial, or other purposes, given that these plants (or their locations) may not 

be known by the BLM?
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

14 

Socioeconomics

• Issue 1: What are the economic impacts of invasive plants on the Coos Bay District on local area timber 

production, agriculture, and recreation?

• Issue 2: Given the checkerboard land ownership pattern, what is the potential for herbicide 

contamination of yards, gardens, organic farms, vineyards, and beehives on private lands?

• Issue 3: How would the alternatives affect permitted land uses, including rights-of-way and administrative 

site grant and leaseholders?

• Issue 4: How and when will the public and Tribes be notified of herbicide application? 

Recreation

• Issue 1: How would herbicide treatments at recreation sites affect visitor access and recreational 

experiences?

• Issue 2: What are the effects of herbicides on horses, dogs, and other pets that accompany recreationists?

Decision to Be Made

The decision whether to adopt the Proposed Action or a different alternative and whether to modify the action 

based on environmental analysis and any other factors identified during public review of this EA and unsigned 

Finding of No Significant Impact will be made by the District Manager for the Coos Bay District. The decision-maker 

will make the decision based on the analysis of the issues and how well the alternatives respond to the need and 

purposes. The decision-maker will also decide whether the analysis reveals a likelihood of significant adverse 

effects from the selected alternative that cannot be mitigated or that were not already revealed in one or more of 

the Environmental Impact Statements that this EA tiers to. The decision would apply to all invasive plant control 

activities conducted on BLM-managed lands within the Coos Bay District10 (henceforth, District) by its own 

personnel, contractors, grant holders, lessees, cooperators, and others conducting activities on BLM-managed 

lands. 

Additional consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service would be 

required if the BLM decides to adopt Alternative 3 in listed anadromous fish, western lily, or western snowy plover 

habitat. Further information can be found in the Consultation section, later in this chapter. 

Public Involvement

Scoping

Scoping is the process by which the BLM solicits internal and external input on the issues, impacts, and potential 

alternatives that will be addressed as well as the extent to which those issues and impacts will be analyzed in the 

NEPA document. Scoping comments, along with other pertinent information, were used to help develop the 

purposes, issues, and alternatives in this EA.

The BLM sent a scoping letter to interested members of the public in June 2011, and six scoping responses were 

received. Comments received in 2011 focused on the effects of invasive plants (including effects to native species 

and wildlife, as well as socioeconomic effects), the effects of herbicides, or suggested reducing or eliminating 

herbicide use and changing land management practices. Concerns about herbicides were related to human health 

 

10 With the exception of the portion of the District managed by the Medford District, which is addressed in that District’s 2018 

Integrated Invasive Plant Management Plan. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

15

and the unintended effects of herbicides on native vegetation, neighboring private land uses, soil, water, air, and 

wildlife.

The BLM reopened scoping from April 10, 2017 through May 10, 2017 due to the lag in time since initiation of 

scoping and changes to the Proposed Action. Letters were sent to approximately 60 individuals, agencies, and 

organizations, including those who commented in 2011, and posted on the BLM’s ePlanning website. The District 

received no comment letters in response to the 2017 scoping letter.

Public Comment Period

This EA was made available for a 30-day public comment period (July 2018) on BLM’s ePlanning site and interested 

members of the public were notified of the availability of the EA for review. This mailing list is contained in the 

project record file. Two comment letters were received. Umpqua Watersheds acknowledged the need to treat 

invasive plants and encouraged caution and restraint in the use of herbicides, particularly 2,4-D, picloram, and 

dicamba. The Coquille Indian Tribe offered comments as described below in the Consultation section. 

Consultation

Tribes

The BLM initiated Tribal consultation in 2009 with letters to the Coquille Indian Tribe and the Confederated Tribes 

of Coos, Lower Umpqua and Siuslaw Indians. Additional letters were sent in June 2011 to the same groups. The 

letters described the proposed EA, announced that scoping would begin, and invited the Tribes to enter into 

government-to-government consultation. Following a delay in the preparation of this EA, the District contacted 

these Tribes again in May 2017 and described the purpose and need and the alternatives and invited the Tribes to 

enter into government-to-government consultation and be involved with the process. The BLM contacted the 

following Tribes: Coquille Indian Tribe; Confederated Tribes of Coos, Lower Umpqua and Siuslaw Indians;

Confederated Tribes of Grand Ronde; Confederated Tribes of Siletz; Cow Creek Band of Umpqua Tribe of Indians;

and, Tolowa Dee-ni' Nation Tribes in March 2018. Depending on Tribal staff availability, conversations occurred in 

person and via telephone or resulted in voice messaging to invite discussion regarding the project and if the Tribes 

were interested in reviewing the EA. Tribes who were directly contacted or expressed an interest in the project 

are: Coquille Indian Tribe; Confederated Tribes of Coos, Lower Umpqua and Siuslaw Indians; Confederated Tribes 

of Grand Ronde; and Tolowa Dee-ni' Nation. Discussions focused on developing Tribal consultation strategies that 

would allow adequate time for notification prior to invasive plant treatments. The consultation process would 

introduce locations proposed for integrated invasive plant management and work toward determining Tribal areas 

of concern, which would be refined as needed. The EA was also sent to these Tribes for a 6-week review period 

beginning June 27, 2018. In early August, the Confederated Tribes of Coos, Lower Umpqua and Siuslaw Indians met 

with BLM staff to discuss their potential concerns about effects to cultural resources associated with herbicide use.

The meeting included a field trip to a North Spit site, where invasive plants and their potential treatments were 

discussed. In addition, the Coquille Indian Tribe Historic Preservation Officer submitted comments referring to a 

Memorandum of Understanding signed between the Tribe and the BLM to avoid herbicide use where the Tribe 

manages for cultural plants. Additional consultation with the federally recognized Tribes will be conducted if Tribes 

desire, which could include face-to-face meetings with the Tribes. Tribal consultation would include an emphasis 

on identifying traditional gathering areas, species of culturally significant plants, and the effects of herbicide use on 

plant populations of interest to the Tribes.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

16

State Historic Preservation Office

As part of BLM’s requirements under Section 106 of the National Historic Preservation Act and its implementing 

regulations found at 36 CFR 800 (as amended), consultation with the State Historic Preservation Office (SHPO) 

would be conducted on the District’s Annual Treatment Plans prior to implementing any treatments that have the 

potential to adversely affect cultural resources.

The BLM will follow the 2015 State Protocol between the Oregon BLM and the Oregon SHPO regarding the manner 

in which the Bureau of Land Management will meet its responsibilities under the National Historic Preservation Act

and the National Programmatic Agreement among the BLM, the Advisory Council on Historic Preservation, and the 

National Conference of State Historic Preservation Officers (Oregon SHPO and USDI 2015). As part of the annual 

treatment plan review (see Chapter 2), a cultural resource specialist would review each treatment application 

(project) to determine whether fieldwork is required to identify cultural resources, and if additional protection 

measures would be needed.

Endangered Species Act

The Coos Bay District has seven federally listed species that are known to occur on the District (see Table 1-1) 11.

Table 1-1. Listed Species on the Coos Bay District 

Taxon Common Name Scientific Name Population Status

Plant Western lily Lilium occidentale Endangered

Bird Marbled murrelet Brachyramphus marmoratus Threatened

Bird Western snowy plover Charadrius nivosus Pacific Coastal Population Threatened

Bird Northern spotted owl Strix occidentalis caurina Threatened

Anadromous Fish Coho Salmon Oncorhynchus kisutch S. Oregon/N. California Coast Threatened Oregon Coast

Anadromous Fish Green Sturgeon Acipenser medirostris Southern Threatened

Anadromous Fish Pacific Eulachon Thaleichthys pacificus Southern DPS Threatened

Formal and informal consultation that covers herbicides and other invasive plant treatments on the Coos Bay 

District has occurred with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) on 

numerous occasions (see Table 1-2). The BLM submits annual reports to the Services in compliance with these 

consultations at both the State- and District-level.

Table 1-2. Endangered Species Act Consultation

Program and Biological Assessment Agency - Area Year Consultation

Vegetation Treatments Using Herbicides on BLM Lands in 

17 Western States PEIS (USDI 2007a) and Vegetation 

Treatments on BLM Lands in 17 Western States 

Programmatic Environmental Report (USDI 2007d) and 

Vegetation Treatments on BLM Lands in 17 Western States 

Biological Assessment (USDI 2007c)

BLM - 17 Western 

States 2007 Letter of Concurrence (FWS)Biological Opinion (NMFS)

Biological Assessment of the BLM’s North Spit Plan as it 

may affect the Threatened Western Snowy Plover and its 

Critical Habitat (USDI 2007f)

BLM - Coos Bay 

District, North Spit

2008-2018, 

extended to 

2022

Biological Opinion (FWS)

Biological Assessment of the Effects of the New River 

Foredune Management Project (USDI 2009b)

BLM - Coos Bay 

District, New River 

ACEC

2009 Letter of Concurrence 

(NMFS)

 11 More information about the effects to these species can be found in Native Vegetation Issue 1 (for federally listed plants), 

Fish and Aquatic Organisms Issue 1 (for federally listed fish), and Wildlife Issue 2 (for the federally listed birds).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

17

Program and Biological Assessment Agency - Area Year Consultation

Vegetation Treatments Using Herbicides on BLM Lands in 

Oregon (USDI 2010a) and Vegetation Treatments on BLM 

Lands in 17 Western States Biological Assessment (USDI 

2007c)

BLM - Oregon 2010 Letter of Concurrence (FWS)

Biological Opinion (NMFS)

Management of the Western Snowy Plover on Federal 

Lands Within the New River Area of Critical Environmental 

Concern during the 2011-2021 Nesting and Wintering 

Seasons (USDI 2011)

BLM – Coos Bay 

District, New River 

ACEC

2011-2021 Biological Opinion (FWS)

Aquatic Restoration Biological Assessment II (USDA et al. 

2013, NMFS 2013)

BLM and Forest 

Service - OR, WA, 

plus parts of CA, 

NV, and ID

2013

Aquatic Restoration 

Biological Opinion (ARBO II –

FWS and NMFS)

Fiscal Years 2014-2018 Programmatic Suite of Activities 

that May Affect Spotted Owls, Murrelets and their 

designated Critical Habitats Proposed by The Coos Bay 

District BLM and the Coquille Indian Tribe Biological 

Assessment (USDI 2014a)1

BLM - Coos Bay 

District 2014 - 2018 Biological Opinion (FWS)

Vegetation Treatments Using Aminopyralid, Fluroxypyr, and 

Rimsulfuron PEIS (USDI 2016a) and Biological Assessment 

(USDI 2016c)

BLM - 17 Western 

States

2015 and 

2016

Letter of Concurrence (FWS)

Biological Opinion (NMFS)

1. Amended by the 2016 Programmatic Suite of Activities that May Affect Spotted Owls, Murrelets and their designated Critical Habitats 

Proposed by The Coos Bay District BLM and the Coquille Indian Tribe Biological Opinion (USDI 2016f).

Consultation resulted in Conservation Measures and Project Design Criteria identified to protect Coos Bay District 

listed species from treatments. These are listed in Appendix A, in the Protection Measures for Federally Listed 

Species section. More details about the 2007, 2008, 2010, 2011, 2013, 2014, and 2016 consultations can be found 

at the start of that section.

Additional consultation with the National Marine Fisheries Service and the U.S. Fish and Wildlife Service would 

occur before the BLM could select and implement Alternative 3. Specifically—

Additional consultation with the National Marine Fisheries Service would occur if—

• The use of hexazinone, fluroxypyr, rimsulfuron, or fluazifop-P-butyl is proposed within 1,500 feet of listed 

fish habitat12.

Additional consultation with the U.S. Fish and Wildlife Service would occur if—

• Any herbicide use is proposed in western snowy plover habitat, with the exception of 24 acres annually of 

glyphosate on the Coos Bay North Spit that was addressed in 2007 consultation (see Table 1-2).

• The use of hexazinone, fluroxypyr, rimsulfuron, or fluazifop-P-butyl is proposed within the same 

watershed13 as western snowy plover or western lily habitat.

The Proposed Action and Alternative 3 are not expected to adversely affect the northern spotted owl or the 

marbled murrelet. Effects to these species are not anticipated because proposed invasive plant treatments would 

not modify habitat for either species and would not affect the owl’s prey species. Potential disturbance near nest 

sites is not anticipated because projects are usually short in duration, spatially limited, and affected areas receive 

baseline disturbance from vehicle traffic and other activities. These species would likely be acclimated to the 

potential noise disturbance associated with invasive plant treatments.

 12 As determined by consultation with NMFS for the 2010 Oregon FEIS. More information can be found in the Protection 

Measures for Federally Listed Species section of Appendix A. 13 Fifth field hydrological unit code (HUC).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

18

Tiering and Reference

Tiering refers to the coverage of general matters in broader environmental impact statements with subsequent 

narrower statements or environmental analyses. Tiering allows agencies to narrow the range of alternatives, 

narrow the scope of analysis, and reach a Finding of No Significant Impact for an action that may have significant 

impacts. This allows incorporation by reference of the general discussions, so as to concentrate solely on the issues 

specific to the statement subsequently prepared (40 CFR 1508.28). For its analysis of herbicide effects, this EA tiers 

to three EISs, all completed at the state or national level. This EA tiers to the 2007 PEIS and Record of Decision for 

Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States (USDI 2007a, b) for the use of 

chlorsulfuron (west of the Cascades) and the use of fluazifop-b-butyl for research and demonstration purposes. In 

addition, this EA tiers to the Final Programmatic EIS for Vegetation Treatments Using Aminopyralid, Fluroxypyr, 

and Rimsulfuron (USDI 2016a, b), for the use of those three herbicides. For the remaining herbicides analyzed in 

this EA, this EA tiers to the 2010 Final Environmental Impact Statement (Oregon FEIS) and Record of Decision for 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon (USDI 2010a, b).

For its non-herbicide treatments, this EA tiers to the 1985 Northwest Area Noxious Weed Control Program Final EIS 

and 1987 Supplement (USDI 1985, 1987). This EA also incorporates by reference elements of the 2007 Vegetation 

Treatments on BLM Lands in 17 Western States Programmatic Environmental Report, which describes the 

integrated vegetation management program and discloses the general effects associated with non-herbicide 

control methods (USDI 2007d).

The EA also tiers to the Proposed Resource Management Plan and Final Environmental Impact Statement for 

Resource Management Plans for Western Oregon (USDI 2016e), which contains analysis of invasive plant control 

activities. Where relevant to specific effects, the analysis in Chapter 3 will tier to this document (see Fire, 

Archaeological and Cultural Resources, Traditional and Cultural Uses (Native American Interests), and 

Socioeconomics Issues).

Conformance and Consistency with Land Use 

Plans, Laws, Policies, and Other Decisions

BLM’s integrated invasive plant management program is the product of decades of laws, Executive orders, and 

BLM and Department of the Interior policies and direction. Several Federal laws direct the BLM to aggressively 

manage invasive plants and other vegetation to improve ecosystem health. Section 302(b) of the Federal Land 

Policy and Management Act of 1976 directs BLM to “take any action necessary to prevent unnecessary or undue 

degradation of the lands” (43 U.S.C. § 1732(b)(2)). Executive Order 13112 (February 1999, as amended December 

5, 2016) requires Federal agencies to “(i) prevent the introduction of invasive species; (ii) detect and respond 

rapidly to and control populations of such species in a cost-effective and environmentally sound manner; (iii) 

monitor invasive species populations accurately and reliably; [and] (iv) provide for restoration of native species and 

habitat conditions in ecosystems that have been invaded...” In particular, the Carlson-Foley Act of 1968 (43 U.S.C. 

§§ 1241-1243), the Plant Protection Act of 2000 (7 U.S.C. § 7702) and the Noxious Weed Control and Eradication 

Act of 2004 (7 U.S.C. § 7781) authorize the BLM to manage noxious weeds and to coordinate with other Federal 

and State agencies in activities to eradicate, suppress, control, prevent, or retard the spread of any noxious weeds 

on Federal lands. (The Plant Protection Act replaced, in part, the Federal Noxious Weed Act of 1974 (7 U.S.C. § 

2814(a)), which established a program to manage undesirable plants, implemented cooperative agreements with 

State agencies, and established integrated management systems to control undesirable plant species.)
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

19

Land Use Plans on the Coos Bay District

The Federal Land Policy and Management Act (1976) requires that all management decisions be consistent with 

the approved land use plan (43 CFR 1610.5-3). Management activities on the Coos Bay District are covered by the 

Northwestern and Coastal Oregon Resource Management Plan and Record of Decision (USDI 2016d).

Northwestern and Coastal Oregon Resource Management Plan

The Northwestern and Coastal Oregon Resource Management Plan provides direction for the management of all 

resources on BLM-managed lands in the Coos Bay District, Northwest Oregon District, and the Swiftwater Field 

Office of the Roseburg District. Goals and management direction related to invasive species management are 

included in the following sections of the Resource Management Plan. This EA is consistent with the objectives and 

directions of the Resource Management Plan.

Invasive Species

Management Objective (USDI 2016d:80)

• Prevent the introduction of invasive species and the spread of existing invasive species infestations.

Management Direction (USDI 2016d:80)

• Implement measures to prevent, detect, and rapidly control new invasive species infestations.

• Use manual, mechanical, cultural, chemical, and biological treatments to manage invasive species 

infestations.

• Treat invasive plants and host species for invasive forest pathogens in accordance with the Records of 

Decision for the Northwest Area Noxious Weed Control Program Environmental Impact Statement (USDI 

1985, 1987) and the Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 

Oregon Environmental Impact Statement (USDI 2010a).

District-Designated Reserve – Areas of Critical Environmental Concern

Management Objective (USDI 2016d:57)

• Maintain or restore relevant and important values in Areas of Critical Environmental Concern, including 

Research Natural Areas and Outstanding Natural Areas.

Management Direction (USDI 2016d:57)

• Implement activities as necessary to maintain, enhance, or restore relevant and important values.

District-Designated Reserve – Lands Managed for their Wilderness Characteristics

Management Direction (USDI 2016d:58)

• Allow mechanical vegetation treatment consistent with Visual Resource Management Class II for the 

purpose of improving ecological condition, contributing to threatened or endangered species recovery, or 

enhancing long-term wilderness characteristics.

• Allow trail construction and maintenance, fuels treatments, invasive species management, riparian or 

wildlife habitat improvements, forest management, and other vegetation management only if any 

reductions in wilderness characteristics are temporary and wilderness characteristics are protected over 

the long term.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

20

Riparian Reserve

Management Objective (USDI 2016d:68)

• Contribute to the conservation and recovery of ESA [Endangered Species Act]-listed fish species and their 

habitats and provide for conservation of Bureau Special Status fish and other Bureau Special Status 

riparian-associated species.

• Maintain and restore natural channel dynamics, processes, and the proper functioning condition of 

riparian areas, stream channels, and wetlands by providing forest shade, sediment filtering, wood 

recruitment, stream bank and channel stability, water storage and release, vegetation diversity, nutrient 

cycling, and cool and moist microclimates.

• Maintain water quality and streamflows within the range of natural variability, to protect aquatic 

biodiversity, provide quality water for contact recreation and drinking water sources.

• Meet Oregon Department of Environmental Quality (ODEQ) water quality criteria.

• Maintain high quality water and contribute to the restoration of degraded water quality for 303(d)-listed 

streams.

• Maintain high quality waters within ODEQ-designated Source Water Protection watersheds.

Hydrology

Management Objective (USDI 2016d:79)

• Maintain water quality within the range of natural variability that meets ODEQ water quality standards for 

drinking water, contact recreation, and aquatic biodiversity.

Rare Plants and Fungi

Management Objective (USDI 2016d:86)

• Support the persistence and resilience of natural communities, including those associated with forests, 

oak woodlands, shrublands, grasslands, cliffs, rock outcrops, talus slopes, meadows, and wetlands. 

Support ecological processes and disturbance mechanisms to allow for a range of seral conditions.

Management Direction (USDI 2016d:87)

• Maintain or restore natural processes, native species composition, and vegetation structure in natural 

communities through actions such as applying prescribed fire, thinning, removing encroaching vegetation, 

treating non-native invasive species, retaining legacy components (e.g., large trees, snags, and down logs), 

maintaining water flow to wetlands, and planting or seeding native species.

Soil Resources

Management Direction (USDI 2016d:89-90)

• Apply BMPs [Best Management Practices] (Appendix C [of the Resource Management Plan]) as needed to 

maintain or restore soil functions and soil quality, and limit detrimental soil disturbance.

• Limit detrimental soil disturbance from forest management operations to a total of < 20 percent of the 

harvest unit area. Where the combined detrimental soil disturbance from implementation of current 

forest management operations and detrimental soil disturbance from past management operations 

exceeds 20 percent of the unit area, apply mitigation or amelioration to reduce the total detrimental soil 

disturbance to < 20 percent of the harvest unit area. Detrimental soil disturbance can occur from erosion, 

loss of organic matter, severe heating to seeds or microbes, soil displacement, or compaction.

• Do not till soils where tillage will cause soils to become unstable due to increasing the soil moisture 

content.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

21

Other Management Plans on the Coos Bay District

North Spit Plan (2005)

This EA is consistent with the North Spit Plan (USDI 2005), which provides the current direction for comprehensive 

management of the North Spit. Prior planning efforts by BLM for the North Spit include the Coos Bay Shorelands 

Draft Management Plan (USDI 1989) and the Coos Bay Shorelands Draft Management Plan and Environmental 

Assessment (USDI 1994). The 2005 update reflects changes in land ownership and environmental conditions. A 

portion of the BLM-managed lands on the North Spit is designated as an Area of Critical Environmental Concern 

(725 acres) primarily for the conservation of its outstanding biological values with a unique assemblage of habitats 

in a relatively confined area including estuarine, fresh water wetlands, mudflats, and forested uplands. The Spit 

was also designated as an ACEC for its cultural and historic resources, and its scenic value to the communities of 

North Bend and Coos Bay. The Spit is also a Special Recreation Management Area with specific recreational 

activities and experience opportunities. The Plan identifies invasive plants as a threat to the area’s natural 

resources, displacing native vegetation and consequently diminishing habitat quality for wildlife such as the 

western snowy plover. Invasive plant species of concern include European beachgrass, brooms, gorse, Himalayan 

blackberry, English ivy, and thistles (USDI 2005:43).

BLM annually removes European beachgrass to create suitable open, sandy habitat for snowy plovers. However, 

beachgrass contributes to the stability of the area; it traps migrating sand, causing the creation and elevation of 

the foredune, which greatly increases the Spit’s stability (Beckham 2000 cited in USDI 2005:38). The threatened 

western snowy plover nests above the high tide line and behind the foredune. The North Spit provides nesting 

habitat for the largest breeding population of coastal snowy plovers in Oregon (USDI FWS 1993 cited in USDI 

2005:46).

The North Spit Plan includes the following management objectives and actions that relate to invasive plant 

management—

Vegetation and Wildlife Resources

Management Objective (USDI 2005:8):

• Conserve, enhance, or restore natural habitats, with an emphasis on habitats that support Special Status 

plant and wildlife species.

Actions Ongoing:

• Coordinate with other agencies and institutions to restore degraded and disturbed plant communities.

• European beachgrass is removed annually from plover areas.

• Continue to implement snowy plover conservation actions:

• Removing beachgrass from the inland snowy plover areas to maintain open, sandy habitat suitable for 

nesting plovers.

• Monitor plover nesting to gauge the success of management actions and progress toward plover 

recovery.

Actions Proposed:

• On the North Spit Area of Critical Environmental Concern: Implement beach and dune ecosystem 

restoration.

• Continue treatments to remove noxious and exotic species. Restore treated areas with native seeds and 

plants.

• Use best management practices to prevent the further spread of exotic plants and noxious weeds.

• Actively manage habitats to promote the conservation of Special Status species and raptors.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

22

Monitoring

Management Objective (USDI 2005:9):

• Facilitate improved management of the Spit through monitoring to learn more about the natural and 

cultural resources of the area and to assess the effects of management actions.

Actions Ongoing

• Monitor noxious weed species to document existing population areas, effectiveness of management 

actions for removal, and the spread of these species to new sites. (ongoing)

Actions Proposed:

• Track elevation changes on the ocean foredune and monitor the effects of weather and beachgrass 

removal on foredune erosion.

New River Foredune Management EA and Decision Record (2009)

This EA is consistent with western snowy plover habitat restoration plans, including the New River Foredune 

Management EA and associated Decision Record (USDI 2009a), which works towards re-establishing the 

geomorphic stability of the New River foredune.

In 1998, the BLM prepared an EA to enhance and restore habitat for the western snowy plover on lands within the 

New River ACEC. The action consisted of removing European beachgrass (a county-listed noxious weed) to provide 

open sand habitat for breeding western snowy plovers. Based on the successful response of plovers to this activity, 

another Environmental Assessment was prepared in 2000 to increase the total amount of acres available for 

treatment. However, in 2003, scientists studying the New River area started documenting sand mobilization of the 

dunes and deposition into the river channel associated with the removal of European beachgrass, which in turn 

had impacts to both western snowy plover and listed anadromous fish. The selected alternative in the 2009 EA 

develops two vegetated foredunes along the east and west edges of the New River Spit (one along the ocean and 

one along the river), which reduces the risk of shoreline change associated with western snowy plover restoration 

activities. While the District would continue to generally treat other European beachgrass in western snowy plover 

habitat, these two foredunes would be stabilized with European beachgrass (USDI 2009a). As further described in 

the Alternatives section in Chapter 2, this EA does not propose to modify the foredune re-establishment described 

and selected in the 2009 New River Foredune Management EA and Decision Record.

Other BLM Direction

State and National Environmental Analyses on Herbicide Use

This EA tiers to, and is consistent with, the 2010 Oregon FEIS and Record of Decision. The Record of Decision 

requires, with a few specific exceptions14, the preparation of new site-specific analyses before herbicides other 

than 2,4-D, dicamba, glyphosate, or picloram can be used (USDI 2010b). This EA provides the site-specific analysis 

for the Coos Bay District. The alternatives (including the No Action Alternative) must adhere to restrictions (USDI 

2010b:30), which include:

• Standard Operating Procedures from the 2007 PEIS.

 14 Exceptions include NEPA analyses done for the Tyrrell and Horning seed orchards (on the Northwest Oregon District), the 

Provolt and Sprague seed orchards (on the Medford District), and an EA for Sudden Oak Death on the Coos Bay District (USDI 

2010b:30).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

23

• Mitigation Measures15 from the 2007 PEIS.

• Conservation Measures for Special Status species from the 2007 PEIS Biological Assessment.

• Mitigation Measures from the 2010Oregon FEIS Record of Decision.

• Typical and maximum herbicide application rates analyzed in the 2010 Oregon FEIS.

In addition, this EA is consistent with the 2016 PEIS and Record of Decision. All of the alternatives (including the No 

Action Alternative) must adhere to the Mitigation Measures and Conservation Measures adopted with the 2016 

Record of Decision (USDI 2016b), and these are also included in Appendix A (Protection Measures) of this EA.

Integrated Vegetation Management (BLM Handbook 1740-2)

This EA is consistent with BLM Handbook 1740-2, which guides the implementation of vegetation management 

planning and treatment activities to maintain and restore native plant communities, diversity, resiliency, and 

productivity, by combining biological, cultural, physical, and chemical tools in a way that minimizes economic, 

health, and environmental risk (USDI 2008a).

National Policy

Federal Insecticide, Fungicide and Rodenticide Act

The Federal Insecticide, Fungicide and Rodenticide Act directs Federal agencies to use an integrated pest 

management approach to manage pests (including vegetation), stating “Integrated Pest Management is a 

sustainable approach to managing pests by combining biological, cultural, physical, and chemical tools in a way 

that minimizes economic, health, and environmental risks” (7 U.S.C. § 136r-1).

Clean Water Act - Section 303(d)

Under Section 303(d) of the Clean Water Act, the Oregon Department of Environmental Quality (ODEQ) establishes 

standards for the maximum amount of a pollutant that can be received by water quality limited waterbodies in the 

State of Oregon. The Rogue and Umpqua Basins and portions of the South Coast Basin (Upper South Fork Coquille 

Watershed and Tenmile Lakes Watershed) have Total Maximum Daily Loads (TMDLs) in place as required by the 

ODEQ and Environmental Protection Agency (EPA). The BLM is required to publish a Water Quality Restoration 

Plan (WQRP) for basins with an existing TMDL. These WQRPs address how the BLM will manage land and water to

not further limit water quality as defined in the TMDL. As plans are completed, the BLM incorporates the goals, 

objectives, and provisions from the WQRP into the Coos Bay District integrated invasive plant management 

program. The goals, objectives, provisions of future WQRPs will be consistent with the action alternatives.

The Clean Water Act requires a National Pollution Discharge Elimination System (NPDES) permit for herbicide use 

that may directly enter streams. The permit is needed for herbicide treatments within three feet of streams, 

wetlands, and other seasonally wet areas when water is present, including conveyances with a hydrologic surface 

connection to a water body (e.g., near a road culvert that runs water to a creek). Treatments on small portions of 

infestations (currently mapped or detected in the future) may meet those criteria. BLM holds a NPDES Pesticide 

General Permit, which complies with ODEQ requirements for implementing any treatments in which herbicide 

could be directly introduced into surface waters. This generally includes treatment within stream banks or for 

target plants that emerge from or overhang water bodies.

 15 Mitigation Measures are practices or limitations adopted to mitigate potential adverse effects identified in the PEIS and 

Oregon FEIS analysis. Like the Standard Operating Procedures, application of the Mitigation Measures is assumed in the analysis 

in this EA, and on-site determinations would decide if their application is unnecessary to achieve the intended purpose or 

protection.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 1 – Purpose and Need

24

Federal Strategy to Promote the Health of Pollinators

On June 20, 2014, the President issued a memorandum directing the establishment of a Pollinator Health Task 

Force, chaired by the Secretary of Agriculture and Administrator of the EPA. The memorandum directs the creation 

of a National Pollinator Health Strategy with research, education, and public-private partnership objectives. It 

further directs agencies to develop plans and practices for increasing and improving pollinator habitat, including 

the use of pollinator-friendly species in future restoration and rehabilitation projects, following wildfires, and in 

landscaping. To support these habitat-focused efforts, the U.S. Department of Agriculture and the U.S. Department 

of the Interior issued a set of Pollinator-Friendly Best Management Practices for Federal Lands (USDA and USDI 

2015a), which include direction to identify and remove invasive species. Direction includes, “Management of 

invasive species may include felling by hand or machine, machine mulching, applying spot treatments of herbicide 

to bark, cut stumps, or leaves, controlled burning, mowing, or combinations of the approaches” (USDA and USDI 

2015a). The National Pollinator Health Strategy states that agencies “shall, as appropriate, take immediate 

measures to support pollinators during the 2014 growing season and thereafter. These measures may include 

avoiding the use of pesticides16 in sensitive pollinator habitats through integrated vegetation and pest 

management practices.”

The action alternatives and the analysis in this EA conform to the objectives of this new direction. Memorandumdescribed pollinator direction, as it is developed, may supplement but is not expected to conflict with treatments 

described in this EA. Standard Operating Procedures and Mitigation Measures for pollinators outlined in Appendix 

A (Protection Measures) conform with the Strategy. There is a long-term benefit to pollinators from controlling 

invasive plants and allowing native vegetation to reestablish.

EPA Ruling on Inert Ingredients

Most herbicide products contain substances in addition to the active ingredient(s) that are referred to as inert 

ingredients or sometimes as “other ingredients.” An inert ingredient generally is any substance (or group of similar 

substances) other than an active ingredient that is intentionally included in a pesticide product. Examples of inert 

ingredients include emulsifiers, solvents, carriers, aerosol propellants, fragrances, and dyes. In December 2016, the 

EPA removed 72 ingredients approved for use in pesticide products. The EPA took this action in response to 

petitions asking the agency to issue a rule requiring disclosure of 371 inert ingredients found in pesticide products. 

A full list of these ingredients is listed on the EPA website. The BLM does not use products that contain these 

ingredients. A list of the herbicides approved for use on BLM-managed lands is included in Appendix B, The 

Herbicides, Formulations, and Adjuvants.

 16 The term “pesticide” covers a wide array of chemicals and substances used to kill, repel, or control certain forms of animal or 

plant life that are considered pests. This includes insecticides, rodenticides, and even disinfectants intended to kill bacteria and 

viruses, in addition to herbicides for plants. Effects from herbicides to pollinators would generally be related to habitat loss; 

herbicides are formulated to work specifically on plants by disrupting the metabolic processes inherent in plants and not in 

other organisms.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

25

Chapter 2 – Integrated Invasive Plant 

Management and the Alternatives

This chapter begins with an Invasive Plants section, which summarizes information on infestations of invasive 

plants on the District. The Categories of Invasive Plant Infestations section describes known or estimated invasive 

plant sites to help clarify invasive plant treatments and the analysis in Chapter 3.

The Integrated Invasive Plant Management section explains how various methods are used together 

programmatically to control invasive plants. Actions taken for prevention, education, and coordination are 

described as context and do not vary between alternatives (and in fact, are not part of the alternatives). This 

section also describes direct control methods, which may vary between alternatives. Direct control methods 

include manual and mechanical treatment methods, competitive planting and seeding, prescribed fire, biological 

treatment methods (insects and targeted grazing), and herbicide application.

The Alternatives section is a detailed description of the alternatives analyzed in this EA: the No Action Alternative, 

the Proposed Action, and Alternative 3. This section outlines the key differences between these alternatives and 

lists Project Design Features to prevent unwanted effects from treatments under the action alternatives. 

Alternatives considered but not carried forward for detailed study are included at the end of Chapter 2.

Invasive Plants

An invasive plant thrives and spreads aggressively outside its natural range. An invasive plant species that colonizes 

a new area may gain an ecological edge since the insects, diseases, and foraging animals that naturally keep its 

growth in check in its native range are not present in its new habitat. The susceptibility of plant communities to 

colonization by invasive plants is influenced by many factors, including community structure, proximity to infested 

areas, and the biological and evolving genetic traits of the invading species.

Categories of Invasive Plant Infestations

The following Categories of known or estimated invasive plant sites are described here to help characterize 

invasive plant treatments and the analysis in Chapter 3.

Category I: Invasive Plants Currently Known on District

Invasive plant surveys17 on the District generally focus on locations where invasive plants are most likely to occur 

and spread from, such as road corridors and other rights-of-way, riparian areas, campgrounds, and mining and 

common materials sites. The BLM also conducts surveys in advance of planned projects, such as forest 

management projects, so that the District can take measures to prevent the introduction and spread of invasive 

plants into and from project areas. While certain surveys may be specific to invasive plant management, surveys 

conducted for other purposes also record the presence of invasive plants. Such surveys include clearance surveys 

for Special Status species or cultural resources, and inventories of special management areas, like New River and 

Dean Creek Elk Viewing Area. The BLM also maps and documents invasive plant infestations detected during 

 17 Surveys are conducted to determine if an invasive plant is present or absent in a project area. If presence is confirmed, 

inventories are completed to catalog the abundance and distribution of the invasive plants present.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

26

implementation monitoring for forest management, engineering, recreation, and other ground-disturbing projects. 

BLM policy requires monitoring of new project areas with high likelihood of noxious weed introduction18 for the 

first three years after completion (USDI 1992b).

Figure 2-1. Gross and Net Treatment Acres

Survey and inventory results are uploaded to the BLM’s National Invasive Species Information Management 

System (NISIMS), which links to BLM planning and reporting systems. NISIMS records include the infestation’s 

spatial location, size, and shape; the invasive plant’s abundance and distribution pattern; treatment records; and 

other associated characteristics. Sites where the species appears to have been eradicated are retained in NISIMS 

to guide future site monitoring. As the current program is focused on noxious weeds, most data in NISIMS concern 

noxious weeds19.

Category I includes known locations of invasive plants mapped in NISIMS on the District. The most prevalent 

species are brooms, thistles, and blackberry. As shown in Table 2-1, Category I includes 35 different invasive plant 

species mapped in NISIMS on 18,100 gross acres on 19,284 sites on the District. As shown in Figure 2-1, the gross 

infested area is the area of land defined by drawing a line around the general perimeter of the infestation, and 

does not reflect the canopy cover of the plants. This area may contain large areas of land that are not occupied by 

an invasive plant species. Net acres are the actual infestation within the area. In some areas, a large area may have 

a sparse infestation and net acres would be calculated by multiplying the gross acres by the percent cover of the 

 18 Generally, any type of project resulting in ground disturbance, such as slash/pile/burn units, timber harvest areas, road or 

bridge construction, and trail construction.

19 In 2018, the BLM made NISIMS data about invasive plant sites and treatment history accessible to the public.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

27

infestation. In addition, to the mapped acres, this Category includes species and infestations known to occur on 

the District, but are not mapped in NISIMS. These species are generally widespread and dispersed throughout the 

District. District botany, invasive plant, and silviculture staff estimated these unmapped areas based on their 

professional judgement and field experience and while the locations have not been mapped, it is possible to 

characterize the areas and habitat where invasive plant species may occur. This includes additional unmapped sites 

for all mapped species, as well as an additional 47 invasive plant species. The majority of the species that are not 

mapped are not listed as noxious weeds (and hence have not been part of the existing integrated weed 

management program; thus, they generally have not been recorded during surveys or in NISIMS). While the 

precise acreage occupied by these species on the Coos Bay District is unknown, the treatment acres column in 

Table 2-1 indicates how many gross acres are estimated to be in need of treatment.

Table 2-1. Summary of Known Invasive Plant Sites

Common Name

Scientific Name

NISIMS

Gross/Net Acres1

(Sites)

Gross 

Treatment 

Acres

Treatment 

Group2

Primary Locations Noxious

Weed?3

Treatment

Priority4

American/European searocket

Cakile edentula/C. maritima

None 232 Mustard 

Family North Spit, New River, dunes No High

Annual ryegrass

Lolium multiflorum None 10 Annual Grasses

North Spit, New River, Dean 

Creek, Spruce Reach Island No Low

Biddy-biddy

Acaena novae-zealandiae

18.33/1.50

(16) 20 Misc. 

Herbaceous

Indian Creek, Cape Blanco, 

New River, roadsides, 

disturbed areas where there 

is little competition

Yes 

(Oregon) Highest

Big quakinggrass

Briza maxima None 30 Annual Grasses

North Spit, New River, dunes, 

coastal terraces, Spruce 

Reach Island, roadsides

No Moderate

Bigleaf/common periwinkle

Vinca major/V. minor

0.10/0.01

(1) 5 Misc. Herbaceous roadsides, forest edges No Low

Birdsfoot trefoil

Lotus corniculatus/

L. angustissimus/

L. pedunculatus

2.57/0.14

(4) 20 Pea Family roadsides, meadows, riparian 

areas, disturbed areas No Low

Blessed milkthistle

Silybum marianum None 1 Sunflower Family roadsides and pastures Yes (Oregon) Highest

Brome fescue

Vulpia bromoides None 15 Annual Grasses New River, roadsides No Low

Bull thistle

Cirsium vulgare

999.89/30.51

(2,825) 500 Sunflower Family

roadsides, open disturbed 

areas such as harvest areas 

or pastures

Yes 

(Oregon) High

Burdock

Arctium minus None 10 Sunflower Family

roadsides, disturbed areas 

along forest edges No High

Butterfly bush

Buddleja davidii

3.00/0.03

(3) 5 Woody 

Species

roadsides, forest edges, 

riparian areas

Yes 

(Oregon) High

Calla lily

Zantedeschia aethiopica

0.00/0.00

(1) 1

Lilies, Iris, 

Sedges, 

Rushes

Smith River Road, roadsides, 

coastal bluffs and headlands No Low

Canada thistle

Cirsium arvense

188.02/5.70

(558) 800 Sunflower Family

roadsides, harvest areas, 

open disturbed areas

Yes 

(Oregon) High

Cape ivy

Delairea odorata None 1 Woody 

Species

Pistol River School, Myers 

Creek Road, coastal bluffs 

and forests below 660' 

including on serpentine soil

Yes 

(Oregon) Highest

Catchfly

Silene gallica None 5 Carnation Family New River, dunes, roadsides No Low
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

28

Common Name

Scientific Name

NISIMS

Gross/Net Acres1

(Sites)

Gross 

Treatment 

Acres

Treatment 

Group2

Primary Locations Noxious

Weed?3

Treatment

Priority4

Coastal burnweed

Erechtites (Syn. Senecio)

minimus 

None 20 Sunflower 

Family roadsides, harvest units Yes (County) Moderate

Common ragweed

Ambrosia artemisiifolia None 1 Sunflower Family New River, dunes, sandy soil Yes (Oregon) High

Common sow thistle

Sonchus oleraceus None 40 Sunflower Family

New River, roadsides, waste 

areas, forest edges No Low

Corn spurry/sandspurry

Spergula arvensis/

Spergularia maritima/S. 

rubra

None 1 Carnation 

Family North Spit, New River, dunes No Moderate

Cotoneaster

Cotoneaster franchetii/C. 

lacteus

None 20 Woody 

Species roadsides, forest edges No Moderate

Creeping buttercup

Ranunculus repens None 50 Misc. Herbaceous

forested roadsides, rights-ofway, recreation sites No Moderate

Creeping yellow cress

Rorippa sylvestris None 1 Mustard Family

Hunter Creek ACEC, riparian, 

marsh

Yes 

(Oregon) Moderate

Dandelion

Taraxacum officinale None 5 Sunflower Family

North Spit, New River, 

roadsides, trail sides No Low

Darwin’s barberry

Berberis darwinii None 5 Woody Species

North Spit, forest edges, 

sandy soil No Highest

Diffuse knapweed 

Centaurea diffusa

0.25/0.25

(1) 1 Sunflower family Elk Creek Yes Highest

English holly

Ilex aquifolium

0.77/0.01

(1) 10 Woody Species

forestland, roadsides, 

recreation sites

Yes 

(County) Low

English/Atlantic ivy

Hedera helix

24.63/0.41

(28) 100 Woody Species

forested areas, roadsides, 

riparian areas

Yes 

(Oregon) High

European beachgrass

Ammophila arenaria

58.73/26.54

(13) 240 Perennial 

Grasses

New River, North Spit, 

coastal sand dunes to coastal 

meadows

Yes 

(County) High

Evergreen/cutleaf 

blackberry

Rubus laciniatus

63.34/3.31

(315) 100 Woody Species roadsides, riparian areas Yes (County) High

False brome

Brachypodium sylvaticum

78.26/5.93

(19) 200 Perennial Grasses

roadsides, rights-of-way, 

forest edges

Yes 

(Oregon) High

False dandelion

Hypochaeris radicata/H. 

glabra

None 25 Sunflower 

Family

North Spit, New River, 

roadsides, trails, open areas 

No Lowest

Fennel

Foeniculum vulgare

0.10/0.00

(1) 10

Perennial 

Parsley 

Family

North Spit Boat Ramp, 

Umpqua Eden cultural site, 

roadsides, waste areas

Yes 

(County) High

Field bindweed

Convolvulus arvensis

0.20/0.00

(2) 10 Misc. Herbaceous

roadsides, waste areas, 

sunny disturbed areas

Yes 

(Oregon) Moderate

French broom

Genista monspessulana

370.62/12.60

(329) 500 Woody Species

North Spit, New River, dunes, 

roadsides, forest edges, 

timber harvest areas

Yes 

(Oregon) High

Giant knotweed

Polygonum sachalinense

1.10/0.01

(10) 100 Knotweed Family

riparian areas, North Fork 

Coquille, Smith and Coos 

Rivers 

Yes 

(Oregon) High

Gorse

Ulex europaeus

28.90/0.53

(119) 40 Woody Species

North Spit, New River, rightsof-way, dunesYes 

(Oregon) Highest

Hawkbit

Leontodon saxatalis None 1 Sunflower Family

North Spit, New River, dunes 

roadsides, meadows, trails No Low
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

29

Common Name

Scientific Name

NISIMS

Gross/Net Acres1

(Sites)

Gross 

Treatment 

Acres

Treatment 

Group2

Primary Locations Noxious

Weed?3

Treatment

Priority4

Herb Robert

Geranium robertianaum

77.12/5.83

(206) 25 Geranium Family

Dean Creek, Spruce Reach 

Island, New River, roadsides, 

stabilized dunes

Yes 

(Oregon) Moderate

Himalayan blackberry

Rubus armeniacus

5,880.08/700.86

(4,210) 5,000 Woody Species

roadsides, riparian, open 

areas

Yes 

(Oregon) High

Hyssop loosestrife

Lythrum hyssopifolia None 5 Loosestrifes New River, seasonal wetlands, ditches, mudflats No Highest

Iceplant

Carpobrotus chilensis None 1 Misc. Herbaceous

Cape Blanco, coastal 

headlands No Highest

Italian/slenderflower thistle

Carduus pycnocephalus/ C.

tenuiflorus

0.2/0.2

(1) 20 Sunflower 

Family roadsides, open areas

Yes 

(Oregon) Highest

Japanese knotweed

Polygonum cuspidatum

11.10/0.11

(89) 100 Knotweed 

Family

riparian areas, North Fork 

Coquille, Smith and Coos 

Rivers

Yes 

(Oregon) High

Jubata grass

Cortaderia jubata

0.60/0.00

(9) 10 Perennial Grasses

North Spit, New River, 

roadsides, dunes, coastal 

bluffs and headlands, timber 

harvest areas

Yes 

(Oregon) High

Lance-leaved plantain

Plantago lanceolata None 10 Misc. Herbaceous New River No Low

Marestail/horseweed

Conyza bonariensis None 50 Sunflower Family

North Spit, New River, 

roadsides, grassland

Yes 

(County) Moderate

Meadow knapweed

Centaurea x moncktonii

177.89/2.93

(285) 500 Sunflower Family roadsides Yes (Oregon) High

Montbretia

Crocosmia x crocosmiflora None 5

Lilies, Iris, 

Sedges, 

Rushes

roadsides, forest edges No Moderate

Old man's beard

Clematis vitalba

9.65/0.16

(15) 10 Woody Species

Coos River watershed, 

roadsides and forests

Yes 

(Oregon) High

Old-man-in-the-spring

Senecio vulgaris None 50 Sunflower Family

ACECs, roadsides, recreation 

sites, harvest units No Low

One seed hawthorn

Crataegus monogyna

1.58/0.37

(2) 1 Woody Species Elkton area, open areas Yes (County) Moderate

Oxeye daisy

Leucanthemum vulgare

3.35/0.25

(4) 50 Sunflower 

Family

North Spit, New River, Dean 

Creek, Spruce Reach Island, 

Hunter Creek, roadsides, 

meadows

No Low

Pampas grass

Cortaderia selloana None 10 Perennial Grasses

North Spit, New River, 

roadsides, dunes, bluffs, road 

cuts, harvest areas

No High

Panic veldt grass

Ehrharta erecta

0.01/0.01

(1) 1 Perennial Grasses Hinsdale Garden No Highest

Pennyroyal

Mentha pulegium None 20 Perennial Mints

Dean Creek, Spruce Reach, 

open moist fields, roadsides

Yes 

(County) Low

Perennial peavine

Lathyrus latifolia

8.78/0.29

(41) 100 Pea Family roadsides, pastures, meadows

Yes 

(Oregon) Moderate

Perennial ryegrass

Lolium perenne None 10 Perennial Grasses

North Spit, New River, Dean 

Creek, Spruce Reach Island No Low

Poison hemlock

Conium maculatum None 10

Perennial 

Parsley 

Family

North Spit, roadside, ditches, 

moist meadow edges

Yes 

(Oregon) Moderate
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

30

Common Name

Scientific Name

NISIMS

Gross/Net Acres1

(Sites)

Gross 

Treatment 

Acres

Treatment 

Group2

Primary Locations Noxious

Weed?3

Treatment

Priority4

Purple deadnettle

Lamium purpureum None 20

Misc. 

Annual 

Herbaceous

Dean Creek, Spruce Reach, 

open moist areas No Low

Purple loosestrife

Lythrum salicaria

17.09/1.44

(29) 25 Loosestrifes

Dean Creek, Spruce Reach 

Island, wetlands, wetland 

areas

Yes 

(Oregon) Highest

Rat-tail fescue

Vulpia myuros None 10 Annual Grasses

New River, areas of sparse 

vegetation No Low

Reed canarygrass

Phalaris arundinacea

0.36/0.00

(1) 1,200 Perennial Grasses

Dean Creek, wetland, 

riparian areas No High

Ripgut brome

Bromus diandrus None 30 Annual 

Grasses

North Spit, New River, 

Spruce Reach, Dean Creek, 

roadsides.

No Moderate

Rose campion

Lychnis coronaria None 50 Carnation Family

forest edges, roadsides, 

moist areas No Low

Saltmeadow rush

Juncus gerardi ssp. gerardi None 1 Perennial Grasses North Spit, New River No Moderate

Scotch broom

Cytisus scoparius

9,961.22/1,190.50

(9,887) 2,000 Woody 

Species

North Spit, New River, 

roadsides, dunes, forest 

edges, timber harvest areas

Yes

(Oregon) High

Sheep sorrel

Rumex acetosella None 40 Knotweed 

Family

North Spit, New River, Dean 

Creek, Spruce Reach Island, 

roadsides

No Moderate

Shiny leaf geranium 

Geranium lucidum

18.00/25.00

(20) 25 Geranium Family Campgrounds, Roadsides Yes Highest

Silver wattle

Acacia dealbata

0.12/0.02

(2) 1 Woody Species New River Yes (County) Highest

Spiny sow thistle

Sonchus asper None 20 Sunflower Family

New River, roadsides, 

meadows No Low

Spotted knapweed

Centaurea stoebe None 10 Sunflower Family

Gold Beach, North Spit, 

Woodward creek, Elk creek

Yes

(Oregon) Highest

Spotted medick

Medicago arabica None 20 Pea Family New River, roadsides, recreation sites No Low

St. Johnswort

Hypericum perforatum

11.99/0.31

(29) 20 Misc. Herbaceous roadsides, open areas

Yes

(Oregon) Moderate

Stinging nettle

Urtica dioica ssp. dioica None 1 Misc. Herbaceous

roadsides, recreation areas, 

meadows, riparian No Low

Subterranean clover

Trifolium subterraneum None 20 Pea Family

North Spit, New River, Dean 

Creek, Spruce Reach Island, 

roadsides

No Low

Sweet vernal grass

Anthoxanthum odoratum None 25 Perennial 

Grasses

North Spit, New River, Dean 

Creek, Spruce Reach Island, 

dunes, roadside

No Low

Tall fescue

Schedonorus arundinaceus None 10 Perennial Grasses

New River, coastal scrub, 

roadsides, ditches No Low

Tansy ragwort

Senecio jacobaea

45.79/3.23

(109) 50 Sunflower Family

Dean Creek pastures, 

roadsides

Yes 

(Oregon) Moderate

Teasel/Fuller's teasel

Dipsacus fullonum

31.11/1.26

(38) 50 Teasels wetland edges, ditches No Moderate

Three-sided leek

Allium triquetrum None 1

Lilies, Iris, 

Sedges, 

Rushes

roadsides, meadows No Moderate

Tree-of-heaven

Ailanthus altissima None 1 Woody Species open disturbed areas Yes (Oregon) Highest
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

31

Common Name

Scientific Name

NISIMS

Gross/Net Acres1

(Sites)

Gross 

Treatment 

Acres

Treatment 

Group2

Primary Locations Noxious

Weed?3

Treatment

Priority4

Velvetgrass

Holcus lanatus None 20 Perennial Grasses

Dean Creek, North Spit, New 

River No Low

White/yellow sweetclover

Melilotus albus/M. 

officianalis

20.51/7.89

(69) 50 Pea Family roadsides No Moderate

Wild radish

Raphanus raphanistrum/R. 

sativas

None 232 Mustard 

Family

North Spit, New River, 

roadsides, fields No High

Woodland tansy

Senecio sylvaticus None 100 Sunflower Family

ACECs, roadsides, harvest 

areas No Low

Yellow flag iris

Iris psuedacorus

0.00/0.00

(1) 5

Lilies, Iris, 

Sedges, 

Rushes

New River, Spruce Reach 

Island, spits, wetland edges, 

ditches

Yes 

(Oregon) Highest

Yellow glandweed

Parentucellia viscosa None 40 Snapdragon Family open areas, roadsides Yes (County) Low

Yellow nutsedge

Cyperus esculentus None 1

Lilies, Iris, 

Sedges, 

Rushes

North Spit Yes

(Oregon) High

Yellow starthistle

Centaurea solstitialis None 1 Sunflower Family

roadsides, river gravels, 

dunes

Yes

(Oregon) Highest

1. Acres are rounded to two decimal places; acres that are shown as 0.00 are smaller than 0.005 acres.

2. Species of invasive plants that would be treated in the same manner have been arranged into treatment groups. Further information about 

treatment methods for these treatment groups can be found in Table 2-10, Treatment Key.

3. Noxious weeds are classified by the ODA or Coos, Curry, or Douglas County for the purpose of prioritizing and implementing noxious weed 

control projects. “Oregon” indicates that the plant species is listed as a noxious weed by the ODA, and “County” indicates that the species is 

listed as a noxious weed by one or more of the counties in the District. Under the No Action Alternative, only species that are listed as noxious 

weeds can be treated. 

4. See Prioritization of Treatments, under Planning, later in this chapter for more information. Highest: treat for eradication; high: treat for 

control and then to reduce the existing infestation; moderate: treat for containment; low: treat to prevent spread to other areas.

Table 2-2. Summary of Invasive Plants Documented in NISIMS by Infestation Size

Approximately 83 percent of sites mapped 

in NISIMS are smaller than one (gross) acre 

each (see Table 2-2 and Table D-1, Invasive 

Plants Mapped in NISIMS by Infestation Size

in Appendix D). However, a relatively small 

number of large sites account for a majority 

of infested acres (about 47 percent of the 

mapped acres are on sites that are larger 

than five (gross) acres).

Category II: Spread from Existing Invasive Plant Sites

The current spread rate for noxious weeds on the Coos Bay District is estimated to be about 10 percent annually20

(USDI 2010a:595) and new sites are found on the District with each invasive plant inventory. Invasive plants can 

spread quickly and over long distances by wind, water, animals, and humans through vehicle and foot traffic. 

Infestations begin mostly on sparsely vegetated or disturbed sites such as roads and trails, logged areas, wildlife 

and livestock concentration areas, mining areas, and recreation sites. Livestock and wildlife (including birds) can 

introduce invasive plant seeds from their coats and feces. The checkerboard ownership pattern and patchiness of 

vegetation increases opportunities for invasive plant movement onto the District.

 20 In other words, the invasive plant infestations discussed in Category I are estimated to grow 10 percent per year.

Infestation Size 

(in Acres)

Number of Sites

(percent of total sites1)

Total Acres

(percent of total acres1)

< 0.1 9,029 43% 774.35 4%

0.1 to < 0.5 5,761 28% 1,769.03 9%

0.5 to < 1 2,650 13% 1,913.89 10%

1 to < 5 3,175 15% 6,136.20 31%

5 to < 20 261 1% 2,207.07 11%

20 to <100 56 0% 2,105.94 11%

>100 6 0% 4,941.63 25%

1. Rounded to the nearest percent.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

32

Linear disturbances such as roads and utility corridors are the primary pathways for spread on the District. Many 

invasive plant species for which there are no currently available effective control methods (such as invasive 

bromes) are being spread along roads by vehicles annually. (See Maps 2-2B and 2-2C, Routes of Invasive Plant 

Spread: Ground Transportation Network and Utility Corridors and Water Developments.)

Streams are also major pathways for the movement of invasive plants. The Umpqua, Coquille, Smith, and Rogue 

Rivers and smaller tributaries transport invasive plant propagules (seeds, root fragments) downstream. These 

areas attract birds, wildlife, and humans who spread invasive plants along these corridors. (See Map 2-2A, Routes 

of Invasive Plant Spread: Recreation Sites and Waterways.)

Recreation sites, both developed and dispersed, are the hub of several means of invasive plant spread. Recreation 

sites bring together people and their recreation equipment, vehicles, pack stock and pets where roads, trails, and 

waterways converge. Invasive plants can be easily transported from one site to other areas on the District and 

beyond. (See Map 2-2A, Routes of Invasive Plant Spread: Recreation Sites and Waterways.)

Timber harvest, restoration, wildfire, prescribed fire, and silviculture activities disturb vegetation and soil in ways 

that can result in germination of seeds present in the soil, reduce barriers to invasive seed dispersal, and improve 

site conditions for invasive plant establishment and growth. Particularly where project disturbances are more 

severe, such as skid roads and burn pile scars, invasive plant infestations can persist and become sources for 

further seed spread. Equipment and work crews can also spread invasive plant seeds to and from project areas.

Material sites such as quarries and areas where mulch, gravel, rocks, oyster shells, or fence posts are stored are 

continuously disturbed and may have numerous users. Despite precautions, the site may be vulnerable to 

establishment and spread of invasive plants.

Category III: Invasive Plants Not Yet Known on District

Species of invasive plants not previously documented on the District may be found at any time. Initial infestations 

are small, but may become large before being discovered. The BLM periodically checks common routes of spread 

(e.g., roads and waterways). Species of concern not yet documented on the District but documented on adjacent 

lands include Portuguese broom (Cytisus striatus), Spanish heath (Erica lusitanica), pine echium (Echium pininana), 

and various toadflaxes (Linaria spp.) (see Table 2-3). For example, Portuguese broom and Spanish heath are 

present along Highway 101, within the District, but have yet to be detected on BLM-managed lands. The District 

works with numerous entities to coordinate early detection activities across jurisdictional boundaries and educate 

the public about new invasive plants that occur or are likely to invade. All of these invasive plant species are a high 

priority for treatment in order to prevent them from becoming established on the District (see further information 

in the Prioritizing Areas for Treatment section later in this chapter). It is assumed that if they were found on the 

District, the infestations would be small (generally a few plants) and would be high priority for treatment; thus 

eradicating the invasive plant infestation before it can spread further. Hence, the BLM would treat few acres in this 

Category.

Table 2-3. Invasive Plants Documented on Neighboring Lands but Not Known to Occur on the District

Common Name Scientific Name Treatment Group

Noxious Weed1

(State or Coos, Curry, or Douglas 

County)

Annual yellow sweetclover Melilotus indicus Pea Family -

Bindweed Solanum dulcamara Misc. Herbaceous -

Black locust Robinia pseudoacacia Woody Species -

Buffalobur nightshade Solanum rostratum Misc. Annual 

Herbaceous Oregon B, Coos A, Douglas A, T

Common reed Phragmites australis Perennial Grasses Oregon B
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

33

Common Name Scientific Name Treatment Group

Noxious Weed1

(State or Coos, Curry, or Douglas 

County)

Cut leaf teasel Dipsacus laciniatus Teasels Oregon B

Dalmatian toadflax Linaria dalmatica Snapdragon Family Oregon B, Coos A

Earth loosestrife Lysimachia terrestris Loosestrifes -

Garden yellow loosestrife Lysimachia vulgaris Loosestrifes Oregon A

Garlic mustard Alliaria petiolata Mustard Family Oregon B, Coos A

Giant hogweed Heracleum mantegazzianum Misc. Annual 

Herbaceous Oregon A, Coos A

Ground ivy Glechoma hederacea Perennial Mints -

Himalayan knotweed Polygonum polystachyum Knotweed Family Oregon B, Coos B, T

Japanese (Field) brome Bromis japonicus (B. arvensis) Annual Grasses -

Jimsonweed Datura stramonium Misc. Annual 

Herbaceous -

Lesser swinecress Coronopus (Syn. Lepidium) 

didymus Mustard Family -

Maltese starthistle Centaurea melitensis Sunflower Family Douglas B

Matgrass Nardus stricta Perennial Grasses Oregon A

Mediterranean rabbitsfoot grass Polypogon maritimus Annual Grasses -

Morning-glory Ipomoea purpurea Misc. Herbaceous -

New Zealand geranium Geranium core-core Geranium Family -

Pine echium Echium pininana Borage Family Coos A

Policemen’s helmet Impatiens glandulifera Misc. Herbaceous Oregon B, Coos B

Portuguese broom Cytisus striatus Woody Species Oregon B, Coos A, Curry A, T, 

Douglas A, T

Puncturevine Tribulus terrestris Misc. Annual 

Herbaceous Oregon B, Douglas B

Red valerian Centranthus ruber Misc. Herbaceous Curry Watch list

Ribbongrass Phalaris arundinacea var picta Perennial Grasses Oregon B

Scotch thistle Onopordum acanthium Sunflower Family Oregon B, Curry A, Douglas A

Small flower buttercup Ranunculus parviflorus Misc. Herbaceous -

Spanish broom Spartium junceum Woody Species Oregon B, Curry A, T, Douglas B

Spanish heath Erica lusitanica Woody Species Oregon B, Coos A

Spurge laurel Daphne laureola Woody Species Oregon B

Sulfur cinquefoil Potentilla recta Misc. Herbaceous Oregon B, Douglas B

Sweetbriar rose Rosa rubiginosa Woody Species -

White ramping fumitory Fumaria capreolata Misc. Herbaceous Coos A

Yellow archangel Lamiastrum galeobdolon Perennial Mints Oregon B

Yellow foxtail Setaria pumila Annual Grasses -

Yellow toadflax Linaria vulgaris Snapdragon Family Oregon B, Coos A; Douglas A

1. Noxious weeds are classified by the counties or the ODA for the purpose of prioritizing and implementing noxious weed control projects 

(ODA 2017):

A List: A weed of known economic importance that occurs in the State or County in small enough infestations to make eradication or 

containment possible.

B List: A weed of economic importance which is regionally abundant, but which may have limited distribution in some areas.

T list: A designated group of species that are selected and will be the focus for prevention and control by the State or County. Action against 

these will receive priority. T designated noxious weeds indicate the need to develop and implement a management plan. T designated 

noxious weeds are species that are also on the A or B list.

2. Species of invasive plants that would be treated in the same manner have been arranged into treatment groups. Further information about 

treatment methods for these treatment groups can be found in Table 2-10, Treatment Key.

Category IV: Lower Priority Invasive Plants

Additional invasive plants (other than those in the above Categories) are known on the District. They are generally 

not inventoried because they are currently a low priority for treatment. These plants are less likely (than Category I 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

34

or III plants) to interfere with a management objective as the harm they cause is still below the threshold level for 

action in most areas. However, in the future these plants may become problematic in specific conditions and 

would require treatments (e.g., in an ACEC or in Special Status plant habitat). In addition, the BLM may treat these 

plants in conjunction with other invasive plants being treated in the immediate area; for example, velvet grass 

(Holcus lanatus) may be treated incidentally when treating higher priority grasses like pampas grass or jubata 

grass, as treatment methods would be the same. Category IV does not include any species where more than 10 

gross acres of treatments are anticipated over the next 20 years. A full list of these species is part of Table D-2,

Further Information about Invasive Plant Species in Appendix D.

Integrated Invasive Plant Management

As noted in Chapter 1, the action alternatives would update the direct control methods that are available to the 

existing noxious weed management program, including increasing the number of herbicides available for use. In 

addition, the action alternatives would add other invasive plants that are not listed as noxious weeds to the plant 

species that can be treated. As described in the alternatives, these additional herbicides and additional invasive 

plants would cause the use of some treatment methods to increase. Other elements of the program would remain 

the same across all alternatives. These unchanging elements of the program, including prevention, education, 

awareness, coordination, cooperation, planning, and monitoring are described below. 

Prevention, Education, and Awareness

Prevention, education, and awareness are the highest priority for the management of invasive plants, as was 

described in the 1997 Integrated Noxious Weed Program on the Coos Bay District Environmental Assessment (USDI 

1997). The District maintains a District Weed Prevention Schedule (see Appendix E, Prevention) that outlines 

prevention steps like inspecting vehicles and equipment for invasive plant materials (e.g., seeds) and helping with 

community invasive plant education events. Specific responsibilities are assigned for keeping administrative sites 

free of invasive plants, reestablishing desirable vegetation on disturbed sites, inspecting gravel and other materials 

sites, and including invasive plant prevention measures in all planning documents, contracts, and leases. Other 

activities include the continuing education of employees, contractors, and the public. The BLM, in cooperation with 

other groups21, publishes news articles, signs recreation sites, and conducts invasive plant awareness meetings and 

lessons in communities and local schools. In addition, in cooperation with Coos County Weed Board, the BLM 

participates in an invasive plant education booth at the Coos County fair.

Additionally, BLM policy requires that planning for ground-disturbing projects (or projects that have the potential 

to alter plant communities) include an assessment of the risk of introducing or spreading noxious weeds (see 

Appendix E, USDI 1992b).22 If there is a moderate or high risk of spread, actions to reduce the risk must be 

implemented and monitoring of the site (see Monitoring section below) must be conducted to prevent 

establishment of new infestations (USDI 1992b). A list of prevention measures applicable to projects or vegetation 

treatment actions is included in Appendix E, Invasive Plant Prevention Measures.

The BLM requires weed-free forage for pack stock, weed-free seed for revegetation projects, weed-free straw for 

erosion control, and specifies in contracts that materials brought on to the District are to be weed-free. 

Competitive seeding and planting is done on the District as both a preventative and a control measure. Further 

information can be found in the Direct Control Methods section later in this chapter.

 21 Such as Coos County Weed Advisory Board, Oregon Dunes Cooperative Weed Management Area (CWMA), the South Coast 

CWMA, the Gorse Action Group, South Slough National Estuarine Research Reserve, and the Coos and Coquille Watershed 

Association. 22 Current handbook direction requires this assessment only for noxious weeds (Integrated Weed Management Manual 9015; 

USDI 1992b). Handbook direction is in the process of being updated to include all invasive plant species in order to comply with 

Executive Order 13112 (February 1999, amended December 2016).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

35

Coordination and Cooperation

The District has worked cooperatively with several entities, including local, State, and Federal agencies, nongovernmental organizations, and private landowners for several decades. Coordination includes the 

implementation of prevention and education activities (see previous section), sharing of inventory and monitoring 

information, and developing and implementing annual treatment programs. The District works closely with 

adjacent timber owners; the Gorse Action Group; the Oregon Dunes Cooperative Weed Management Area 

(CWMA); Coos-Curry CWMA; the Coos, Curry, Umpqua, and Douglas Soil and Water Conservation Districts (SWCD); 

the South Coast, Smith River, Coos and Coquille Watershed Associations; Partnership for Umpqua Rivers; Coos 

County; Oregon Parks and Recreation Department; Oregon Department of Agriculture; and the Rogue 

River/Siskiyou and Siuslaw National Forests. Invasive plant treatments on neighboring lands may occur through 

interagency and cooperative agreements in which grant monies and BLM contributions (in-kind and monetary) 

help fund invasive plant treatments on BLM and adjacent lands.

Planning

Integrated invasive plant management includes a process to determine when and where to take action. The 

Integrated Vegetation Management Manual (USDI 2008a:59) describes an adaptive management approach based 

on clearly identified outcomes (see Prioritization of Treatments, below), monitoring to determine if management 

actions are meeting outcomes (see Monitoring, below), and if not, facilitating management changes that will best 

ensure that outcomes are met or re-evaluated (see Table 2-10, Treatment Key). An example of how this would be 

implemented can be found in Appendix D, Invasive Plant Infestations, in the Invasive Plant Treatments Example

section.

In general, the District’s strategy is to manage invasive plants to minimize adverse effects to ecological function 

and economic values. This strategy requires District staff to set action thresholds and to evaluate sites to 

determine when those thresholds have been reached or exceeded. Action thresholds are the levels of ecological or 

economic damage that can be done by invasive plant infestations before treatments are needed, and these 

thresholds differ across sites, projects, and species. For example, for most invasive plant species, the action 

threshold would be different along a disturbed roadside than it would be next to a population of a rare plant 

species. For some invasive plant species (e.g., gorse) the threshold may be a single plant, regardless of the site, 

while for other species (e.g., dandelion and Queen Anne’s lace) the threshold would rarely be reached except at 

sensitive sites (such as ACECs or Special Status species habitat).

Prioritization of Treatments

The number of acres treated annually varies and is based on factors such as available funding and weather. In 

general, the District’s strategy is to manage invasive plants to minimize adverse effects to ecological function and 

economic values. Priorities are as follows:

• Eradication of new infestations of species previously unknown on the District, or of satellite infestations of 

plants that have spread to new locations, where the plant is a known ecologic and economic threat as 

determined by the Oregon Department of Agriculture (ODA) or the counties.

• Control of existing infestations of invasive plants that are of known ecologic and economic threat in areas 

that have a high potential for spread such as along roads and trails, recreation sites, rivers and streams, 

mineral material sites, and other places where soil disturbance occurs.

• Containment and reduction of large invasive plant infestations, and rehabilitation as time and funding 

permit.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

36

Within the above broad categories, setting treatment priorities is primarily driven by the resources that would be 

adversely affected by the invasive plants such as habitats for Special Status species, special management areas 

(such as ACECs), and recreation. Other considerations include: the risk of spread (e.g. if it is along a road or 

recreation site where it can be easily picked up and moved long distances, or if it is next to a site-disturbing activity 

into which it may spread); the species and its priority on State and County noxious weed control lists; the size of 

the infested area and whether the site is isolated or near others; and, the control priorities of BLM neighbors and 

cooperators. Knowledge of the control methods that would work for each species and that are appropriate for the 

lands infested also informs the prioritization process.

Monitoring

Monitoring involves repeated assessment or measurement of a site or infestation to document changes over time. 

Monitoring is required for many resources managed by the BLM. Some of this monitoring, even if not directly done 

because of the invasive plant program, can reveal information about the program. For example, monitoring Special 

Status plant populations is required to determine whether management objectives are being met, and can also 

reveal invasive plant infestations (Special Status Species Management Manual, USDI 2008b). Directly related to the 

invasive plant program, implementation and effectiveness monitoring are also required (Integrated Vegetation 

Management Handbook, USDI 2008a:71). The methods in these handbooks and manuals are followed and 

adjusted as necessary for different sites and objectives. Data from monitoring identifying the location of invasive 

plants are recorded in NISIMS.

Implementation Monitoring

Where the BLM uses herbicides, BLM policy and the EPA require monitoring. The BLM completes Pesticide Use 

Proposals prior to application that identify the site, target species, herbicide (product and active ingredient) and 

application rate, adjuvants, and anticipated effects to non-target species and susceptible areas. Applicators fill out 

Pesticide Application Records within 24 hours of each application, documenting environmental conditions at the 

time of treatment, invasive plant species targeted, actual herbicide use, treatment method, applicator and license, 

and equipment used. Both documents have sufficient detail to determine if planning and application requirements 

have been met. Similar records are also kept for non-herbicide treatments.

Invasive plant treatments conducted by contractors, regardless of treatment method, must also comply with all 

laws, Bureau policies, Standard Operating Procedures and other Protection Measures (see Appendix A), and 

contract specifications. To ensure proper implementation, District Project Inspectors review contractor operations, 

treatment sites, and treatment records.

Effectiveness Monitoring

Monitoring invasive plant treatments involves revisiting treated sites to assess how the infestation and associated 

plant community have changed over time. Observers look at factors such as the size and density of the invasive 

plant infestation; the amount of colonization by other non-native plants; the amount of damage or mortality in 

non-target plants; the growth, vigor, and density of native vegetation; and the need for follow-up treatments. 

Follow-up treatments are recommended when a treatment has not reduced the target invasive plant infestation to 

below an acceptable threshold, if there is a remaining seed bank from which invasive plants may regrow, or when 

sufficient native vegetation has not reoccupied the site.

An example of how effectiveness monitoring would be implemented can be found in Appendix D, Invasive Plant 

Infestations, in the Invasive Plant Treatments Example section.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

37

Direct Control Methods

Direct control methods will vary by alternative. Selection of a treatment method considers methods that would be 

effective for each species and what is appropriate for the lands infested (including what nearby resources may be 

affected). For many species, small infestations may be controlled with manual or other non-herbicide treatments. 

Others may require herbicides to obtain control or reduce ground disturbance. The selection of a treatment 

method is guided by Department of the Interior policy which states “Bureaus will accomplish pest management 

through cost-effective means that pose the least risk to humans, natural and cultural resources, and the 

environment” and requires bureaus to “[e]stablish site management objectives and then choose the lowest risk, 

most effective approach that is feasible for each pest management project” (USDI 2007e).

Manual Treatment Methods

Manual treatment methods (such as pulling, digging, and grubbing) can be used to control some invasive plants, 

particularly if the infestation is relatively small. These techniques can be extremely target specific and are often 

used to minimize damage to adjacent desirable plants. However, they can be labor and time intensive. Treatments 

often must be conducted several times annually to prevent the invasive plant from re-establishing, which often 

makes manual treatments of invasive plants in remote locations unpractical. Manual techniques are used on small 

infestations or where a large pool of labor is available. They can be used in combination with other techniques. For 

example, shrubs can be pulled and cut, and re-sprouts and seedlings can be treated with herbicides several weeks 

or months later (Tu et al. 2001). English ivy is another example; the cuticle on ivy effectively repels herbicide, so ivy 

must be manually (or mechanically) removed before herbicide application could be effective on young plants 

without fully developed cuticles.

The placement of weed barriers involves putting a plastic sheet or tarp over an area for up to six months. Weed 

barriers can be used in areas where invasive plants are not intermingled with native vegetation. It is often done as 

site preparation in advance of seeding and planting.

Mechanical Treatment Methods

Mechanical treatment methods include tractors with mowers or discs or bulldozers. Some methods (e.g., 

chainsaws and string trimmers) can be more target-specific than others. String trimmer and mowing methods are 

commonly used in administrative sites, like communication and recreation sites, to prevent invasive plants from 

spreading and to maintain clear access. Propane torches can be used in parking lots, sidewalks, dunes, or other 

areas where the substrate is not flammable. Propane torches do not work by burning the plant; rather, the torch 

applies heat approximately two inches from the plant, causing the water in the invasive plants' cells to boil and 

burst. Leaves wilt and dry out in two to three days. Once the heat destroys any section of a stem, for instance, 

water and nutrients cannot reach the leaves, and the top part of the plant dies.

Competitive Seeding and Planting

When revegetating disturbed sites, the District uses locally adapted, weed-free native grass and forb seeds and 

mulches. Plant materials are generally native and genetically appropriate for each revegetation site, increasing the 

probability of successful and persistent native plant establishment that is resilient and resistant to invasive plants.

The objective of competitive seeding and planting is to provide a desirable native vegetative component to 

compete with invasive plants in treatment areas. BLM’s Integrated Vegetation Management Handbook states, 

“Diverse, healthy, and resilient native plant communities provide the greatest opportunity to be successful in 

meeting multiple use objectives within BLM. [BLM is required to] set resource management objectives that can be 

met using native species for most situations” (USDI 2008a:87). Competitive seeding and planting of locally sourced 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

38

seed and container plants often occurs in conjunction with other treatments but can also occur independently as a 

measure to prevent invasive plant establishment. Seeding is primarily accomplished by hand spreading to achieve 

a specific density of seed per area. Mulching with weed-free straw often occurs in conjunction with seeding, unless 

the site is difficult to access. Mulch reduces seed herbivory, prevents seeds from blowing or washing off site, 

retains moisture to increase successful germination, and reduces soil erosion. Plugs and potted plants are used to 

complement seeding at sites where immediate vegetation cover is desired or to include native species that do not 

establish well from seed.

Decisions on which species to include in a planting prescription are based on an evaluation of the surrounding 

native plant community, so that, the planted site has similar species composition and structure once established. 

Other factors that affect the planting prescription include environmental conditions, availability and condition of 

native plant materials, and budget. Seed mixes and planting prescriptions typically include a combination of plant 

functional groups including perennial grasses, annual forbs, and perennial forbs. Shrubs and trees are included in 

some prescriptions.

Perennial grasses are seeded on roadsides, landings, and other areas of bare soil to prevent invasive plant 

establishment and soil erosion. The native perennial grasses used on the District are cool-season growers and do 

best if planted in fall or early spring when moisture and soil temperatures are favorable for plant establishment. 

Unlike annual grasses, perennial grasses generally grow slowly during the first year and many native perennial 

grasses might take two years to express their potential as a solid stand (Pacific Coast Seed 2010). A sterile triticale 

hybrid is added to some native grass seed mixes, particularly those planted in spring and summer when growing 

conditions are less favorable. The sterile hybrid is an annual and serves as a nurse crop to assist in establishment of 

perennial native grasses (it greens up rapidly and holds soil until the perennials can establish). Informal monitoring 

has shown that native perennial grasses used on Coos Bay District lands take 2 to 3 years to establish (Jeanne 

Standley, Coos Bay Weed Coordinator, 2017 personal communication).

Prescribed Fire

Prescribed fires are used for invasive plant control, and can be most effective in spring or in fall when conducted 

just before flower or seed set, or at the young seedling or sapling stage. It may also be used in conjunction with 

other methods as a pre-treatment to an herbicide application, such as when the target invasive plants have gone 

to seed and there is a need to remove the seed source or to remove thatch (the mat of un-decomposed plant 

material) in invasive annual grass stands. Like other treatments, timing is critical and is dependent on 

characteristics of the invasive plant, presence of desirable plants, soil moisture, and environmental conditions.

(Propane torches are used to heat plants to boil the water in invasive plant cells, not to consume plants with fire. 

Propane torches are described above, in the Mechanical Treatment Methods section.)

Biological Treatment Methods

Biological treatment methods involve the intentional use of domestic animals (such as goats, sheep, or cattle) or 

biological control agents (such as insects, bacteria, or fungi) that weaken or destroy vegetation (USDI 2007d). 

Biological control is used to reduce the targeted invasive plant infestation to an acceptable level by stressing target 

plants and reducing competition with native plant species.

Biological Control Agents

Classical biological control refers to a subset of organisms (or “agents”) that includes plant-eating insects, 

nematodes, mites, or pathogens. Biological control agents are usually acquired from the same ecosystems where 

the target invasive plant originated, and are rigorously tested by the Federal Animal and Plant Health Inspection 

Service (APHIS) Plant Protection and Quarantine Program to ensure that they are host specific and feed only on the 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

39

target plant and not on crops or native flora. Issuance of permits by APHIS for the environmental release of 

nonindigenous invasive plant biological control organisms is considered a Federal action and triggers compliance 

with the Endangered Species Act and NEPA. The ODA’s Noxious Weed Control Program coordinates releases and 

monitors populations. Since the biological control agents are not successful unless there are enough invasive 

plants for them to feed upon, typically only large infestations are targeted. Often, several biological control agents 

are used together to reduce the density of invasive plants but biological controls seldom remove an invasive plant 

infestation entirely. Many biological control agents are common and widespread on noxious weeds throughout 

Oregon. The primary factors for when and where to release additional biocontrols are infestation size and 

availability of effective agents for the specific site. Table 2-4 shows biocontrols that are active within the Coos Bay 

District boundary (those marked with a “5”).

Table 2-4. Biocontrol Releases within the Coos Bay District Boundary

Invasive plant (host) Biocontrol (agent) Status, by County1

Coos Curry Douglas

Blessed milkthistle - Silybum marianum Rhinocyllus conicus - seed head weevil 5 5 5

Bull thistle - Cirsium vulgare

Rhinocyllus conicus - seed head weevil 5 5 5

Trichosirocalus horridus - crown/root weevil 0 0 5

Urophora stylata - seed head gall fly 4 2 5

Canada thistle - Cirsium arvense

Ceutorhynchus litura - crown/root weevil 1 1 1

Rhinocyllus conicus - seed head weevil 5 5 5

Urophora cardui - stem gall fly 4 2 4

Field bindweed - Convolvulus arvensis Aceria malherbae - eriophyid mite 2 0 0

Tyta luctuosa - defoliating moth 1 1 2

French broom – Genista monspessulana Bruchidius villosus - seed beetle 2 2 5

Gorse - Ulex europaeus Exapion ulicis - seed weevil 5 5 5

Tetranychus lintearius - spider mite 5 5 5

Italian thistle - Carduus pycnocephalus Rhinocyllus conicus - seed head weevil 5 5 5

Trichosirocalus horridus - crown/root weevil 0 0 5

Meadow knapweed - Centaurea x 

moncktonii

Larinus minutus - seed head weevil 0 0 4

Larinus obtusus - seed head weevil 1 1 5

Urophora affinis - seed head gall fly 0 0 1

Urophora quadrifasciata - seed head gall fly 5 5 5

Purple loosestrife - Lythrum salicaria

Galerucella calmariensis - defoliating beetle 5 2 4

Galerucella pusilla - defoliating beetle 5 2 4

Hylobius transversovittatus - root weevil 2 2 2

Nanophyes marmoratus - seed head weevil 2 1 5

Scotch broom - Cytisus scoparius

Bruchidius villosus - seed beetle 2 2 5

Exapion fuscirostre - seed weevil 5 3 5

Leucoptera spartifoliella - twig mining moth 5 5 5

St. Johnswort - Hypericum perforatum

Agrilus hyperici - root/stem boring beetle 1 1 4

Aplocera plagiata - defoliating moth 1 1 4

Chrysolina hyperici - defoliating beetle 5 5 5

Chrysolina quadrigemina - defoliating beetle 5 5 5

Tansy ragwort - Senecio jacobaea

Botanophila seneciella - seed head fly 5 5 5

Longitarsus jacobaeae - root/defoliating flea beetle 5 5 5

Tyria jacobaeae - defoliating moth 5 5 5

Cheilosia corydon - crown/root fly 5 5 5

Eustenopus villosus - seed head weevil 0 1 5

Larinus curtus - seed head weevil 0 1 5

Puccinia jacea var. solstitialis - rust fungus 0 1 6

Urophora sirunaseva - seed head fly 0 5 5

1: Numbers indicate the following: 0: Invasive plant not present, 1: Invasive plant present, no biocontrol released, 2: Biocontrol released, status 

unknown, 3: Biocontrol recovered, nursery sites established, 4: Biocontrol limited in distribution, being collected and redistributed, 5: 

Biocontrol widespread within host range (occurs on at least 50 percent of plants), 6: Biocontrol released, failed to establish.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

40

Targeted Grazing

Targeted grazing23 is the purposeful application of a specific species of livestock at a determined season, duration, 

and intensity, to accomplish defined vegetation or landscape objectives (ASI 2006). The basic goal of targeted 

grazing is to give the desired plants a competitive advantage over the target invasive plant or plants. In general, 

goats prefer shrubs, while cattle graze on grasses. Grazing can be seasonally timed for when the target plant is 

most palatable to livestock and to minimize effects to non-target plants and surrounding resources. Typically, a 

full-time herder or fencing is required to keep the grazing focused on the target areas and species. Employing 

grazing prescriptions may be particularly useful in areas with limited access, steep slopes, or where the most 

effective herbicide for a particular plant species cannot be applied (e.g., a non-aquatic herbicide application near 

water). Although targeted grazing with livestock can reduce invasive plant abundance and vigor at a particular site, 

grazing rarely, if ever, eradicates invasive plants. As with many other treatments, targeted grazing with livestock 

can be most effective when used in combination with other treatments (USDI 2010a:75).

Herbicide Treatment Methods

Herbicides used on BLM-managed lands must be approved by the BLM National Office, and must, by policy, be 

subject to detailed ecological and human health Risk Assessments for wildland applications to help satisfy the 

requirements of NEPA (USDI 2010a:37). However, BLM practice allows for limited and controlled use of herbicides 

that do not have Risk Assessments on demonstration plots up to 5 acres in size, with a maximum of 15 acres per 

Field Office.24 Approval to use an herbicide for research and demonstration is provided by the BLM National Office 

after an initial evaluation of Federal Insecticide, Fungicide and Rodenticide Act registration materials, Risk 

Assessments, and the appropriate level of NEPA analysis (USDI 2010a:478). Herbicides analyzed in this EA are 

shown on Table 2-5, Herbicide Information and Table 2-6, Herbicide Characteristics.

Herbicides are utilized:

• on stands of an invasive plant species where desirable and non-target plants are scarce or absent;

• for rhizomatous invasive plant species that would otherwise require repeated cutting or pulling over 

several years to control;

• on plants whose characteristics make them difficult or unfeasible to remove with non-herbicide 

methods;25

• in areas where non-herbicide methods are cost prohibitive;

• in areas where non-herbicide methods have unacceptable adverse effects to native plants;

• in areas where considerable soil disturbance is not acceptable;

• for species located in remote or limited access areas where non-herbicide methods are not feasible;

• in combination with other control treatments (for example, woody species like silver wattle can be 

controlled by cutting stems close to the ground in the fall and then spraying the cut stumps with an 

herbicide registered for this use).

Herbicides are applied only to lands and uses for which they are labeled and only by certified or licensed 

applicators or persons working under their direct supervision (USDI 2010a:85). A Pesticide Application Record is 

completed within 24 hours of the application documenting environmental conditions at the time of treatment as 

 23 Also referred to as directed livestock grazing or prescribed grazing.

24 Not an annual limit. If research and demonstration results appear favorable, then the BLM further considers the herbicide for

general approval. This 15-acre limit could only be exceeded by the issuance of ecological and human health Risk Assessments, 

done or adopted by the BLM, and results evaluated through programmatic NEPA analysis done at the national or state level. 25 For example, Canada thistle root fragments readily resprout and some plants can be injurious to workers attempting to 

manually remove them.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

41

well as actual herbicide use. This record, kept in District files for 10 years, helps the BLM duplicate successes, 

change procedures to improve effectiveness, and understand when and if unintended effects occur.

Herbicide products (brands), as well as adjuvants (used to enhance the effectiveness, handling, deposition, or 

application of the herbicide) must be on the BLM lists of approved herbicides and adjuvants and in accordance 

with current NEPA documents at the time of application. The current lists are included in Appendix B, The 

Herbicides, Formulations, and Adjuvants. For applications with a potential to enter streams or other waterbodies, 

herbicides are limited to aquatic formulations. For applications with a potential to affect federally listed and 

Bureau Sensitive fish, aquatic-approved adjuvants26would also be used.

Ground-based herbicide applications are primarily done with a hand-directed sprayer. This is usually done in small 

areas and in areas where invasive plants are scattered. A hand-directed sprayer is used because it can target 

specific plants, so effects to non-target species can be kept to a minimum. Hand-directed sprayers include 

motorized, truck mounted sprayers, and backpacks. Herbicides are primarily applied to plant foliage, but some 

herbicides may be applied to the soil. For woody invasive plants (like tree–of-heaven), herbicides may also be 

basally applied with a wick (wiped on), or wand (sprayed on). Herbicides can be applied to trees around the 

circumference of the trunk on the intact bark (basal bark), to cuts in the trunk or stem (frill, or “hack and squirt”), 

to cut stems and stumps (cut stump), or injected into the inner bark.

Ground-based herbicide application is also accomplished from off-highway vehicles with vehicle-mounted spraying 

systems using handguns, boom-less nozzles, or booms. Spray tank sizes generally vary from 4 to 100 gallons. Using 

a larger tank (as is typical for vehicle-mounted sprayers) provides the advantage of less mixing and loading of 

herbicides, which, in turn, leads to less risk of accidental spills of concentrated products. Most vehicle applications 

are done from an existing road as spot treatments. Treatments that cannot be reached from the roadway (further 

than 300 feet away) are done with backpack sprayers. Aerial applications are not authorized and would not occur.

Table 2-5. Herbicide Information

Herbicide: Representative Trade Names1

Common Targets

Alternatives

Selective to 

Plant Types

Pre or post 

emergent

Point of 

application

Areas Where Registered 

Use is Appropriate2

Application Rate3

(lbs./acre/year)

No Action 

Proposed Action

Alternative 3

Rangeland

Forest and Woodland

Riparian or Seasonal Wetland

Aquatic or Wetland

Oil, Gas, & Mineral Sites

Rights-of-Way

Recreation & Cultural Sites

Typical Max4

2, 4-D: Many, including Weedone LV6

Broadleaf plants

  

broadleaf

Post

Foliar

   2    1 (1.9 or 2) 5

Aminopyralid: Milestone

Starthistles, thistles, knapweeds

 

broadleaf

Post

Foliar

      0.078 0.11

Chlorsulfuron: Telar

Perennial mustards

 

broadleaf

Pre and early 

post

Foliar

     0.047 0.141

 26 These “approved adjuvants” shown in Appendix B are indicated in the ARBO II column of Table B-3. These adjuvants were 

analyzed in the U.S. Fish and Wildlife Service and National Marine Fisheries Service ARBO II biological opinions (USDI 2013a,

NMFS 2013).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

42

Herbicide: Representative Trade Names1

Common Targets

Alternatives

Selective to 

Plant Types

Pre or post 

emergent

Point of 

application

Areas Where Registered 

Use is Appropriate2

Application Rate3

(lbs./acre/year)

No Action 

Proposed Action

Alternative 3

Rangeland

Forest and Woodland

Riparian or Seasonal Wetland

Aquatic or Wetland

Oil, Gas, & Mineral Sites

Rights-of-Way

Recreation & Cultural Sites

Typical Max4

Clopyralid: Transline, Stinger, Spur

knapweed, biennial thistles, starthistles 

 

broadleaf

Post

Foliar

      0.35 0.5

Dicamba: Vanquish, Banvel, Diablo, Vision, 

Clarity

Perennial mustards, biennial thistles, field 

bindweed, puncturevine 

  

broadleaf, 

woody plants

Pre and post

Foliar

     0.3 26

Diflufenzopyr + Dicamba: Overdrive, 

Distinct

Field bindweed, oxeye daisy, St Johnswort  

broadleaf

Post

Foliar

    0.2625 0.4375

Dicamba 0.1875 0.25

Diflufenzopyr 0.075 0.1

Fluroxypyr: Comet, Vista

Mustards, spurge, blackberry



broadleaf

Post

Foliar

      0.26 0.5

Glyphosate: Many, including Accord, 

(Rodeo), AquaNeat, AquaMaster

Grasses, trees and shrubs, yellow flag iris

  

no

Post

Foliar

   2    2 3 or 77, 8

Hexazinone: Velpar

Grasses in rights-of-way



Grasses, 

broadleaf, 

woody plants

Pre and post

Foliar

     2 (4)8

Imazapic: Plateau, Panoramic

Annual grasses

 

some 

broadleaf and 

grasses

Pre and post

Soil

      0.0313 0.1875

Imazapyr: Arsenal, Stalker, Habitat, Polaris

Starthistles, trees and shrubs, yellow flag 

iris

 

no

Pre and post

Foliar

       0.45 1.56

Metsulfuron methyl: Escort, Patriot, 

PureStand

Trees and shrubs, perennial mustards, St. 

Johnswort, biennial thistles 

 

broadleaf

Pre and post

Foliar

      0.03 0.156

Picloram: Triumph, OutPost, Tordon

field bindweed, knapweed, St. Johnswort, 

starthistles, biennial thistles 

  

broadleaf, 

woody plants

Pre and post

Foliar

     0.35 1

Rimsulfuron: Matrix

Annual grasses 



annual grasses

Pre and post

Soil

      0.0469 0.0625

Sulfometuron methyl: Oust, Spyder

Annual grasses

 

no

Pre and post

Foliar

     0.14 0.38
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

43

Herbicide: Representative Trade Names1

Common Targets

Alternatives

Selective to 

Plant Types

Pre or post 

emergent

Point of 

application

Areas Where Registered 

Use is Appropriate2

Application Rate3

(lbs./acre/year)

No Action 

Proposed Action

Alternative 3

Rangeland

Forest and Woodland

Riparian or Seasonal Wetland

Aquatic or Wetland

Oil, Gas, & Mineral Sites

Rights-of-Way

Recreation & Cultural Sites

Typical Max4

Triclopyr: Garlon, Renovate, Element

Purple loosestrife, trees, and shrubs

 

broadleaf, 

woody plants

Post

Foliar

   2    1 (10)

Proposed For Research and Demonstration

Fluazifop-P-butyl9: Fusilade DX

Annual and perennial grasses



grasses

Post

Foliar

   

Single application: 

0.1 to 0.375.

Maximum seasonal 

application 1.1259

1. See Table B-2, Herbicide Formulations Approved for use on BLM-managed Lands, in Appendix B for the full list of herbicide trade names 

approved for use on lands managed by the BLM in Oregon, including formulations with two or more active ingredients.

2. Different registrations are listed on the herbicide product label. Some types of registration (e.g., aquatic) require extensive additional testing 

with the EPA; the lack of registration for an area may indicate that a product has not completed that registration, not that there would be a risk. 

Some herbicide products may not be registered for use in an area, even though the active ingredient may have registration (e.g., in aquatic 

habitats, only certain formulations of glyphosate, the amine formulation of 2,4-D, and the trimethylamine (TEA) salt formulation of triclopyr are 

registered for aquatic use).

3. Actual intended application rates can be found in Table 2-10, Treatment Key.

4. Maximums are determined by herbicide product label and information analyzed in Risk Assessments. In cases where these two rates differ, 

the lower of the two rates is the maximum that can be applied on BLM-managed lands. Parentheticals denote herbicides that are limited by 

PEIS Mitigation Measures to typical application rates where feasible.

5. One (typical) and 1.9 (maximum) lbs./acre under the No Action, 1 and 2 lbs./acre for the Proposed Action for annual and perennial species.

6. Mitigation Measures adopted by the Oregon Record of Decision state, “where there is a potential for herbivore consumption of treated 

vegetation, apply dicamba, imazapyr, and metsulfuron methyl at the typical, rather than maximum, application rate to minimize risks.”

7. Three lbs./acre acid equivalent for the No Action Alternative and 7 lbs./acre under the Proposed Action. The 1987 Integrated Weed Control 

Plan and EA relies on a 1985 glyphosate Risk Assessment that analyzes glyphosate at 3 lbs./acre acid equivalent, based on the maximum 

application rate on a Rodeo © label. The 2011 glyphosate Risk Assessment analyzes a maximum rate of 7 lbs./acre. Maximum rates on 

formulated product labels listed in Table B-2 (Appendix B) range from 7 lbs./acre to 14 lbs./acre.

8. PEIS Mitigation Measures include “where practical, limit glyphosate and hexazinone to spot applications in grazing land and wildlife habitat 

areas to avoid contamination of wildlife food items.”

9. Information from SERA (2014). BLM maximum and typical rates have yet to be calculated, but would not exceed labeled rate.

Table 2-6. Herbicide Characteristics

Herbicides analyzed for Research and Demonstration

Fluazifop-P-butyl Fluazifop-P-butyl is effective on annual and perennial grasses, but does not affect broadleaf plants.

Herbicides approved for use on BLM-managed lands

2,4-D

2,4-D is effective on a wide range of broadleaf invasive plants while not affecting most grasses. 2,4-D 

can help inhibit seed production, prevent herbicide resistance, and effectively treat multiple invasive 

plant species when a variety are encountered in a particular treatment area. While having additional 

herbicides available can allow for more target specific control, having one herbicide that controls a vast 

range of vegetation can be beneficial when an area is dominated by a variety of invasive broadleaved 

plants. In addition, adding 2,4-D to a tank mix can often improve the effectiveness of the other 

herbicides and reduce the likelihood of an invasive plant developing herbicide resistance. The amount 

of 2,4-D used in combination with other herbicides would vary, based on these factors.

2,4-D is formulated as an amine or an ester. Esters have higher vapor pressures than amines, which 

results in increased likelihood of volatilization. 

Aminopyralid Aminopyralid is selective for broadleaf species, particularly members of the sunflower and legume 

families and is also effective on certain species in the carrot, nightshade, and knotweed families. It is 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

44

effective at controlling yellow starthistle, and various thistles (DiTomaso and Kyser 2006, Enloe et al. 

2008, Bell et al. 2012). It is an alternative to other growth regulator herbicides that are commonly used 

on broadleaf invasive plants, such as picloram, clopyralid, 2,4-D, and dicamba. Studies have also found 

aminopyralid to be as or more effective than the currently approved growth regulator herbicides at 

lower application rates (Enloe et al. 2007, 2008; Bell et al. 2012). It is more effective than clopyralid on 

tough to control members of the sunflower family. In mixtures with other active ingredients like 

metsulfuron methyl, it can be used on hard-to-control species like poison hemlock (DiTomaso et al. 

2013).

Chlorsulfuron

Chlorsulfuron is especially effective on broadleaf plants such as toadflax and thistles. It is often mixed 

with 2,4-D to reduce the likelihood of developing plant resistance and to deter seed production. Some 

grass species can be damaged by this herbicide, particularly wet meadow grass species such as meadow 

foxtail, some brome species, and timothy.

Clopyralid

Clopyralid targets many of the same species as picloram, but is more selective. It is particularly effective 

on knapweeds and Canada thistle, while minimizing risk to surrounding desirable brush, grass, and 

trees. 

Dicamba

Dicamba provides control right up to seed set, which extends the treatment window. It is often used in 

a tank mix with 2,4-D. It is effective on invasive broadleaves but offers little residual control. It is an 

option where resistance to sulfonylureas is a concern. It can reduce seed set in mustards but does not 

provide effective control. 

Dicamba + 

Diflufenzopyr

Diflufenzopyr + dicamba would be used for many of the same species as dicamba. Used where 

resistance to sulfonylureas is a concern. It is applied in the fall when native plants are dormant. Often 

used on roadsides. 

Fluroxypyr

Fluroxypyr is effective on annual and biennial invasive plants. It would be used to manage annuals in the 

carrot, sunflower, pea, knotweed, and nightshade families. Fluroxypyr is an option for addressing 

invasive plants that are resistant to herbicides with different modes of action. Its uses would likely 

include administrative sites and rights-of-way where resistance to currently approved herbicides could 

be a problem. 

Glyphosate

Glyphosate is used on broadleaf invasive plants and woody species and has been used to treat nearly all 

of the mapped noxious weed species on the District. However, it is a non-selective herbicide and can 

harm desirable plants. The overall use of glyphosate would decrease in riparian areas if additional 

aquatic formulations were available since glyphosate and 2,4-D have been the only two aquatic 

herbicides available to the District for the past 30 years. Aminopyralid would replace glyphosate for 

many terrestrial broadleaf species. The BLM does not use glyphosate formulated with 

polyoxyethylenamine (POEA).

Hexazinone

Hexazinone is effective on grasses, broadleaf and woody plants, both pre- and post- emergent. It could 

also be used to treat new invaders to the District where appropriate. Common targets could include 

invasive perennial grasses (especially false brome) and invasive broadleaf plants. Hexazinone is 

primarily used on roadsides.

Imazapic

Imazapic is a broad-spectrum herbicide for broadleaf and grass species, but is particularly effective on 

invasive annual grasses. It is selective for these grasses at low rates, leaving the perennial herbaceous 

species critical for restoration unharmed. It is applied before plants have emerged or to small rapidly 

growing plants. If heavy thatch or leaf litter is present, herbicide effectiveness is reduced.

Imazapyr

Imazapyr is very effective on brushy and woody species such as brooms, gorse, and blackberry. It is also 

used to treat perennial grasses, knotweeds, and European beachgrass. Imazapyr may be used for the 

control of yellow flag iris in and around standing and flowing water, as well as in riparian settings. 

Metsulfuron methyl Metsulfuron methyl has similar targets and effects as chlorsulfuron. It could be used on mustards and 

thistles. It can be used in combination with aminopyralid (Opensight) to treat annual forbs. 

Picloram

Picloram is effective on knapweeds, toadflax, and thistles, and provides good residual control. 

Appropriate at sites where soils are not sandy or gravelly. Aminopyralid and clopyralid target many of 

the same species and are more selective.

Rimsulfuron

Rimsulfuron is effective against annual grasses in the fall pre-emergence or post-emergence in the fall 

or spring when soil temperature is cool and rainfall is available to activate the herbicide. It provides a 

longer window of control than imazapic, although it must be used at the highest label rates for effective 

spring applications. It would not be applied near water. 

Sulfometuron 

methyl

Like imazapic, sulfometuron methyl is effective on invasive annual grasses and can be selective for 

annuals at low rates. It has a shorter half-life than imazapic, which speeds restoration efforts. At typical 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

45

and maximum rates, sulfometuron methyl will control many annual and perennial grass and broadleaf 

species. At low rates, it is safe on perennial grasses while controlling forbs and annual grasses. 

Triclopyr

Triclopyr is effective on woody plants, and would be used on brooms, gorse, trees, and shrubs. The 

aquatic formulations are also the most effective herbicide for treatment of purple loosestrife. Triclopyr 

BEE, the ester formulation, is more effective at smaller doses, but is more toxic to fish (and as a result, 

triclopyr BEE cannot be used in aquatic or riparian habitat). It is often used as a cut-stump treatment, in 

addition to foliar applications.

Stressors such as imperfect growing conditions (too wet, too dry, or poor soil nutrients) may prevent the herbicide 

from acting optimally. As described in the Issue sections in Chapter 3, in addition to the effects of the herbicides 

themselves, the application methods may have unintended adverse consequences. Similar to manual and 

mechanical treatments, personnel and equipment may trample vegetation and disturb soil, which can cause 

further spread of invasive plants. However, herbicide treatments are less likely to require numerous retreatments. 

In the Oregon FEIS, overall treatment efficacy was estimated at 30 percent if herbicides were not used.27

Resistance and Rotation

Herbicide resistance28 is the evolved ability of an invasive plant population to survive an herbicide application that 

was previously known to control the population. Where invasive plant infestations have been sprayed annually 

with the same herbicides with low likelihood of effective control, a concern is that plant populations could become 

herbicide resistant. Most plant populations showing herbicide resistance are in agriculture settings; however, 

resistance has been documented in wildland vegetation management settings (University of Idaho 2011). 

Resistance can result from repeated use of the same herbicides, or several herbicides with the same site of action. 

BLM has been limited to use of the same four herbicides for over 30 years, which may have inadvertently 

contributed to resistant invasive plant species.

The use of additional herbicides would help prevent herbicide resistance by adding chemicals that control the 

plants through different modes (sites) of action. More effective rotation of herbicides (see Table 2-7), when 

coupled with integrated invasive plant management, would help prevent the development of herbicide resistance. 

Many product labels for the acetolactate synthase (ALS)-inhibitors (such as chlorsulfuron and metsulfuron methyl) 

recommend tank-mix partners, sequential herbicide applications that have different modes of action, or both.

Table 2-7. Guide for Herbicide Rotation1

Herbicide 

Group

Herbicide Chemical 

Family

Herbicide Common 

Name Resistant Plants2 States with Resistant Plants

ACCase 

Inhibitors

Aryloxyphenoxypropanoates Fluazifop-P-butyl cheatgrass Oregon

ALS-Inhibitors

Imidazolinones Imazapic none none

Imazapyr none none

Sulfonylureas

Chlorsulfuron

prickly lettuce

kochia

Russian thistle

annual ryegrass

dogfennel

littlepod falseflax

Idaho, Oregon, Washington

Idaho, Oregon, Washington

Idaho, Oregon, Washington

Oregon

Idaho, Washington

Oregon

Metsulfuron methyl prickly lettuce

kochia

Idaho, Oregon

Oregon

 27 See the Alternatives section for treatment efficiency under each of the alternatives. 28 Naturally resistant plants occur within a population in extremely small numbers (somewhere between 1 in 100,000 to more 

than 1 in 1,000,000). They differ slightly in genetic makeup from the original populations, but they remain reproductively 

compatible with them. The repeated use of one herbicide, or of herbicides that kill the plants the same way (same mode or site 

of action), allows these few plants to survive and reproduce. The number of resistant plants then increases in the population

until the herbicide no longer effectively controls it.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

46

Herbicide 

Group

Herbicide Chemical 

Family

Herbicide Common 

Name Resistant Plants2 States with Resistant Plants

Russian thistle

littlepod falseflax

Oregon

Oregon

Rimsulfuron none none

Sulfometuron methyl none none

Synthetic auxins

Phenoxyacetic acids 2,4-D prickly lettuce Washington

Benzoic acids Dicamba kochia

prickly lettuce

Idaho

Washington

Pyridines

Aminopyralid none none

Clopyralid none none

Fluroxypyr none none

Picloram yellow starthistle Washington

Triclopyr none none

Photosystem II 

inhibitors As-triazines Hexazinone Shepard’s-purse Oregon

ESPS synthase 

inhibitors Glycines Glyphosate annual ryegrasskochia

Oregon

Oregon, Idaho

1. Adapted from Herbicide-resistant Weeds and Their Management (University of Idaho 2011). To avoid selecting for herbicide-resistant 

invasive plants, rotate to a different group every year if possible. Avoid using herbicides from the same group more than once every three 

years.

2. Some species not present on Coos Bay District

Human Health and Ecological Risk Assessments

The following section is adapted from Appendix 8 of the Oregon FEIS (USDI 2010a:605-606).

One of the purposes identified in Chapter 1 is Prevent 

control treatments from having unacceptable adverse 

effects to applicators and the public, to desirable flora and 

fauna, and to soil, air, and water. To help address this 

purpose, the EA (and the 2007 PEIS, the 2010 Oregon FEIS, 

and the 2016 PEIS to which the EA tiers) rely on BLM and 

U.S. Forest Service-prepared Human Health and Ecological 

Risk Assessments for the herbicides included in this EA. 

The BLM prepared or adopted these Risk Assessments as part of the 2007 and 2016 PEIS process and they are 

included as appendices to those documents. These Risk Assessments are used to quantitatively evaluate the 

probability (i.e., risk) that herbicide use in wildland settings might pose harm to humans or other species in the 

environment. As such, they address many of the risks that would be faced by humans, plants, and animals, 

including Special Status species, from exposure to the herbicides. The level of detail in the Risk Assessments for 

wildland use exceeds that normally found in the EPA’s registration examination. Court decisions and others have 

affirmed that although the BLM can use EPA toxicology data, the BLM is still required to do an independent 

assessment of the safety of pesticides rather than relying on Federal Insecticide, Fungicide and Rodenticide Act

registration alone.

Risk is defined as the likelihood that an effect (such as skin or eye irritation, leaf damage, mortality, etc.) may result 

from a specific set of circumstances. Risks to non-target species associated with herbicide use are often 

approximated via the use of surrogate species, as toxicological data does not exist for most native non-target 

species. Survival, growth, reproduction, and other important processes of both terrestrial and aquatic non-target 

species are considered. The Risk Assessments consider acute and chronic toxicity data. The Risk Assessments 

analyze the exposures of receptors29 to direct spray, surface runoff, wind erosion, and accidental spills.

 29 A biological entity such as a human, fish, plant, or invertebrate.

A summary of the risk ratings from the various Risk 

Assessments, along with an explanation of how the risk 

ratings were derived, are included in Appendix C, 

Herbicide Risk Assessment Summaries.

The risk ratings are the source for much of the individual 

herbicide information, including the high-moderatelow-no (0) risk ratings, presented in Chapter 3.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

47

The Risk Assessments, related separate analyses, the Oregon FEIS, and the 2007 and 2016 PEISs include analyses of 

inert ingredients and degradates for which information is available and not constrained by confidential business 

information restrictions30. To the degree a toxic substance is known to pose a significant human or ecological risk, 

the BLM and U.S. Forest Service have undertaken analyses to assess their effects through Risk Assessments. 

Information about uncertainty in Risk Assessments is included in the Oregon FEIS, Appendix 13.

It is important to remember that risk ratings are based on exposure scenarios described in the Risk Assessments. 

The likelihood of actual exposures comparable to those described in the Risk Assessments is reduced by 

application of Standard Operating Procedures and other Protection Measures (see below), as well as by the nature 

of the application and the location and actions of the receptor.

The effects described in the issues in Chapter 3 often describe risk ratings, but also describe the levels at which 

there is an effect (or high levels where no effect can be found), even though those scenarios may involve much 

higher concentrations or use than the BLM proposes.

For more information, see Appendix C, Herbicide Risk Assessment Summaries.

Standard Operating Procedures and other Protection Measures

The BLM has identified Standard Operating Procedures to reduce adverse effects to environmental and human 

resources from vegetation treatment activities based on guidance in BLM manuals and handbooks, regulations, 

and standard BLM and industry practices (listed in Appendix A, Protection Measures). Effects described in this EA 

are predicated on application of the Standard Operating Procedures or equivalent, unless an on-site determination 

is made that their application is unnecessary to achieve their intended purpose or protection. For example, the 

Standard Operating Procedure to “Provide alternative forage sites for livestock, if possible” would not need to be 

applied where livestock are not present.

Mitigation Measures were identified for all potential adverse effects identified for herbicide applications in the 

2007 and 2016 PEISs (USDI 2007a, USDI 2016a), and adopted by their Records of Decision (also listed in Appendix 

A). In other words, no potentially significant adverse effect identified in the PEIS analyses remained at the 

programmatic scale after the Mitigation Measures were adopted. Like the Standard Operating Procedures, 

application of the Mitigation Measures is assumed in the analysis in this EA. Mitigation Measures were also 

identified and adopted for adverse effects identified in the Oregon FEIS (USDI 2010a). In the analysis in this EA, 

application of these measures (also listed in Appendix A) is assumed. No potentially significant adverse effect was 

identified at the programmatic scale in the Oregon FEIS with the Standard Operating Procedures and Mitigation 

Measures applied.

In addition, consultation regarding federally listed species resulted in the identification of Conservation Measures 

and Project Design Criteria to protect Coos Bay District listed species from treatments. These are provided in

Appendix A, in the Protection Measures for Federally Listed Species section. Project Design Features were also 

identified to prevent unwanted effects from treatments under the Proposed Action and Alternative 3 in this EA.

The District would also follow applicable Best Management Practices listed in the Northwest and Coastal Oregon 

Resource Management Plan (USDI 2016d:139-180). These can be found in Appendix C of the Resource 

Management Plan.

 30 Under the Toxic Substances Control Act, an herbicide manufacturer may request that certain proprietary information, the 

release of which would cause substantial business injury to the owner, be kept confidential by the EPA.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

48

The Alternatives

This section describes three alternatives in detail, the No Action Alternative (Alternative 1), the Proposed Action 

(Alternative 2), and Alternative 3. These are the alternatives addressed in the effects analysis in Chapter 3. This 

section also describes the other alternatives that were considered but were not carried forward for detailed 

analysis. The alternatives address the dynamic nature of invasive plants, including increasing numbers of invasive 

plant31 species and changing conditions of infestations. Due to the nature of invasive plants, the size of the land 

base involved, and the nature of multiple uses that take place on it, invasive plant control would remain an 

ongoing need. For the purposes of this analysis, it is assumed the alternatives would be implemented for a period 

of 20 years. The intent is to manage invasive plants in order to minimize adverse ecological and economic effects. 

A comparison of the treatment methods used under each alternative is shown in Table 2-11, Comparison of the 

Alternatives, Treatment Methods.

The 2010 Oregon FEIS, to which this document tiers, considered three action alternatives, as well as a reference 

analysis which displayed the effects of not using herbicides on BLM-managed lands. The Proposed Action and 

Alternative 3 in this EA are most similar to Alternative 3 in the Oregon FEIS, whereas the No Action Alternative in 

this EA is similar to the No Action Alternative (Alternative 2) in the Oregon FEIS. The 2007 PEIS, to which the 

Oregon FEIS tiered, considered four action alternatives. In addition, both of these EISs considered numerous 

alternatives not analyzed in detail. The 2016 PEIS, to which this EA also tiers, considered three additional action 

alternatives.

The No Action Alternative – Noxious Weed Management 

(Alternative 1)

Under the No Action Alternative, the District would continue to implement the district-wide 1997 Integrated 

Noxious Weed Program on the Coos Bay District Environmental Assessment (USDI 1997), consistent with the

Resource Management Plan and other Coos Bay District direction. Treatment methods analyzed in the 1997 EA 

include herbicides, biological control agents (or biocontrols), targeted grazing, prescribed fire, and manual and 

mechanical methods to treat noxious weeds. The herbicides available for noxious weed management efforts are 

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

Direct control treatments on the District have consisted primarily of manual methods (hand pulling) and 

mechanical methods (e.g., bulldozers, discing, mowing, or chainsaws), competitive seeding and planting, 

biocontrols, targeted grazing with cattle, and the herbicide glyphosate. Prescribed fire and the herbicides 2,4-D, 

picloram, and dicamba are also occasionally used (see Table 2-8).

Under this alternative, the District would treat approximately 1,000 gross acres annually. Approximately 80 

percent of those treatments would be with herbicides, 10 percent would be manual methods, 10 percent would be 

mechanical, and less than 1 percent would be targeted grazing and biocontrols. Mechanical treatments with large 

machinery (e.g., bulldozers) would only be done in the North Spit, New River, and Dean Creek areas. Of the 

herbicides, about 95 percent of the herbicide treatments would be with glyphosate and 5 percent would be with 

2,4-D, dicamba, picloram, or a tank mix of two or more of those (see Table 2-10, Treatment Key). The Annual 

Treatment Summary table (Table 2-8) shows the last six years of treatments. All herbicide applications are done as 

spot treatments with a hand-directed sprayer.

 31 The inclusive term “invasive plants” is used here for simplicity. Herbicide use under the No Action Alternative is limited to

noxious weeds, a subset of invasive plants.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

49

Figure 2-2. Western Snowy Plover Habitat Restoration Areas (North Spit and New River)
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

50

Table 2-8. Annual Treatment Summary (2012-2017)

For the No Action Alternative, Table 2-

10, Treatment Key, shows treatment 

options by treatment group. (Treatment 

groups are indicated in Tables 2-1, 2-3, 

and D-5, which describe the different 

Categories of invasive plants on the 

District.) In addition, the District would 

use competitive seeding and planting on 

an average of 100 acres/year of noxious 

weed infestations; these sites would 

generally be about 1⁄2 acre and would 

occur in conjunction with direct control 

methods. In Dean Creek, tilling may be 

done in advance of seeding and planting 

if soil compaction has occurred. Plants 

excluded from treatment would be 

invasive plants not listed as noxious 

weeds, and most infestations of noxious 

weeds not reasonably controlled by the 

four herbicides and other treatment 

methods available under this 

alternative.

In western snowy plover habitat, 172 acres are designated as habitat restoration areas, including 100 acres at New 

River and 72 acres at the North Spit (see Figure 2-2). These acres are infested with European beachgrass and other 

noxious weeds. In these habitat restoration areas, approximately 100 acres of European beachgrass would 

primarily be treated mechanically twice a year, with heavy equipment such as tractor-mounted discs or bulldozers. 

At New River, no herbicides would be used in the plover habitat restoration area and, as described in the New 

River Foredune Management EA (USDI 2009a), European beachgrass stabilizing the 50-foot-wide vegetated 

foredunes along New River would not be treated.

At the North Spit, in BLM-managed snowy plover habitat restoration areas, the BLM would treat up to 24 acres 

annually with glyphosate. In addition to treatments on BLM managed lands, the BLM has a 2012 interagency 

agreement to treat western snowy plover habitat restoration area land managed by the U.S. Army Corps of 

Engineers. Invasive plant treatments on land managed by the U.S. Army Corps of Engineers are not covered by this 

EA; however, treatments on BLM-managed lands would follow the guidelines described in the interagency 

agreement, or updated equivalent32. The 2012 interagency agreement specifies that European beachgrass on the 

ocean foredune as well as a vegetated buffer east of it would not be treated, except for plover access cuts, where 

treatments would avoid the removal of the root system. While treatments in western snowy plover habitat 

primarily target European beachgrass, approximately three acres (net) of other noxious weed species (such as 

Scotch broom and field bindweed) in this area would be treated with manual or mechanical methods or 

glyphosate. 

All treatments are constrained by the Standard Operating Procedures and other measures listed in Appendix A, by 

the herbicide application rates listed on Table 2-5 (Herbicide Information), and by the other policy constraints 

described earlier in the Integrated Invasive Plant Management section of this chapter.

 32 Provided any updates to the interagency agreement continued to follow guidance in the North Spit Plan (USDI 2005) and 

Biological Assessment of the BLM’s North Spit Plan as it may affect the Threatened Western Snowy Plover and its Critical Habitat

(USDI 2007f) and associated Biological Opinion.

Treatment Method1 Acres2 Treated

2012 2013 2014 2015 2016 2017

Herbicide (total) 1,346.5 725.7 469.0 1,071.6 613.3 155.9

2,4-D (only) 82.0 9.0 - - - -

Dicamba (only) - - - - - -

Glyphosate (only) 1,201.0 644.3 269.0 757.9 581.0 155.4

Picloram (only) - - 19.5 - - -

2,4-D + Dicamba 63.5 64.4 185.5 313.7 32.3 -

2,4-D + Glyphosate - - - - - 0.5

2,4-D + Picloram - 8.0 - - - -

Manual 55.0 38.0 85.0 246.0 112.0 42.0

Mechanical 480.0 402.0 35.0 175.0 292.0 240.0

Biocontrol3 - - - - - -

Targeted Grazing 10.0 10.0 10.0 10.0 10.0 10.0

Re-vegetation or Seeding 47.0 69.0 77.0 54.0 70.0 52.0

Inventory 3,825.0 3,100.0 350.0 3,100.0 813.0 116.0

1. Prescribed fire has been used on the District to remove invasive plants not listed as a 

noxious weed. This has been done as habitat restoration (not as part of the noxious 

weed program) and has occurred on 50 to 100 acres annually.

2. Acres of plants treated each year should be considered gross and not net, as mapping 

accuracy and reporting has not been consistent between applicators. 

3. Biocontrols are present and widespread on the District (see Table 2-4, Biocontrol 

Releases within the Coos Bay District Boundary) but no biocontrols have been released 

on BLM-managed lands in the last five years.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

51

As described in the Oregon FEIS to which this EA tiers, the use of these herbicides along with non-herbicide 

methods would continue to slow the spread of noxious weeds within the District. However, certain noxious weeds 

and most of the other invasive plants would continue to spread. For example, the spread of Canada thistle and 

false brome can be slowed but not adequately controlled under this alternative; available treatments for these 

species only reduce the vigor or seed development. Invasive grasses cannot be effectively treated because there is 

no herbicide available that is selective to these grasses. Roughly half of the treatments in a given year would be retreatments of areas treated in previous years, because the treatments available under this alternative are 

estimated to be 60 percent effective at controlling small infestations with one treatment (USDI 2010a:136). The 

site-specific analysis of this can be found in Chapter 3.

Proposed Action – Invasive Plant Management with ARBO II 

Consultation (Alternative 2)

The Proposed Action allows all terrestrial invasive plants (not just noxious weeds) to be treated, and is expanded to

include the use of nine additional herbicides. Herbicides and treatment methods would be limited to those 

consulted on in the 2013 Aquatic Restoration Biological Opinions (ARBO II, USDI 2013a, NMFS 2013), which

programmatically addressed the effects of aquatic restoration activities (including invasive plant management) in 

Oregon and Washington. In addition to the manual and mechanical treatment methods, biological control agents, 

targeted grazing, and seeding and planting used under the No Action Alternative, non-herbicide direct control 

methods would increase the use of prescribed fire and add the use of weed barrier mats and propane torch spot 

treatments. Herbicides available for use under the Proposed Action would include 2,4-D, aminopyralid, 

chlorsulfuron, clopyralid, dicamba, dicamba + diflufenzopyr, glyphosate, imazapic, imazapyr, metsulfuron methyl, 

picloram, sulfometuron methyl, and triclopyr.

The District would continue to treat approximately 1,000 gross acres annually with herbicides, manual and 

mechanical methods, and targeted grazing. Approximately 90 percent of those treatments would be with 

herbicides. As described under the No Action Alternative, mechanical treatments with large machinery (e.g., 

bulldozers or tractors with discs, plows, or mowers attached) would only be done in the North Spit, New River, and 

Dean Creek Elk Viewing areas. Of the herbicide treatments, more than 40 percent of the treatments would be with 

triclopyr, which is effective on woody species, like brooms, gorse, and blackberry. Aminopyralid (effective on 

thistles, starthistles, and knapweeds) would account for about 15 percent of treatments, and glyphosate would 

drop from about 95 percent (under the No Action) to approximately 15 percent. Table 2-10, Treatment Key, shows 

treatment options by treatment group, including considerations as to why a specific treatment would be used. Of 

the herbicide treatments, approximately 95 percent would be spot treatments and 5 percent would be broadcast 

treatments.

In addition to the treatments described in the Treatment Key, the District would continue to use competitive 

seeding and planting to complement other treatment methods on an average of 100 acres/year. In Dean Creek, 

tilling may be done in advance of seeding and planting if soil compaction has occurred. Weed barrier mats would 

be used in conjunction with some seeding and planting; this would happen on approximately 1⁄4 acre annually in 

administrative sites and recreation sites, and treatments would occur over two to six months. Examples of areas 

where this may occur are a 4 or 5 foot strip next to the fence line at Dean Creek Elk Viewing Area or as a 30 by 100 

foot tarp at the boat ramp at the North Spit.

Prescribed fire would also be used in meadows and on dunes to control invasive plants, primarily33 grasses. For 

example, in the Hunter Creek and New River ACECs, prescribed fire would be used to reduce seed and thatch of 

 33 Approximately 95 percent of species treated with prescribed fire would be invasive annual or perennial grasses. Scotch 

broom and annual species like yellow starthistle could also be treated in meadows when intermixed with these invasive 

grasses.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

52

invasive annual and perennial grasses; in the Dean Creek Elk Viewing Area, it would be used primarily to reduce 

thatch and vigor of perennial reed canarygrass; and on dunes, it would be used to reduce thatch and vigor of 

perennial European beachgrass. These treatments have been done in previous years as habitat restoration but 

would be done as part of the invasive plant program under the Proposed Action. Prescribed fire would typically be 

used in conjunction with other treatments, such as seeding or application of herbicides. This would happen on 

approximately 100 acres annually. Project sizes would generally be between 1 to 20 acres, except in the Dean 

Creek Elk Viewing Area, where prescribed fire treatments would be up to 100 acres. Prescribed fire would happen 

in conjunction with an agency administrator-approved burn plan.

Treatments in western snowy plover habitat would be implemented as described under the No Action Alternative, 

with the exception that invasive plants that are not listed as noxious weeds would be treated as well. As described 

in the No Action Alternative, 172 acres are designated as western snowy plover habitat restoration areas (100 

acres at New River and 72 acres at the North Spit; see Figure 2-2). These acres are infested with European 

beachgrass and other invasive plants. In these habitat restoration areas, European beachgrass would primarily be 

treated mechanically twice a year, with heavy equipment such as discs or bulldozers. 

At New River, no herbicides would be used in the plover habitat restoration area and, as described in the New 

River Foredune Management EA (USDI 2009a), European beachgrass stabilizing the 50-foot-wide vegetated 

foredunes along New River would not be treated.

At the North Spit, in BLM-managed snowy plover habitat restoration areas, the BLM would treat up to 24 acres 

annually with glyphosate. In addition to treatments on BLM managed lands, the BLM has a 2012 interagency 

agreement to treat western snowy plover habitat restoration areas on North Spit land managed by the U.S. Army 

Corps of Engineers. Invasive plant treatments on land managed by the Corps is not covered by this EA; however, 

treatments on BLM-managed lands would follow the guidelines described in the interagency agreement, or 

updated equivalent34. This agreement specifies that European beachgrass on the ocean foredune as well as a 

vegetated buffer east of it would not be treated, except for plover access cuts, where treatments would avoid the 

removal of the root system. While treatments in western snowy plover habitat primarily target European 

beachgrass, other invasive plant species (such as Scotch broom, field bindweed, sea-rocket, false dandelions, wild 

radish, annual grasses, and sheep sorrel) in this area would be treated with manual or mechanical methods or 

glyphosate.

As with the No Action Alternative, all treatments are constrained by the Standard Operating Procedures and other

measures listed in Appendix A, by the herbicide application rates listed on Table 2-5 (Herbicide Information), and 

by the other policy constraints described earlier in the Integrated Invasive Plant Management section of this 

chapter.

As described in the Oregon FEIS to which this EA tiers, the wider range of herbicides from which to choose would 

generally increase the effectiveness of the average treatment to an estimated 80 percent (USDI 2010a:136). 

Although some level of retreatment would still take place, the additional herbicides would substantially improve 

the chances that the invasive plant would be controlled with fewer retreatments (USDI 2010a:135-136). 

Treatments described under this alternative are efective on almost all of the types of invasive plants known to be 

present on the District, including those with potential to be new invaders. The site-specific analysis of this can be 

found in Chapter 3.

 34 Provided any updates to the interagency agreement continued to follow guidance in the North Spit Plan (USDI 2005) and 

Biological Assessment of the BLM’s North Spit Plan as it may affect the Threatened Western Snowy Plover and its Critical Habitat

(USDI 2007f) and associated Biological Opinion.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

53

Annual Treatment Plans

The District determines potential treatments based in part on available tools and funding, and develops a districtwide Annual Treatment Plan prior to the beginning of control treatments. In addition, specific area or project 

treatment plans are developed in coordination with partners. Annual Treatment Plans are subject to an 

interdisciplinary team35 review to ensure there is no new information or changed circumstances that would change 

the Decision that results from this EA or substantially alter this EA’s analysis. If there is relevant new information or 

changed circumstances, the District would revise the Annual Treatment Plan to comply with the Decision or the 

appropriate level of NEPA analysis would be completed and a new Decision would be issued. Annual Treatment 

Plans help the District ensure that treatments conform to design and mitigation standards in the relevant NEPA 

documents36, and that the required Pesticide Use Proposals, Biological Control Agent Release Proposals, and other 

authorizations, obligations, and commitments37 are completed prior to implementation. Every control treatment, 

however, is not always on the Annual Treatment Plan. Unexpected events such as increased or decreased funding, 

new invaders, wildfire, or weather conditions could alter implementation of the Annual Treatment Plan.

This year’s invasive plant control activities planned for the District are summarized on Table 2-9 to present an 

example of how priorities and treatment methods would be implemented.

Additional Monitoring Under the Proposed Action

For treatment methods that are new to the Coos Bay District, for the first three years after the plan is 

implemented, the BLM would closely monitor the response of Special Status plants to invasive plant treatments. 

Monitoring would happen yearly and would measure Special Status plant numbers, plant size, and whether plants 

are reproductive or not. No more than five percent of a Special Status plant population would be included within a 

treatment area until effects to Special Status plants can be determined. If adverse effects occur (e.g., impacts or 

loss of a few individual Special Status plants), the BLM would weigh the consequences of these effects against the 

long-term impacts of invasive plants, including continued spread, that would be expected in the absence of 

treatments. By monitoring community-level treatment effects and refining prescriptions for subsequent 

treatments, adverse effects are expected to decline with increasing experience. The BLM would accept short-term 

adverse effects in Special Status plant communities if treatments were expected to benefit conditions and 

ecosystem function in the long-term. It is expected that information gained from this monitoring will provide 

additional information to consider as part of Table 2-10, Treatment Key; helping to refine future prescriptions for 

greater success.

 35 The interdisciplinary team would include botanists, wildlife and fisheries biologists, archeologists, and other natural resource 

specialists with expertise in potentially affected resources. 36 For example, Project Design Features, Standard Operating Procedures, Mitigation Measures, and Conservation Measures (for 

Special Status species). These are all included in Appendix A.

37 Such as required Special Status species, archaeological, and paleontological surveys, as well as SHPO consultation.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

54

Table 2-9. Annual Treatment Plan

Field Office 

or Area Project Name Gross Acres

Primary Treatment 

Methods1

Anticipated 

Treatment Window Target Species Objective and Comments

District-wide New invaders 5 Manual

and herbicide Year-round Gorse or new invaders

Inventory and treat reported infestations of gorse or new 

invaders. All sites would be less than 0.1 acres and are typically 

on roadsides.

District-wide Recreation Sites 40 Mechanical, manual, 

and herbicide Year-round Scotch broom, blackberry, other invasive plants

Prevent spread and preserve recreation access. Most 

treatments would be with string trimmers or mowers. Fall 

application of herbicides on dense blackberry patches.

District-wide Revegetation 

with native seed 90 Revegetation Fall orearly spring All non-natives Prevention. Post project revegetation of bare soil following soil disturbance.

Myrtlewood Bosely Butte 20 Herbicide and manual Spring to early 

summer Brooms, all invasive plants Habitat enhancement for Gasquet manzanita.

Myrtlewood Gorse Outliers 

Priority Sites 50 Herbicide and manual Year-round Gorse

Eradicate gorse on power line rights-of-way, roadsides and in 

forest areas.

Herbicide spring and fall. Manual when soil is moist.

Myrtlewood Grizzly Mountain 1 Manual Spring, early 

summer, fall Brooms, all non-natives Habitat enhancement for Gasquet manzanita.

Myrtlewood Hunter Creek 

ACEC 25 Herbicide or manual Late spring, early 

summer or fall 

Canada thistle, bristly dogtail grass, 

annual grasses, tansy ragwort, 

woodland tansy, coastal burnweed

Habitat enhancement for Mardon skipper and other rare 

butterflies. Herbicide needed for control of Canada thistle and 

annual grasses.

Myrtlewood Hunter Creek 

Bog Trail 1 Manual or herbicide Late spring, summer, fall All invasive plants Inventory and treat or monitor and treat.

Myrtlewood Myrtlewood 

Roadside 100 Herbicide Late spring or early 

summer to fall

Scotch broom, French broom, 

blackberry, meadow knapweed, 

Japanese knotweed, biddy-biddy

Prevent from spreading into planned project areas and down 

roads. Mostly roadside except Japanese knotweed (riparian).

Myrtlewood New River -

Floras Lake 5 Manual, propane 

torch or herbicide Year-round

European beachgrass, big 

quakinggrass, ripgut brome, rattail 

fescue, tall fescue, sweet vernal grass, 

lance-leafed plantain, false dandelion, 

catchfly, birdsfoot trefoil, other 

invasive plants

Habitat enhancement for silvery phacelia, many-leafed gilia, 

and coastal cryptantha at Floras Lake. Propane burner used to 

destroy seed heads. Herbicide would be used in fall, winter to 

early spring.

Myrtlewood New River - Lost 

Lake 40

Herbicide,

manual, and 

mechanical 

Year-round Gorse

Prevent from producing seed or spreading. Goal: eradication. 

Herbicide would be used in spring and fall. Manual treatments 

when soil is moist and mechanical in summer.

Myrtlewood New River - Lost 

Lake 20 Herbicide andmanual Summer and fall European beachgrass, lance-leafed plantain Habitat enhancement for silvery phacelia and coastal sagewort.

Myrtlewood New River ACEC 30 Herbicide and manual Late spring, 

summer, and fall

Gorse, brooms, meadow knapweed, 

yellow flag iris, Canada thistle, 

Himalayan blackberry, silver wattle

Prevent spread and preserve native plant communities.

Myrtlewood New River ACEC 100 Mechanical, manual, 

and herbicide

September 16 -

March 14 European beachgrass Habitat enhancement for western snowy plover, pink sand verbena. (Herbicides only available under Alternative 3.)
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

55

Field Office 

or Area Project Name Gross Acres

Primary Treatment 

Methods1

Anticipated 

Treatment Window Target Species Objective and Comments

Myrtlewood New River-Open 

Sand 20 Herbicide and manual Year-round European beachgrass, annual grasses, plantain

Habitat enhancement for pink sand verbena. Herbicides used 

summer-fall, manual year-round.

Myrtlewood North Fork 

Coquille 50 Herbicide Late summer, fall Japanese knotweed Ongoing control of priority infestation.

Myrtlewood Palmer Butte 1 Manual Spring, summer, fall Brooms, all non-natives Habitat enhancement for Gasquet manzanita. Done when soil is 

moist.

Myrtlewood Roadside Weed 

Control 100 Herbicide Fall and spring Brooms, blackberry, false brome, meadow knapweed

Reduce or prevent spread on roadsides and into planned 

project areas.

Umpqua North Spit 200 Mechanical, manual or 

herbicide Year-round

European beachgrass, gorse, Scotch 

broom, English ivy, field bindweed, 

Darwin’s barberry

Invasive plant treatment and habitat enhancement for pink 

sand verbena, western snowy plover, salt marsh bird’s beak, 

western rosemary. Treatments in habitat restoration areas 

limited to Sept. 16 to March 14. Manual treatments year round 

in other areas. Herbicides used in spring and fall.

Umpqua Dean Creek Elk 

Viewing Area 50 Herbicide and manual Spring, summer, fall

Tansy ragwort, Canada thistle, bull 

thistle, Scotch broom, purple 

loosestrife, Himalayan blackberry

Habitat enhancement 

Umpqua Dean Creek Elk 

Viewing Area 5 Manual, mechanical, or herbicide Year round

Tansy ragwort, woodland tansy, bull 

thistle, Scotch broom, invasive grasses, 

invasive clovers, false dandelions, herb 

Robert

Ongoing control of invasive plants in visitor areas and plantings. 

Herbicides used in spring and fall.

Umpqua Dean Creek Elk 

Viewing Area 100 Mechanical, prescribed fire Early summer Reed canarygrass Habitat enhancement for elk forage. Mowing followed by grass removal or prescribed fire.

Umpqua Spruce Reach 

Island 5 Herbicide Spring and fall

Himalayan blackberry, Scotch broom, 

butterfly bush, herb Robert, creeping 

buttercup, yellow flag iris

Preserve historical garden and surrounding wetland supporting 

Henderson’s checkermallow.

Umpqua Umpqua 

Roadside 800 Herbicide Spring to early 

summer and fall

Scotch broom, French broom, 

blackberry, meadow knapweed, 

Japanese knotweed

Maintain road access, preserve forest and riparian health.

Umpqua W Fork Smith 

Timber Sale 50 Herbicide Spring to early summer Brooms, all invasive plants Prevention. Pre-timber sale to remove invasive plants prior to ground disturbance.

Umpqua Wassen Creek 20 Herbicide Spring to early 

summer Scotch broom, blackberry Prevent spread from roads into ACEC to preserve relevant and important values.

Umpqua Wells Creek 1 Herbicide Fall Japanese knotweed Eradication

1. All herbicide treatments in this table would be spot treatments with hand directed application, Treatments are listed in order of probable use; e.g., “manual, herbicide” means that manual treatments would be used 

more often than herbicide.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

56 

Project Design Features of the Proposed Action

In addition to Standard Operating Procedures, Mitigation Measures adopted with the 2007 and 2016 PEISs and 

2010 Oregon FEIS, and protection measures designed to protect federally listed species (all described in Appendix 

A), the following Project Design Features are included in the Proposed Action to reduce potential adverse effects of 

the Proposed Action:

Bureau Sensitive Species (Plants, Fish, and Wildlife)

• Follow the Bureau Sensitive Species Treatment Conditions flowchart (Figure 3-2, Bureau Sensitive Species 

Treatment Conditions) when working in potential habitat for Bureau Sensitive species.

Special Status Plants

• When using prescribed fire in western snowy plover habitat restoration areas, reseed with pink sand 

verbena or other appropriate native species in areas where revegetation will not occur through natural 

processes. 

Fish and Aquatic Organisms

• Apply the aquatic no-herbicide application buffers specified in the Aquatic Restoration Biological Opinion 

II (NMFS 2013) from the National Marine Fisheries Service to all waterbodies with known or suitable 

habitat for Bureau Sensitive or Strategic fish and other aquatic species (see Appendix A). 

Wildlife

• In listed species habitat, follow all Project Design Criteria outlined in the Coos Bay BLM District Bureau of 

Indian Affairs/Coquille Indian Tribe FY2014 – 2018 Land Management Activities That May Affect Northern 

Spotted Owls or Marbled Murrelets (USDI 2014a) (see Appendix A, Protection Measures) or future 

updates.

• Conservation Measures (see Appendix A) applicable to butterflies and moths will be applied, as 

appropriate, for other Special Status insects.

Archaeological and Cultural Resources 

• Avoid getting herbicides (through drift or accidental direct spray) on rock art or wooden/metal structures 

or artifacts at National Register of Historic Places (NRHP) listed or eligible sites.

• Avoid repeated use of livestock (more than one grazing episode annually) at National Register of Historic 

Places (NRHP) listed or eligible sites.

Traditional and Cultural Uses (Native American Interests)

• At least one month prior to beginning treatments, Annual Treatment Plans will be presented to the Tribes 

showing planned treatments and treatment areas. Any resultant consultation will identify where timing of 

treatments can be modified, where cultural features should be avoided or protected, and where posting 

would help Tribe members avoid areas. Maps of known invasive plant infestations (see Map 2-1, Invasive 

Plants Documented in NISIMS, for example) will also be shared with the Tribes at this time.

• Where coordination with the Tribes about the Annual Treatment Plan identifies areas where herbicide use 

would not be consistent with cultural values and uses, alternative control methods will be implemented 

where feasible.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

57

Invasive Plant Management with Additional Endangered 

Species Act Consultation (Alternative 3)

Alternative 3 is the same as the Proposed Action (approximately 1,000 acres of invasive plants treated annually 

with herbicides, manual and mechanical methods, and targeted grazing), except that it also includes the use of the 

herbicides hexazinone, rimsulfuron, and fluroxypyr and allows herbicides other than glyphosate to be used in 

western snowy plover habitat restoration areas. In addition, there would be limited and controlled use of fluazifopP-butyl, which does not have a Risk Assessment created or adopted by the BLM. This would occur on research and 

demonstration plots up to 5 acres in size, with a maximum of 15 acres per Field Office.38

Hexazinone, rimsulfuron, and fluazifop-P-butyl would be used to treat invasive grasses: hexazinone would be used 

primarily to treat false brome (a perennial grass) along rights-of-way in forests; rimsulfuron would be used in 

rotation with imazapic to treat annual grasses, and fluazifop-P-butyl would be used in limited situations to treat 

perennial grasses like pampas grass, jubata grass, and sweet vernal grass. Fluroxypyr would be used on 

miscellaneous annual herbaceous invasive plants and on invasive plants in the geranium family. Hexazinone and 

rimsulfuron would be used approximately one percent of the time when herbicides are used, and fluazifop-P-butyl 

and fluroxypyr would be very rarely used (30 acres and 3.7 acres over the life of the plan, respectively).

In western snowy plover habitat, 172 acres are designated as habitat restoration areas (100 acres at New River and 

72 acres at the North Spit; see Figure 2-2, Western Snowy Plover Habitat Restoration Areas (North Spit and New 

River). These acres are infested with European beachgrass and other invasive plants. In these habitat restoration 

areas, imazapyr, glyphosate, or imazapyr mixed with glyphosate would be used to treat European beachgrass. 

While this could occur on all 172 acres in one year, it would generally happen on approximately 100 acres annually. 

The use of these more effective herbicides on European beachgrass would reduce the treatments done by heavy 

equipment. In the next five years, this is anticipated to result in greater than 75 percent reduction in the use of 

bulldozers or tractors with discs or plows (or approximately once every two years). While treatments in western 

snowy plover habitat primarily target European beachgrass, approximately 25 acres (net) of other invasive plant 

species (such as Scotch broom, field bindweed, sea-rocket, false dandelions, wild radish, annual grasses, and sheep 

sorrel) in this area could be treated with manual or mechanical methods or herbicides39. As described below, all 

treatments in western snowy plover habitat restoration areas would follow guidelines established in future NEPA 

coordinated with the U.S. Army Corps of Engineers to protect the North Spit foredune, as well as project design 

criteria identified in future consultation with the U.S. Fish and Wildlife Service.

For more information on proposed treatment methods and invasive plants treated, see Table 2-10, Treatment Key.

Similar to the Proposed Action and as described in the Oregon FEIS to which this EA tiers, the wider range of 

herbicides from which to choose would increase the effectiveness of the average treatment to an estimated 80 

percent (USDI 2010a:136). Although some level of retreatment would still take place, the additional herbicides 

would substantially improve the chances invasive plants would be controlled with fewer retreatments (USDI 

2010a:135-136). Treatments described under this alternative are effective on almost all of the types of invasive 

plant species known to be present on the District, including those with potential to be new invaders. The sitespecific analysis of this can be found in Chapter 3.

 38Not an annual limit. This 15-acre limit could only be exceeded by BLM’s issuance or adoption of ecological and human health 

Risk Assessments, done or adopted by the BLM, with results evaluated through programmatic NEPA analysis done at the 

national or state level. 39 Treatments on invasive plants other than European beachgrass could be done with the herbicides available under Alternative 

3 (not just imazapyr and glyphosate). See Table 2-10, Treatment Key, for more information on potential treatment methods.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

58 

Project Design Features of Alternative 3

In addition to Project Design Features included with the Proposed Action, the following Project Design Features are 

included to reduce effects of Alternative 3:

Fish and Aquatic Organisms

• All applicable Project Design Criteria identified in potential future consultations with the National Marine 

Fisheries Service will be incorporated into all treatments in listed anadromous fish habitat.

• The use of fluazifop-P-butyl will be confined to flat dry ground located greater than 1,500 feet from any 

aquatic features to prevent runoff to surface water or leaching to groundwater.

• Use only ARBO II (NMFS 2013) approved herbicides, adjuvants, and buffer distances in the New River 

western snowy plover habitat restoration areas (see Appendix A). 

Wildlife

• Do not use dicamba, triclopyr, or fluazifop-P-butyl (herbicides with a low or moderate risk to birds) in 

areas that are currently capable of supporting western snowy plovers. (Dicamba in formulation with 

diflufenzopyr has no risk to birds and can be used in these areas.)

• Implement all current (see Appendix A) and future reasonable and prudent measures and terms and 

conditions identified by the U.S. Fish and Wildlife Service through consultation on western snowy plovers.

• Do not use fluroxypyr at known Mardon skipper sites.

Soil

• All guidelines established in potential future North Spit western snowy plover NEPA would be done in 

conjunction with the U.S. Army Corps of Engineers.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

59

Table 2-10. Treatment Key (All Alternatives)1 (treatments ordered by preferred treatment method)

For each species group, the preferred treatment method is listed first, with second and third choices (and so on) listed subsequently. Factors that could lead to the preferred (and subsequent) 

methods not being appropriate are listed in the Treatment Considerations and Notes column, and includes information such as plant life cycle, soil types, plant resistance to herbicides, infestation 

size, herbicide selectivity to neighboring desirable vegetation, weather conditions, and Standard Operating Procedures or label restrictions that limit areas an herbicide could be used in.

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Annual Grasses

[I, II, III, IV]

170 acres

(noxious weeds: 0 

acres)

Imazapic 0.06 to 0.12 NA 90% 50% Apply at the pre-emergent stage in the fall, when desirable grasses and forbs are 

dormant.

Rimsulfuron 0.03 to 0.06 NA NA 40%

Apply pre-emergence to early post-emergence when target plants are young and 

actively growing. Add surfactant per label. Perennial grasses are tolerant to fall 

applications.

Glyphosate <3.00 NA <1% <1% Apply at the seedling stage. Since it is non-selective, minimize exposure to nontarget plants. Use aquatic formulations near water. 

Fluazifop-P-butyl 0.38 NA NA <1%

See Special Local Needs Label (FIFRA Sec 24) OR-120016. Add 0.5 to 1 percent crop 

oil concentrate or 0.25% to 0.5% nonionic surfactant. Apply to actively growing 

grasses. Repeat applications may be needed. Do not apply more than 72 fluid 

oz./ac. per year.

Sulfometuron methyl 0.05 to 0.09 NA <1% <1% Apply pre-emergence or early when plants are germinating and actively growing. 

May be used in seasonally wet areas when water is not present.

Hexazinone 0.75 NA NA <1% Apply pre-emergence or early post emergence. Use primarily on road rights-of-way.

Targeted grazing (cattle) NA NA <1% <1% Can reduce biomass of invasive plants especially on sand dunes. Fencing or herding 

required.

Propane torch NA NA 5% 5% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Mechanical control NA NA <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, but 

non-selectively removes growth of desirable species. May require multiple 

treatments per year for effective weed control.

Manual control NA NA 5% 5% Hand pull scattered plants or for areas where other control methods are not 

feasible. Limited to small infestations. 

Borage Family

[III, IV]

2 acres

(noxious weeds: 0 

acres)

Manual control NA NA 50% 50% Hand pull scattered plants or for areas where other control methods are not 

feasible. Limited to small infestations. 

Glyphosate <3.00 NA 15% 15% Apply when plants are actively growing.

Chlorsulfuron + 2,4-D 0.06 + 0.95 NA 15% 15% Apply to budding or blooming plants to prevent seed formation or set or where 

resistance to sulfonylureas8 is a concern. 

Metsulfuron methyl + 2,4-D 0.04 + 0.95 NA 10% 10%

Use to prevent seed formation or set or where resistance to sulfonylureas8 is a 

concern. More likely than chlorsulfuron to harm non-target wet meadow grass 

species.

2,4-D 1.90 NA 5% 5% Apply in spring when plants are actively growing. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

60

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Propane torch NA NA <1% <1% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Aminopyralid + Metsulfuron 

methyl

0.08 to 0.11

+ 0.12 to 

0.15

NA <1% <1% Apply pre-emergence in fall or when target plants are in the seedling to rosette 

stage.

Chlorsulfuron 0.04 to 0.05 NA <1% <1% Apply in spring from bud to bloom stage or fall rosettes. Do not use with acidifying 

spray adjuvants, such as LI-700, per label restrictions.

Imazapic 0.13 to 0.19 NA <1% <1% Apply pre-emergence or early post-emergence. Add methylated seed oil if applied 

post-emergence.

Imazapyr 0.75 NA <1% <1% Apply in spring when plants are growing rapidly or apply in mid-fall to dormant 

infestation.

Metsulfuron methyl 0.04 to 0.08 NA 5% 5% Apply early when plants are small and rapidly growing.

Sulfometuron methyl + 

Chlorsulfuron 0.05 + 0.14 NA <1% <1% Apply at or before early weed growth. May be used in seasonally wet areas when water is not present.

Carnation Family

[I, II, IV]

78 acres

(noxious weeds: 0 

acres)

Manual control NA NA 85% 85% Hand pull scattered plants or for areas where other control methods are not 

feasible. Limited to small infestations. 

Glyphosate <3.00 NA 5% 5% Apply in spring to actively growing plants from germination to bolting, with green 

basal leaves.

Aminopyralid + Metsulfuron 

methyl

0.08 to 0.11

+ 0.12 to 

0.15

NA 3% 3% Apply pre-emergence in fall or when target plants are in the seedling to rosette 

stage.

Imazapic 0.06 to 0.12 NA 3% 3% Apply in spring or to bolting plants with green basal leaves.

Dicamba + 2,4-D 0.50 + 0.95 NA 2% 2% Apply in spring from rosettes to bolting, on plants with green basal leaves. Use a 

non-ionic surfactant.

2,4-D 0.95 NA 2% 2% Apply to spring rosettes or to bolting plants with green basal leaves.

Geranium Family

[I, II, III, IV]

56 acres

(noxious weeds: 25 

acres)

Manual control NA 10% 5% 5% Pull, dig, or till before flowers and seeds.

Mechanical control NA 5% 5% 5%

Target plants are suppressed with mowing or weed whackers before seed set, but 

non-selectively removes growth of desirable species. May require multiple 

treatments per year for effective weed control.

Propane torch NA NA 5% 5% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Metsulfuron methyl 0.01 to 0.02 NA 20% 20% Apply in spring before flowering on rapidly growing plants.

Aminopyralid 0.05 to 0.11 NA 20% 20% Apply in spring on rosette to flowering stages or in fall to seedlings or rosettes.

Imazapyr 0.38 to 0.75 NA 15% 15% Apply pre- or post-emergence to control visible plants and seeds.

Dicamba + Diflufenzopyr 0.18 to 0.35 NA 10% 10% Apply in spring to actively growing invasive plants. Use higher rates on perennials or 

large plants. Use non-ionic surfactant or methylated seed oil surfactant.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

61

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Dicamba + 2,4-D 0.75 + 0.25 5% 5% 5% Apply in spring before flowering on rapidly growing plants.

Fluroxypyr 0.49 NA NA 5% Apply in spring on rapidly growing plants.

2,4-D 0.95 40% 5% 5% Apply from seedling to flowering, to actively growing plants.

Glyphosate <3.00 40% 10% 5% Apply to rapidly growing plants. Use higher rates on larger plants. Add a non-ionic 

surfactant.

Knotweed Family

[I, II, III, IV]

276 acres

(noxious weeds: 

200 acres)

Imazapyr 0.75 to 1.00 NA 50% 50% Apply in mid-summer to fall. Most effective for large plants. 

Glyphosate <3.00 100% 40% 40% Apply mid-summer to fall, when plants are fully leafed. Injection treatments are also 

effective.

Triclopyr 0.50 to 2.00 NA 10% 10% Add 0.25% to 0.5% surfactant. Apply midsummer to actively growing plants.

Triclopyr + 2 4-D 1.50 + 0.95 NA <1% <1% Apply midsummer to actively growing plants.

Aminopyralid 0.11 NA <1% <1% Apply mid-summer to fall when plants are 3-4 feet tall. Repeat applications may be

necessary.

Manual control NA <1% <1% <1% Recommended when rhizomes can be completely removed.

Lilies, Iris, Sedges, 

Rushes

[I, II, III, IV]

28 acres

(noxious weeds: 5 

acres)

Imazapyr 0.75 to 1.00 NA 50% 50% Apply to plants at pre-bloom stage or in the fall to late season plants.

Glyphosate <3.00 25% 15% 15% Apply when plants are actively growing, before flowering. Use a non-ionic surfactant 

in aquatic areas.

2,4-D 1.90 10% 5% 5% Apply in spring before bloom or in fall. Use a surfactant.

Mechanical control NA 10% 5% 5%

Target plants are suppressed with mowing or weed whackers before seed set, but 

non-selectively removes growth of desirable species. May require multiple 

treatments per year for effective weed control.

Manual control NA 5% 5% 5% Effective on small infestations when entire plant and rhizome are removed. 

Hexazinone 0.75 NA NA 10% Apply pre-emergence or early post emergence. Use primarily on road rights-of-way.

Imazapic 0.13 to 0.19 NA 5% 5% Apply pre-emergence or post-emergence to yellow nutsedge, rushes, and iris. 

Typically suppresses but does not control rushes.

Metsulfuron methyl 0.04 to 0.08 NA 5% 5% Apply in spring from seedling or rosette to flowering stages.

No effective control9 NA 50% 10% NA

Loosestrifes

[I, II, IV]

30 acres

(noxious weeds: 25 

acres)

Biological control agents NA 50% 50% 50% Three widespread agents with high attack rates provide good to excellent control on 

purple loosestrife. 

Imazapyr 0.75 to 1.00 NA 5% 5% Apply in summer to rapidly growing plants.

Glyphosate <3.00 25% 5% 5% Apply to rapidly growing plants in full to late flowering. Treat seedlings in spring.

Triclopyr 1.00 NA 5% 5% Apply to rapidly growing plants at mid to full bloom. Use non-ionic surfactant. Use 

formulations labeled for aquatic use if treatments near water.

Metsulfuron methyl 0.04 to 0.08 NA 10% 10% Apply in spring from seedling or rosette to flowering stage.

Manual control NA 25% 25% 25% Hand pulling is effective on small infestations when the root system can be 

removed.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

62

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Misc. Annual 

Herbaceous

[I, II, III, IV]

45 acres

(noxious weeds: 0 

acres)

Manual control NA NA 5% 5% Hand pulling is effective on single plants or small infestations. May require multiple 

treatments per year.

Mechanical control NA NA 5% 5% Suppressed with mowing or weed whackers before seed set, but non-selectively 

removes growth of desirable species. May require multiple treatments per year.

Propane torch NA NA 1% 1% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Aminopyralid 0.05 to 0.11 NA 15% 15% Apply early when plants are small and rapidly growing.

Imazapic 0.06 to 0.12 NA 7% 5% Apply to forbs after summer dry period when plants begin to grow.

Aminopyralid + Metsulfuron 

methyl

0.08 to 0.11

+ 0.12 to 

0.15

NA 15% 15% Apply pre-emergence in fall, or in the seedling to rosette stage.

Chlorsulfuron + 2,4-D 0.06 + 0.95 NA 5% 5% Apply pre or early post-emergence when invasive plants are actively germinating or 

growing. Use when resistance is a concern, especially to sulfonylureas8. 

Dicamba + Diflufenzopyr 0.18 to 0.35 NA 10% 10% Use to control invasive plants along roads or in disturbed areas. 

Fluroxypyr 0.13 to 0.49 NA NA 2% Apply when plants are growing rapidly.

Clopyralid 0.09 to 0.19 NA 5% 5% Apply at early rosette stage.

Rimsulfuron 0.03 to 0.06 NA NA 2%

Apply pre-emergence to early post-emergence when target plants are young and 

actively growing. Add surfactant per label. Native perennial grasses are tolerant to 

fall applications.

Imazapic + Glyphosate

0.06 to 0.09

+ 0.13 to 

0.19

NA 2% 2% Apply early when target invasive plants emerge, if desirable plants are not present. 

Glyphosate + 2,4-D 0.50 + 0.70 NA 2% 2% Apply when plants are actively growing, before flowering. Use a non-ionic surfactant 

in aquatic areas.

Dicamba + 2,4-D 0.50 + 0.95 NA 2% 2% Apply in spring when plants are small and actively growing. Use a non-ionic 

surfactant.

2,4-D 1.90 NA 2% 2% Apply only aquatic formulations near water. 

Glyphosate <3.00 NA 9% 7% Apply in spring to actively growing plants with green basal leaves, from germination 

to bolting.

Picloram 0.50 to 0.95 NA <1% <1% Do not apply near trees or young grass seedlings.

Imazapyr 0.75 NA 15% 15% Apply post-emergence from seedling to flowering stage.

Misc. Herbaceous

[I, II, III, IV]

170 acres

Biological control agents NA 20% 15% 15%

Three biological agents with high attack rates provide excellent control against St. 

Johnswort on the District. Biological control agents are used on widespread invasive 

plants when agents become available.

Imazapyr 0.75 to 1.00 NA 20% 20% Apply post-emergence from seedling to flowering stage.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

63

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

(noxious weeds: 60 

acres) Glyphosate <3.00 50% 20% 20% Apply in spring to actively growing plants with green basal leaves from germination to bolting.

Triclopyr 2.00 NA 10% 10% Apply at flowering stage.

Manual control NA 10% 10% 10% Hand pulling can be effective on single plants or small infestations.

Glyphosate + 2,4-D 0.50 + 0.70 10% 5% 5% Apply in late spring, prior to seed set.

Dicamba + Diflufenzopyr 0.18 to 0.35 NA 5% 5% Apply in spring to actively growing invasive plants. Use higher rates on perennials or 

large plants. Use non-ionic surfactant or methylated seed oil surfactant.

Dicamba + 2,4-D 0.50 to 1.00

+ 0.95 10% 9% 9% Apply to actively growing plants. Use a non-ionic surfactant.

Aminopyralid 0.05 to 0.11 NA 4% 4% Apply to actively growing plants. Use a non-ionic surfactant

Metsulfuron methyl 0.01 to 0.08 NA 2% 2% Apply early when plants are small and rapidly growing.

2,4-D 0.95 <1% <1% <1% Apply in spring to rosettes.

Picloram 0.50 to 0.95 <1% <1% <1% Evaluate soil, slope, and proximity to water when considering this herbicide.

Picloram + 2,4-D 0.50 + 0.95 <1% <1% <1% Evaluate soil, slope, and proximity to water when considering this herbicide. Apply 

from seedling to bud, before bloom.

Targeted grazing (sheep) NA 0% <1% <1% Sheep selectively choose broadleaf species over grass. Fencing or herding required.

Propane torch NA NA <1% <1% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Mechanical control NA <1% <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Mustard Family

[I, II, III, IV]

475 acres

(noxious weeds: 1 

acre)

Manual control NA NA 50% 50% Hand pulling is effective on small infestations when the root system can be 

removed.

Chlorsulfuron + 2,4-D 0.06 + 0.95 NA 15% 15%

Apply when annual invasive plants are germinating or actively growing. Apply when 

perennial invasive plants are from bud to bloom or fall rosette stage. Do not use 

with acidifying spray adjuvants, such as LI-700, per label restrictions. Use where 

resistance to sulfonylureas8 is a concern.

Aminopyralid + Metsulfuron 

methyl

0.08 to 0.11

+ 0.12 to 

0.15

NA 5% 5% Apply when the plants are in the bloom stage for optimum control. 

Glyphosate <3.00 NA 25% 25% Apply in spring to actively growing plants with green basal leaves from germination 

to bolting.

Aminopyralid 0.05 to 0.11 NA 5% 5% Apply early when plants are small and actively growing.

2,4-D 0.95 to 1.90 NA <1% <1% Apply in spring when plants are actively growing before budding.

Imazapic 0.13 to 0.19 NA <1% <1% Apply post or pre- emergence when plants are small and growing rapidly.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

64

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Dicamba + 2,4-D 0.50 + 0.95 NA <1% <1% Apply in spring before budding when plants are actively growing. Use a non-ionic 

surfactant.

Propane torch NA NA <1% <1% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Mechanical control NA NA <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Pea Family

[I, II, III, IV]

308 acres

(noxious weeds: 

100 acres)

Manual control NA 80% 25% 25% Hand pulling can be used on small infestations or isolated plants, as long as 

belowground tissue is also removed (to prevent re-sprouting).

Aminopyralid 0.05 to 0.11 NA 35% 35% Apply in spring before flowering.

Clopyralid 0.23 to 0.49 NA 15% 15% Apply in spring before flowering.

Triclopyr 2.00 NA 15% 15% Apply in spring when plants are rapidly growing.

Glyphosate <3.00 5% 5% 5% Apply in spring before flowering.

2,4-D 0.95 NA 5% 5% Apply in spring to actively growing plants, particularly at bud to flower stage.

Picloram 0.50 to 0.95 5% <1% <1%

Evaluate soil, slope, and proximity to water when considering this herbicide. Apply 

when plants are growing rapidly in spring before full bloom or in late summer to 

early fall.

Mechanical control NA 10% <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Targeted grazing (goats or 

sheep) NA <1% <1% <1% Delay spring grazing until plants are at least 8 inches tall.

Propane torch NA NA <1% <1% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Perennial Grasses

[I, II, III, IV]

1,743 acres

(noxious weeds: 

450 acres)

Fluazifop-P-butyl 0.38 NA NA <1%

See Special Local Needs Label (FIFRA Sec 24) OR-120016. Add 0.5 to 1 percent crop 

oil concentrate or 0.25 to 0.5 percent nonionic surfactant. Apply to actively growing 

grasses. Repeat applications may be needed. Do not apply more than 72 fluid 

oz./ac. per year.

Imazapyr 0.75 to 1.50 NA 15% 10% Apply in early spring. 

Imazapyr + Glyphosate 0.75 to 1.50

+ 3.00 NA 20% 20% Preferred treatment for European beachgrass. 

Rimsulfuron 0.03 to 0.06 NA NA 5%

Apply pre-emergence to early post-emergence when target plants are young and 

actively growing. Add surfactant per label. Perennial grasses are tolerant to fall 

applications.

Imazapic 0.13 to 0.19 NA 5% 5% Apply before plants germinate, when desirable grasses and forbs are dormant in the 

fall.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

65

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Imazapic + Glyphosate

0.06 to 0.19

+ 0.13 to 

0.38

NA 10% 10% Apply early when target plants emerge, if desirable plants are not present. 

Glyphosate <3.00 10% <1% <1% Apply at the seedling stage. Minimize damage to non-targets. Use aquatic 

formulations near water. 

Hexazinone 2.00 NA NA 20% Especially for use on false brome. Apply pre-emergence or early post emergence. 

Use primarily on road rights-of-way. 

Propane torch NA NA <1% <1% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Mechanical control NA 65% 30% 30%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Manual control NA <1% <1% <1% Only practical for sites with a few plants.

No effective control9 NA 25% 20% NA

Perennial Mints

[I, II, III, IV]

26 acres

(noxious weeds: 20 

acres)

Manual control NA 10% 10% 10%

Infestations can be suppressed by manual removal of plants before flowering, 

including rhizomes and stolons. Belowground tissues should be severed 

approximately three inches below soil surface.

Triclopyr 1.50 to 3.00 NA 45% 45% Apply when plants are mature. Most effective when they have bolted but before

seed production.

2,4-D 1.90 15% 15% 15% Apply after bolting and before seed production. 

Propane torch NA NA 10% 10% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Glyphosate <3.00 10% 10% 10% Apply when plants are bolting but before seed production.

Mechanical control NA 15% 5% 5%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Clopyralid 0.25 to 0.38 NA 5% 5% Apply in spring or fall to control small actively growing plant.

No effective control9 NA 50% NA NA

Perennial Parsley 

Family

[I, II, IV]

30 acres

(noxious weeds: 20 

acres)

Manual control NA 1% 1% 1% Hand removal is recommended for small infestations. Remove taproot. Wear gloves 

and wash hands after pulling plants.

Aminopyralid + Metsulfuron 

methyl

0.08 to 0.11

+ 0.12 to 

0.15

NA 50% 50% Apply in seedling to rosette stage or pre-emergence in the fall.

Imazapic 0.13 to 0.19 NA 5% 5% Apply pre-emergence or early when plants are germinating and actively growing.

Triclopyr 0.75 to 5.00 NA 14% 14% Apply in spring when plants are rapidly growing.

Metsulfuron methyl 0.01 to 0.02 NA 3% 3% Apply when plants are actively growing.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

66

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Dicamba + 2,4-D 0.50 to 2.00

+ 0.95 20% 5% 5% Apply in seedling to rosette stage.

Sulfometuron methyl 0.19 NA 2% 2% Apply pre-emergence or early when plants are germinating and actively growing.

Imazapyr 1.00 to 1.50 NA 10% 10% Apply from germination to rosette.

Glyphosate <3.00 75% 10% 10% Apply in spring to fully developed leaves but before flowering. Control is less 

effective once plant has bolted.

Chlorsulfuron 0.05 to 0.12 NA <1% <1% Apply in spring from bud to bloom or fall rosettes. Do not use with acidifying spray 

adjuvants, such as LI-700, per label restrictions.

Picloram + 2,4-D 0.50 + 0.95 4% <1% <1% Apply from early to mid-spring when the target plants are less than 3 inches in 

height.

Mechanical control NA <1% <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Snapdragon Family

[I, II, III, IV]

67 acres

(noxious weeds: 40 

acres)

Manual control NA NA 10% 10% Hand pulling is only effective on seedlings and in sand before plants become 

established.

Glyphosate + 2,4-D 0.50 + 0.70 NA 10% 10% Apply to rapidly growing plants. Use higher rates on larger plants and add a nonionic surfactant.

Aminopyralid + Metsulfuron 

methyl

0.08 to 0.11

+ 0.12 to 

0.15

NA 10% 10% Apply in spring or fall to plants in the rosette stage or to bolting plants less than 12 

inches tall.

Aminopyralid 0.05 to 0.11 NA 10% 10% Apply in spring from the rosette stage to early bolting.

Propane torch NA NA 10% 10% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Glyphosate <3.00 NA 10% 10% Apply in spring to rapidly growing plants.

Chlorsulfuron 0.05 NA 10% 10% Apply in fall for most consistent control.

Imazapyr 0.75 to 1.50 NA 5% 5% Apply in spring when plants are growing rapidly or apply in mid-fall to dormant 

infestation.

Dicamba 1.00 NA 10% 10% Apply in spring before flowering.

Imazapic 0.06 to 0.12 NA 5% 5% Apply in fall when top 25 percent of plant is necrotic, usually after a hard frost.

Dicamba + 2,4-D 1.00 + 0.95 NA 10% 10% Apply from seedling to bud stage, before bloom. Use a non-ionic surfactant.

Picloram + 2,4-D 0.50 + 1.50 NA <1% <1% Apply from seedling to bud stage, before bloom.

Picloram 0.50 to 0.95 NA <1% <1%

Evaluate soil, slope, and proximity to water when considering this herbicide. Apply 

when plants are growing rapidly in spring before full bloom or in late summer to 

early fall.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

67

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Mechanical control NA NA <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective control.

Biological control agents NA NA 0% 0% Agents are available for toadflaxes and could be used if infestations become large 

enough to support a population. 

Sunflower Family

[I, II, III, IV]

2,323 acres

(noxious weeds: 

1,963 acres)

Manual control NA 5% 5% 5%

Hand pulling and grubbing are effective on visible plants. These treatments 

stimulate the seed bank. Would only be used on small infestations and where 

retreatment is planned. 

Biological control agents NA 5% 5% 5% Numerous agents are available for thistles, knapweeds, and tansy ragwort. 

Aminopyralid 0.05 to 0.11 NA 50% 50% Apply in spring at bud stage. Preferred treatment when desirable plants in 

susceptible families not present. Longer soil residual than clopyralid. 

Clopyralid 0.23 to 0.49 NA 5% 5% Apply at the rosette to bolting stage.

Glyphosate <3.00 54% 10% 10% Apply in spring to rapidly growing plants before flowering. 

Aminopyralid + Metsulfuron 

methyl

0.08 to 0.11

+ 0.12 to 

0.15

NA 5% 5% Apply to plants in spring.

Clopyralid + 2,4-D 0.38 + 0.95 NA 5% 5% Apply in spring from germination to flowering when plants are actively growing.

Dicamba + Diflufenzopyr 0.18 to 0.35 NA 5% 5% Apply in spring to actively growing plants. Use higher rates on perennials or large 

plants. Use non-ionic surfactant or methylated seed oil adjuvant.

Metsulfuron methyl 0.02 to 0.04 NA 5% 5% Use to prevent seed formation or set. Primarily on roadsides.

Picloram + 2,4-D 0.25 + 0.95 <1% <1% <1% Evaluate soil, slope, and proximity to water when considering this herbicide. Apply 

pre- or post-emergence to control visible plants and seeds.

Dicamba + 2,4-D 0.50 + 0.95 5% <1% <1% Apply in spring or fall to rosettes. Use a non-ionic surfactant.

Chlorsulfuron + Clopyralid + 

2,4-D

0.05 + 0.38

+ 0.95 NA 2% 2%

Apply when annual plants are germinating or actively growing. Apply when 

perennial plants are from bud to bloom or fall rosettes. Do not use with acidifying 

spray adjuvants, such as LI-700, per label restrictions. Use where resistance to 

sulfonylureas8 is a concern. 

Chlorsulfuron + 2,4-D 0.05 + 0.95 NA 1% 1%

Apply when annual plants are germinating or actively growing. Apply when 

perennial plants are from bud to bloom or fall rosette stage. Do not use with 

acidifying spray adjuvants, such as LI-700, per label restrictions. Use where 

resistance to sulfonylureas8 is a concern. Use aquatic 2,4-D near water.

Chlorsulfuron 0.05 NA 1% 1%

Apply when annual plants are germinating or actively growing. Apply when 

perennial plants are from bud to bloom or fall rosette stage. Do not use with 

acidifying spray adjuvants, such as LI-700, per label restrictions.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

68

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Picloram + 2,4-D + Dicamba 0.25 + 0.95

+ 0.50 1% 1% 1%

Evaluate soil, slope, and proximity to water when considering this herbicide. Apply 

in spring. Use lower rate when plants are less than 3 inches tall, use higher rate 

when plants are greater than 3 inches until early flowering.

Hexazinone 2.00 to 4.00 NA NA <1% Apply pre-emergence or early post emergence. Use primarily on road rights-of-way.

Propane torch NA NA <1% <1% Most effective on small plants. Use only on infestations on non-flammable substrate 

(e.g., sand, gravel, concrete).

Mechanical control NA <1% <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

No effective control9 NA 30% NA NA Canada thistle cannot be controlled with currently available tools.

Teasels

[I, II, III]

50 acres

(noxious weeds: 0 

acres)

Manual control NA NA 10% 10% Digging or hand pulling before flowering are effective controls. When digging, sever 

the root below the soil surface.

Glyphosate <3.00 NA 30% 30% Apply in spring or fall to rapidly growing plants from rosette to bolting stage.

Chlorsulfuron 0.05 NA 30% 30% Apply in spring from rosette to bolting stage. 

2,4-D 0.95 NA 10% 10% Apply in spring to rosettes.

Imazapic 0.13 to 0.19 NA 10% 10% Apply to rosettes and add a methylated seed oil.

Dicamba + 2,4-D 0.50 + 0.95 NA 2% 2% Apply in spring or fall to rosettes. Use a non-ionic surfactant.

Metsulfuron methyl 0.02 to 0.04 NA 2% 2% Apply from seedling or rosette to flowering stage.

Clopyralid 0.23 to 0.49 NA 2% 2% Apply from the rosette to young bolting stage. Add a non-ionic surfactant.

Dicamba + Diflufenzopyr 0.18 to 0.35 NA 2% 2% Apply in spring to actively growing plants. Use higher rates on perennials or large 

plants. Use a non-ionic surfactant or methylated seed oil adjuvant.

Clopyralid + 2,4-D

0.16 to 0.38

+ 1.00 to 

1.90

NA 2% 2% Apply from the rosette to young bolting stage. Add a non-ionic surfactant.

Mechanical control NA NA <1% <1%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Woody Species

[I, II, III, IV]

7,806 acres

(noxious weeds: 

7,789 acres)

Triclopyr 2.00 NA 53% 53% Apply as a foliar treatment mid-summer to early fall to smaller plants.

Glyphosate <3.00 81% 12% 12% Apply as foliar or cut stump. Foliar treatments would be made in late summer. 

Aquatic formulations would be used near water. 

Imazapyr 1.00 to 1.50 NA 5% 5% Apply late summer to early fall.

Triclopyr + 2 4-D 2.00 + 0.95 NA 10% 10% Apply when plants are actively growing.

Mechanical control NA 2% 2% 2%

Target plants are suppressed with mowing or weed whackers before seed set, nonselectively removes growth of desirable species. May require multiple treatments 

per year for effective weed control.

Manual control NA 2% 2% 2% Grubbing can effectively control small infestations.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

69

Treatment Group2

[Categories]3

Gross Treatment 

Acres4

Treatment Method Lbs./Acre5

Percent of Acres where 

Treatment Would be Used6 Treatment Consideration and Notes7

No 

Action

Proposed 

Action Alt. 3

Triclopyr <6.00 NA 5% 5% Used primarily as a cut stump treatment. Use formulations labeled for aquatic use if 

treatments near water. 

Aminopyralid + Triclopyr 0.11 + 1.00 NA 2% 2% Apply before bud to early flowering.

Aminopyralid 0.05 to 0.11 NA 2% 2% Apply after full leaf expansion, generally around flowering period. Apply preemergence to control seedlings. 

Metsulfuron methyl 0.02 to 0.04 NA 2% 2% Apply when fully leafed and before fall coloration.

Picloram 1.00 <1% <1% <1% Apply when plants are actively growing and at or beyond full bloom.

Biological control agents NA 10% 5% 5% Widespread biocontrol agents with high attack rates provide good control on gorse, 

Scotch and French brooms.

Targeted grazing (goats) NA <1% <1% <1% Effective at defoliating blackberries, but does not provide long-term control. Limited 

to areas without desirable plants or vehicle traffic.

No effective control9 NA 5% NA NA

NA: Herbicide not available under the alternative or plant species is not listed as a noxious weed; invasive plants that are not noxious weeds would not be treated with herbicides under the No Action 

Alternative.

1. Most treatments are suggested by Weed Treatments in Natural Areas in the Western United States (DiTomaso et al. 2013) and the Pacific Northwest Weed Management Handbook (OSU 2017).

2. Species of invasive plants that would be treated in the same manner have been arranged into treatment groups. Information about which plants species are in which group can be found in Table 2-

1, Summary of Known Invasive Plant Sites, Table 2-3, Invasive Plants Documented on Neighboring Lands but Not Known to Occur on the District, and Table D-2, Further Information about Invasive Plant 

Species.

3. See the Categories of Invasive Plant Infestations section at the start of this chapter. Indicates which Categories are included in each treatment group. For example, the Loosestrifes treatment group 

includes Category I (invasive plant species known on the District), Category II (spread from sites), and Category IV (lower priority invasive plant species), but does not include Category III (invasive 

plants not yet known on the District).

4. The treatment acres column indicates how many acres are currently estimated to need treatments over a 20-year analysis period. More information about treatment acres can be found in the 

Category I: Invasive Plants Currently Known on District section at the start of this chapter.

5. Amounts listed are averages. Actual formulations may vary slightly, depending on mixes of herbicides or surfactants, timing, and other factors that could increase effectiveness on individual plants. 

Competitive planting and seeding using manual methods may also occur to revegetate areas in conjunction with other treatment methods. Lbs./acre calculated from rates per acre on the label, and 

can vary based on formulation. Typical and maximum application rates are listed on Table 2-5, Herbicide Information. Lbs./acre in bold are at or above the typical application rate. Red indicates 

lbs./acre at the maximum application rate. Rates are rounded to two digits; e.g., the max rate of imazapic is 0.1875 lbs./acre is shown as 0.19 in this table.

6. Within each species group, and by alternative, these add up to 100 percent and show how often a treatment method would be used when a species is found. For example, under the Proposed 

Action, knotweeds would be controlled with imazapyr 50 percent of the time, treated with glyphosate 40 percent of the time, treated with triclopyr 10 percent of the time, and otherwise treated with 

manual methods, aminopyralid, or triclopyr + 2,4-D (less than 1 percent of the time each). These estimates are generally based on treatment of known sites. These percentages are based on net acres 

treated, not on number of sites treated. For example, if 20 one-acre sites had invasive plants that were manually pulled, and one 20-acre site is sprayed with imazapyr, manual and imazapyr would 

both be listed as 50 percent each.

7. This includes common treatment considerations and is not an exhaustive list.

8. The sulfonylureas are chlorsulfuron, metsulfuron methyl, rimsulfuron, and sulfometuron methyl. The Oregon FEIS states that sulfonylureas can quickly confer resistance to plant populations, 

particularly where they are used extensively as the primary invasive plant control method in cropping systems (USDI 2010a:145).

9. Indicates percent of acres that cannot be controlled because an effective control method is unavailable. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

70

Table 2-11. Comparison of the Alternatives, Treatment Methods

Direct Control Method No Action Alternative Proposed Action Alternative 3

Non-Herbicide Methods

Biological control agents Allowed Allowed Allowed 

Manual control Allowed Allowed Allowed 

Mechanical control Allowed Allowed Allowed 

Weed barrier mats Not allowed Allowed Allowed

Prescribed fire (broadcast) Allowed Allowed Allowed

Propane torch (spot) Not allowed Allowed Allowed 

Targeted grazing (cattle, 

sheep, goats) Allowed Allowed Allowed 

Seeding and planting Allowed Allowed Allowed 

Herbicides

2,4-D Allowed Allowed Allowed 

Aminopyralid Not allowed Allowed Allowed 

Chlorsulfuron Not allowed Allowed Allowed 

Clopyralid Not allowed Allowed Allowed 

Dicamba Allowed Allowed Allowed 

Dicamba + diflufenzopyr Not allowed Allowed Allowed 

Fluroxypyr Not allowed Not allowed Allowed 

Glyphosate Allowed Allowed Allowed 

Hexazinone Not Allowed Not allowed Allowed

Imazapic Not allowed Allowed Allowed 

Imazapyr Not allowed Allowed Allowed 

Metsulfuron methyl Not allowed Allowed Allowed 

Picloram Allowed Allowed Allowed 

Rimsulfuron Not allowed Not allowed Allowed 

Sulfometuron methyl Not allowed Allowed Allowed 

Triclopyr Not allowed Allowed Allowed 

Allowed in limited areas as part of Research and Demonstration

Fluazifop-P-butyl Not allowed Not allowed Allowed (up to 15 acres per 

Field Office)

Alternatives Considered but Eliminated from Detailed Study

The BLM is required to include a discussion of all reasonable alternatives that achieve the purpose and need. 

Reasonable alternatives include alternatives which are technically and economically feasible, and which meet the 

purpose and need for the project. The BLM may eliminate from detailed analysis any alternatives that are not 

reasonable, including if the alternative:

• does not meet the purpose and need;

• is technically or economically infeasible;

• is inconsistent with the basic policy objectives for the management of the area;

• implementation is remote or speculative;

• is substantially similar to an alternative being analyzed in detail; or,

• would have substantially similar effects to an alternative being considered in detail.

The interdisciplinary team considered several other alternatives for analysis during the interdisciplinary process. 

The majority of these alternatives were submitted in the form of public comments during scoping. The reasons 

why these alternatives were eliminated from detailed analysis follows.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

71

No Herbicides

This alternative was suggested during scoping. An alternative was considered that would manage invasive plants 

with a full range of treatment methods except herbicides. This alternative was eliminated from detailed study 

because a no-herbicides reference analysis was included in the Oregon FEIS (USDI 2010a:27) and indicated the rate 

of spread for noxious weeds would increase over time. A no-herbicides alternative would not meet the need for 

more effective invasive plant control and therefore is not a reasonable alternative.

Use Fewer Herbicides than Analyzed Under the Proposed Action

This alternative was suggested during scoping. An alternative was considered that would remove one or more 

herbicides from consideration in the Proposed Action for various reasons including stated risks or apparent lack of 

need. All of the herbicides available in the Proposed Action have specific species or conditions for which they are 

the most suitable control. This proposed alternative would not meet the purpose and need; having this range of 

herbicides available allows applicators to select the most appropriate one for a wider range of invasive plant 

species, site conditions, timing, and management objectives, and helps to avoid resistance of targeted species to 

specific herbicides. This allows the BLM to more effectively control invasive plants to protect native ecosystems 

and the flora and fauna that depends on them. Specific treatments and treatment considerations are shown in the 

Treatment Key (Table 2-10) and effects are analyzed in Chapter 3. For any herbicide or use, the Decision-maker 

could modify the selected alternative to remove an herbicide or modify its use. However, there are no adverse 

effects (as described in this EA) that indicate a need to remove any of the herbicides considered in the alternatives.

The District would not use herbicides that are not appropriate for the invasive plants or the conditions on the 

District. Hence, this alternative was eliminated from detailed analysis, as it would have substantially similar effects 

to the Proposed Action.

Use More Herbicides than Analyzed Under the Action Alternatives

This alternative was suggested during scoping. An alternative was considered that would include additional 

herbicides, including herbicides that are not approved for use on BLM-managed lands. Herbicides used on BLMmanaged lands must be approved by the BLM National Office, and are, by policy, subject to detailed ecological and 

human health Risk Assessments for wildland applications to help satisfy the requirements of NEPA (USDI 

2010a:37). However, BLM practice allows for limited and controlled use of new herbicides on demonstration plots 

up to five acres in size, with a maximum of 15 acres per Field Office. Approval to use an herbicide for research and 

demonstration is provided by the BLM National Office after an initial evaluation of Federal Insecticide, Fungicide 

and Rodenticide Act (FIFRA) registration materials and Risk Assessments (USDI 2010a:478).

In addition to the herbicides analyzed in this EA, Risk Assessments have been completed or adopted by the BLM for 

bromacil, diquat, diuron, fluridone, and tebuthiuron, and the results have been evaluated through the NEPA 

process (USDI 2010b). Research and demonstration has been approved on numerous herbicides, including one that 

the Coos Bay District analyzes in this EA (fluazifop-P-butyl). In general, having a larger range of herbicides available 

allows applicators to select the most appropriate one for a wider range of invasive plant species, site conditions, 

timing, and management objectives, and helps to avoid resistance of targeted species to specific herbicides. 

However, the herbicides available under the action alternatives effectively treat almost all of the invasive plants 

species currently present on the District (in varying conditions), as well as invasive plants on neighboring lands that 

have the potential to be new invaders, without unacceptable adverse effects to District resources. At this time, 

additional herbicides are not needed to aid the BLM with its invasive plant program. Since the District would not 

use herbicides that are not appropriate for the invasive plants or the conditions on the District, these herbicides 

would not be applied. Hence, this alternative was eliminated from detailed analysis, as it there would be no 

difference in effects between the alternatives. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

72

Use Non-Herbicide Methods First, Use Herbicides Only Where Absolutely 

Necessary and Decrease Their Use in the Future

This alternative was suggested during scoping. This alternative was not considered because existing Department of 

the Interior policy, applicable to all alternatives, states that, “Bureaus will accomplish pest management through 

cost-effective means that pose the least risk to humans, natural and cultural resources, and the environment” and 

requires bureaus to “Establish site management objectives and then choose the lowest risk, most effective 

approach that is feasible for each pest management project” (USDI 2007e), and “Determine, for each target pest, 

the possible courses of action and evaluate relative merits for controlling the pest with the least adverse effects on 

the environment” (USDI 1992a). Invasive plants are difficult to control and previous analysis in the 2010 Oregon 

FEIS and monitoring data show that all control methods including herbicide applications (individually or in 

combination) are necessary to prevent undue degradation and promote land health (USDI 2010a, USDI 2010b:18-

25). The Proposed Action and Alternative 3 include adding use of more selective herbicides that are subject to 

numerous Project Design Features to reduce potential adverse effects. These alternatives also include an adaptive 

management approach to select the control method (herbicide and non-herbicide) that is most effective while 

minimizing adverse effects.

Given the continued spread of invasive plants and an increasing emphasis on protecting threatened habitats, it is 

unlikely the need for effective invasive plant control will decrease in the foreseeable future (USDI 2010a:139); 

therefore, this alternative would not meet the purpose and need, and is inconsistent with the basic policy 

objectives for the management of the area.

Limit Herbicide Treatments to Early Detection Rapid Response

An alternative was considered using the herbicides included in the action alternatives, but strictly limiting their use 

to early detection, rapid response-type treatments40 of new sites or new species. Non-herbicide treatments of 

invasive plant sites would continue, but existing invasive plant sites would not be actively controlled with 

herbicides.

This alternative was eliminated from detailed analysis because it does not meet the purpose and need and it is 

inconsistent with the basic policy objectives for the management of the area. Control of established infestations is 

essential to preventing or reducing ecologic and economic degradation, and controlling many of these sites cannot 

be achieved without using herbicides. Using herbicides to prevent invasive plant spread to uninfested areas is costeffective and consistent with current laws, administrative direction, and the Resource Management Plans and 

plans that tier to them.

Include the Use of Herbicides for Native Vegetation

An alternative was considered that would allow herbicides to be used on both invasive and native vegetation to:

• Meet safety and operations objectives (clearing) along roads and around administrative sites. The Oregon 

Department of Transportation and others responsible for road maintenance use herbicides to maintain 

site clearances and protect investments, for example.

• Improve Special Status species habitat. Examples of this could include treatment of native species to 

promote federally-listed species habitat restoration.

The need described in Chapter 1 is focused on more effective invasive plant management, and does not include a 

need for more effective native plant management. Therefore, this alternative was eliminated from detailed 

analysis because it does not respond to the purpose and need.

 40 Treatment of small, new infestations while there is high likelihood for eradication.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

73

Reduce Management Activities Implicated in Invasive Plant Spread

This alternative was suggested during scoping. This alternative would curtail or restrict various management and 

public use activities taking place on BLM-managed lands (such as timber harvest, grazing, mining, off-highway 

vehicle use, camping, hiking, wildfire control, or boating) in order to reduce invasive plant spread. This alternative 

is inconsistent with the basic policy objectives for the management of the area, as established in the Resource 

Management Plan. This alternative is not considered in detail because a reconsideration of the level of various land 

uses is the purview of the land management planning process described in the Federal Land Policy and 

Management Act (FLPMA) and it is beyond the scope of this project to change land use plan decisions. A variety of 

management uses are authorized and directed by the FLPMA, the Oregon and California Lands Act, and other 

policy and direction. While these activities variously contribute to the spread of invasive plants (and in some cases, 

to their control), it is the role of each district’s Resource Management Plan to identify an appropriate mix of public 

uses and management practices consistent with land capability, long-term productivity, and ecosystem health. The 

potential for an activity to contribute to the spread of noxious weeds and other invasive plants was analyzed in the 

Final EIS for the Northwestern and Coastal Oregon Resource Management Plan and was considered in the decision 

to select the current Resource Management Plan (USDI 2016d:93).

Ongoing and Reasonably Foreseeable Actions

In addition to the invasive plant management program described in this EA, other activities occur on or near the 

Coos Bay District. These activities are described below, as they may have the potential to affect resources analyzed 

in Chapter 3.

Neighboring Lands

Pesticide Use

In 2007 and 2008, the State of Oregon compiled pesticide use in Oregon via the self-reporting Pesticide Use 

Reporting System. Reports compile the resultant information by major water basin. The report acknowledges a 

number of limitations associated with the data; it was largely voluntary for some users, and some of the reporting 

fields were ambiguous, so the amount of pesticide use reported was likely underestimated. However, the ODA’s 

2008 Annual Report provides the best available information on the use of pesticides in Oregon (USDI 2010a, ODA 

2009).

Ninety-four percent of the BLM-managed lands on the Coos Bay District lie within the Southern Oregon Coast 

drainage basin41 (see Figure 2-3); hence, a rough comparison between pounds of pesticides used under each 

alternative and pounds of pesticides used in these basins as a whole is possible. Thirty-three percent of the 

Southern Oregon Coast drainage basin is managed by the Coos Bay District and 29 percent of the Southern Oregon 

Coast drainage basin is managed by the Medford District.

In 2008, 3,098,503 pounds of pesticides (including herbicides) were reported used in the Southern Oregon Coastal 

basin. Under the alternatives in this EA, the annual pounds of herbicides used annually by the BLM would be 

approximately 1,250 (No Action) and 1,060 (Proposed Action and Alternative 3). (With the exception of the 

pesticide use described below for other Districts and Sudden Oak Death management, the BLM uses no other 

pesticides in this basin.) This represents about 0.04 (No Action) and 0.03 (Proposed Action and Alternative 3) 

percent of the pounds of pesticides used in the basin.

 41 Two percent and four percent of the District (respectively) are in the Northern California Coastal and Northern Oregon 

Coastal drainage basin.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

74

Figure 2-3. Water Basins on the Coos Bay District

A direct comparison of quantities of 

specific active ingredients is not possible. 

The State report provides the pounds of 

pesticides for the top five most-used 

active ingredients. The top five active 

ingredients used in the Southern Oregon 

Coastal basin are not herbicides; they are 

insecticides, algaecides, or wood 

preservatives, and together represent 72 

percent of all reported pesticide use.

The 2008 State of Oregon report 

estimated that 15,221,190 pounds (or 77 

percent) of pesticides used in the State 

were for agriculture purposes. 

Glyphosate is commonly used, along with 

soil fumigants, insecticides, and 

desiccants. Pesticides used for forestry 

represent 4.4 percent of statewide use. 

All of the most commonly applied pesticides for forestry use were herbicides: glyphosate, atrazine, 2,4-D, 

hexazinone, and triclopyr (ODA 2009).

Forest landowners (e.g., timber companies) are responsible for reporting their proposed herbicide use to the 

Oregon Department of Forestry before they spray herbicides. (Reporting is required for herbicide applications 

where the desired outcome is forest management, but they are not required for vegetation management around 

households and personal property.) Between 2004 and 2014, 9,827 and 2,028 parcels respectively were sprayed in 

Coos and Curry Counties (ODF 2014).

The 2010 Oregon FEIS to which this EA tiers suggests the use of herbicides on lands adjacent to lands managed by 

the BLM would decrease as BLM and cooperative invasive plant treatments become more effective, reducing the 

number of private land invasive plant infestations originating from BLM-managed lands (USDI 2010a:118).

Invasive Plants

The Oregon Department of Agriculture has mapped 52 current or historical42 noxious weeds in Curry County, Coos

County, or both (all ownerships). Of these, five current noxious weeds (cape ivy, dense flowered cordgrass 

(Spartina densiflora), matgrass, orange hawkweed (Pilosella aurantiacum (Syn. Hieracium)), and woolly distaff 

thistle (Carthamus lanatus)), and one historical weed (smooth cordgrass (Spartina alterniflora) are on the State’s A 

list. The A list includes all invasive plant species of known economic importance which occur in the State in small 

enough infestations to make eradication or containment possible. The rest of the noxious weeds mapped by the 

Oregon Department of Agriculture are on the State’s B list, which consists of invasive plants of economic 

importance which are regionally abundant, but which may have limited distribution in some counties. Eighteen of 

these B-listed noxious weeds are widespread throughout one or both the counties, including Himalayan 

blackberry; bull, Canada, Italian, milk, and slender flowered thistles; gorse; and French and Scotch broom. These 

noxious weeds also spread quickly and over long distances by multiple means and do well in disturbed areas like 

burned areas, harvested areas, and pastures (see Category II, Spread from Existing Invasive Plant Sites, for a 

detailed description). The Cooperative Weed Management Areas work with Federal, State, and local government 

agencies, Tribes, individuals, and various interested groups to manage invasive plants in these counties.

 42 Historical indicates previously known noxious weed species that have been eradicated from the area.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

75

Other BLM Pesticide Use

Sudden Oak Death

On the Coos Bay District, the BLM uses glyphosate and imazapyr on tanoak to prevent the spread of Sudden Oak 

Death. Phythophthora ramorum, the pathogen that causes Sudden Oak Death, is subject to State quarantine 

regulations to prevent the spread of the pathogen when it is found. The methods to achieve this include 

glyphosate or imazapyr injection of tanoak prior to cutting to prevent resprouting, mechanical removal of infected 

host species and target hosts within a defined treatment area, and burning of all cut vegetation. Sites are retreated 

if this pathogen persists. Treatments generally occur on approximately 50 to 100 acres annually on the District.

Medford District

The Medford District BLM, east of the Coos Bay District, updated their Integrated Invasive Plant Management Plan 

in 2018 to add additional herbicides and to add invasive plants that are not noxious weeds to the vegetation that 

can be treated. Their plan is similar to Coos Bay’s Proposed Action; however, their plan includes fluroxypyr and 

rimsulfuron, as well as the experimental use of fluazifop-P-butyl43 and Pseudomonas fluorescens (a biopesticide for 

invasive annual grasses), and does not include picloram. The Medford District treats approximately 2,000 acres of 

noxious weeds each year – 75 percent with herbicides, and 25 percent with other methods (primarily manual).

In addition, the BLM manages two seed orchards in the Medford District – the 300-acre Provolt Seed Orchard 

located near Grants Pass and the 200-acre Sprague Seed Orchard near Merlin, managed under a 2006 Record of 

Decision (USDI 2006) for an Integrated Pest Management program on these seed orchards. Dicamba, glyphosate, 

hexazinone, picloram, and triclopyr are the herbicides allowed for vegetation treatments on these seed orchards, 

though BLM has only applied glyphosate for the past several years. Other pesticides that can be used include 

dimethoate, esfenvalerate, horticultural oil, imidacloprid, and insecticidal soap (insecticides) and chlorthalonil 

(fungicide). Acephate, chlorpyrifos, diazinon, and propargite (all for insects) are also allowed, but are very seldom 

or never used. Typically, less than one acre annually is treated with these pesticides on seed orchard lands.

Northwest Oregon District

The Northwest Oregon District BLM, north of the Coos Bay District, is in the process of updating their integrated 

weed control plan to add additional herbicides to the treatment methods that are currently approved. Until 2016, 

the Northwest Oregon District was managed as two districts – the Salem District and the Eugene District. Available 

invasive plant treatment methods have varied by field office and specific management areas. For example, invasive 

plant management in the West Eugene Wetlands has involved the use of prescribed fire, seeding, manual and 

mechanical methods, solarization, targeted grazing, and herbicides including glyphosate, triclopyr, and clopyralid, 

and research and demonstration plots of aminopyralid and fluazifop-P-butyl. The updated plan would allow 

treatment of all terrestrial invasive plants (not just noxious weeds) with herbicides, and would allow the use of 

additional herbicides. The non-herbicide direct control methods currently available would remain and would be 

permitted district-wide under the action alternatives. The District currently treats approximately 2,500 acres of 

invasive plants each year – 2,000 acres with herbicides and 500 acres by manual, mechanical, targeted grazing, fire, 

and biological control methods.

 43 Fluroxypyr, rimsulfuron, and the experimental use of fluazifop-P-butyl are analyzed in Alternative 3 (but not the Proposed 

Action) of this EA.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

76

Roseburg District

The Roseburg District BLM, east of the Coos Bay District, is in the process of updating their Integrated Weed 

Control Plan to add up to 13 herbicides to the four that are currently approved (2,4-D, dicamba, glyphosate and 

picloram), and to treat invasive plants and certain native species in specified areas to meet restoration or safety 

objectives. The District currently treats approximately 2,500 acres of invasive plants each year – 2,000 acres with 

herbicides and 500 acres by manual, mechanical, fire, and biological control methods.

Other Federal and State Lands

U.S. Forest Service

U.S. Forest Service administered lands in the project area are within the Rogue River-Siskiyou and Siuslaw National 

Forests in Region 6. An environmental impact statement authorizing the use of herbicides, manual and mechanical 

methods, biological control agents, mulching, and seeding to treat invasive plants was completed in 2005 for 

Region 6. This EIS allows the use of herbicides on Region 6 National Forests once site-specific analysis has been 

conducted. Herbicide treatments would be part of the initial prescription for most sites, with the ongoing goal to 

reduce reliance on herbicides over time as control objectives are met and infestations become small enough to 

effectively treat manually or mechanically.

The Siuslaw National Forest operates under a 2010 Forest Integrated Weed Management Project EA. The EA 

analyzes the use of glyphosate and imazapyr and focuses on high-priority invasive plant species and sites on the 

Forest. Target species include purple foxglove, oxeye daisy, common tansy, knotweed, European beachgrass, reed 

canarygrass, bull thistle, Canada thistle, Scotch broom, false brome, and meadow knapweed. In 2016, invasive 

plant management focused on sand dune and meadow restoration, forest landscape restoration, non-native 

species with limited occurrence, and rock pits identified for future development. Treatment methods included 

both manual and chemical. Manual methods were used on 313 acres and herbicide was applied on 790 acres.

On the Rogue River-Siskiyou National Forest, invasive plant treatments primarily target medusahead, Japanese 

knotweed, garlic mustard, dyer’s woad, Scotch broom, spotted knapweed, yellowtuft, and yellow starthistle. The 

Rogue River-Siskiyou National Forest primarily uses triclopyr, imazapic, picloram, and glyphosate on sites 

addressed in a 1999 EA decision for the 1.7 million acre National Forest. In 2016, the National Forest treated 1,080 

acres with herbicides; this includes 582 acres of spotted knapweed with picloram, 165.7 acres of Dalmatian 

toadflax and 178.9 acres of spotted knapweed with clopyralid, 133.9 acres of tansy ragwort and Scotch broom with 

glyphosate, and 19.5 acres of medusahead rye with imazapic. An additional 1,685 acres were hand-pulled, cut, or 

pulled with weed wrenches44.

Bandon Marsh National Wildlife Refuge (U.S. Fish and Wildlife Service)

Bandon Marsh National Wildlife Refuge manages invasive plants according to their 2013 National Wildlife Refuge 

Comprehensive Conservation Plan (USDI 2013b). Because invasive plants and animals currently represent the 

greatest threat to the Refuge’s wildlife and habitat, control of invasive species is a high priority management 

activity. Target species include reed canarygrass, Himalayan blackberry, English ivy, Scotch broom, gorse, spartina, 

and Japanese eelgrass. These are controlled with mechanical and manual methods, as well as herbicides to protect 

established trees and shrubs.

 44 A manually operated tool designed to remove woody plants by uprooting them.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 2 - Integrated Invasive Plant Management and the Alternatives

77

Coquille Forest (Coquille Indian Tribe)

Noxious weeds on the Coquille Forest have been managed under the BLM’s 1997 Integrated Noxious Weed 

Program on the Coos Bay District Environmental Assessment. The Coquille Tribe does not plan to manage invasive 

plants as described in this plan’s Proposed Action and it is assumed that the Tribe will continue to manage noxious 

weeds on the forest under the 1997 plan (the No Action Alternative) until the Tribe implements a new forest plan.

Elliot State Forest

The Elliot State Forest operates under a 2011 forest management plan that allows it to treat invasive plants using 

an integrated weed management strategy (ODF 2011). Similar to previous years, Elliot State Forest planned to 

treat approximately 5,000 acres (gross) of Scotch broom along roadsides in 2017 using triclopyr.

Oregon State Parks

Oregon State Parks are managed by the Oregon Parks and Recreation Department. Invasive plants are common on 

State park lands and threaten natural native environments. Preventative methods of control include prohibiting 

collection of plant resources, excluding access to some areas, and requesting visitors to stay on trails. Within 20

state parks in Coos and Curry County, the Oregon Parks and Recreation District treated broom, gorse, knotweed,

biddy-biddy, matgrass, yellow flag iris, fennel, and jubata grass with imazapyr, metsulfuron methyl, triclopyr, and 

glyphosate.

Oregon Department of Transportation (ODOT)

ODOT controls vegetation using a statewide integrated vegetation management approach, including mechanical 

methods, biological control agents, and herbicides. The local maintenance district plan maps locations of sensitive 

natural resources and identifies areas where herbicide spraying would not occur. It also identifies buffer limits and 

other restrictions around water resources, sensitive fish, and plant species. Herbicides are used to control invasive 

plants and roadside vegetation. From 2010 to 2015, ODOT reduced its herbicide use statewide by 44 percent, 

(measured in pounds of active ingredients) from the 2010 level of approximately 55,000 lbs./year, largely by 

switching to herbicides with less active ingredient (ODOT 2016).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3- Affected Environment and Environmental Consequences

78

Chapter 3 – Affected Environment and 

Environmental Effects

This chapter describes the natural, cultural, and social environment of BLM-managed lands on the Coos Bay 

District that would potentially be affected by the alternatives under consideration. It focuses on resource issues 

that were identified during scoping, and presents the consequences of the Proposed Action and Alternative 3 as 

opposed to continuing current management (the No Action Alternative) relative to those issues.

Determination of Effects in this Environmental 

Analysis

The individual issues in this chapter take into consideration the following factors to draw conclusions as to whether 

the alternatives have the potential for significant adverse effects at the site-specific scale:

• Treatments and Application Methods: The Treatments Planned Related to the Issue section describes 

those parts of the alternatives that specifically relate to the issue statement.

• Risk Assessments: These serve as indicators of a potential adverse effect from an herbicide application. 

The analysis describes the potential for the given resource to experience the Risk Assessment-modeled 

exposure scenarios (See Appendix C, Herbicide Risk Assessment Summaries).

• Estimated Gross Treatment Acres (see Tables D-3 and D-4, Estimated Total Treatment Acres, 20-Year 

Analysis Period): Acres provided both for annual estimates and total acres potentially treated over the life 

of the plan.

• Protection Measures: Standard Operating Procedures have been identified to reduce adverse effects to 

humans and environmental resources from vegetation treatment activities based on guidance in BLM 

manuals and handbooks, regulations, and standard BLM and industry practices. Mitigation Measures were 

identified for all potential adverse effects identified for herbicide applications in the 2007 and 2016 PEISs 

and the Oregon FEIS (USDI 2007a, USDI 2016a, USDI 2010a), and adopted by their Records of Decision 

(USDI 2007b, USDI 2016b, USDI 2010b). Conservation Measures were identified in the 2007 and 2016 

Biological Assessments (USDI 2007c, USDI 2016c) for the 2007 and 2016 PEISs, and minimize adverse 

effects to federally listed species. Mitigation Measures adopted in the 2007 and 2016 PEISs also apply 

these Conservation Measures to other Special Status species. Project Design Criteria adopted in ARBO II 

(USDI 2013a, NMFS 2013) further protect federally listed species. In addition, Project Design Features are

included as part of this analysis’ action alternatives.

• Other NEPA Analyses: The analysis tiers to the Oregon FEIS and the 2007 and 2016 PEISs (USDI 2007a, 

2010a, 2016a) at the programmatic scale for effects that could be anticipated from herbicide treatments.

• Cumulative Effects: These are defined in the Council on Environmental Quality (CEQ) regulations as those 

that result from the incremental effects of a proposed action when added to other past, present and 

reasonably foreseeable future actions, regardless of which agency or person undertakes them (40 CFR 

1508.7). Effects from past actions are generally considered part of the description of the Affected 

Environment in the analysis in this chapter. Ongoing and reasonably foreseeable actions are addressed in 

the cumulative effects discussions for each issue as applicable.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Invasive Plants

79

Invasive Plants

Invasive Plants Issue 1

How does the availability of additional herbicides under each alternative affect treatment effectiveness 

for individual invasive plant species?

Analytical Assumptions and Methods

As described in the Oregon FEIS, invasive plant control treatments are not 100 percent effective at controlling all 

treated populations, as some level of retreatment may be necessary to achieve complete control (USDI 2010a:135-

139). The Oregon FEIS found that program effectiveness (based on how often retreatments occur) had been 60 

percent in a program where the districts were limited to glyphosate, picloram, dicamba, and 2,4-D. Hence, the 

BLM estimates treatment efficacy to be 60 percent under the No Action Alternative in this EA. The herbicides 

analyzed in the Oregon FEIS were chosen, in part, because they would be more effective at treating invasive plants 

that occur in the Pacific Northwest. Hence, an 80 percent treatment effectiveness rate was estimated for a 

program where a full range of treatment methods were available, as under the Proposed Action and Alternative 3. 

These projections of effectiveness should not be considered absolute, rather reasonable approximations of the 

relative differences among the alternatives. Program-wide treatment efficacy under each alternative is briefly 

described in this issue, however, it is not analyzed in detail. It was previously described in the analysis for the 

Oregon FEIS (USDI 2010a:135-139) and there are no new circumstances or information that would change the 

effects anticipated district-wide for this EA. The type of actions under all alternatives would be consistent with the 

actions analyzed in the 2010 Oregon FEIS.

However, these effectiveness estimates are not accurate for all invasive plant species on the District. Table 3-1 

provides examples of species where the treatment effectiveness varies from the district-wide treatment efficacy 

assumptions.

Table 3-1. Treatment Effectiveness under the Alternatives

The District has found that existing treatment methods have been 10 percent effective on Canada thistle, as the 

available treatment methods do not effectively control this species and retreatments occur at least annually. For 

perennial grasses such as false brome, there are no selective options under the No Action Alternative and (like 

other treatments under the No Action Alternative) effectiveness has been approximately 60 percent. The Proposed 

Action does not add treatment methods that are selective to perennial grasses, so effectiveness would remain at 

60 percent. In western snowy plover habitat, European beachgrass treatments with bulldozers and discs and 

limited treatments with glyphosate (available under the No Action Alternative and the Proposed Action) have been 

found to be approximately 10 percent effective. 

The availability of aminopyralid and clopyralid to treat Canada thistle (under the Proposed Action), fluazifop-Pbutyl and hexazinone to treat false brome (under Alternative 3), and imazapyr and glyphosate to treat European 

beachgrass (under Alternative 3) is expected to provide the full range of treatment methods for these species. As 

Species Treatment Group No Action Alternative Proposed Action Alternative 3

District-wide, all species varies 60% 80% 80%

Canada thistle Sunflower Family 10% 80% 80%

False brome Perennial Grasses 60% 60% 80%

European beachgrass Perennial Grasses 10% 10% 80%

St. Johnswort Misc. Herbaceous 80% 80% 80%

Buffalobur nightshade Misc. Annual Herbaceous 80% 80% 80%
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Invasive Plants

80

described above, an 80 percent treatment effectiveness rate was estimated for a program where a full range of 

treatment methods were available.

Conversely, some species are adequately controlled under the No Action Alternative, and the Proposed Action or 

Alternative 3 would not lead to an improvement in treatment efficacy. For example, three biological control agents 

currently provide excellent control against St. Johnswort on the District and treatment with this method would 

continue (see Table 2-10, Treatment Key (Misc. Herbaceous)). If buffalobur nightshade (Category III) were to be 

found on the District, the most appropriate control method under all alternatives would be glyphosate or 

handpulling (see Table 2-10, Treatment Key (Misc. Annual Herbaceous)). Where invasive plant treatments, and the 

effects of those treatments, would not differ between the alternatives (including the No Action Alternative), those 

treatments and effects are not discussed in detail.

The analysis area/geographic scale includes locations where invasive plants species are found on BLM-managed 

lands on the District (see Affected Environment). The temporal scale of the analysis is 20 years, the expected life of 

this plan; short-term effects include those that would last less than two growing seasons, long-term effects would 

last greater than two growing seasons. Treatments would be done according to the Treatment Key (Table 2-10), 

which lays out treatment options and considerations by treatment groups.

Affected Environment

The District has mapped 36 invasive plant species on 19,284 sites, totaling 18,100 infested acres (Table 2-1,

Summary of Known Invasive Plant Sites, Map 2-1, Invasive Plants Documented in NISIMS). An additional 207 

invasive plant species are known or suspected to occur on the District (Tables 2-1 and D-2, Further Information 

about Invasive Plant Species), but the BLM has not mapped infestations of these species. Most infestations on the 

Coos Bay District occur on roadsides within forests, at recreation sites, meadows, or sand dune communities 

where invasive plants have more access to sunlight and less competition from native woody plants. Chapter 2 

describes in additional detail the District’s invasive plant species and infestations.

Further information about the species described in detail in this issue can be found in Table 3-2. The treatment 

efficacy for these three species varies from the district-wide treatment efficacy assumptions described in the 2010 

Oregon FEIS. As described in Analytical Methods section above and in the Oregon FEIS to which this EA tiers, 

treatment effectiveness for other species would be 60 percent under the No Action Alternative and 80 percent 

under the action alternatives (USDI 2010: 135-139); or the treatment efficiency does not vary between the 

alternatives (St. Johnswort and buffalo nightshade) and hence, these other species are not analyzed in detail.

Table 3-2. Specific Species, Locations, and Extent1

1. Further information about these species and their extant and mapping in NISIMS can be found in the Category I: Invasive Plants Currently 

Known on the District section of Chapter 2.

2. As described in Category I and displayed in Table 2-1, Summary of Known Invasive Plant Sites, these gross acres are how many acres are 

estimated to be in need of treatment.

Species

NISIMS Gross 

Treatment 

Acres2

Primary Locations Sites Gross 

Acres

Canada thistle 558 188 800 Roadsides, pastures, harvest areas, open disturbed areas

False brome 19 78 200 Roadsides, rights-of-way, forests

European beachgrass 13 59 240 New River, North Spit, coastal sand dunes to coastal meadows
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Invasive Plants

81

Environmental Consequences

No Action Alternative

Under the No Action Alternative, the District would treat approximately 1,000 gross acres per year. Invasive plants 

would continue to spread at their current rate, estimated at 10 percent per year (see Invasive Plants Issue 2 for 

additional detail about spread). Treatment efficacy would be limited because fewer treatment methods and only 

four herbicides are available. The BLM estimates that district-wide, treatment methods would be effective on 60 

percent of treated acres (USDI 2010a:136), requiring multiple retreatments to meet management objectives.

Several noxious weed species would not be effectively controlled using the tools available under this alternative, 

including Canada thistle and noxious weeds in the perennial grasses treatment category45. Mowing Canada thistle 

is effective when it is repeated every 3 to 4 weeks over several growing seasons (DiTomaso et al. 2013), but this 

frequency of mowing is not practical (estimated at 3 to 6 times a year). In addition, topographic features like steep

slopes and woody debris present on most BLM-managed lands precludes the use of mowing in many areas. Canada 

thistle can be effectively controlled with dicamba or picloram, but these herbicides are not registered for use in the 

wetland and riparian areas where this species commonly occurs. Perennial grasses could be controlled with 

glyphosate, but they are intermingled with desirable vegetation that would be damaged by glyphosate, a nonselective herbicide. Treatments generally happen in areas where damage to desirable vegetation can be avoided. 

In areas where perennial grasses are not treated, they continue to spread. 

Some noxious weed species would be treated under this alternative because the treatment method reduces vigor 

or seed development, but the treatment does not actually eliminate the targeted plant or achieve treatment 

objectives. For example, European beachgrass can be manually pulled, but roots remain to resprout. Annual 

treatments of European beachgrass have been 10 percent effective, but beachgrass also spreads at about 10

percent a year. The entire 172 acres of beachgrass infestation in western snowy plover habitat restoration areas at 

New River and the North Spit is re-treated twice annually with heavy equipment such as discs or bulldozers. At the 

North Spit, up to 24 acres of beachgrass would be treated with glyphosate. However, the literature suggests that 

the effectiveness of glyphosate on European beachgrass is marginal because it has no soil activity46 (DiTomaso et 

al. 2013:31). 

Forty-one invasive plants listed in Category I would not be treated under this alternative unless the State of Oregon 

or a county within the District designates them as noxious weeds. In the meantime, they would continue to spread 

unchecked. Category IV, Lower Priority Invasive Plants, are also not listed as noxious weeds and would not be 

treated under this alternative. These species are currently below the threshold level for action but may become 

problematic in the future.

Following a noxious weed treatment, secondary invasions (an increase in abundance of non-target invasive plants 

following the treatment of a targeted invasive plant) often occur. For example, following treatment of Himalayan 

blackberry with mowers or glyphosate, Scotch broom, evergreen blackberry, and Canada thistle may appear. 

Under the No Action Alternative, Canada thistle does not have an effective treatment method and evergreen 

blackberry is only listed in Curry County as a noxious weed and would only be treated in this area of the District.

Limited treatment efficacy would affect the distribution and abundance of invasive plants across all ownerships 

within and surrounding the District. The inability to effectively control species on BLM-managed lands would result 

 45 These include European beachgrass, false brome, jubata grass, pampas grass, perennial ryegrass, reed canarygrass, sweet 

vernal grass, tall fescue, and velvetgrass in Category I (Invasive Plants Currently Known on District) and common reed, matgrass, 

and ribbongrass in Category III (Invasive Plants Not Yet Known on District). In addition, there are numerous Category IV (Lower 

Priority Invasive Plants) perennial grasses (see Table D-2). 46 Glyphosate binds to soil particles and is rapidly degraded by microbes, making it inactive in soil. See Soil Issues 2 and 3. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Invasive Plants

82

in the spread of infestations to other landowners. Even if those landowners have more effective treatment 

options, their long-term success would be reduced because infestations on BLM-managed lands would continue to 

provide a seed or propagule source. Thus, the opportunity to collaborate in an all-lands strategy to control these 

species would be compromised. Ultimately, limited treatment efficacy on BLM-managed lands would reduce 

treatment efficacy at the landscape scale. For example, gorse and brooms spread along roads and power line 

rights-of-way that cross multiple ownerships. Treatments used on neighboring lands are not available on BLMmanaged lands. Hence, potential partners have been reluctant to engage in cooperative control due to BLM’s 

herbicide use restrictions and resulting confusion and complication of switching treatments at ownership 

boundaries. The checkerboard nature of land ownership exacerbates spread when some parties are not able to 

participate fully. However, in western snowy plover habitat the BLM works closely with – and uses similar 

treatment methods to – the U.S. Army Corps of Engineers on treatments of European beachgrass in plover habitat 

restoration areas, as invasive plant treatments on Corps- and BLM-managed lands have the potential to destabilize 

the foredunes next to the shipping channel (see Soil Issue 1 and Wildlife Issue 1 for more information on 

treatments in western snowy plover habitat).

Proposed Action

Under the Proposed Action, the BLM would add additional treatment methods (including additional herbicides) 

and allow treatment methods to be used on invasive plants that are not listed as noxious weeds. This would result 

in a more effective integrated management program compared to the No Action Alternative. Invasive plants would 

continue to spread at an estimated 10 percent per year, but the BLM estimates that herbicide treatments would 

be effective on 80 percent of treated acres (USDI 2010a:136), requiring fewer retreatments to meet management 

objectives compared to the No Action Alternative. The improvement in herbicide efficacy would allow the BLM to 

focus non-herbicide treatments where they are most practical and effective, either as stand-alone treatments or in 

combination with herbicide treatments. The combination of tools available under the Proposed Action would be 

effective on most of the invasive plant species known or suspected to occur on the District, as well as potential 

new invaders. As a consequence, treatment objectives, such as reducing infestations to below damage levels for 

Special Status species and special communities (see Native Vegetation Issue 1), would be met more frequently and 

on more acres compared to the No Action Alternative.

Treatment effectiveness of Canada thistle would increase to approximately 80 percent. Canada thistle can be 

effectively controlled with aminopyralid or clopyralid, both of which would be available under this alternative. 

(However, aminopyralid has longer residual activity than clopyralid, and is less likely to harm neighboring desirable 

species (DiTomaso et al. 2013).)

Similar to the No Action Alternative, perennial grasses such as false brome and European beachgrass would not 

have effective treatment methods under this alternative. Treatments in western snowy plover habitat restoration 

areas would continue to be limited to discing, bulldozing, or plowing beachgrass, with limited treatments using 

glyphosate or methods that would leave the root system intact. Neighboring infestations of beachgrass could be 

treated with imazapyr and glyphosate, which would limit its spread into these areas. False brome and other 

perennial grasses infesting roadsides would be spot treated with glyphosate; however, glyphosate has no residual 

activity and would not control undetected seedlings, thus reducing overall treatment efficiency.

An important benefit of the more effective integrated invasive plant management under the Proposed Action 

would be the opportunity to better collaborate with partners on an all-lands strategy to reduce the impacts of 

invasive plants in coastal Douglas, Coos, and Curry Counties. Currently, adjacent landowners have not opted to do 

treatments in cooperation with the BLM due to the limited treatment options that are available; however, several 

major timberland operators have expressed an interest in doing cooperative treatments where applicators do not 

have to change herbicides or rates at property boundaries (Jeanne Standley, Coos Bay Weed Coordinator, 2018 

personal communication).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Invasive Plants

83

Alternative 3

Alternative 3 is similar to the Proposed Action, except that four additional herbicides47 would be available for use 

district-wide and additional treatment methods would be used in western snowy plover habitat restoration areas. 

These additional herbicides would include hexazinone and fluazifop-P-butyl, which are effective on perennial 

grasses. This is not expected to change the district-wide 80 percent effectiveness estimate, as these perennial 

grasses account for less than one percent of the currently mapped invasive plants on the District. (While these 

perennial grasses have not been mapped in part because these species have no effective treatment methods 

available under the other alternatives, the majority of the District’s invasive plant species are woody species (trees, 

shrubs, and vines), which would be effectively treated under both the Proposed Action and Alternative 3.)

In western snowy plover habitat restoration areas, the BLM would use imazapyr and glyphosate to treat up to 172 

acres of European beachgrass. Treatment effectiveness of European beachgrass would increase from 

approximately 10 percent to 80 percent with the addition of imazapyr and expansion of the area that could be 

treated with glyphosate. The addition of more effective treatments would decrease dependence on less effective

mechanical treatments and reduce the need for heavy equipment treatments when compared to the No Action 

and Proposed Action from twice annually to once every two to three years.

Infestations of false brome currently occur on roadsides, where they can be easily accessed by people or crews 

doing invasive plant treatments. The most effective treatment on this species is glyphosate application in the 

midsummer to fall, followed by hexazinone the following spring to control germinants (OSU 2017). Under 

Alternative 3, this would replace mowing, which must be done multiple times a year to effectively treat 

infestations and can harm non-target vegetation. Effectively treating false brome on the roadsides with glyphosate 

and hexazinone would prevent the spread of this species into forests where it forms monocultures and crowds out 

other understory species.

Other effects remain as described under the Proposed Action.

Invasive Plants Issue 2 (Not Analyzed in Detail)

How would invasive plant treatments under each alternative affect the spread rate of invasive plants?

This issue is not analyzed in detail here; the spread rate does vary between the alternatives, as described in the 

analysis for the Oregon FEIS (USDI 2010a:131-139) but there are no new circumstances or information at the sitespecific level that would change the effects anticipated for this EA. The type of actions under all alternatives would 

be consistent with the actions analyzed in the 2010 Oregon FEIS.

The rate of spread from existing infestations was estimated based on BLM and U.S. Forest Service data which 

showed that invasive plants spread at an estimated 10 to 15 percent annually (USDI 2010a:594-603), with 10 

percent a more likely estimate west of the Cascades due primarily to the steeper, more vegetated landscape 

where wind-born species cannot spread as easily (USDI 2010a:595)48. Within particular plant communities or 

infestations, rate of spread fluctuates over time (see Figure 3-1). As described in the Oregon FEIS, the invasive 

plant invasion process occurs in three phases: introduction, establishment, and spread. Once an introduction 

occurs, a delay or lag phase often takes place while an invasive plant becomes established. This phase is followed 

by a period of rapid growth that continues until the invasive plant species reaches the bounds of its new range 

 47 Rimsulfuron, hexazinone, fluroxypyr, and fluazifop-P-butyl. 48 The Oregon FEIS projections were based on noxious weed data and may not hold true for other invasive plants (USDI 

2010a:595). Nonetheless, in the absence of better data, the BLM assumes in this analysis that the rate of spread for all invasive 

plants is equivalent to the rate for noxious weeds.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Invasive Plants

84

(Figure 3-1)(USDI 2010a:132). In the earliest phases (between introduction and before rapid spread), control 

programs are the most effective.

Figure 3-1. Relationship between Area Occupied by Invasive Plant Species and Time

Eighty-four percent of mapped invasive plant 

infestations are smaller than one acre (Table 2-2, 

Summary of Invasive Plants Documented in 

NISIMS by Infestation Size). These sites are a 

higher priority for treatment, in part because 

they are closer to the introduction phase of the 

invasion curve, where if effective treatments are 

available, they can control the infestation and 

eradication is more likely. One percent of sites 

are larger than 5 acres, but account for 47 

percent of mapped acres (Table 2-2). These larger 

sites would generally not be candidates for 

eradication but would be treated to prevent 

spread (containment).

Under the No Action Alternative, the District 

would treat approximately 1,000 gross acres per year. Invasive plants would continue to spread at their current 

rate, estimated at 10 percent per year. Given a 10 percent rate of spread and annual treatment of 1,000 gross 

acres per year at a 60 percent effective treatment rate, the 18,100 acres of mapped infestations is estimated to 

spread to 36,428 acres over the next decade and to 83,966 acres in 20 years. The effective annual rate of increase 

in infested acres in year 10 would be 101 percent, and in year 20 would be 364 percent, meaning that despite a 

combination of prevention efforts and control treatments (biocontrol, chemical, manual, and mechanical), rate of 

spread would rapidly outpace rate of control. Forty-one invasive plants listed in Category I would not be treated 

under this alternative unless the State of Oregon or a county designates them as noxious weeds. In the meantime, 

they would continue to spread unchecked. Category IV, Lower Priority Invasive Plants, are also not listed as noxious 

weeds and would not be treated under this alternative. These species are currently below the threshold level for 

action at the landscape scale; however, in limited areas treating them is a priority as they compete with Special 

Status plants and degrade unique plant communities in ACECs.

Under the Proposed Action, the BLM would add additional treatment methods (including additional herbicides) 

and allow treatment methods to be used on invasive plants that are not listed as noxious weeds. This would result 

in a more effective integrated invasive plant management program compared to the No Action Alternative. Given a 

10 percent rate of spread and annual treatment of 1,000 gross acres per year at an 80 percent effective treatment 

rate, the 18,100 acres of mapped infestations are estimated to grow to 71,366 acres after 20 years of treatment 

(or 32,922 after 10 years), which is 12,600 fewer acres after 20 years (or 3,500 acres after 10 years) than under the 

No Action Alternative. This is a 294 percent increase to the existing infestation (compared to 364 percent under 

the No Action Alternative). However, given the more effective treatment methods available (as discussed in 

Invasive Plant Issue 1), as well as the existing prioritization of small invasive plant sites, many infestations would be 

eradicated while they are in the introduction (or establishment) phase. While it is not possible to quantify this 

influence on the rate of spread, it can be assumed that this would result in a reduction in the spread rate (USDI 

2010a:137-138). As described in the Oregon FEIS (USDI 2010a:133), implementing control efforts in this phase can 

prevent future infestations on tens to hundreds of times more acres (Radtke and Davis 2009)49.

Alternative 3 is similar to the Proposed Action, except that four additional herbicides would be available for use 

district wide and additional treatment methods could be used in western snowy plover habitat restoration areas. 

 49 An updated version of this 2009 report is cited in this EA as The Research Group, LLC (2014).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Invasive Plants

85

These additional four herbicides would include herbicides that are effective on perennial grasses. Although this 

would affect the spread rate of some individual species that would not be effectively treated under the other 

alternatives (for example, false brome; see Invasive Plants Issue 1), this is not expected to change the district-wide

spread rate described under the Proposed Action.

Invasive Plants Issue 3 (Not Analyzed in Detail)

How would climate change affect the spread of invasive plants?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

(USDI 2010a:171-172) and there are no new circumstances or information at the site-specific level that would 

change the effects anticipated for this EA.

The Oregon FEIS discusses that increased temperatures, longer hotter summers, earlier snowmelt, and resultant 

increased hydrologic droughts will change plant communities. Climate change is essentially a disturbance that 

makes an increasing number of niches available for invasive plants to occupy. The same characteristics that make 

invasive plants successful at invading other disturbances will likely give other invasive plants an advantage over 

native plants during this migration (USDI 2010a:171).

One recent (2017) study by the Oregon Climate Change Research Institute (OCCRI) reported similar conclusions as 

the Oregon FEIS. At present, there is no local-scale modeling of processes affecting the Southern Oregon coast 

(such as upwelling, coastal fog, etc.), and it is not feasible to deduce local-scale change from large-scale models. 

However, the OCCRI report documents and describes changes to communities and coastlines and, whenever 

possible, south coast-specific projections are detailed and inferred. On the coast, sea level rise will increase the risk 

of coastal erosion and flooding; warming waters and ocean acidification will degrade estuarine habitat crucial for 

salmon and shellfish and negatively affect nearshore fisheries; and forest vegetation in the Coast Range may shift. 

Future warming and changes in precipitation may considerably alter the spatial distribution of suitable climate for 

many important tree species and vegetation types in Oregon by the end of the 21st century. More frequent 

drought conditions projected for the future will likely increase forest susceptibility to disturbance agents (such as 

invasive plants) (Halofsky and Peterson 2016).

Background: Potential Effects to Non-Target 

Organisms

The following four Issue sections (Native Vegetation, Fish and Aquatic Organisms, Wildlife, and Human Health) rely 

on herbicide Risk Assessments to aid in analyzing and describing adverse effects. As further described in Chapter 2 

and Appendix C, Herbicide Risk Assessment Summaries, these BLM and U.S. Forest Service-prepared Risk 

Assessments quantitatively evaluate the probability (i.e., risk) that herbicide use in wildland settings might pose 

harm to an organism. These Risk Assessments were done or adopted as part of the 2007 and 2016 PEISs and the 

2010 Oregon FEIS. Risk Assessments are necessarily done on surrogate species in laboratory conditions, identified 

to represent a species group. Risk Assessments take a conservative approach at assessing risk, incorporating 

assumptions in the analysis to account for highly susceptible50 individuals; testing builds in and accounts for 

uncertainty (multiplying the lowest observable effects by a factor of 10, 100, or even 1,000) and testing scenarios 

may be severe (e.g., soaking the test animal or consuming treated vegetation for an entire day). The likelihood of 

actual exposures comparable to those described in the Risk Assessments is reduced by application of Protection 

Measures (see Appendix A), as well as by the nature of the application and the location and actions of the 

 50 Rare, old, young, sick, etc.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

86

receptor51. The Risk Assessments are summarized in tables in Appendix C and show herbicide risk ratings for 

vegetation, wildlife, and humans at BLM maximum and typical application rates52, in a variety of application 

scenarios.

Figure 3-2. Bureau Sensitive Species Treatment Conditions

Three Issues sections (Native Vegetation, Fish and Aquatic Organisms, and Wildlife) include effects to Special 

Status species; species that are federally listed as threatened or endangered or proposed for listing, as well as 

Bureau Sensitive species; species that are rare, but are not federally listed or proposed for listing. Bureau Sensitive 

species are those for which population viability is a concern, as evidenced by significant current or predicted 

downward trends in population numbers or density and habitat capability that would reduce a species’ existing 

distribution. Management of Bureau Sensitive species “must not result in a loss of species viability or create 

significant trends toward Federal listing” (USDI 2008b). Consultation with the U.S. Fish and Wildlife Service or the 

National Marine Fisheries Service has occurred for listed species on the District, including at the national level with 

the 2007 and 2016 PEISs. This consultation resulted in Conservation Measures applicable to listed species or 

species proposed for listing (see Appendix A, Protection Measures). (Consultation done at other levels has also 

resulted in other Protection Measures that are applicable to listed species; see Appendix A.) Mitigation Measures 

adopted with the Records of Decision for the 2007 and 2016 PEISs at the national level state that, “To protect 

Special Status wildlife species, implement Conservation Measures for terrestrial animals presented in the 2007

Vegetation Treatments on Bureau of Land Management Lands in 17 Western States and 2016 Vegetation 

Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron Biological Assessments.” These Conservation 

 51 For example, a Risk Assessment might indicate a risk to a large mammal if the mammal were directly sprayed. However, 95 

percent of herbicide applications are spot treatments and a large mammal is unlikely to remain in a treatment area while 

treatment is occurring.

52 Actual rates used are listed in Table 2-10 (Treatment Key). Maximum rates are rarely used.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

87

Measures include herbicide-free buffers for non-target species. The following Project Design Feature, included in 

the analysis of the Proposed Action, would further minimize the potential for invasive plant treatments to 

adversely affect a site or population of Bureau Sensitive species. The loss of a few individuals may be acceptable if 

treatments are expected to improve habitat conditions, which would provide long-term benefits to the population.

• Follow the Bureau Sensitive Species Treatment Conditions flowchart (Figure 3-2) when working in 

potential habitat for Bureau Sensitive species.

Native Vegetation

Native Vegetation Issue 1

How would treatment methods affect unique plant communities in Areas of Critical Environmental 

Concern (ACECs) and other areas with Special Status plant species?

Analytical Methods

The analysis area includes the areas where invasive plants threaten unique plant communities: Special Status 

species habitat or ACECs within the Coos Bay District. These areas are located in estuarine areas, coastal sand 

dunes, Jeffrey pine savannah, rocky serpentine mountain tops, and Coast Range meadows. As described in the 

Planning section of Chapter 2, treatment of invasive plants in these areas is a high priority.

ACECs in late-successional forests, Darlingtonia fens, coastal wetlands and meadows, knobcone pine forests, and 

grassy knobs currently either contain no known invasive plants or the invasive plants are only found along 

roadsides where Special Status species are not found and will not be analyzed in detail because there is no 

potential for significant effects. In addition, a majority of the District’s Special Status plant sites contain no invasive 

plants and will not be analyzed in detail because there is no potential for significant effects.

Analysis of effects to plants from herbicide treatments is based on the Risk Assessments conducted for the 

individual herbicides (see Appendix C, Herbicide Risk Assessment Summaries) and on proposed application rates, 

and treatment acres (described in Chapter 2 of this EA). Conclusions are based on the review of existing data; 

spatial data; utilization of professional research and literature; and professional expertise (both internal and 

external).

The following terms will be used to describe the intensity and duration of effects on Special Status plant species:

• Negligible: The effects on Special Status plants would be at or below the level of detection, and the 

changes would be so slight that they would not be of any measurable or perceptible consequences to 

individuals or the population as a whole. Effects on individuals would be detectable or measurable, but 

localized, and of little or no consequence to the population. A minor effect could include mortality of a 

few individuals from treatment methods. Mitigating measures, if needed to offset effects, would be 

simple to implement.

• Minor: Effects on Special Status plants would be detectable or measurable, but localized, and of little or 

no consequence to the population. A minor effect could include mortality of a few individuals from 

treatment methods. Mitigating measures, if needed to offset effects, would be simple to implement.

• Moderate: Effects on the individuals would be detectable and measurable and could cause some loss of 

the population. Mitigating measures would be needed to assure the viability and probability of 

persistence.

• Major: Effects on individuals or habitat conditions would include a measureable decline in population 

viability and probability of persistence. A major adverse effect could trigger a population decline that may 

not be reversible, even with extensive mitigating measures.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

88

Short term: a change in a resource or its condition would last less than two growing seasons.

Long term: a change in a resource or its condition would last for more than two growing seasons.

Affected Environment

Researchers have ranked invasion from non-native species as the second largest threat to endangered species in 

the United States (Wilcove et al. 1998). Rare plant species, including BLM Special Status species, generally display 

narrow ecological amplitudes, keeping them geographically restricted and unable to compete over a wide range of 

site conditions. Although effects vary depending on species, invasive plants have the potential to disrupt native 

plant communities through modification of nutrient cycles and disturbance regimes, competition for resources, 

changes in habitat structure, and effects on regeneration of native plants (Gordon 1998).

Unique Plant Communities

ACECs are designated to protect important natural resources and as a result, unique plant communities and 

habitat types are often found in ACECs. Coos Bay BLM manages these lands to maintain or restore the relevant and 

important values, which includes preservation of Special Status plant populations and their habitats. These unique 

plant communities include late-successional conifer forests, Port-Orford-cedar forests, knobcone pine forest, 

Jeffrey pine savannah, grasslands and meadows, grassy balds, coastal wetlands, and Darlingtonia fens. In addition, 

other unique plant communities that contain Special Status plants on the Coos Bay District include coastal sand 

dunes, estuarine habitats, and rocky serpentine mountain tops. Although most of these unique plant communities 

contain Special Status plant species, some sites face little risk from invasive plant species.

Unique plant communities in mid- to late-successional forest have no documented threats from invasive plant 

infestations as few invasive plants are shade tolerant. Noxious weeds such as ivy, old man’s beard, herb Robert, 

and false brome are known to occur along roadsides, rights-of-way, or riparian areas but spread has been 

prevented to adjacent forest, and thus have not threatened any Special Status plants in forest habitat. The current 

infestation level of invasive plants in Darlingtonia fens, coastal wetlands, coastal meadows, and grassy balds is also 

low (less than 5 percent), with invasive plant species restricted to road rights-of-way that bisect or are adjacent to 

these habitats. No known Special Status plant sites are currently threatened by invasive plants in these 

communities and thus they will not be discussed further.

There are 263 acres of unique plant community habitat containing Special Status plants that are currently 

threatened by invasive plant species. The habitat with the greatest acreage is the coastal sand dune community in 

the New River and North Spit ACECs with about 238 acres of infestations from 10 invasive plant species. The 

remaining 25 acres are found in Jeffrey pine savannah, Coast Range meadows, estuarine habitat, and rocky 

serpentine mountain tops.

Table 3-3. Plant Communities, Management Areas, Invasive Plants, and Species Affected

Plant 

Community

Special 

Management 

Areas

Percent of Community Infested with Known 

Invasive Plants1

Special Status 

Species Threatened 

by Invasive Plants

Acres of Special 

Status Plant Habitat 

Threatened 

Coastal sand

dunes

New River ACEC, 

North Spit ACEC

>25% European beachgrass, Scotch broom, 

gorse, silver wattle, Canada thistle, field 

bindweed; ripgut brome, big quaking grass, 

bristly and crested dogtail grass, sweet vernal 

grass, wild radish, sea rocket, sheep sorrel, 

false dandelion, English plantain

Pink sand verbena, 

silvery phacelia, 

seaside gilia, coastal 

cryptantha, beach 

sagewort, and 

western snowy 

plover (bird, see 

Wildlife Issue 1)

238, including:

North Spit HRA: 72

New River HRA: 100

Storm Ranch: 15

Lost Lake: 40

Fourmile Creek: 1

Floras Lake: 10
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

89

Plant 

Community

Special 

Management 

Areas

Percent of Community Infested with Known 

Invasive Plants1

Special Status 

Species Threatened 

by Invasive Plants

Acres of Special 

Status Plant Habitat 

Threatened 

Coast Range 

meadows 

China Wall ACEC, 

meadow near 

Kenyon Mountain 

>10% Canada thistle, blackberries (roadside), 

Scotch broom (roadside); sweet vernal grass, 

bristly dogtail grass

Oregon bensoniella 2

Estuarine 

New River ACEC, 

North Spit ACEC, 

Dean Creek

>10% yellow flag iris, blackberries, purple 

loosestrife, Canada thistle, herb Robert

European beachgrass; reed canarygrass, 

velvetgrass, birdsfoot trefoil, saltmeadow 

rush

Henderson’s 

checkermallow, 

Point Reyes bird’s 

beak, western marsh 

rosemary

2

Jeffrey pine 

savannah

North Fork Hunter 

Creek ACEC <1% Canada thistle; bristly dogtail grass

Mardon skipper 

(butterfly; see 

Wildlife Issue 3)

20

Rocky 

serpentine 

mountain 

tops

Bosley Butte, 

Palmer Butte, and 

Grizzly Mountain 

Communication 

Sites

<1% Scotch broom Gasquet manzanita 1

1. Known noxious weeds listed first followed by semicolon, then other invasive plants, if known.

The North Fork Hunter Creek ACEC contains a Jeffrey pine savannah with a unique relic grassland composed almost 

entirely of native perennial grasses, the only one known on the District. This native grass savannah provides 

habitat for the Mardon skipper, a Special Status butterfly and has recently been invaded by Canada thistle and 

bristly dogtail grass. The area is used for recreation and additional invasive plants are likely to be introduced from 

the surrounding areas.

Special Status Species

There are 80 Bureau Special Status plants and fungi documented or suspected to occur within the Coos Bay 

District, including 39 vascular plants, 9 liverworts, 10 mosses, 11 lichens, and 11 fungi (fungi are further discussed 

in Native Vegetation Issue 2). Special Status plants occur in a variety of habitats on the District. These rare species 

display narrow ecological amplitudes and are geographically restricted, making them particularly vulnerable to 

degradation from invasive plants (USDI 2010a:149). Of the 80 known or suspected Special Status species on the 

Coos Bay District, 46 are documented. Eleven of these species are currently threatened by invasive plants (see 

Table 3-4).

Table 3-4. Special Status Plants Threatened by Invasive Plants1

Family Scientific Name Common Name Number of 

sites

Preferred Habitat on 

District

Asteraceae Artemisia pycnocephala Beach sagewort 2 Coastal sand dunes

Boraginaceae Cryptantha leiocarpa Coastal cryptantha 1 Coastal sand dunes

Hydrophyllaceae Phacelia argentea Silvery phacelia 4 Coastal sand dunes

Nyctaginaceae Abronia umbellata ssp. breviflora Pink sand verbena 4 Coastal sand dunes

Polemoniaceae Gilia millefoliata Seaside gilia 2 Coastal sand dunes

Saxifragaceae Bensoniella oregona Oregon bensoniella 1 Coast Range meadows

Malvaceae Sidalcea hendersonii Henderson’s checkermallow 1 Estuarine

Orobanchaceae Cordylanthus maritimus Point Reyes bird’s beak 1 Estuarine

Plumbaginaceae Limonium californicum Western marsh rosemary 1 Estuarine

Ericaceae Arctostaphylos hispidula Gasquet manzanita 3 Rocky serpentine 

mountain tops

1. All species in this table are Bureau Sensitive.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

90

Five Special Status plants – pink sand verbena, silvery phacelia, coastal cryptantha, seaside gilia, and beach 

sagewort – occur at open coastal sand dune communities on the District and all are threatened by invasive plants, 

particularly dense monocultures of European beachgrass. When European beachgrass has been removed, other 

invasive plants colonize within one growing season. These other invasive plants include big quaking grass, ripgut 

brome, bristly dogtail grass, rat-tail fescue, sweet vernal grass, English plantain, and false dandelion. All pink sand 

verbena habitat is within the western snowy plover habitat restoration areas at the North Spit and New River. 

Beach sagewort, coastal cryptantha, silvery phacelia, and seaside gilia populations are only found in dune 

communities outside of the plover habitat restoration areas.

Almost all meadows on the District have a mix of native and invasive grasses. In some instances, invasive grasses 

dominate meadow communities yet the Special Status plant populations persist. For instance, dwarf brodiaea is a 

Special Status species that grows in meadows in the New River ACEC dominated by invasive sweet vernal grass. 

However, the sweet vernal grass has not appeared to affect the presence, abundance, or persistence of the dwarf 

brodiaea; therefore, control in these meadows would not occur unless invasive plants begin to have a measurable 

negative effect on the dwarf brodiaea (and thus they will not be discussed further). Another example is Oregon 

bensoniella, which is documented in one Coast Range meadow with a mix of native and invasive grasses. The 

invasive grasses have had a negligible effect on the Oregon bensoniella population for the last 20 years and 

therefore have not been treated. However, Canada thistle has recently invaded the meadow and, where it grows, 

Oregon bensoniella is absent. Control of Canada thistle is necessary for Oregon bensoniella to continue to persist 

on the District.

Estuarine habitat at the Dean Creek Elk Viewing Area and adjacent Spruce Reach Island hosts a population of 

Henderson’s checkermallow. This Special Status species is threatened by noxious weeds: yellow flag iris, Canada 

thistle, butterfly bush, blackberries, herb Robert, and purple loosestrife, as well as other invasive plants that are 

not listed as noxious weeds, including reed canarygrass, creeping buttercup, birdsfoot trefoil, and velvetgrass.

Estuarine habitat on the North Spit of Coos Bay provides habitat for two Special Status plants which grow side by 

side- Point Reyes bird’s beak and western marsh rosemary. A noxious weed, European beachgrass, and an invasive 

weed, saltmeadow rush, have begun to invade this site.

The federally listed western lily has been documented at one site on the Coos Bay District. There are no known 

invasive plant sites within a thousand feet of the western lily population. The western lily site is also located offtrail in a location where disturbance by visitors is minimal which also limits the exposure of the site to invasive 

plants that can spread along well-used trails and rights-of-way.

Treatments Planned Related to the Issue

No Action Alternative

There are 263 total acres of unique plant community habitat containing Special Status plants that are currently 

threatened by invasive plants; 172 of these acres fall within western snowy plover habitat restoration areas, where 

treatment of noxious weeds are limited to non-herbicide methods and a limited amount of glyphosate available for 

use at the North Spit. These acres are generally treated mechanically twice a year with non-selective heavy 

equipment such as tractor-mounted discs and plows, as well as bulldozers. Invasive plants that are not designated 

as noxious weeds would not be treated. On the other 91 acres of unique plant communities, herbicides, manual 

and mechanical methods, competitive seeding and planting53, prescribed fire, and targeted grazing would be used 

to treat noxious weeds and no treatments would be available for other invasive plant species. However, the BLM 

would generally treat noxious weeds in these Special Status plant sites using manual techniques. (Conservation 

Measures applicable to Special Status Plants include non-herbicide buffers of varying distance from Special Status 

 53 Competitive seeding and planting could include the reintroduction of Special Status plants to the area.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

91

plants. See Appendix A, Protection Measures.) Herbicides would include 2,4-D, dicamba, glyphosate, and picloram. 

A Conservation Measure prohibits the use of picloram within 1⁄2 mile of Special Status plant species, but it may be 

used in the Jeffrey pine savannah plant communities, where Special Status plants are not present. The BLM would 

use backpack sprayers or wipers to directly apply herbicide to foliage for all herbicide treatments.

Proposed Action

The Proposed Action would allow all terrestrial invasive plants (not just noxious weeds) to be treated and is 

expanded to include the use of additional herbicides. There are 263 total acres of unique plant community habitat 

containing Special Status plants that are currently threatened by invasive plant species. As described under the No 

Action Alternative, 172 of these acres fall within western snowy plover habitat restoration areas, where 

treatments are limited to non-herbicide methods and a limited amount of glyphosate at the North Spit. These 

acres are generally treated mechanically twice a year with non-selective heavy equipment such as tractormounted discs and plows, as well as bulldozers.

In addition to 2,4-D, dicamba, glyphosate, and picloram, the following herbicides would be available for treatment 

under this alternative: aminopyralid, chlorsulfuron, clopyralid, dicamba + diflufenzopyr, imazapic, imazapyr, 

metsulfuron methyl, sulfometuron methyl, and triclopyr. In coastal sand dune communities, imazapyr and 

glyphosate would be used to control European beachgrass, except in western snowy plover habitat restoration 

areas. In addition to methods used under the No Action Alternative, direct control methods would include the use 

of propane torches to selectively spot treat invasive plants within Special Status plant habitat and weed barrier 

mats at Dean Creek special management area adjacent to the Henderson checkermallow site and fence lines.

Alternative 3

Alternative 3 allows all terrestrial invasive plants to be treated and includes the use of herbicides available in the 

Proposed Action plus four additional: hexazinone, rimsulfuron, fluroxypyr, and fluazifop-P-butyl. However, 

hexazinone cannot not be used within 300 feet of Special Status plants (see Protection Measures, below) or near 

Mardon skipper habitat (see Wildlife Issue 3) and a Project Design Feature prohibits the use of fluroxypyr at known 

Mardon skipper sites (see Wildlife Issue 3).

In addition, this alternative allows the use of glyphosate and imazapyr in the 172 acres of western snowy plover 

habitat restoration areas where the Special Status plant pink sand verbena also occurs.

Other treatments remain as described under the Proposed Action.

Protection Measures

Standard Operating Procedures and Mitigation Measures Relevant to the Issue

Projects that have the potential to disturb Special Status plant habitat require pre-project clearances, including 

review for potential habitat and surveys in suitable habitat (USDI 2008b) to identify populations and necessary 

protection measures. The potential for adverse effects to Special Status plants would be reduced for all 

alternatives by implementing existing Standard Operating Procedures and Mitigation Measures (see Appendix A), 

including:

• Conduct pre-treatment reviews and surveys for sensitive habitat and Special Status species within or 

adjacent to proposed treatment areas.

• Provide clearances for Special Status species before treating an area as required by Special Status Species

Program policy. Consider effects to Special Status plants when designing herbicide treatment programs.

• Use a selective herbicide and a wick or backpack sprayer to minimize risks to Special Status plants.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

92

• Apply the least amount of herbicide needed to achieve the desired result.

• Manage animals [used for targeted grazing] to prevent overgrazing and minimize damage to sensitive 

areas.

• Avoid treating vegetation during time-sensitive periods (e.g., nesting and migration, sensitive life stages) 

for Special Status species in area to be treated.

• Minimize direct impacts [of prescribed fire] to species of concern, unless studies show that species will 

benefit from fire.

• When necessary to protect Special Status plant species, implement all Conservation Measures for plants 

presented in the 2007 Vegetation Treatments on Bureau of Land Management Lands in 17 Western States

and 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron Biological Assessments

(see Conservation Measures in Appendix A).

Conservation Measures include the following for picloram (applicable under all alternatives):

• Do not apply by ground methods, at any application rate, with 1⁄2 mile of terrestrial TEP54 plant species.

Conservation Measures for hexazinone (applicable under Alternative 3) include:

• Do not apply by ground methods at the typical application rate within 300 feet of terrestrial TEP plant 

species or aquatic habitats that support aquatic TEP plant species.

• Do not apply by ground methods at the maximum application rate within 900 feet of terrestrial TEP plant 

species or aquatic habitats that support aquatic TEP plant species.

Project Design Features for the Proposed Action and Alternative 3

The following Project Design Feature would further reduce effects to Special Status plants under the Proposed 

Action and Alternative 3:

• When using prescribed fire in western snowy plover habitat restoration areas, reseed with pink sand 

verbena or other appropriate native species in areas where revegetation will not occur through natural 

processes.

Monitoring for the Proposed Action and Alternative 3

In addition to the implementation and effectiveness monitoring described in Chapter 2 that is applicable to all 

alternatives, for treatment methods that are new to the Coos Bay District, for the first three years after the plan is 

implemented, the BLM would closely monitor the response of Special Status plants to invasive plant treatments. 

Monitoring would happen yearly and would measure Special Status plant numbers, plant size, and whether plants 

are reproductive or not. No more than 5 percent of a Special Status plant population would be within the 

treatment area until effects to Special Status plants can be determined. If adverse effects occur (e.g., impacts or 

loss of a few individual Special Status plants), the BLM would weigh the consequences of these effects against the 

long-term impacts of invasive plants, including spread, that would be expected in the absence of treatments. By 

monitoring community-level treatment effects and refining prescriptions for subsequent treatments, undesirable 

outcomes would decline with increasing experience. The BLM would accept short-term adverse effects in Special 

Status plant communities if treatments were expected to benefit conditions and ecosystem function in the longterm. It is expected that information gained from this monitoring will provide additional information to consider as 

part of Table 2-10, Treatment Key; which would inform future treatments, helping to refine prescriptions for 

greater success. This would also inform decisions made by following the Bureau Sensitive Species Treatment 

Conditions flowchart (Figure 3-2, Bureau Sensitive Species Treatment Conditions) when working in potential habitat 

for Bureau Sensitive plants.

 54 Federally listed as threatened or endangered, or proposed for such listing.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

93

Application of this flowchart, would allow the BLM to determine when Conservation Measures should not be 

followed because their implementation would result in greater harm from an untreated invasive plant infestation.

For example, this would help identify whether treatment buffers or other control measures would be needed with 

the use of imazapyr in pink sand verbena habitat under Alternative 3.

Environmental Consequences

Direct and Indirect Effects

Common to All Alternatives

Although the protection of sites occupied by Special Status plants is a priority for BLM invasive plant control efforts

– invasive plants compete for space, water, and nutrients and can also have adverse allelopathic55 effects to other 

vegetation – the success of those efforts would vary depending upon the degree to which those sites are invaded 

and whether effective invasive plant control tools are available. Individual Special Status plants could be injured or 

killed by invasive plant treatments, but adverse effects to populations from treatments would be negligible to 

minor because implementation of Protection Measures (Appendix A) would reduce effects to below levels that 

could adversely affect populations or trend species toward listing. Annual Treatment Plan reviews would provide 

additional opportunities to develop site-specific treatment prescriptions and prescribe Protection Measures that 

would further reduce adverse effects to Special Status plants. Treatments would improve habitat conditions and 

provide long-term benefits to the population.

Manual and mechanical treatments in Special Status plant sites would cause injury and mortality to plants, reduce 

vigor, and reduce seed production. Habitat changes, such as reduced vegetated cover, soil disturbance, trampling, 

and germination of weed seeds could also reduce the vigor and reproductive output of Special Status plants in the 

short term. For selective treatments that target individual plants or patches, such as hand-pulling, digging, and 

grubbing, these short-term effects would be minor, affecting individual Special Status plants, but not entire 

populations. Long-term effects would benefit Special Status plants and their habitat. Discing and plowing are not 

selective, but would only be used in coastal sand dune communities where management of pink sand verbena (an 

annual or short-lived perennial) occurs in western snowy plover habitat restoration areas. (No other Special Status 

plants have been found in these habitat restoration areas.) All treatments would be done between September 15 

and March 15, which is after most of the pink sand verbena has set seed. Sand verbena seed is collected before 

invasive plant treatments and distributed at the site in early spring. So, although mortality of sand verbena plants 

takes place during the treatments, the existing seed bank and additional seeding provides for persistence of sand 

verbena populations. 

In general, seeding and planting would disturb soil and could damage above- and below-ground plant parts. 

Establishment of additional plant cover could also occupy niche space important to Special Status plants or exert 

pressure by competing for space, water, and nutrients that could reduce vigor and reproduction. The decision to 

use competitive seeding or planting within Special Status species’ habitat would weigh the benefits of reducing 

invasive plant cover against the risks of negative effects to Special Status plants.

Biological control agents are tested for host specificity and approved by the U.S. Department of Agriculture (USDA) 

Animal and Plant Health Inspection Service (APHIS), prior to release in the United States. Biocontrols suspected of 

being capable of adversely affecting non-target organisms are not approved for release. In some instances, 

approved biocontrols have attacked closely related non-target plant species; however, none of the invasive plants 

targeted for biocontrol treatments on the Coos Bay District are in the same genus as any documented or suspected 

 55 Allelopathy is a biological phenomenon by which an organism produces one or more biochemicals that influence the 

germination, growth, survival, and reproduction of other organisms.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

94

Special Status plants. All available biological control agents are widespread on the District and noxious weed 

populations in Special Status plant habitats are not abundant enough to support agents. New agents are 

anticipated to be approved by the ODA for gorse and Japanese knotweed; however, no native species in the same 

genus as these noxious weeds occur on the District. Consequently, there would be no effects from the use of 

biological control agents on Special Status plants.

Coos Bay BLM has a limited amount of Special Status plants in habitats that would be suitable for targeted grazing. 

One unique plant community that would benefit is the coastal sand dune habitat. In areas where coastal sand 

dune communities have become overgrown with invasive grasses, targeted cattle grazing would remove primarily 

grasses through consumption and trampling, reducing vigor and reproduction. Regrowth would be treated with 

glyphosate and or imazapyr to further control the grasses, reducing competition for Special Status species or 

creating habitat for reintroduction. Similarly, sheep grazing would affect forbs and grasses, while goats would 

preferentially remove shrubby invasive plants. In areas where existing Special Status plants are already present, 

livestock would be carefully managed with fencing or herding to avoid damaging existing Special Status plants. 

Because targeted grazing would avoid Special Status plant populations or create conditions for Special Status plant 

reintroduction, short-term effects would be negligible and long-term effects would be beneficial.

Prescribed fire is non-selective and has the potential to harm Special Status plant populations if the Special Status 

species is not fire adapted. Following Standard Operating Procedures as well as Fire and Fuels Management Best 

Management Practices described in the Northwestern and Coastal Oregon Resource Management Plan (USDI 

2016d:162-167) minimizes this risk. One of the risks of using prescribed fire is that many invasive plants are 

adapted to fire and can rapidly establish themselves post fire. Prescribed fire would not be used to treat invasive 

plants in or near most Special Status plant sites, unless those Special Status plants are adapted to periodic burning, 

such as Gasquet manzanita. Proposed treatment at Dean Creek would exclude habitat for Henderson’s 

checkermallow. Prescribed fire in plover habitat restoration areas would be followed with seeding pink sand 

verbena seed that was collected prior to treatment or other appropriate native species if necessary.

Under all alternatives, 2,4-D, glyphosate, and dicamba would be available to treat noxious weeds near Special 

Status plant habitat, though dicamba has been used infrequently, some years not being used at all (see Table 2-8, 

Annual Treatment Summary (2012-2016)). Picloram could be used in the Jeffrey pine savannah community where 

no Special Status species are present, but where Canada thistle threatens the native grasslands. The U.S. Forest 

Service Risk Assessment ratings and discussions for susceptible plants (Appendix C, Herbicide Risk Assessment 

Summaries) are assumed to represent Special Status plants. 2,4-D, glyphosate, dicamba, and picloram present a 

high risk of damage to susceptible plants under direct spray scenarios. 2,4-D, glyphosate, and dicamba present no 

risk under surface runoff scenarios. Picloram is high risk in direct runoff scenarios, but is not registered for use in 

areas where Special Status plants occur on the District (e.g., riparian areas, areas with sandy soil, or areas with 

shallow water tables). Hence, there would be no effects to plants from these four herbicides in runoff scenarios. 

2,4-D presents low risk with low boom applications and zero risk with backpack direct foliar application for off-site 

drift scenarios56. Risk of off-site drift from low booms is low for dicamba and moderate for glyphosate at typical 

rates. Risk of off-site drift from backpack direct foliar applications is low for glyphosate at typical rates, but was not 

evaluated for dicamba (although the risk can be reasonably assumed to be lower than for drift from low booms). 

The BLM would use spot treatments on 95 percent (action alternatives) to 100 percent (No Action Alternative) of 

herbicide treatments. However, in Special Status plant habitat, only spot treatments would be used under all 

alternatives. Hence, the overall effects to Special Status plants from drift would be negligible to minor.

 56 Additional information about the 0 (or no), low, moderate, and high risk ratings and how they are derived can be found in 

Appendix C, Herbicide Risk Assessment Summaries.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

95

No Action Alternative

Under the No Action Alternative, only noxious weeds are treated and no other invasive plants would be treated. As 

described in Invasive Plants Issue 1, treatment effectiveness would be approximately 60 percent district-wide for 

noxious weeds and 0 percent for other invasive plants. For some infestations near Special Status plant species, 

effectiveness would be less than 60 percent; for example, treatments of European beachgrass (in the coastal sand 

dune communities and estuarine habitats) and Canada thistle (in most unique plant communities that are 

threatened by invasive plants) are only 10 percent effective. As described below, this could lead to major adverse 

long-term effects on the Special Status plants and these communities, including loss of individual plants, 

degradation of habitat, competition and exclusion of entire populations in areas where invasive plants would 

totally displace Special Status plants. In addition, treating only noxious weeds (and not other invasive plant 

species) results in an increase of invasive plants that are not listed as noxious weeds. The subsequent increase in 

untreated invasive plants reduces the quality of the habitat for Special Status species.

In western snowy plover habitat restoration areas where pink sand verbena populations occur, the entire 172 

acres is retreated biannually to prevent a major adverse effect from regrowth of European beachgrass. Most 

treatments in this area would be mechanical with some hand-pulling and limited treatments with glyphosate on 

the North Spit. Mechanical treatments and reseeding allow persistence of the pink sand verbena; however, plant 

size and seed production have decreased under this regime and persistence depends on seed collection and 

reseeding (Jennie Sperling, Umpqua Field Office Botanist, 2018 personal communication). Closure of the area 

during snowy plover nesting from March 15 to September 15 precludes treatments of noxious weeds (European 

beachgrass, Scotch broom, and field bindweed) during the most effective treatment period, perpetuating the need 

to use mechanical treatments twice a year to control European beachgrass.

Outside of the western snowy plover habitat restoration areas, the BLM would treat noxious weeds in most Special 

Status plant sites by manual techniques. Effects of pulling, digging, and grubbing would be localized and negligible; 

however, manual treatments are more costly and time consuming and repeated treatments are necessary within 

each year.

Canada thistle can be effectively controlled with dicamba or picloram, but these herbicides are not registered for 

use in riparian areas or sandy soil where this species is the most problematic. Hence, major adverse long-term 

effects would occur to unique plant communities (e.g., Dean Creek and New River), as Canada thistle continues to 

spread. Canada thistle cannot be effectively treated using manual techniques and would continue to degrade 

habitat for Henderson’s checkermallow, Oregon bensoniella, and several Special Status coastal sand dune species.

Additionally, the District would treat new invaders (Category III) that are noxious weeds; however, invasive plants 

that are not noxious weeds would not be treated and would also result in long-term adverse effects to Special 

Status plants and their habitat.

Proposed Action

Under the Proposed Action, all invasive plants could be treated and additional herbicides and treatment methods 

are available for use. As described in Invasive Plants Issue 1, treatment effectiveness would be approximately 80 

percent district-wide.

Similar to the No Action Alternative, for some infestations near Special Status plant species, effectiveness would be 

less than 80 percent; for example, treatments of European beachgrass (in the coastal sand dune communities and 

in estuarine habitat) remain only 10 percent effective. As described in the No Action Alternative, the entire 172 

acres in the western snowy plover habitat restoration areas is retreated biannually to prevent a major adverse 

effect from the regrowth of European beachgrass. Outside of western snowy plover habitat restoration areas in 

coastal sand dune communities, imazapyr and glyphosate would be used to control European beachgrass. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

96

Glyphosate alone is less effective on beachgrass; better control is found when glyphosate is tank mixed with 

imazapyr. The tank mix has improved efficacy and fewer adverse effects to the native plant community than using 

imazapyr alone. Imazapyr and glyphosate are both non-selective; however imazapyr has longer soil activity and 

tank mixing the two reduces the rate of each herbicide and thus the risk associated with longer persistence 

(DiTomaso et al. 2013). Other invasive plants have also begun to invade coastal sand dune communities where 

Special Status species occur; including the invasive annual grasses big quakinggrass, ripgut brome, and rat-tail 

fescue, as well as sweet vernal grass (perennial), sheep sorrel, false dandelions, and English plantain.

Manual treatments of invasive annual grasses are effective, but must be done repeatedly as seed germinates 

under favorable conditions, typically multiple times annually on the District. Effective manual treatments are 

difficult to achieve on perennial and deep rooted species because the roots are difficult to remove and these 

plants will often survive manual treatments. In addition, removing these plants manually results in minor to 

moderately adverse effects to adjacent Special Status plants from trampling, soil turnover, and accidental 

uprooting. Treatment of all invasive plants in coastal sand dune communities is necessary for Special Status plants 

to persist and to avoid competition from invasive plants’ major adverse effects on one or more of the Special 

Status plants at these sites. Spot treatments of imazapyr (with or without glyphosate), imazapic, or sulfometuron 

methyl would be used to effectively treat invasive grasses and plantain in open sand dune habitats. Spot 

treatments with herbicides can target invasive plants while avoiding avoid Special Status plants. This results in less 

trampling and soil disturbance than manual or mechanical treatments.

In Coast Range meadows and Jeffrey pine savannahs where Canada thistle threatens Special Status plants and 

native grasslands, aminopyralid, aminopyralid + metsulfuron methyl, or 2,4-D mixed with clopyralid are effective 

treatments for Canada thistle. Wicks or backpack sprayers would be used to apply herbicide directly to target 

plants, and spray shields would be used, which would minimize inadvertent application to Special Status plants. 

These treatments would have negligible to minor effects to Special Status plants and the native grassland in these 

unique plant communities.

Conservation Measures (see Appendix A) specify herbicide buffers for all Special Status species on the District; 

however, as described in Project Design Feature and Figure 3-2, Bureau Sensitive Species Treatment Conditions,

these buffers may be modified if treatments are not expected to harm individual plants, sites, or populations. 

Hence, short term adverse effects from herbicides are expected to be negligible to minor. Table 3-5 shows 

treatment considerations that indicate when buffers would be modified.

Table 3-5. Effects of Herbicides on Native Vegetation and Special Status Plants

Herbicide Considerations

ALS-inhibitors:

chlorsulfuron, 

imazapic, 

imazapyr, 

metsulfuron 

methyl, 

sulfometuron 

methyl

Highly active as both pre- and post-emergents and can injure or kill Special Status plants at low application 

rates. Off-site movement of small concentrations of these herbicides can result in damage to non-target 

plants, even at concentrations lower than those reportedly required to kill target invasive plants (Fletcher et 

al. 1996). Hence, chlorsulfuron, metsulfuron methyl, and sulfometuron methyl would not be a preferred 

treatment method in Special Status plant habitat. Metsulfuron methyl (formulated with or without 

aminopyralid) would not be a preferred treatment for Canada thistle infestations near Special Status plants. 

However, it would be used in Jeffrey pine savannah where Canada thistle threatens native grasslands and 

no Special Status plants are present.

Imazapyr is non-selective and would be a preferred treatment method on European beachgrass and other 

invasive perennial grasses when combined with glyphosate. The mix has improved efficacy and fewer 

adverse effects to the native plant community than using imazapyr alone. Imazapyr and glyphosate are both 

non-selective; however imazapyr has longer soil activity. Tank mixing imazypyr and glyphosate reduces the 

rate of each herbicide and thus the risk associated with longer persistence (DiTomaso et al. 2013). The risk 

to Special Status plants would be further reduced to minor or less by limiting treatment areas, spot 

applications, monitoring treatment effects, and adaptive management.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

97

Herbicide Considerations

Imazapic, a selective herbicide, would be preferred for treating invasive annual grasses in Special Status 

plant habitat. However, the risk to Special Status plants from direct imazapic spray is low at typical 

application rates and moderate at high rates. Imazapic labels indicate that annual dicots may be harmed by 

imazapic (particularly at high rates), but perennial dicots would not. This is consistent with studies that have 

observed tolerance in perennial forbs (e.g., Bahm and Barnes 2011), but more variable responses have 

occurred in annual forbs, depending on rate and site conditions (e.g., Sheley et al. 2007). Many of the 

habitats infested by invasive annual grasses where imazapic would be a preferred treatment are also 

occupied by annual Special Status forbs, such as seaside gilia and coastal cryptantha. Because the effects of 

imazapic on these species are unknown, the BLM would implement protective measures and conduct 

treatments on less than five percent of a Special Status plant population to clarify effects prior to 

operational-scale treatments in these sites. 

Synthetic auxins: 

aminopyralid, 

clopyralid, 

triclopyr

Present a high risk of damage to Special Status plants under direct spray scenarios. For clopyralid and 

triclopyr, the risk of plant damage from off-site drift ranges from low to moderate (depending on rate) for 

low boom applications and zero risk for backpack foliar spraying. Aminopyralid has a low risk from off-site 

drift under all scenarios. Aminopyralid and clopyralid have zero risk of damage from surface runoff, but the 

risk is low to moderate for triclopyr, depending on rate. Aminopyralid is selective for broadleaf forbs and 

would be a preferred treatment for thistle and knapweed. It would be applied with hand-directed spot 

treatments.

Triclopyr would be a preferred treatment for woody invasive plants such as Scotch broom, French broom, 

blackberry, and gorse. These are uncommon in Special Status sites. When using triclopyr within 300 feet of 

Special Status plants (such as on blackberry), all treatments would be hand-directed spot applications so 

that any effect to Special Status plants would be negligible to minor.

Auxin transport 

inhibitor: 

diflufenzopyr

Selective for annual broadleaf plants. It is a weak herbicide by itself, but is formulated with dicamba for use 

on the District, which reduces the amount of dicamba needed.

Weed barrier mats would be used at Dean Creek and Spruce Reach Island Special Management Areas to deprive 

perennial grasses (such as reed canarygrass, sweet vernal grass, orchard grass and tall fescue) and yellow flag iris 

of sunlight. This treatment would be used to prepare sites for seeding and planting native species. This technique 

could be used adjacent to native plants. For example, a tarp or mat could be pinned over vegetation next to 

Henderson’s checkermallow to control invasive grasses or yellow flag iris and there would be no effect to the 

checkermallow. Propane torches would be used to selectively spot treat invasive plants within Special Status plant 

habitat. For example, when invasive annual grasses go to seed within silvery phacelia habitat at Floras Lake in the 

New River ACEC, torches could be used to remove the seed heads and prevent viable seed from being added to the 

site. The heat is directed at the seed heads, approximately 8 to 12 inches above silvery phacelia plants. Because 

the heat would be directed away from the Special Status plants, there would be negligible effects from this 

treatment.

Seeding and planting prescriptions for Special Status plant habitats would use only locally sourced (genetically 

appropriate) native plant materials from species that are typical components of the Special Status species’ habitat, 

and those materials would be planted at rates and patterns that reflect typical relative abundance and distribution 

for that habitat. The adverse effects of seeding and planting would be temporary and minor or negligible with 

positive long-term effects.

Treatment of invasive plants would improve habitat conditions and provide long-term benefits to unique plant 

communities and Special Status plant populations. Treating invasive plants with more selective herbicides would

reduce competition with Special Status plants with less adverse effects on non-target species. However, in the pink 

sand verbena habitat, limited glyphosate use for control of noxious weeds and other invasive plants would result in 

continued reliance on semi-annual mechanical treatments supplemented with manual treatments. Annual invasive 

plants that germinate after March 15 and produce seed before September 15 (the closure season for western 

snowy plover) would continue to survive.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

98

Alternative 3

This alternative allows all treatments under the Proposed Alternative, and adds three additional herbicides that 

may be used in these unique plant communities: fluroxypyr, rimsulfuron, and fluazifop-P-butyl and allows the use 

of other herbicides besides glyphosate in western snowy plover habitat restoration areas.

The effects of fluroxypyr on Special Status plants would be negligible. This herbicide would not be a preferred 

treatment for any invasive plant treatment group and it would be used on less than 4 acres district-wide over the 

life of the plan. Fluroxypyr presents a low risk of damage from off-site drift to susceptible plants and a zero risk of 

damage from surface runoff. Rimsulfuron is highly active on both pre- and post-emergent plants and can injure or 

kill Special Status plants at low application rates. Off-site movement of small concentrations of this herbicide can 

result in damage to non-target plants, even at concentrations lower than those reportedly required to kill target 

invasive plants (Fletcher et al. 1996). Rimsulfuron would be one of the preferred treatments for invasive annual 

grasses in coastal sand dunes and Jeffrey pine savannahs; however, the BLM would not use this herbicide in sites 

that are occupied by Special Status plants unless Protection Measures could be implemented to reduce effects to 

minor or below. Fluazifop-P-butyl inhibits fatty acid synthesis by blocking activity of the ACCase enzyme. The 

ACCase enzyme of many, but not all, grass species is more sensitive than in broadleaf plants, which are tolerant of 

fluazifop-P-butyl. Thus, fluazifop-P-butyl could be used to treat invasive grasses with negligible effects to Special 

Status forbs. The scale of adverse or beneficial effects would be limited because experimental use of this herbicide 

would not exceed 15 acres per Field Office, for a total of 30 acres across the District.

In the plover habitat restoration areas where populations of pink sand verbena exist, the ability to use a chemical 

treatment method that is more selective than discing would reduce the need to rely on semi-annual manual and 

mechanical treatments to control European beachgrass. Although pink sand verbena is often classified as a shortlived perennial, many individuals act as annuals, flowering and dying in their first year of growth. Discing/plowing 

does not allow the longer-lived perennials a chance to overwinter. These short-lived perennial plants, when left 

undisturbed, would have an additional season to grow larger and produce more seed than smaller annual plants. 

Although these effects have been observed, there have not been empirical studies to quantify the amount of 

additional seed that would be produced. The additional seed would increase the seed in the soil which would 

provide both short- and long-term benefits by helping ensure there are viable seeds in the following season as well 

as in future years. This reduction in discing would benefit the existing pink sand verbena population by allowing 

pink sand verbena plants to produce seed later in the fall and preserve the short-term perennials in the 

population, thus providing short- and long-term benefits to the survival and persistence of the pink sand verbena 

populations at these sites.

Other coastal sand dune communities contain a mix of annual and perennial Special Status species and European 

beachgrass has historically been the primary threat to these species. Glyphosate applied in late fall or winter would 

not affect annual plants, but could injure or kill short-lived perennials. Imazapyr has soil activity and could kill 

emerging seedlings or established plants; however, a study done by the Oregon Department of Agriculture found 

that a mix of 1 percent imazapyr and 3.6 percent glyphosate sprayed on soil pots planted with pink sand verbena 

seed did not affect emergence rates compared to those that were not treated (Amsberry et al. 2016). However, in 

this study, above ground or partially buried fruits of pink sand verbena were not sprayed and so the effects on 

germination or survival of unburied seed is unknown. Field documentation of the effects of imazapyr treatment on 

pink sand verbena germination and seedling survival is needed (Amsberry et al. 2016) and additional monitoring 

included with the Proposed Action and Alternative 3 would help to refine these prescriptions by determining 

effective control measures.

As European beachgrass is controlled, other invasive perennial grasses (sweet vernal grass, velvetgrass, and tall 

fescue) and winter annual grasses (big quaking grass, ripgut brome, and rat-tail fescue) increase in abundance. All 

of these species can be controlled with imazapic or rimsulfuron treatments conducted in fall or winter when the 

annual Special Status plant species are dormant and no negative effects to Special Status plants from over-spray 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

99

would occur. (Annual Special Status plants do not germinate until later in the spring or have deep roots protecting 

them.) As described in the Monitoring for the Proposed Action and Alternative 3 section, above, since there is 

uncertainty about the residual effects of rimsulfuron or imazapic in coastal sand dunes, only five percent or less of 

known sites would be treated until monitoring identifies effects.

All other effects remain as described under the Proposed Action. Treatment of invasive plants would improve 

habitat conditions and provide long-term benefits to unique plant communities and Special Status plant 

populations.

Summary of Effects

Table 3-6. Summary of Effects (Native Vegetation Issue 1)

Alternative Direct Effects Indirect Effects

Common to all 

Alternatives

Individual Special Status 

plants could be injured 

or killed by invasive 

plant treatments, but 

adverse effects to 

populations from 

treatments would be 

negligible to minor 

because 

implementation of 

Protection Measures 

(Appendix A) would 

reduce effects to below 

levels that could 

adversely affect 

populations or trend 

species toward listing. 

Annual Treatment Plan 

reviews would provide 

additional opportunities 

to develop site-specific 

treatment prescriptions 

and prescribe 

Protection Measures 

that would further 

reduce adverse effects 

to Special Status plants. 

Treatment would improve habitat conditions and provide long-term benefits to 

unique plant communities and Special Status plant populations.

No Action

In coastal sand dune communities, biannual treatments of European beachgrass 

and seeding and planting prevent major adverse effects to pink sand verbena from 

beachgrass, however no effective treatment for other invasive plants results in 

their populations increasing.

Canada thistle infestations that cannot be effectively treated in estuarine areas, 

coastal sand dunes, Jeffrey pine savannah, and Coast Range meadows could lead to 

the loss of individual plants, degradation of habitat, competition and exclusion of 

entire Special Status species populations.

Proposed 

Action

Treatment of invasive plants would improve habitat conditions and provide longterm benefits to unique plant communities and Special Status plant populations. As 

described in the No Action Alternative, in coastal sand dune communities, annual 

treatments of European beachgrass and seeding and planting prevent major 

adverse effects to pink sand verbena; however, annual invasive plants that 

germinate after March 15 and produce seed before September 15 (the closure 

season for western snowy plover) would continue to survive.

Effective treatments of Canada thistle infestations would reduce adverse effects to 

unique plant communities and Special Status plant populations to negligible.

Alternative 3

Treatment of invasive plants would improve habitat conditions and provide longterm benefits to unique plant communities and Special Status plant populations. In 

western snowy plover habitat restoration areas, European beachgrass treatments 

using discing and bulldozers would occur less frequently, allowing pink sand 

verbena to remain undisturbed and have an additional season to grow larger and 

produce more seed.

Other effects would remain as described under the Proposed Action/Common to 

all Alternatives

Cumulative Effects

On BLM-managed land, when any habitat-disturbing projects are proposed, the BLM reviews projects and surveys

all potential habitat for Special Status plants and incorporate Protection Measures to ensure that projects would 

not adversely affect populations. Similar to invasive plant management, in the short term, restoration project 

activities could damage or kill a few plants, but the overall long-term effects would be beneficial because of habitat 

improvements.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

100

Off of BLM-managed land, other Federal, state, and local agencies and organizations have invasive plant 

management programs that, when combined with the effects of Coos Bay BLM’s actions under each alternative, 

would have cumulative benefits to the unique plant communities that host Special Status plants. The magnitude of 

these benefits would be greater under the Proposed Action and greatest under Alternative 3 (compared to the No 

Action Alternative) where more acres can be effectively treated and BLM has more available tools to use for 

treatment.

For example, the BLM works with Oregon State Parks to treat biddy-biddy at Cape Blanco State Park and the 

adjacent BLM-managed Cape Blanco lighthouse. In addition to controlling noxious weeds, these treatments 

protect large-flowered goldfields (Lasthenia ornduffii) that occurs in the state park. Oregon State Parks manages 

land bordering the New River ACEC where both agencies are controlling gorse; however, the dense infestation on 

the state-managed side continues to threaten unique habitats and five Special Status plants in the coastal sand 

dune community at the New River ACEC.

The Oregon Department of Agriculture Noxious Weed Control Program coordinates, releases, and monitors 

populations of traditional biological control agents used to help control noxious weeds. Several of the noxious 

weeds targeted are also species present in the unique plant communities where Special Status plants are 

threatened by invasive plants and include Canada thistle, French broom, gorse, purple loosestrife, and Scotch 

broom. In addition, Coos Bay BLM and ODA have worked together to control new invaders such as matgrass; one 

site was eradicated at the New River ACEC where several Special Status plants could be adversely affected if this 

invasive plant species were to spread.

Known populations of pink sand verbena are actively managed on Federal and state lands in Oregon and California,

including adjacent lands on the Siuslaw National Forest and lands managed by the U.S. Army Corps of Engineers 

and Oregon Parks and Recreation Department. Manual, mechanical, and herbicide treatments to control European 

beachgrass and other invasive plants improve habitat conditions for pink sand verbena. While agencies seek to 

maintain and foster surviving wild populations, new populations have increased known populations from 6 to 23. 

In 1999, the North Spit habitat restoration area was seeded with 50,000 pink sand verbena seeds following 

mechanical treatments to control European beachgrass (USDI et al. 2006) and since then, the population has 

become well established and grown steadily in size. Currently, the North Spit population is the largest in Oregon

and the seed source for augmentations and reintroductions at other sites. Ongoing activities to improve pink sand 

verbena habitat and populations across its range add cumulative long-term positive effects for pink sand verbena 

populations, as agencies share information about the effects of treatments, so that other land managers can 

capitalize on lessons learned and improve treatments to benefit populations.

When combined with the overall beneficial effects of invasive plant management across the Coos Bay District, 

projects on adjacent lands would not contribute to adverse cumulative effects and, instead, are anticipated to 

cumulatively maintain or improve population viability of Special Status plants.

Native Vegetation Issue 2 (Not Analyzed in Detail)

How would invasive plant treatments, especially herbicides, affect Special Status and edible fungi?

This issue is not analyzed in detail because there would be no potential for significant effects beyond those already 

analyzed in the Oregon FEIS, to which this analysis is tiered. This was previously described in the Oregon FEIS (USDI 

2010a:145) and there are no new circumstances or information at the site-specific level that would change the 

effects anticipated for this EA.

There are 11 species of Special Status fungi that are documented or suspected of occurring on the Coos Bay 

District. All of these were former Survey and Manage species suspected to primarily occur in late successional 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

101

forest habitat (see Table 3-7). Almost all the edible fungi found on District occur in forested habitats. This includes 

common edibles such as chanterelles, hedgehogs, oysters, king boletes, and matsutakes.

Table 3-7. Special Status Fungi Known or Suspected to Occur on Coos Bay BLM

Special Status Fungus Documented or 

Suspected Habitat

Albatrellus avellaneus Suspected

Ectomycorrhizal. Found under conifers, primarily associated with large western 

hemlock/Douglas fir and spruce. Occurs principally in coastal Sitka spruce, 

Western hemlock and in Pacific silver fir old growth forest. 

Chamonixia caespitosa Suspected

Ectomycorrhizal. It has been found in association with the roots of hemlock 

species and Pacific silver fir in high elevation forests and western hemlock, 

Douglas-fir and, Sitka spruce in coastal forests.

Cortinarius barlowensis Suspected

Ectomycorrhizal. Populations have been located in Pacific silver fir (46%), 

western hemlock (27%), mountain hemlock (15%), and Sitka spruce (12%) plant 

associations.

Cortinarius pavelekii Suspected

Ectomycorrhizal. Endemic to mature old growth coastal forests or forests with 

an old growth legacy of coarse woody debris, usually mossy places, from sea 

level (17 ft.) to around 588 ft. in Oregon.

Dermocybe 

humboldtensis Suspected Ectomycorrhizal. Occurs in White Fir-Grand Fir vegetation zones at elevations of 1,337-1,781 ft. Associated species include Douglas fir and ponderosa pine.

Gastrolactarius 

camphoratus Documented

Ectomycorrhizal. Occurs principally in soil and litter in western hemlock, tan oak, 

live oak, sugar pine, Douglas fir, Pacific madrone, California black oak, Port 

Orford cedar and Sitka spruce series at elevations of 3-3,385 (1,847) ft. of 

primarily moist forest types.

Phaeocollybia 

californica Documented Ectomycorrhizal. Associated with the roots of Pacific silver fir, Sitka spruce, Douglas-fir, and western hemlock with huckleberry. 

Phaeocollybia gregaria Suspected Ectomycorrhizal. Associated with the roots of western hemlock, Sitka spruce and 

Douglas-fir in coastal rainforests.

Phaeocollybia 

oregonensis Documented Ectomycorrhizal. Associated with the roots of pacific silver fir, noble fir, Douglasfir, and western hemlock. 

Ramaria rubella var. 

blanda Documented Ectomycorrhizal. Associated with western hemlock rainforest.

Rhizopogon exiguus Suspected

Ectomycorrhizal. Documented in the Douglas-fir series/wet Douglas-fir habitat 

association, white fir/grand fir series/moist white fir/grand fir habitat 

association, western red cedar series/wet western red cedar association, and 

western hemlock series/western hemlock wetlands.

As described in the Oregon FEIS, the risk of herbicide contamination on wild edible mushrooms is expected to be 

limited because proposed invasive plant management would be focused primarily on invasive plant infestations 

which are currently located in non-forest habitats and rights-of-way (primarily roads), rather than healthy forests 

where edible species are dependent on the roots (ectomycorrhizae) of conifer trees (USDI 2010a:145).

The type of actions and the amount of treatments under all alternatives would be consistent with the actions

analyzed in the 2010 Oregon FEIS and the 2016 PEIS. All Standard Operating Procedures and Mitigation Measures 

analyzed in those documents would be applied to all alternatives. The wet forests (western hemlock, Sitka spruce) 

and westside moist forest (white/grand fir, tanoak) that are the majority of the forested habitat on Coos Bay BLMmanaged lands have a low susceptibility to invasion by invasive plants because the cover type is too shady for most 

invasive plant species. Hence, it is unlikely that invasive plant treatments would have any negative effects under 

any of the alternatives to Special Status or edible fungi. In addition, invasive plant treatments are typically 

completed during the drier months of the year, from late spring through summer. Most fungi on the Coos Bay 

District come up after the rains begin later in the fall and are done fruiting by early winter, so the edible mushroom 

picking season and the invasive plant treatment windows do not generally overlap. Invasive plant treatments in 

forest habitat would be primarily accomplished along rights-of-way through the forest habitat where spot spraying 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Native Vegetation

102

would target invasive plants, leaving the nearby vegetation unharmed. Due to the lack of potential for adverse 

effects, this issue was not analyzed in detail.

Native Vegetation Issue 3 (Not Analyzed in Detail)

Even though herbicides would not be used for timber production, would more effective invasive plant 

treatments indirectly decrease or increase timber harvest volume or quality?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

(USDI 2010a:280) to which this analysis is tiered and there are no new circumstances or information at the sitespecific level that would change the effects anticipated for this EA.

The Oregon FEIS showed that it is likely that the effects of invasive plant treatments on timberlands themselves, 

whether accomplished with herbicide or non-herbicide methods, are expected to be negligible. If there are effects 

to timber production, they would likely be positive as invasive plants competing with desirable conifers are 

removed (USDI 2010a:280). Treatments on invasive plants are generally focused on specific plants, and collateral 

damage to crop trees is rare (USDI 2010a:280). Invasive plants such as Scotch broom are more efficient than native 

plants at populating recently harvested sites and being competitive with desired conifers. While this results in 

decreased growth, the effects are gradual; current silvicultural methods are already dealing with some level of 

invasive plants. Yield predictions are based in part on the performance of existing stands, and quantifying the 

growth loss from the current or future percentage of invasive plants has not been done (USDI 2010a:281). Though 

the Oregon FEIS did not discuss the effects of aminopyralid, fluroxypyr, or rimsulfuron, the analysis would lead to 

the same conclusions since these herbicides are not ones that the BLM is likely to use on timber sale units in 

forests and woodlands. The primary targets in timber sale units are gorse and brooms that are most effectively 

treated with triclopyr. Other invasive plant species documented in timber sale areas include blackberries, Canada 

thistle, jubata grass, false brome, knotweeds, pampas grass, old man’s beard, biddy-biddy, ivy, and fennel, though 

infestations are less than 1/10th acre per site and would be treated with spot applications.

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2007 and 2016 PEISs. All Standard Operating Procedures and Mitigation 

Measures analyzed in those documents would be applied to all alternatives.

There are approximately 304,000 acres of forest land on the Coos Bay District (or 93 percent of the District). In 

2016, just under 1,700 acres was partial cut or regeneration harvested (USDI 2017b). Invasive plant treatments 

could occur in recently harvested timber sale units because any area is susceptible to invasion, and because site 

disturbances and increased sunlight to the ground increase the likelihood of infestation. Under all alternatives, the 

BLM would treat approximately 1,000 gross acres a year throughout the District. Treatments on average may 

account for 50 gross acres or less of treatments annually in timber sale units, primarily along roadsides to treat 

infestations before they spread. These treatments are estimated to be 80 percent effective under the Proposed 

Action and Alternative 3 and 60 percent effective under the No Action Alternative, which means that there are 

potentially 40 additional acres annually of improved forest land under the Proposed Action and Alternative 3, 

depending on the species treated. However, treatments are generally small (71 percent of known invasive plant 

sites are smaller than 0.5 acres; see Table 2-2, Summary of Invasive Plants Documented in NISIMS by Infestation 

Size), and these areas would be scattered across the District. BLM would not use herbicides for the production of 

timber.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Fish and Aquatic Organisms

103

Fish and Aquatic Organisms

Fish and Aquatic Organisms Issue 1 (Not Analyzed in Detail)

How would invasive plant treatments in riparian areas affect aquatic organisms or their habitat, 

including riparian vegetation?

This issue was not analyzed in detail because effects are unlikely to differ between the alternatives and because 

effects are expected to be negligible. In addition, effects of herbicides were described in the three NEPA analyses 

to which this EA tiers; the 2007 and 2016 PEISs (done at the national level) and the 2010 Oregon FEIS (USDI 

2010a:208-240, USDI 2007a:4-36 to 4-4-96, USDI 2016a:4-41 to 4-51). The nature of the disturbance associated 

with invasive plant treatments would have little potential to cause measurable effects to fish and other aquatic 

organisms and their habitat on the Coos Bay District. In addition, if there are site conditions in which adverse 

effects may result, the BLM would apply Protection Measures that minimize the potential for effects; for example, 

the risk of adverse effects is further minimized as a result of Project Design Features adopted for the Proposed 

Action and Alternative 3.

There are 17 Special Status aquatic species on the District, including four documented federally listed species: the 

Green Sturgeon, two populations segments of Coho Salmon, and the Pacific Euchalon (see Table 3-8).

Table 3-8. Aquatic Special Status Species within the Coos Bay District

Common Name Scientific Name Category Taxon

Green Sturgeon (Southern DPS1) Acipenser medirostris Threatened Anadromous Fish

Coho Salmon (Southern Oregon 

Northern California Coast ESU2) Oncorhynchus kisutch Threatened Anadromous Fish

Coho Salmon (Oregon Coast ESU) Oncorhynchus kisutch Threatened Anadromous Fish

Pacific Eulachon Thaleichthys pacificus Threatened Anadromous Fish

Pacific lamprey Entosphenus tridentatus Sensitive Anadromous Fish

Chum salmon Oncorhynchus keta Sensitive Anadromous Fish

Steelhead (Klamath Mountain Province 

Steelhead/Oregon Coast DPSs) Oncorhynchus mykiss Sensitive Anadromous Fish

Chinook salmon (Southern Oregon 

Northern California Coast ESU) Oncorhynchus tshawytscha Sensitive Anadromous Fish

Millicoma Dace Rhinichthys cataractae Sensitive Non-anadromous Fish

Western ridged mussel Gonidea angulata Sensitive Class Bivalvia (clams, oysters, and 

mussels)

Rotund lanx Lanx subrotunda Sensitive

Class Gastropoda (snails and 

slugs)

Robust walker Pomatiopsis binneyi Sensitive

Pacific walker Pomatiopsis californica Sensitive

Newcomb’s littorine snail Littorina subrotundata Sensitive

Caddisfly Rhyacophila chandleri Sensitive Order Trichoptera (caddisflies and 

Haddock’s caddisfly Rhyacophila haddocki Sensitive water moths)

1. Distinct population segment 2. Evolutionarily significant unit

Given the large geographic area covered by the District, and the many miles of streams contained within, there 

exists a wide range of aquatic habitat conditions, from relatively pristine to highly degraded. In general, due to the 

locations of larger urban and industrialized areas, the large fish-bearing streams and mainstem rivers have been 

the most altered by non-natural disturbances and are the portion of the aquatic ecosystem most likely to be 

impacted by chemicals, including herbicides. The smaller streams located further up in the analysis area generally 

have steeper gradients, are located in narrower valleys, and have been much less impacted by urban and 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Fish and Aquatic Organisms

104

agricultural development. Timber management (past and ongoing) is the dominant land use in most of these areas. 

The majority of the Coos Bay District lands include these types of smaller streams.

Riparian Reserves on the Coos Bay District range in width from 50 feet on either side of the stream up to a full site 

potential tree height, depending on the particular class of sub-watershed and if the stream is fish bearing, 

perennial, or intermittent, as described in the Northwestern and Coastal Oregon Record of Decision and Resource 

Management Plan (USDI 2016a). The majority of the Riparian Reserves on the Coos Bay District are a full site 

potential tree height, which ranges from 140 to 240 feet. There are approximately 85,381 acres of Riparian 

Reserves on BLM-managed lands within the Coos Bay District. The majority of Riparian Reserves adjacent to large 

fish bearing streams are paralleled by roads and have had some past disturbances within them, including but not 

limited to timber harvests, stream cleaning, and splash damming. Roads are a known route of dispersal for invasive 

plants, so it stands to reason that watersheds with higher road densities would have a higher likelihood of 

infestations by invasive plants. Infestations by invasive plants are a common problem in disturbed areas, and in 

some cases, this has reduced riparian function.

Treatments targeting invasive plants in Riparian Reserves would not result in any negative effects to the health and 

function of the Riparian Reserves or fish habitat. Under the Proposed Action and Alternative 3, 95 percent of 

herbicide treatments on the Coos Bay District would be spot treatments to target specific plants, so that effects to 

non-target species can be kept to a minimum. Protection Measures would limit the potential for terrestrial 

applications of herbicides or sediment from areas of bare soil from entering the water directly. The magnitude of 

sediment potentially contributed to aquatic habitat in any given stream from treatments would be very small and 

undetectable in aquatic habitat. Any sediment would occur during the first freshet (elevated stream flow caused 

by heavy rain) following treatments, and would quickly dissipate downstream as a small turbidity pulse which 

would be undetectable in relation to the background levels expected to occur during a freshet. None of the 

proposed treatments would target large overstory trees, so shade and sources of future large woody debris inputs 

would be maintained in treatment areas. In streamside areas where no native vegetation exists, there could be a 

loss of cover associated with treatments, for example if a blackberry thicket around a small narrow stream was 

removed. Where this occurs, bare areas would be replanted with native shrubs, hardwoods, or conifers or seeded 

with native grasses so that increased sediment input into streams would be avoided or minimized.

Applications of herbicides to terrestrial invasive plants are unlikely to adversely affect aquatic organisms. Several 

Protection Measures would limit the potential for terrestrial applications of herbicides from entering the water 

directly. As further described in Water Issue 1, indirect contributions of herbicide to aquatic habitat from runoff or 

leaching has the potential to occur but is unlikely due to Protection Measures and depth to groundwater on the 

District.

Of the additional herbicides proposed to treat vegetation, only aminopyralid and aquatic formulations of imazapyr 

and triclopyr would be spot sprayed up to the water line of aquatic habitats. Risk Assessments prepared for 

aminopyralid and aquatic imazapyr showed no risk to any tested aquatic organisms under any of the tested 

application rates and delivery scenarios as shown in Appendix C, Herbicide Risk Assessment Summaries. Based on 

the toxicity data reviewed for the Risk Assessment, aminopyralid exposure to fish and aquatic invertebrates did not 

result in any observable mortality or sub-lethal effects and would not likely accumulate in fish tissue (USDI 

2016a:4-45). Aquatic formulations of triclopyr were found to have only a low risk for susceptible fish, amphibians, 

and susceptible insects at maximum application rates under the accidental spill scenario, with no risks under any 

other scenarios (see Appendix C). The Treatment Key (Table 2-10) specifies triclopyr would only be used at or

above typical rates, but below maximum application rates.

Improvements to fish habitat and Riparian Reserves from treatments would only be achieved in dispersed areas 

across the District in any given year. Most treatment areas would be small and benefits accrued by these 

treatments would only be measurable at local levels. In the long term (one year to decades, depending on the 

riparian area and length of time required for native vegetation to become re-established), treating invasive plants 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Fish and Aquatic Organisms

105

in riparian areas would have a beneficial effect to Riparian Reserves as it would allow for the establishment of 

native vegetation in previously infested areas. Depending on the site, this could be a conversion from a blackberry 

thicket to a wooded riparian corridor, which would (at the site level) yield positive benefits to riparian and aquatic 

habitats through increased shade, cover, nutrient inputs, bank stability, and source of future wood recruitment to 

stream channels. The 2010 Oregon FEIS states:

“In riparian areas, invasive plants (e.g. Himalayan blackberries, Japanese knotweed [...]) often support 

fewer native insects than native plant species, which could affect food availability for insectivorous fish 

species, such as salmonids. The replacement of native riparian plant species with invasive plants may 

adversely affect stream morphology (including shading and instream habitat characteristics), bank 

erosion, and flow levels. Invasive plants break down the complex natural vegetative physical structure and 

interfere with natural processes” (USDI 2010a:230).

The removal of European beachgrass by mechanical methods at New River occurs adjacent to fish habitat. Prior to 

the 2009 New River Foredune Management EA, the BLM did not leave foredune buffers and an excessive amount 

of sand entered New River from wave overwash and wind. This increased amount of sand caused a decline in fish 

habitat in New River as the channel filled with sand. This impact was alleviated when foredune buffers from the 

2009 EA were implemented. Because of the foredune buffers designed in the New River Foredune Management 

EA (USDI 2009a), the creation of bare sand associated with invasive plant removal would not result in changes to 

fish habitat in New River.

The following Project Design Features included with the Proposed Action and Alternative 3 further minimize the 

potential for effects to fish and other aquatic species:

Project Design Features for the Proposed Action and Alternative 3

• Apply the aquatic no-herbicide application buffers specified in the Aquatic Restoration Biological Opinion 

II (NMFS 2013) from the National Marine Fisheries Service to all waterbodies with known or suitable 

habitat for Bureau Sensitive or Strategic fish and other aquatic species (see Appendix A).

Project Design Features for Alternative 3

• All applicable Project Design Criteria identified in potential future consultations with the National Marine 

Fisheries Service will be incorporated into all treatments in listed anadromous fish habitat.

• The use of fluazifop-P-butyl will be confined to flat dry ground located greater than 1,500 feet from any 

aquatic features to prevent runoff to surface water or leaching to groundwater.

• Use only ARBO II (NMFS 2013) approved herbicides, adjuvants, and buffer distances in the New River 

western snowy plover habitat restoration areas (see Appendix A).

Wildlife

Wildlife Issue 1

How would mechanical and herbicide treatment methods affect the western snowy plover?

Analytical Methods

The analysis area includes 453 acres of designated western snowy plover critical habitat on the Coos Bay District in 

the New River Area of Environmental of Concern and the North Spit (see Figure 2-2, Western Snowy Plover Habitat 

Restoration Areas (North Spit and New River) in Chapter 2), of which 172 acres is included in habitat restoration 

areas and is treated to control European beachgrass. For the purpose of this analysis, short-term effects are 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

106

defined as those taking place during the invasive plant treatment. Long-term effects are those greater than a day 

or less than a year. Effects to western snowy plovers could be both short term and long term.

Numerical projections of treatment efficacy vary across the three alternatives and are based on the methodology 

and assumptions in the 2010 Oregon FEIS (USDI 2010a:135-139, 594-603). District-wide, treatments under the 

Proposed Action and Alternative 3 are expected to be 80 percent effective and treatments under the No Action 

Alternative are expected to be 60 percent effective on invasive plants. However, as described in Invasive Plant

Issue 1, current treatments of European beachgrass are only 10 percent effective. In addition, noxious weed 

populations are estimated to spread 10 percent a year, damaging native plant communities and wildlife habitat 

and inhibiting ecosystem functions associated with those communities.

Herbicide Risk Assessments, done with the 2007 and 2016 PEISs are the basis for the effects discussion of herbicide 

use. Additional information about the effects of specific herbicides to birds, including the western snowy plover, 

can be found in Table 3-11, Effects of Herbicides (Wildlife), in Wildlife Issue 3.

Prescribed fire would be used under all alternatives, either for habitat restoration (No Action Alternative) or as an 

invasive plant treatment method (under the action alternatives). Manual treatment methods would remain the 

same between the alternatives. There would be no measurable difference in the effects between the alternatives 

for the use of prescribed fire or manual methods. Thus, these treatment methods are not analyzed in detail.

Affected Environment

Western snowy plover habitat located in New River Area of Critical Environment of Concern and on the Coos Bay 

North Spit is 80 percent covered by European beachgrass. Prior to the introduction of European beachgrass in the 

1930s to stabilize open sand near roads and campgrounds, the dunes and beach were largely open sand, pocketed 

by native plants such as American dunegrass (Leymus mollis), and yellow sand verbena (Abronia latifolia) (Pickart 

2008). Species that lived in these open sand conditions evolved with a high degree of disturbance from wind and 

tides. The establishment of European beachgrass dramatically altered the original biota by outcompeting native 

vegetation and stabilizing foredunes (ODFW 2016). While European beachgrass is the primary threat, other 

invasive plants that are present in New River and the North Spit include Scotch broom, field bindweed, sea-rocket, 

false dandelions, wild radish, annual grasses, and sheep sorrel.

On March 5, 1993, the western snowy plover was listed as threatened under the Endangered Species Act (USDI 

2007g). Critical habitat was designated in 1995 and updated in 2004. The Coos Bay BLM began management of 

European beachgrass in the 1990s, and continues to target beachgrass removal along with other snowy plover 

habitat improvements. Currently, 172 acres out of 453 acres of designated critical habitat on BLM are habitat 

restoration areas that function as nesting habitat. (See Figure 2-2, Western Snowy Plover Habitat Restoration Areas 

(North Spit and New River) in Chapter 2.)

Western snowy plover numbers have steadily increased on District since their listing date. A combination of 

actions including habitat work, predator control, public education, roping and signing habitat, and invasive plant 

removal have led the numbers to increase in Oregon from 33 in 1993, to 518 in 2016 (Lauten et al. 2015).

Treatments Planned Related to the Issue

Under the No Action Alternative, treatment proposed for western snowy plover habitat would be restricted to 

mechanical, and hand pulling of noxious weeds, with the exception of 24 acres on the North Spit of Coos Bay, 

where spot treatments of glyphosate would be used. No herbicides would be allowed at New River Area of Critical 

Environmental. Here up to 100 acres of bulldozing would take place annually. On the North Spit of Coos Bay, up to 

72 acres of tractor, disc, and bulldozers work would be conducted annually, along with the use of glyphosate on 24 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

107

acres. Prescribed fire has also been used in snowy plover habitat, as habitat restoration and not as part of the 

invasive plant program. European beachgrass stabilizing the foredunes would not be treated, with the exception of 

plover access cuts. Standard Operating Procedures and Mitigating Measures identified in the in three NEPA 

analyses to which this EA tiers - the 2007 and 2016 PEISs (done at the national level) and the 2010 Oregon FEIS 

(USDI 2010a:241-257, USDI 2007a:4-96 to 4-113, USDI 2016a:4-51 to 4-64) - would be implemented.

Under the Proposed Action, western snowy plover habitat would be treated the same as the No Action Alternative, 

with some additional treatment of invasive plants on land adjacent to western snowy plover critical habitat. 

Prescribed fire would be done as part of the invasive plant program. Under this alternative, the additional 

herbicide use on non-critical habitat would allow BLM greater flexibility in designing treatment projects.

Under Alternative 3, additional herbicides would be available to treat invasive plants in western snowy plover 

habitat. The preferred treatment method for European beachgrass would be a combination of imazapyr and 

glyphosate. As imazapyr and glyphosate are both non-selective, they would be applied as spot treatments. 

Mechanical treatment would take place every 2 to 3 years to remove thick clumps of beachgrass and to contour 

the habitat. A total of 172 acres of western snowy plover habitat would be treated. There are approximately 25 

acres of invasive plants (3 acres of noxious weeds) in western snowy plover habitat restoration areas other than 

European beachgrass and additional herbicides could be used on these invasive plants. Similar to the No Action 

Alternative and the Proposed Action, prescribed fire would be used. All Standard Operating Procedures and 

Mitigating Measures identified in the in three NEPA analyses to which this EA tiers; the 2007 and 2016 PEISs (done 

at the national level) and the 2010 Oregon FEIS (USDI 2010a:241-257, USDI 2007a:4-96 to 4-113, USDI 2016a:4-51 

to 4-64) would be implemented.

Protection Measures

Standard Operating Procedures and Mitigation Measures Relevant to Effects

There are numerous Conservation Measures adopted with U.S. Fish and Wildlife Service consultation on the 2007 

and 2016 PEISs that protect federally listed sand nesting birds such as the snowy plover. These are listed in full in 

Appendix A. Some of the ones most relevant to the issue include:

● Do not treat vegetation in nesting areas during the breeding season (as determined by a qualified 

biologist).

● Do not use 2,4-D in western snowy plover, piping plover, or interior least tern57 habitats; do not broadcast 

spray 2,4-D within 1⁄4 mile of western snowy plover, piping plover, or interior least tern habitat.

● Where feasible, avoid use of the following herbicides58 in western snowy plover and piping plover habitat: 

clopyralid, glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr.

● If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to western snowy plover, piping 

plover, or interior least tern habitat, apply at the typical, rather than the maximum, application rate.

● If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in western 

snowy plover, piping plover, or interior least tern habitat, utilize the typical, rather than the maximum, 

application rate.

 57 Piping plover and interior least tern do not occur on the District. (Conservation Measures were adopted at the national level

with the 2007 and 2016 PEISs.) 

58 This Conservation Measure was adopted as part of consultation on the 2007 PEIS, which used Risk Assessments prepared in 

2003 (glyphosate) and 2004 (imazapyr). These 2003 and 2004 Risk Assessments indicated that there was a low or moderate risk 

to small birds from eating contaminated insects. These Risk Assessments were updated in 2011, which indicates that aquatic 

formulations of imazapyr have 0 risk to any fish or wildlife species (SERA 2011b) and aquatic glyphosate has a 0 risk to birds 

under every scenario (SERA 2011a).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

108

In addition, the New River Foredune Management EA specifies the following protection measures at New River:

● Manual and mechanical treatments would occur between September 16th and March 14th, which is 

outside of the plover nesting season.

● Mechanical treatments would include the use of a bulldozer. The bulldozer would be used to treat the 

beachgrass layer only and not cut the established elevation down in the open sand area any further then 

necessary to remove European beachgrass.

Project Design Features for Alternative 3

The following Project Design Features would further reduce effects on western snowy plover under Alternative 3:

● Do not use dicamba, triclopyr, or fluazifop-P-butyl (herbicides with a low or moderate risk to birds) in 

areas that are currently capable of supporting western snowy plovers. (Dicamba in formulation with 

diflufenzopyr has no risk to birds and can be used in these areas.)

● Implement all current (see Appendix A) and future reasonable and prudent measures and terms and 

conditions identified by the U.S. Fish and Wildlife Service through consultation on western snowy plovers.

Environmental Consequences

Direct and Indirect Effects

Common to All Alternatives

Treating European beachgrass would have beneficial effects to the western snowy plover and plover habitat. These 

effects would vary by alternative. The potential for western snowy plovers to be disturbed by invasive plant 

treatments also varies by alternative. All treatments would be conducted during the non-nesting season, when 

birds are mobile and move away from disturbances. Mechanical treatment is a slow process, allowing for time for 

birds to flush away from equipment, but then return to the site once the equipment is gone. The potential for 

direct exposure from herbicides is negligible, as all herbicide application would be done by spot spraying, in which 

the specific invasive plant is treated. Conservation Measures and other Protection Measures adopted as part of 

consultation with the U.S. Fish and Wildlife Service further protect the western snowy plover from any adverse 

effects that may occur because of invasive plant treatments.

No Action Alternative

Under the No Action Alternative, 85 percent of the western snowy plover habitat would be maintained by 

mechanical methods using heavy equipment (bulldozers and tractors) with 1 acre per year of non-mechanical 

treatments in the plover access cuts. Beachgrass control with heavy equipment is temporary, as the grass 

immediately starts to resprout after the disturbance. Since treatments of European beachgrass have only been 

about 10 percent effective and the beachgrass spreads at approximately 10 percent a year, retreating the entire 

area annually is necessary. An estimated 172 acres would be treated using heavy equipment on the North Spit and 

New River Area of Critical Environmental Concern each year. These treatments would cause long-term effects to 

snowy plovers; birds flush from the treatment area until the operation is complete, which is estimated to be six 

weeks annually. This would not occur during nesting season; during non-nesting season, plovers use these areas to 

shelter and rest from storms.

On the North Spit, there would be some additional short-term disturbance associated with spot spraying up to 24 

acres of glyphosate on new European beachgrass shoots that appear after mechanical treatment. The Risk 

Assessments (Appendix C) indicate that at the maximum application rate (7 lbs./acre), glyphosate has a low risk to 

a small bird associated with the consumption of contaminated insects, and no risk at the typical rate (2 lbs./acre). 

However, there is no risk at the maximum application rate when aquatic formulations of glyphosate are used. The 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

109

BLM would treat beachgrass at 3 lbs./acre with the aquatic formulation; therefore, there is a no risk of adverse 

effects to snowy plovers from herbicide treatments (see Table 3-11, Effects of Herbicides (Wildlife)).

The reliance on mechanized equipment and limited herbicide use would make progress towards meeting 

treatment goals of improved western snowy plover habitat; however, this alternative would be the most expensive 

method (see Implementation Costs Issue 1) with the greatest amount of disturbance to the western snowy plover. 

The literature suggests that the effectiveness of glyphosate on European beachgrass is marginal because it has no 

soil activity59 (DiTomaso et al. 2013:31). In addition, under this alternative, invasive plants that are not listed as 

noxious weeds that negatively affect western snowy plover habitat would not be treated. Species such as 

American/European sea-rocket currently occupy approximately 10 percent of the area. If left untreated, they 

would continue to expand, further degrading plover habitat.

Proposed Action

The Proposed Action treatments would be the same as under the No Action Alternative and effects would be 

similar. There would be no additional use of herbicides in western snowy plover habitat restoration areas than 

what is described in the No Action Alternative. However, there would be a greater variety of treatments methods 

used outside of, but adjacent to, habitat restoration areas. This would lead to a reduction of seed source on 

adjacent land, and reduction of other invasive plants spreading into western snowy plover habitat. Invasive plants 

would continue to degrade plover habitat and make it less suitable to meet snowy plover life requirements (e.g. 

sparsely vegetated, flat, open sandy beaches).

Alternative 3

Alternative 3 would allow the District to treat all invasive plants using a more targeted, integrated, and effective 

management approach, resulting in a greater magnitude of beneficial effects to the western snowy plover and its 

habitat. This alternative would best meet the goals of treating invasive plants to maintain western snowy plover 

habitat. It is anticipated that treatments would be 80 percent effective under this alternative, which is anticipated 

to result in a 75 percent reduction in heavy equipment use, and hence less re-entry and disturbance. It is 

estimated that the frequency of treatment with bulldozers or tractors with discs and plows would be reduced to 

once every two years (a total of three weeks of disturbance). Herbicides would provide the most effective, least 

expensive (see Implementation Costs Issue 1), and least disturbing method for restoring suitable habitat.

The Oregon FEIS concluded the likelihood of significant adverse effects to wildlife from contact with the herbicides 

analyzed in that document was negligible at the population scale. The herbicides are formulated to affect plants 

and have been selected to have some of the lowest (or no) demonstrable wildlife toxicity of EPA-registered 

herbicides, do not bioaccumulate, and are quickly degraded in wildland settings (USDI 2010a:245, Wildlife Issue 3). 

An occasional individual could be exposed to doses above the level of concern, but risks would not be expected to 

be significant at the population level (USDI 2010a:245). Imazapyr and glyphosate would be the most widely used in 

the western snowy plover habitat restoration areas. The terrestrial formulation of glyphosate has low risk to small 

birds under the maximum application rate, but the BLM would not use the terrestrial formulation of glyphosate in 

western snowy plover habitat restoration areas and the District does not plan to treat European beachgrass at the 

maximum rate. The risk of imazapyr is lower than glyphosate; imazapyr has no risk at any application rate under 

any wildlife scenario and the EPA classifies it as practically non-toxic to birds. While imazapyr and glyphosate 

would be the most commonly used in these areas to treat European beachgrass, other herbicides may occasionally 

be used in western snowy plover habitat. However, a Project Design Feature included with Alternative 3 prohibits 

the use of herbicides with any risk to birds. Therefore, there is no risk of adverse effects to snowy plovers from 

herbicide treatments (see Table 3-11, Effects of Herbicides (Wildlife)).

 59 Glyphosate binds to soil particles and is rapidly degraded by microbes, making it inactive in soil. See Soil Issues 2 and 3. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

110

Zarnetske et al. (2010) suggest that use of herbicides instead of mechanical treatments allows for a more holistic 

dune community approach, maintaining native plants while producing suitable plover habitat. This alternative 

would have the least disturbance effects to western snowy plover, since long-term disturbance associated with 

mechanical treatment would decrease in frequency (once every other year, instead of twice a year). This 

alternative would require Endangered Species Act consultation with U.S. Fish and Wildlife Service prior to 

implementation.

Summary of Effects

Table 3-9. Summary of Effects (Wildlife)

Indicator No Action Alternative Proposed Action Alternative 3

Disturbance 

Greatest amount of long-term disturbance; up to six weeks 

annually of mechanical treatments using bulldozers, and tractors. 

Least amount of long-term disturbance; 

three weeks every other year of 

mechanical treatments using bulldozers, 

and tractors. 

Treatments would not happen during nesting season.

Herbicides

Herbicides limited to 24 acres with glyphosate (with only marginal 

effectiveness on beachgrass). Greatest selection of herbicides, 

treatment effectiveness is expected to 

be 80%. Can treat invasive plants. Can only treat noxious 

weeds.

Some additional benefit associated with 

herbicide treatment on invasive plants 

near habitat restoration areas, by 

reducing seed source.

Aquatic glyphosate has 0 risk to western snowy plovers. Imazapyr and aquatic glyphosate have 0 

risk to western snowy plovers.

Habitat Invasive plants will continue to spread and degrade plover habitat. 

Best snowy plover habitat in long term 

at the least cost (see Implementation

Costs Issue 2).

Cumulative Effects

In addition to the Coos Bay District, other agencies and organizations have ongoing and foreseeable invasive plant 

management programs, that when combined with the effects of BLM’s actions under each alternative would have 

cumulative benefits to western snowy plover. The magnitude of these cumulative effects would be greater for 

Alternative 3 than under the No Action Alternative and Proposed Action. Since the Federal listing of the western 

snowy plovers in 1993, the BLM, Oregon State Parks, U.S. Army Corps of Engineers, and Siuslaw National Forest 

have worked together to control European beachgrass and improve habitat capability along the Oregon Coast for 

plovers. Because of their restricted range and specialized habitat, maintaining multiple population centers across 

the Oregon Coast allows for pioneering into new unoccupied habitat and the potential of repopulation after a 

stochastic event. For example, in 1999, the freighter New Carissa ran aground on the North Spit of Coos Bay, on a 

beach supporting plovers, spilling 70,000 gallons of fuel oil. A total of 3,000 sea and shore birds were estimated to 

have been killed, including snowy plovers (USDI 2018b). Suitable habitat and populations on the Siuslaw National 

Forest, near the North Spit (Tenmile Creek), provided for plover refugia and subsequent repopulation. In other 

words, the damage to habitat at one population center is mitigated by having suitable habitat nearby. On the other 

hand, habitat degradation due to ineffective European beachgrass control could be detrimental to other nearby 

populations. Thus, the direct and indirect benefits of the BLM’s European beachgrass control, when added to the 

benefits of similar treatments on adjacent lands, has beneficial cumulative effects by providing greater amount of 

habitat, refugia during inclement events, and individuals for repopulating unoccupied habitat. However, because 

there is a possibility that, under the No Action Alternative and Proposed Action, European beachgrass control on 

BLM would be limited, these cumulative beneficial effects would not occur as quickly as under Alternative 3 or 

would not occur at all under the No Action Alternative and Proposed Action.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

111

As described in the analysis of direct and indirect effects, the District’s invasive plant treatments could create 

disturbances to snowy plovers. However, like the BLM, invasive plant treatments implemented by adjacent Oregon 

State Parks, U.S. Army Corps of Engineers, and Siuslaw National Forest would also apply protection measures to 

prevent adverse effects to snowy plovers. Most private landowners would not conduct invasive plant management 

treatments or implement measures to conserve snowy plovers, because they are not legally required to do so. 

Hence, cumulative adverse effects from invasive plant management for snowy plover habitat would not differ 

among the alternatives. The overall beneficial effects of invasive plant management on snowy plover habitat are 

anticipated to cumulatively improve population viability. Alternative 3 would have greater beneficial cumulative 

effects than the Proposed Action and the No Action Alternative.

Wildlife Issue 2 (Not Analyzed in Detail)

How do invasive plants affect wildlife?

This issue was not analyzed in detail because this issue was addressed in the 2010 Oregon FEIS (USDI 2010a:251-

253). There are no new circumstances or information at the specific level that would change the effects 

anticipated for this EA.

The Coos Bay District manages 329,700 acres of land with a wide variety of habitats including forest, meadows, 

dunes, oak woodlands, pine savannas, marsh, and streams. This habitat supports a rich diversity of wildlife species. 

In general, the BLM is responsible for managing wildlife habitat, while the State of Oregon is responsible for 

managing wildlife species, with the exception of federally listed species.

While some wildlife may benefit from or are tolerant of invasive plants (e.g. American black bear and its 

consumption of Himalayan blackberry fruit), they seldom provide wildlife the same food and cover quality of 

native species (USDI 2010a:251). Native insects, especially Special Status insects and native pollinators, tend to 

prefer native species and are generally adversely affected by invasive plants (USDI 2010a:241-242). The Oregon 

FEIS concludes that long-term beneficial effects to native wildlife populations occur with herbicide treatment on 

invasive plants as adverse habitat changes can result from invasive plants (USDI 2010a:252).

The International Union for the Conservation of Nature (IUCN) notes that a substantial portion of species now 

considered extinct, were driven to extinction by invasive species, and generally ranks invasive species as one of the 

top 10 threats to currently threatened species (IUCN 2008 as cited in USDI 2010a:251). As described in Wildlife

Issue 1, one of the most significant causes of habitat loss for the western snowy plover, a federally threatened 

species, has been the encroachment of invasive European beachgrass (Ammophila arenaria) (USDI 2008d). The 

Oregon FEIS notes that native bird diversity corresponds with native plant diversity, invasive plants can crowd out 

amphibians, and many invasive plants are unpalatable to wildlife species (USDI 2010a:251-253).

Noxious weed populations are estimated to spread 10 percent a year, damaging native plant communities and 

wildlife habitat and inhibiting ecosystem function associated with those communities. The type of actions and the 

amount of treatments under all alternatives would be consistent with the actions analyzed in the 2010 Oregon FEIS 

and the 2016 PEIS.

District-wide, treatments under the Proposed Action and Alternative 3 are expected to be 80 percent effective and 

treatments under the No Action Alternative are expected to be 60 percent effective on invasive plants (see 

Chapter 2 and USDI 2010a:136-138). Therefore, the Proposed Action and Alternative 3 will provide greater benefit 

to the habitat of native birds and small animal species than the No Action Alternative. As described in Wildlife Issue 

1, Alternative 3 would treat invasive plants in western snowy plover habitat restoration areas, and hence would be 

more beneficial to the western snowy plover than the No Action Alternative or the Proposed Action.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

112

Wildlife Issue 3 (Not Analyzed in Detail)

How would contact with or ingestion of herbicides affect wildlife species, especially Special Status wildlife 

species?

This issue is not analyzed in detail because the effects of the herbicides on wildlife were analyzed in three NEPA 

analyses to which this EA tiers: the 2007 and 2016 PEISs (done at the national level) and the 2010 Oregon FEIS 

(USDI 2010a:241-257, USDI 2007a:4-96 to 4-113, USDI 2016a:4-51 to 4-64). There are no new circumstances or 

information at the site-specific level that would change the effects anticipated for this EA. The herbicides analyzed 

in this EA were chosen in part because they were unlikely to have adverse effects to wildlife (Appendix C and USDI 

2010a:245) and Mitigation Measures adopted with the Records of Decision for these three EISs mitigated all 

potentially significant effects at the national and state level. The risk of adverse effects is further minimized as a 

result of Project Design Features included with the Proposed Action and Alternative 3.

There are 17 documented and seven suspected Special Status wildlife species on the District, including three 

documented federally listed species: the northern spotted owl, marbled murrelet, and the western snowy plover 

(see Table 3-10). Table 3-10 also includes additional Birds of Conservation Concern (BCC) and Game Birds Below 

Desired Conditions (GBBDC). Western snowy plover is further discussed in Wildlife Issue 1.

Table 3-10. Wildlife Special Status Species, Birds of Conservation Concern, and Game Birds Below Desired 

Conditions

Common Name Scientific Name 2017 Status1 Coos Bay 

Presence2 General Habitat

Birds

Allen's hummingbird Selasphorus sasin BCC Documented

Found in narrow, moist coastal fog zones in open 

areas of coastal scrub. Nest in nearby wooded 

areas.

American peregrine 

falcon

Falco peregrinus 

anatum

Bureau 

Sensitive, 

BCC

Documented Wide range of habitats, nests on cliff ledges.

Bald eagle Haliaeetus 

leucocephalus

Bureau 

Sensitive, 

BCC

Documented

Nests in large older trees in forested areas near 

large bodies of water, along rivers, lakes, and 

reservoirs. 

Band-tailed pigeon Patagioenas 

fasciata GBBDC Documented Coniferous and mixed forests and woodlands.

Marbled murrelet Brachyramphus 

marmoratus

Federally 

Threatened Documented Nests inland in old growth forest stands within 35-50 miles of the coast. 

Mourning dove Zenaida macroura GBBDC Documented Breed in variety of open habitats, including 

agricultural areas, open woods, and forest edges.

Northern goshawk Accipiter gentilis BCC Documented Mature forests with large trees on moderate 

slopes with open understories. 

Northern spotted owl Strix occidentalis 

caurina

Federally 

Threatened Documented Older mixed conifer forests with high canopy cover.

Olive-sided flycatcher Contopus cooperi BCC Documented

Open conifer forests (< 40% canopy cover) and 

edge habitats where standing snags and scattered 

tall trees remain after a disturbance. 

Oregon vesper 

sparrow

Pooecetes 

gramineus affinis

Bureau 

Sensitive 

and BCC

Suspected

Grassland and savannah habitat types in lowland 

valleys and foothills, except for the Klamath 

Mountains ecoregion in the South/southeast 

portion of District where it occurs in montane 

meadows. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

113

Common Name Scientific Name 2017 Status1 Coos Bay 

Presence2 General Habitat

Purple finch Carpodacus 

purpureus

BCC Documented

Breed in moderately moist, open conifer forests, 

and edge habitat at low-to-mid elevations. Use a 

variety of habitats including deciduous 

woodlands, riparian corridors, and edge habitat. 

In winter, they are more widespread, using 

forests, shrubby areas, weedy fields, hedgerows, 

and backyards.

Purple martin Progne subis Bureau 

Sensitive Documented Open habitat near forest edges and clearings. Snags with cavities. 

Rufous hummingbird Selasphorus rufus BCC Documented

Found in a variety of habitats, most likely in 

brushy areas with flowers and forests with a welldeveloped understory.

Western snowy plover Charadrius nivosus 

nivosus 

Federally 

Threatened Documented Open sand habitat along the ocean and bays.

White-tailed kite Elanus leucurus Bureau 

Sensitive Documented Open fields and agricultural lands.

Willow flycatcher Empidonax traillii BCC Documented Riparian and shrub habitat.

Amphibians

Foothill yellow-legged 

frog Rana boylii Bureau Sensitive Documented Permanent streams with gravel bottoms.

Reptiles

Northwestern pond 

turtle

Actinemys 

marmorata

Bureau 

Sensitive Documented

Spends the majority of their life cycle in aquatic 

environments, but leave the water to adjacent 

meadows to dig terrestrial nests and lay their 

eggs. Often over-winter in the uplands.

Mammals

Fisher Pekania pennantia Bureau 

Sensitive Documented Mature older forests with higher canopy cover, snags, and down logs.

Fringed myotis bat Myotis thysanodes Bureau 

Sensitive Documented

Roosts in caves, abandoned buildings, rock 

crevices, and trees. They are found in chaparral to 

ponderosa pine habitat, but preferred habitats 

are oak woodlands, mixed conifers, and mature 

Douglas firs and snags. 

Pacific marten Martes caurina Bureau 

Sensitive Documented

Older/mature conifer dominated forests with 

dense understory shrub layers and down wood 

and snags.

Pallid bat Antrozous pallidus Bureau 

Sensitive Suspected

Found in brushy, rocky terrain, but have been 

observed at edges of coniferous and deciduous 

woods and open farmland. Roosts in buildings, 

bridges, large decadent snags, and rock outcrops.

Townsend’s big-eared 

bat

Corynorhinus 

townsendii

Bureau 

Sensitive Documented Roost and hibernate in mines and caves, but have been found roosting in hollow trees. 

Invertebrates

Coastal greenish blue 

butterfly

Plebejus saepiolus 

littoralis

Bureau 

Sensitive Suspected

Coastal grasslands, bogs, roadsides with clover. 

Eggs are laid in clover flowers, where the species 

overwinters as an instar. 

Hoary elfin Callophrys polios 

maritima

Bureau 

Sensitive Suspected

All life stages of the elfin are closely associated 

with the kinnikinnick hostplant. Oregon and 

California populations occupy sites on coastal 

bluffs and ancient sand dunes.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

114

Common Name Scientific Name 2017 Status1 Coos Bay 

Presence2 General Habitat

Johnson’s hairstreak 

butterfly Callophrys johnsoni Bureau Sensitive Documented

Spends lifespan in and near the tops of conifer 

trees, although it descends to ground level for 

nectaring (including Oregon grape, Pacific 

dogwood, ceanothus, pussy paws, and Rubus 

species) and to visit moist muddy areas as a 

source of water. Dependent on conifer mistletoe 

for egg laying and for food in its larval stage. 

Mardon skipper 

butterfly Polites mardon Bureau Sensitive Documented

Populations in the southern Oregon Coast occupy 

small (0.5 to 10 ac), grasslands within mixed 

conifer forests. They are usually associated with a 

water source, usually a small perennial or 

intermittent stream running through the 

grassland, but also with areas with shallow 

subsurface water.

Siuslaw sand tiger 

beetle

Cicindela hirticollis 

siuslawensis

Bureau 

Sensitive Documented

Immediate sandy edge of river mouths on 

beaches along the Pacific Ocean, near New River 

ACEC.

Oregon shoulderband 

snail

Helminthoglypta 

hertleini

Bureau 

Sensitive Suspected

Associated with shrublands or rocky inclusions in 

forested habitat with substantial grass and 

subsurface water sources. 

Green sideband snail Monadenia fidelis 

flava

Bureau 

Sensitive Documented

Oregon endemic, limited to the western slope of 

the Coast Range and the immediate adjacent 

Coast, found in mesic forest habitats or near 

springs or other water sources in forest 

situations.

Western bumblebee Bombus occidentalis Bureau 

Sensitive Suspected

Require plants that bloom and provide adequate 

nectar and pollen throughout the colony’s life 

cycle. Flower-rich meadows of forests and 

subalpine zones. Nests are primarily in 

underground cavities such as old squirrel or other 

animal nests and in open west-southwest slopes 

bordered by trees.

1. BCC = Migratory Birds of Conservation Concern; GBBDC = Game Birds Below Desired Conditions

2. Source: 2015 State Directors List (USDI 2015b), with updates from site-specific information. Includes on-District or adjacent to Coos Bay BLMmanaged lands.

The Oregon FEIS concluded the likelihood of significant adverse effects to wildlife from contact with the herbicides 

analyzed in that document was negligible at the population scale. The herbicides are formulated to affect plants 

and have been selected to have some of the lowest (or no) demonstrable wildlife toxicity of EPA-registered 

herbicides, do not bioaccumulate, and are quickly degraded in wildland settings (USDI 2010a:245). An occasional 

individual could be exposed to doses above the level of concern, but risks would not be expected to be significant 

at the population level (USDI 2010a:245). The 2016 PEIS stated that aminopyralid and rimsulfuron would not pose 

toxicological risks to any Special Status wildlife under modeled exposure scenarios. Fluroxypyr would have a low 

risk to susceptible pollinating insects as a result of direct spray scenarios (USDI 2016a:4-61) and is discussed further 

below.

The Oregon FEIS described that the risk of adverse effects to wildlife from dermal contact or ingestion would vary 

by the amount of herbicide applied to vegetation that is used as forage, the toxicity of the herbicide, physical 

features of the terrain, weather conditions, and the time of year. The likelihood of most larger and mobile wildlife 

species being directly sprayed is very low since human activity associated with herbicide treatments generally 

would cause wild animals to temporarily leave the immediate area.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

115

Table 3-11 is a summary of the potential risks to wildlife from each of the herbicides considered in this analysis. 

This summary was adapted from the 2007 PEIS, the Oregon FEIS, the 2016 PEIS, and the Risk Assessments that 

were created or adopted as part of those analyses.

Table 3-11. Effects of Herbicides (Wildlife)1

Additional information about the risk ratings discussed below can be found in Appendix C, Herbicide Risk Assessment Summaries.

Available under all Alternatives

2,4-D

2,4-D is one of the more toxic herbicides for wildlife of the foliar-use herbicides considered in this EA. 

The ester form is more toxic to wildlife than the salt form. Ingestion of treated vegetation is a concern 

for mammals, particularly since 2,4-D can increase palatability of treated plants (USDA 2006) for up to a 

month following treatment (Farm Service Genetics 2008). Mammals are more susceptible to toxic 

effects from 2,4-D, and the sub-lethal effects to pregnant mammals were noted at acute rates below 

LD50. However, bats were not specifically included in these mammal groups; only small and large 

mammalian herbivores were included. Bats are generally wide-ranging and forage in multiple locations 

two miles or more from their roost sites. It is unlikely they would only forage on insects that have been 

sprayed due to the small treatment areas, so the potential effects are minimal. Birds are less 

susceptible to 2,4-D than mammals, and the greatest risk is ingestion of contaminated insects or plants. 

There is little information on reptile toxicity, although one study noted no sexual development 

abnormalities. Honeybees would not be adversely affected by 2,4-D use, even at the highest 

application rate (SERA 2006). Studies that quantify exposure for other terrestrial invertebrates suggest 

that adverse effects occur at application rates of 4 lbs./acre but this rate is greater than that used by 

the District. The salt form is practically non-toxic to amphibians, but the ester form is highly toxic. It can 

be neurotoxic to amphibians; although not all amphibians respond the same (e.g., toads were more 

susceptible than leopard frogs) (SERA 2006).

Dicamba

No adverse effects on mammals are plausible for either acute or chronic exposures to dicamba at the 

typical rate. At the highest tested rate, there are adverse reproductive effects possible for acute 

scenarios consuming contaminated vegetation. Dicamba has no adverse effects on birds for acute or 

chronic exposures at the typical rate, although highest tested application rates had possible adverse 

reproductive concerns for acute scenarios involving birds consuming contaminated vegetation or 

contaminated insects (SERA 2004g). Dicamba is practically non-toxic to amphibians and honeybees. 

Amphibians are as tolerant as fish to the acute toxicity of dicamba, and aquatic invertebrates appear to 

be somewhat more susceptible to dicamba than fish or amphibians.

Glyphosate

Glyphosate formulations vary in toxicity, but studies support the conclusion that the toxic effect of 

POEA-containing glyphosate herbicides is due to POEA rather than to the active glyphosate ingredient 

and BLM no longer uses formulations that include POEA. The glyphosate Risk Assessment (SERA 2011a) 

found that toxicity to wildlife under most of the Risk Assessment scenarios is very low, so much so that 

No Observed Adverse Effects Levels are used because the LD50 were not found. Observed effects in 

mammals had to do with reduced feeding efficiency and reduced weight gain. Glyphosate does not 

bioaccumulate. Larval amphibians were more susceptible in some studies (Relyea 2005b), but less so in 

other studies (Thompson et al. 2004). However, glyphosate without POEA has not been tested on a 

wide range of amphibians. The Risk Assessment found that glyphosate is low risk to honeybees, but 

little information is available for other terrestrial invertebrates. Most field studies suggest that effects 

on terrestrial invertebrates would be minimal (SERA 2011a). However, more recent research indicates 

that glyphosate used in agricultural settings has been shown to affect honeybee appetite, foraging 

behavior, and navigation (Balbuena et al. 2015 and Herbert et al. 2014). A recent study found that 

chronic exposure (over the course of 75 days) to very low doses of glyphosate resulted in kidney and 

liver damage to laboratory animals (Mesnage et al. 2015).

Picloram

Studies on birds, bees, and snails generally support picloram as relatively nontoxic to terrestrial 

animals. The few field studies indicated no change to mammalian or avian diversity following picloram 

treatment. Variations in different exposure assessments have little effect on risk through ingestion, 

grooming, or direct contact. Maximum rates have higher risk to mammals due to ingestion of 

contaminated grass or insects. No information was found in the literature about picloram’s effect on 

reptiles (SERA 2011c). No conclusive studies on invertebrates were found. No sublethal effects were 

noted on honeybee activity patterns.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

116

Available under both the Proposed Action and Alternative 3

Aminopyralid

The Risk Assessment for aminopyralid predicted that exposure to this active ingredient would not pose 

a risk to terrestrial wildlife (including pollinators) under any of the modeled exposure scenarios. Risk 

quotients were all below the level of concern of 0.5 (acute high risk). Therefore, exposure of wildlife to 

this active ingredient by direct spray, contact with sprayed vegetation, or ingestion of plant materials 

or prey items that have been exposed to this active ingredient is not a concern from a toxicological 

perspective.

Chlorsulfuron

Chlorsulfuron is an ALS-inhibitor; a group of herbicides that has the lowest risk to all groups of wildlife 

of the herbicides evaluated. All likely application scenarios are below the level of concern for wildlife 

groups under tested scenarios, even under spill or off-site drift scenarios. There is very little 

information on the effects of chlorsulfuron on terrestrial invertebrates, amphibians, or reptiles (SERA 

2004a). The literature includes two toxicity studies involving leaf beetles exposed to chlorsulfuron that 

reported there were no substantial effects on survival or growth for insects from host plants treated 

with chlorsulfuron. Toxicity studies in honeybees were not identified for chlorsulfuron.

Clopyralid

Clopyralid is unlikely to pose risk to terrestrial mammals. All of the estimated mammalian acute 

exposures are no or low risk; mammalian chronic exposures are below the no observed adverse effects 

level at the typical rate. At the maximum rate, all but one risk scenario has no risk. Large and small 

birds have some risk of ingestion of contaminated food but hazard quotients are below the level of 

concern for all exposure scenarios under the typical rate. There is no risk to honeybees from direct 

spray at typical application rates. No studies on reptiles, amphibians, or invertebrates were found 

(SERA 2004b).

Dicamba + 

Diflufenzopyr

Diflufenzopyr has slightly more toxic effects to wildlife than dicamba based on evaluations in the 

ecological Risk Assessment. The mixture has a moderate residual effect that could affect insects and 

mammals through ingestion but insect lethal effects are unlikely. Risk quotients for terrestrial wildlife 

were all below the most conservative level of concern of 0.1, indicating that accidental direct spray 

effects are not likely to pose a risk to terrestrial animals. The mixture is practically non-toxic to birds, 

but there are some concerns for ingestion of contaminated thistle or knapweed manifesting in 

reproductive effects at the maximum application rates. There are chronic and acute ingestion concerns 

for mammals as well (see Appendix C, Herbicide Risk Assessment Summaries). It has low toxicity to 

honeybees. It is practically non-toxic to aquatic invertebrates, although they are more susceptible to 

dicamba than fish. One study on dicamba indicates it is practically non-toxic to amphibians (ENSR 

2005d, i).

Imazapic

Imazapic is an ALS-inhibitor that rapidly metabolizes and does not bioaccumulate. Mammals are more 

susceptible during pregnancy and larger mammals are more susceptible than small mammals. No 

adverse short-term exposure risks to birds were noted for imazapic, but some chronic growth 

reduction was noted. None of the risk ratings for susceptible or non-susceptible mammals or birds 

shows any ratings that exceed the level of concern. Imazapic has one of the lowest toxic risks to wildlife 

of herbicides evaluated in this EA along with other ALS-inhibitors (SERA 2004c). Very little information 

on toxicity to terrestrial invertebrates is available. Even at exposure associated with direct spray, there 

is no basis for expecting mortality in honeybees (SERA 2004c). 

Imazapyr

There is a lack of information on dose levels that demonstrate harm to mammals, amphibians, or birds. 

Effects of field studies (Brooks et al. 1995) suggest observed changes to birds and mammals following 

treatment are habitat related, and not due to toxic effects. Imazapyr is one of the least toxic aquatic 

herbicides evaluated. Imazapyr is only slightly more toxic than the other ALS-inhibitors, all of which are 

the least toxic of any of the herbicides evaluated (SERA 2011d). No studies on invertebrates were 

found. 

Metsulfuron 

methyl

Metsulfuron methyl is an ALS-inhibitor that does not appear to bioaccumulate. Metsulfuron methyl can 

be effective for invasive plants that are unsusceptible to other herbicides. None of the acute or chronic 

exposure scenarios exceeded the level of concern at the typical rate, and few exceeded the level of 

concern at maximum rate. Metsulfuron methyl has very low toxicity to birds for direct spray and 

consumption and no mortality of acute spray on honeybees. Aquatic invertebrates do not appear to be 

susceptible. One study on rove beetles indicated reduced egg hatching. Like other ALS-inhibitors, it is 

one of the least toxic of the herbicides evaluated (SERA 2004e).

Sulfometuron 

methyl

Sulfometuron methyl has the lowest risk to all groups of wildlife of the herbicides evaluated (with other 

ALS-inhibitors). All scenarios indicate no risk rating that exceeded the level of concern, although it may 

be moderately toxic to amphibians; Sulfometuron methyl can cause malformations in amphibians 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

117

(SERA 2004f), but whether the malformations are caused by endocrine disruption, cellular toxicity, or 

other pathways has not been reported.

Triclopyr

Triclopyr is available as triethylamine (TEA) salt and butoxyethyl ester (BEE). Some formulations of the 

TEA salt of triclopyr have been labeled for aquatic invasive plant control. Triclopyr TEA is less toxic to 

wildlife than triclopyr BEE. The major metabolite of triclopyr, 3,5,6-trichloro-2-pyridinol (TCP) is more 

toxic than triclopyr to mammals. At the upper range of exposures, hazard quotients for triclopyr exceed 

the level of concern for mammals, but average hazard quotients do not exceed the level of concern for 

any exposure scenario. Triclopyr is practically non-toxic to slightly toxic to birds at the typical rate. 

Consumption of treated vegetation (and insects) is the greatest concern for birds or mammals. Using 

less toxic formulas reduces risk (SERA 2011d). 

Available under Alternative 3 only

Fluroxypyr

The Risk Assessment for fluroxypyr predicted that exposure to fluroxypyr would not pose a risk to most 

terrestrial wildlife (including pollinators) under any of the modeled exposure scenarios; the Risk 

Assessments indicate that there is a low risk under typical and maximum rates to susceptible 

pollinators under the 100 percent absorption scenario (direct spray). All other risk quotients were 

below the level of concern of 0.5 (acute high risk); Therefore, exposure of wildlife to this active 

ingredient by direct spray, contact with sprayed vegetation, or ingestion of plant materials or prey 

items that have been exposed to this active ingredient is not a concern from a toxicological 

perspective.

Hexazinone

Hexazinone inhibits photosynthesis and, at higher levels inhibits the synthesis of RNA, proteins, and 

lipids in plants. Hexazinone poses zero to moderate risk to mammals for ingestion under both acute 

and chronic scenarios; for liquid formulations of hexazinone, hazard quotients exceed the level of 

concern at all application rates and all of the scenarios involving residue rates for contaminated 

vegetation or insects (Fletcher et al. 1994). Birds are more tolerant than mammals (SERA 2005c). 

Studies of the effects on amphibians are not well documented.

Rimsulfuron

Data from the literature indicate that rimsulfuron has low toxicity to birds (AECOM 2014b). Based on a 

review of available ecotoxicological literature, rimsulfuron is characterized as not acutely toxic via 

dermal or oral routes of exposure to mammals. No toxicity studies for amphibians were found in the 

published literature. 

Available for Research and Demonstration (Alternative 3)

Fluazifop-P-butyl

The risk characterization of mammals and birds is constrained by the lack of field studies and is based 

solely on laboratory studies and modeled estimates of exposure. There are no data to suggest that 

levels of long-term exposure cause adverse effects in birds. For acute non-accidental exposures, hazard 

quotients are below the level of concern except for mammals and large birds consuming contaminated 

grass. This scenario is unlikely because fluazifop-P-butyl kills most treated grasses before wildlife has an 

opportunity to consume it. Based on the available toxicity data on the honeybee, fluazifop-P-butyl 

would not cause adverse effects following direct spray or surface contamination of the insect due to 

spray drift. Risks to reptiles and terrestrial phase amphibians cannot be characterized directly because 

of the lack of data.

1. Herbicide information summarized from the 2010 Oregon FEIS (USDI 2010a:247-250), the 2007 PEIS (USDI 2007a:4-96 to 4-123), and the 

2016 PEIS (USDI 2016a:4-51 to 4-63).

Under the Proposed Action and Alternative 3, 95 percent of herbicide treatments on the Coos Bay District would 

be spot treatments to target specific plants, so that effects to non-target species would be minimized. Pre-project 

surveys would identify the presence of Special Status species and inform the Conservation Measures that would be 

applied (see Figure 3-2), including herbicide-free buffers. Risk ratings (the high/moderate/low/none, described in 

Table 3-11 above) are based on various exposure scenarios. Standard Operating Procedures and Mitigation 

Measures including limitation on the herbicide types and doses, handling procedures, application methods, drift 

minimization, and timing of application are designed to greatly reduce the likelihood that the modeled exposure 

scenarios described would actually occur, and thus reduce the described adverse effects to wildlife species, 

including Special Status species.

The District prepares an Annual Treatment Plan containing the invasive plant treatments planned for each year. 

These plans are subject to an interdisciplinary team review, which helps the District ensure that treatments 

conform to design and mitigation standards, and that the required Pesticide Use Proposals, Biological Control 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

118

Agent Release Proposals, and other authorizations, obligations, and commitments are completed prior to 

implementation. Projects that have the potential to disturb Special Status wildlife habitat require pre-project 

clearances, including review for potential habitat or pre-project site surveys (USDI 2008b).

The type of actions and the amount of treatments included in any Annual Treatment Plan, under all alternatives,

would be consistent with the actions analyzed in the 2010 Oregon FEIS and the 2007 and 2016 PEISs. All Standard 

Operating Procedures and Mitigation Measures analyzed in those documents would be applied to all alternatives.

As described earlier in this issue, the Oregon FEIS found that the likelihood of significant adverse effects to wildlife 

from contact with herbicides is negligible at the population scale; where there is potential for effects at the District

level, those species are discussed further in subsequent sections. The conclusions presented regarding wildlife and 

Special Status species above apply to the species discussed in the following sections.

The following Project Design Feature included in the Proposed Action and Alternative 3 further minimizes the 

potential for effects to federally listed species:

• In listed species habitat, follow all Project Design Criteria outlined in the Coos Bay BLM District Bureau of 

Indian Affairs/Coquille Indian Tribe FY2014 – 2018 Land Management Activities That May Affect Northern 

Spotted Owls or Marbled Murrelets (USDI 2014a) (see Appendix A, Protection Measures) or future 

updates.

How would treatments affect birds (Special Status species, migratory birds, birds of conservation 

concern, and game birds below desired conditions) that may use potential treatment areas, especially 

during the nesting season?

The U.S. Fish and Wildlife Service includes a list of “Western BLM Bird Species of Conservation Concern” (Migratory 

Birds of Conservation Concern) and “Game Birds Below Desired Condition” in the Migratory Bird Program Strategic 

Plan 2004-2014 (USDI 2008c). Eleven of the birds on these lists and eight Bureau Sensitive or federally listed birds 

are known to occur within the Coos Bay District BLM (see Table 3-10).

The Oregon FEIS determined that birds would generally avoid the treatment area during treatment because of 

noise and activity (USDI 2010a:253-254). As described in the Oregon FEIS, disturbance may disrupt normal 

behavior to the extent survival of adults is impaired or reproduction compromised depending on the intensity of 

disturbance, extent of habitat affected, duration of the activity, and whether the activity occurs during a 

vulnerable time such as when the animal is restricted to a nest, breeding area, or winter range (USDI 2010a:253). 

Associated with herbicide application, animals that temporarily leave the treatment area have reduced risk of 

directly ingesting the herbicide while grooming or from ingesting herbicides on vegetation or prey (insects or other 

animals that were directly sprayed); the herbicides proposed in this EA have a very short active period where 

wildlife toxicity could occur. Some pre-fledgling birds could be restricted to the treatment area and could be 

adversely affected by broad scale treatments using herbicides with moderate toxicity60 (USDI 2010a:246-250). 

However, herbicide treatments on the Coos Bay District have usually been done with hand-directed sprayers and 

applied selectively (i.e. treatments are not broad scale) and are not likely to result in such a direct spray scenario. 

The 2016 PEIS identified no risk to birds from the use of aminopyralid, fluroxypyr, or rimsulfuron under any 

scenario at either the typical and maximum rates.

Specific to nesting birds, the potential for adverse effects from treatment methods (including non-herbicide 

treatment methods) is also minimized by the following Standard Operating Procedure:

• Minimize treatments during nesting and other important periods for birds and other wildlife.

 60 Triclopyr, 2,4-D, and dicamba at the maximum rate have a moderate risk to birds in certain Risk Assessment scenarios; all 

other scenarios are low or no risk. See Appendix C, Herbicide Risk Assessment Summaries.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

119

How would herbicide treatments affect insects such as the Mardon skipper?

The Mardon skipper (Polites mardon) is a rare butterfly found only in grassland and open meadows, endemic to 

the states of Washington, Oregon, and California. On the Coos Bay District, the Mardon skipper is only known to 

occur in three meadows in the North Fork Hunter Creek ACEC, south east of Gold Beach, Oregon. (See Native 

Vegetation Issue 1 for further information about the North Fork Hunter Creek ACEC.) They are weak fliers and 

usually unable to disperse more than a few hundred yards (Black et al. 2010). They are strongly averse to Scotch 

broom and because they do not fly well, are particularly dependent on habitat quality, making them more 

susceptible to adverse effects from invasive plant infestations (Black and Vaughan 2005).

The Risk Assessments indicate that, for fluroxypyr, there is a low risk under typical and maximum rates to

susceptible pollinating insects under the 100 percent absorption scenario (direct spray). Therefore, the following 

Mitigation Measure adopted with the 2016 PEIS would also be applied to treatments on the Coos Bay District and 

would minimize the potential for adverse effects:

• When conducting herbicide treatments in or near habitats used by Special Status and listed terrestrial 

arthropods, design treatments to avoid the use of fluroxypyr, where feasible. If pre-treatment surveys 

determine the presence of listed terrestrial arthropods, do not use fluroxypyr to treat vegetation.

Conservation Measures were identified in the 2007 and 2016 Biological Assessments for Special Status wildlife to 

eliminate the potential for all significant effects, including the following for Special Status butterflies61.

• To protect host and nectar plants from herbicide treatments, follow recommended buffer zones and 

other Conservation Measures for TEP62 plants species when conducting herbicide treatments in areas 

where populations of host and nectar plants occur.

• Do not broadcast spray herbicides in habitats occupied by TEP butterflies or moths; do not broadcast 

spray herbicides in areas adjacent to TEP butterfly/moth habitat under conditions when spray drift onto 

the habitat is likely.

• Do not use 2 4-D in TEP butterfly/moth habitat.

• When conducting herbicide treatments in or near habitat used by TEP butterflies or moths, avoid use of 

the following herbicides, where feasible: clopyralid, glyphosate, hexazinone, imazapyr, picloram, and 

triclopyr.

• If conducting manual spot applications of glyphosate or triclopyr to vegetation in TEP butterfly or moth 

habitat, utilize the typical, rather than the maximum, application rate.

A full list of Special Status insects on the District is included in Table 3-10. While no Conservation Measures were 

identified for other insect species, the following Project Design Feature included with the Proposed Action and 

Alternative 3 would minimize the potential for effects to other Special Status insects:

• Conservation Measures (see Appendix A) applicable to butterflies and moths63will be applied, as 

appropriate, for other Special Status insects.

In addition, the following Project Design Feature included with Alternative 3 would minimize the potential for 

effects to Mardon skipper:

• Do not use fluroxypyr at known Mardon skipper sites.

 61 Language in these Conservation Measures refer to threatened, endangered, and proposed for listing butterflies and moths. 

Mitigation measures adopted in the 2007 and 2016 PEIS make Conservation Measures applicable to all Special Status species. 

The Coos Bay District has no Special Status moths.

62 Federally listed as threatened or endangered, or proposed for such listing. 63 Conservation Measures for butterflies can be found in Appendix A. These include limits on which herbicides can be used, how 

they can be applied, as well as survey requirements.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Wildlife

120

How would herbicide use affect pollinators, especially Special Status pollinators?

Pollinators include bees, bats, birds, and insects. They play an important role in flowering plant reproduction and 

the production of most fruits and vegetables. Habitat loss, disease, parasites, and environmental contaminants 

have all contributed to the decline of many species of pollinators. Effects from herbicides to pollinators would 

generally be related to habitat loss, not to the pollinators themselves; herbicides are formulated to work 

specifically on plants by disrupting the metabolic processes inherent in plants and not in other organisms. Several 

Special Status wildlife species may serve as pollinators on the Coos Bay District (See Table 3-10).

As described above, this issue is not analyzed in detail because, as described in the Oregon FEIS, effects would be 

minimal, and there is no meaningful difference between the alternatives. In addition, 95 percent (Proposed Action 

and Alternative 3) to 100 percent (No Action Alternative) of herbicide treatments would be spot treatments to 

target specific plants, so that effects to non-target species can be kept to a minimum. The herbicides analyzed in 

this EA were chosen in part because they were unlikely to have adverse effects to wildlife, including pollinators 

(USDI 2010a:245). The Oregon FEIS describes that adult honeybees are used as a surrogate for all invertebrates in 

Risk Assessments. Honeybees are nonnative and have been shown to favor non-native plant species and can 

differentially allow the non-native vegetation to compete against native plants (Goulson 2003 in USDI 2010a). The 

Risk Assessments (see Appendix C) indicate that there is low risk to bees or other insects in certain direct spray or 

vegetation consumption scenarios involving clopyralid, fluroxypyr, glyphosate, hexazinone, and triclopyr at typical 

(fluroxypyr, glyphosate, and hexazinone) or maximum (clopyralid and triclopyr) rates and no risk from all other 

herbicides evaluated in this EA (the effects of 2,4-D and dicamba to insects were not evaluated as part of the Risk 

Assessment process). Additional information summarized from the Oregon FEIS is provided in Table 3-11.

The 2016 PEIS states that treatments that remove non-native plant species that: 1) inhibit the growth of native 

plant species used by pollinators, or 2) limit native forb diversity, would be expected to benefit pollinators. The 

PEIS cites Federal guidance identifying the removal of invasive species as an effective way to increase pollinator 

abundance and diversity (USDI 2016a:4-54). Neither aminopyralid nor rimsulfuron, analyzed in the 2016 PEIS, were 

shown to have any risk under any of the modeled exposure scenarios to pollinators (USDI 2016a:4-56). Habitat 

modification is often the main risk to wildlife (including pollinators) from herbicide use and occurs in the short 

term, but in general the long-term effects of more effective methods to remove invasive plants would improve 

wildlife habitat (USDI 2016a:4-54-56).

As described in Chapter 1, the alternatives would not be in conflict with recommendations from the 2014 

Presidential Pollinator Task Force. Standard Operating Procedures and Mitigation Measures for pollinators outlined 

in Appendix A conform to the Strategy. Conservation Measures were identified in the 2007 and 2016 Biological 

Assessments for Special Status wildlife to eliminate the potential for all significant effects, including the following 

for Special Status insect pollinators:

● Do not use 2,4-D in TEP butterfly/moth habitat.

● When conducting herbicide treatments in or near habitat used by TEP butterflies or moths, avoid use of 

the following herbicides, where feasible: clopyralid, glyphosate, imazapyr, picloram, and triclopyr.

● If conducting manual spot applications of glyphosate, or triclopyr to vegetation in TEP butterfly or moth 

habitat, utilize the typical, rather than the maximum, application rate.

● When conducting herbicide treatments in or near habitats used by Special Status and listed terrestrial 

arthropods, design treatments to avoid the use of fluroxypyr, where feasible. If pre-treatment surveys 

determine the presence of listed terrestrial arthropods, do not use fluroxypyr to treat vegetation.

Therefore, effects from the use of herbicides to Special Status insect pollinators would be minimal.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

121

Human Health

Human Health Issue 1 (Not Analyzed in Detail)

What are the effects to human health from incidentally coming into contact with herbicides used on 

BLM-managed lands?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2007 and 2016 PEISs (USDI 2010a:345-358, USDI 2007a:4-174 to 4-196, USDI 2016a:4-87 to 4-103) and 

there are no new circumstances or information at the site-specific level that would change the effects anticipated 

for this EA.

As described in the Recreation Issue 1 later in this chapter, over 700,000 recreators visit the Coos Bay District’s 

recreation sites annually. Local Tribes have treaty rights on BLM-managed lands which allow them to hunt, fish, 

gather, and trap on the District, and other Tribes without specific off-reservation reserved rights gather natural 

resources for traditional or cultural purposes (USDI 2010a:284). People collect mushrooms and berries on BLMadministered lands and swim in streams and lakes. People live and work on or near the Coos Bay District or drive 

on roads or hike on trails across the District.

Herbicides are formulated to affect plant growth; some mimic plant hormones (auxins), others affect 

photosynthesis, amino acid, or lipid synthesis, or disrupt cell membranes. While they are selective for plants, they 

have the potential to affect human health if used improperly (Appendix C and USDI 2010a:345). Exposure scenarios 

for human health effects for the public were analyzed in human health Risk Assessments for direct spray, dermal 

exposure from contaminated vegetation, consumption of contaminated water, acute exposure from spills, 

consumption of contaminated fish, and consumption of contaminated vegetation (USDI 2010a:347).

Tables 3-12 and 3-13 display a summary of information presented in the 2007, 2010, and 2016 EISs, showing the 

herbicides that have some level of risk (greater than 0) to the public in one or more Risk Assessment-modeled 

scenario. All other herbicides had no risk for any of the modeled scenarios of public exposure, including incidental 

handling, consumption, and contact with the skin.

Table 3-12. Human Health Herbicide Risk Summary, Public

Herbicides

Risk Category

(worst-case scenario, one or more scenarios)

Treatment Acres (over life of plan)

No Action Proposed 

Action

Alternative 

3 Typical 

rate

Maximum rate

Direct 

Spray

Dermal 

Exposure

Consumption of Contaminated 

Substance2

Herbicides available under all alternatives

2,4-D3,5 0 L1 01 01,2 149 361 361

Dicamba 0 0 0 L (water) 129 60 60

Glyphosate3 0 0 0 L (water) 7,690 1,808 1,808

Herbicides available under the Proposed Action and Alternative 3

Clopyralid 0 0 0 L (water) 0 331 331

Diflufenzopyr4 0 0 0 02 0 136 136

Triclopyr3 0 L1 L1 L1,2 (water and fruit) 0 5,572 5,572

Herbicides available under Alternative 3

Fluazifop-P-butyl 0 0 0 L (fish) 0 0 30

1. Limited by Mitigation Measures to typical rate where feasible.

2. Contaminated vegetation, fruit, water, or fish. Consumption of contaminated mammals was not evaluated for human health; large 

mammalian carnivores had detectable risk in scenarios that involved 2,4-D (low at typical and maximum rates), triclopyr (low at maximum 

rates), and dicamba + diflufenzopyr (low at typical rate and moderate at maximum rate, under chronic exposure scenarios).

3. Where different formulations exist, risks reported are the most conservative.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

122

4. When applied on BLM-managed lands, diflufenzopyr is formulated with dicamba. Diflufenzopyr by itself poses no risk to human health under 

any scenario.

5. The use of 2,4-D increases by 142 percent under the action alternatives when compared to the No Action Alternative. Approximately half of 

this increase is due to the addition of invasive plants that are not listed as noxious weeds (e.g., burdock, iceplant, and sweetclover) to the plants 

that can be treated under the action alternatives and the other half is because under the action alternatives, 2,4-D can be tank mixed with 

herbicides that were not available under the No Action Alternative (i.e., clopyralid, chlorsulfuron, and metsulfuron methyl). Under the action 

alternatives, the use of 2,4-D on noxious weeds by itself or in combination with picloram, dicamba, or glyphosate decreases by 67 percent 

compared with the No Action Alternative. It should be noted that very little 2,4-D is currently used on the district (7.5 acres / year), which 

would increase to 18 acres / year.

Table 3-13. Effects of Herbicides1 (Human Health)

Additional information about the risk ratings discussed below can be found in Appendix C, Herbicide Risk Assessment Summaries.

Herbicides available under all alternatives

2,4-D 

The public faces zero risk from all modeled scenarios except one; there is low risk to a child being sprayed 

over their entire body at maximum application rate. In the human health Risk Assessment conducted to 

support the reregistration of 2,4-D (USEPA 2004), the EPA concluded that there is not sufficient evidence 

that 2,4-D is an endocrine disrupting chemical. 

Dicamba The public faces zero risk from all modeled scenarios except one; there is low risk to the public from the 

consumption of water from a pond contaminated with a spill.

Glyphosate 

For both workers and members of the public, there are no risks associated with nearly all exposures to 

glyphosate at the typical or maximum application rate (SERA 2011a). The Risk Assessment calculated no risk 

for all but one of the tested scenarios. There is low risk to children associated with accidental exposure to 

glyphosate through consumption of contaminated water after an herbicide spill at the maximum rate into a 

small pond. See also Human Health Issue 4.

Herbicides available under the Proposed Action and Alternative 3

Clopyralid The public faces zero risk from all modeled scenarios except one; there is low risk to the public from the 

consumption of water from a pond contaminated with a spill.

Dicamba + 

Diflufenzopyr (See dicamba, above. Diflufenzopyr poses no risk to human health under any scenario.)

Triclopyr

There is low risk to the public from triclopyr BEE applications at the maximum rate under four acute or 

accidental scenarios: 1) direct spray to the lower legs; 2) dermal contact with contaminated vegetation; 3) 

acute consumption of contaminated fruit; and 4) acute consumption by a child of pond water contaminated 

by a spill. There is low risk to the public from triclopyr acid (TEA) applications at the maximum rate for acute 

consumption by a child of pond water contaminated by a spill, and for chronic consumption of contaminated 

fruit. 

Herbicides available under Alternative 3

Fluazifop-PbutylThere is low risk to subsistence population from fluazifop-P-butyl applications at the maximum rate after an 

accidental spill.

1. Table does not include herbicides with no measurable risk. Herbicide information summarized from the 2010 Oregon FEIS (USDI 2010a:345-

358), the 2007 PEIS (USDI 2007a:4-174 to 4-196), the 2016 PEIS (USDI 2016a:4-87 to 4-103), and the fluazifop-P-butyl Risk Assessment (SERA 

2014).

Ratings are based on various exposure scenarios. Standard Operating Procedures and Mitigation Measures 

including limitations on the herbicide types and doses, handling procedures, application methods, drift 

minimization, and timing of application are designed to greatly reduce the likelihood that the modeled exposure 

scenarios described below would actually occur, and thus reduce the described adverse effects. As shown in Table 

2-10 (Treatment Key), 2,4-D, dicamba, and fluazifop-P-butyl would be used at the maximum rate in some instances 

(see Table D-3, Estimated Total Treatment Acres, 20-Year Analysis Period):

• 2,4-D on 7.3 acres over the life of the plan (an average of 0.4 acres per year) under the Proposed Action 

and Alternative 3 or 3.5 acres under the No Action Alternative (approximately 0.2 acres annually);

• Dicamba on 4 acres over the life of the plan under the No Action Alternative and 1.5 under the action 

alternatives; and

• Fluazifop-P-butyl on 30 acres under Alternative 3.

Therefore the only scenarios with risk that are theoretically possible under the alternatives are associated with 

accidental applications:

• a low risk associated with a child being sprayed over their entire body with 2,4-D at the maximum rate;
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

123

• a low risk to the public from consuming dicamba contaminated water after an accidental spill; or

• a low risk to a subsistence population from eating contaminated fish after an accidental spill of fluazifopP-butyl.

As described in Water Issue 1, accidental spills directly into water are not expected to occur. Targeted application 

methods and Protection Measures would prevent these scenarios from happening. Under the Proposed Action and 

Alternative 3, 95 percent of herbicide treatments on the Coos Bay District would be spot treatments, generally 

done with a hand-directed sprayer, to target specific plants so that effects to non-target species can be kept to a 

minimum. Effects from broadcast treatments on non-target plants would be minimized by the application of 

Protection Measures (see below).

Standard Operating Procedures, PEIS Mitigation Measures, and Oregon FEIS Mitigation Measures designed to 

reduce potential unintended effects to human health are listed in Appendix A. Specific Standard Operating 

Procedures and Mitigation Measures pertinent to this analysis include:

• Prepare an operational and spill contingency plan in advance of treatment.

• Observe restricted entry intervals specified by the herbicide product label.

• Provide public notification in newspapers or other media where the potential exists for public exposure.

• Consult with Native American Tribes to locate any areas of vegetation that are of significance to the Tribes 

and Native groups and that might be affected by herbicide treatments64.

• Use the typical application rate, where feasible, when applying 2,4-D and triclopyr65 to reduce risk to 

workers and the public.

• Consideration should be given to herbicides other than 2,4-D; use of 2,4-D should be limited to situations 

where other herbicides are ineffective or in situations in which the risks posed by 2,4-D can be mitigated.

• Proposals to boom spray herbicides within 200 feet of streams that are within 1,000 feet upstream from a 

public water supply intake, or spot apply herbicides within 100 feet of streams that are within 500 feet 

upstream from a public water supply intake, will include coordination with the Oregon Department of 

Environmental Quality and the municipality to whom the intake belongs.

• Establish a buffer between treatment areas and human residences based on guidance given in the Human 

Health Risk Assessment, with a minimum buffer of 100 feet for ground applications, unless a written 

waiver is granted.

• Consider the potential for treatments to affect communities from herbicide-contaminated resources 

originating from the BLM, such as subsistence resources or water used downstream for human or 

agricultural uses.

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2007 and 2016 PEISs. All Standard Operating Procedures and Mitigation 

Measures analyzed in those documents would be applied to all alternatives. Additional information about specific 

scenarios and effects from herbicides can be found in subsequent sections. The Standard Operating Procedures 

and Mitigation Measures presented above regarding human health apply to the discussion in the following 

sections.

What are the human health effects to people who regularly consume or come in contact with 

contaminated vegetation, water, or wildlife? How would herbicide use affect the health of people 

gathering, handling, ingesting plants, fish, or wildlife or handling fossils or artifacts that are in or near 

 64 A Project Design Feature states that Annual Treatment Plans will be presented to the Tribes showing planned treatments. 

Any resultant coordination will identify if treatments should be delayed, where cultural features must be avoided or protected, 

and where posting signs would help Tribe members avoid areas (see the Traditional and Cultural Uses Issue 1). 65 An Oregon FEIS Mitigation Measure stating, “do not apply triclopyr by any broadcast method” is not applied in this analysis 

because an updated Risk Assessment for triclopyr found zero risk for all worker and public exposure scenarios at the typical 

rate.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

124

the area of herbicide use? What are the human health and safety hazards to those harvesting and 

consuming special forest products, such as greenery, herbs, berries, and mushrooms?

This was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS and 

2007 and 2016 PEISs and there are no new circumstances or information at the site-specific level that would 

change the effects anticipated for this EA.

Treatments in this EA are targeted towards invasive plants, which – with some exceptions – are generally not plant 

species being collected or ingested. Triclopyr would be used on blackberry plants (and other woody species) on the 

District, applied via foliar, cut-stump, or basal spray methods at typical rates. However, while blackberries are 

widespread on the District, treatments would generally only occur in areas where they threaten Special Status 

plants, along roadsides where they are limiting access, or where forest management projects have recently 

contributed to the spread of invasive plants. These areas are generally not collection areas. In addition, treatments 

typically happen before fruit is present and signs are posted at treatment areas to inform the public of the 

application of herbicides.

With the exception of triclopyr (described above), the herbicides that are low risk (under maximum rates) in 

contaminated water scenarios (see Table 3-12) are unlikely to contaminate water, as they are not registered for 

aquatic use and hence, would not be used in riparian areas where they could contaminate water.

No herbicides present moderate or high risks to human health under any scenario. The consumption of 

contaminated wildlife by humans was not evaluated, but large mammalian carnivores only had risks greater than 

zero in scenarios that involved 2,4-D (low risk at typical and maximum rates), triclopyr (low risk at maximum rates), 

and dicamba + diflufenzopyr (low risk at typical rate and moderate risk at maximum rate, under chronic exposure 

scenarios). However, the potential for actual effects is negligible. As described in the Wildlife Issue 3, larger 

animals (such as deer, rabbits, or birds) are unlikely to remain in a treatment area while treatments are occurring. 

These animals may return to the treatment site and consume treated vegetation, but since 95 percent of herbicide 

treatments would be spot treatments, it would be unlikely that an animal could consume enough treated 

vegetation to reach the levels analyzed in the Risk Assessment scenarios. Triclopyr and dicamba + diflufenzopyr 

would not be applied at maximum rates (see Table 2-10 Treatment Key).

What are the human health hazards to susceptible members of the public (including children, pregnant 

women, the elderly, sick people, and those with chemical-sensitive conditions) associated with herbicide 

applications?

This was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS and 

2007 and 2016 PEISs and there are no new circumstances or information at the site-specific level that would 

change the effects anticipated for this EA.

The Oregon FEIS describes that the Risk Assessments apply uncertainty factors (multiplying the lowest observable 

effects by a factor of 10, 100, or even 1,000 to get a level of concern), which are included to account for 

hypersensitive individuals and otherwise accommodate uncertainties into the measurements. Thus, herbicide 

exposure to a healthy (not susceptible) individual to a dose identified as having a risk would likely have no effect. 

Nevertheless, the low rating indicates that the potential for risk starts at that level of concern (USDI 2010a:91). 

Therefore, the general assessment of the possible effects to humans in the Human Health sections of those 

documents includes those with chemical sensitivities. Risk Assessments scenarios include scenarios with children 

and women (see Appendix C, Herbicide Risk Assessment Summaries).

At the maximum rate, only 2,4-D and triclopyr pose risk to the public from direct spray or dermal exposure. 

Triclopyr would not be applied at the maximum rate. Of the 360 acres on which 2,4-D would be used over the life 

of the plan under the Proposed Action or Alternative 3, only 7.3 acres (or 2 percent) would be at the maximum 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

125

rate. Protection Measures, such as herbicide application buffers and restricting application methods to spot 

spraying (triclopyr), would further reduce risk to susceptible populations (see Appendix A – Protection Measures).

Herbicide use under all alternatives would be scattered and infrequent (typically once per year at a site) and not 

comparable to industrial uses on neighboring farms or timberlands (USDI 2010a:744). As described in the 

Neighboring Lands Pesticide Use section in Chapter 2, BLM use of herbicides is a small fraction (0.03-0.04 percent) 

of the pounds of pesticides used in the water basins containing Coos Bay District-managed lands. Herbicides would 

not be sprayed aerially and drift reduction strategies would be applied to spot and broadcast treatments.

What are the human health effects of herbicides applied near natural springs, private wells, and 

irrigation sources?

This was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS and 

2007 and 2016 PEISs and there are no new circumstances or information at the site-specific level that would 

change the effects anticipated for this EA. Tables 3-12 and 3-13 show that four herbicides (dicamba, glyphosate, 

triclopyr BEE, and clopyralid) have some level of risk (greater than 0) at maximum application rates to the public in 

one or more Risk Assessment-modeled scenarios involving contaminated water. All of the scenarios with some 

amount of risk involved accidental spills. Specific to spills, the following Standard Operating Procedures minimize 

the potential for spills:

• Prepare an operational and spill contingency plan in advance of treatment.

• Conduct mixing and loading operations in an area where an accidental spill would not contaminate an 

aquatic body.

In addition, a variety of Standard Operating Procedures and Mitigation Measures reduce the potential for 

herbicides to contaminate water that may be consumed by humans. These measures are listed in full in Appendix 

A, Protection Measures. They include, but are not limited to:

• To protect domestic water sources, no herbicide treatments should occur within 100 feet of a well or 200 

feet of a spring or known diversion used as a domestic water source unless a written waiver is granted by 

the user or owner (Oregon FEIS Mitigation Measure).

• Proposals to boom spray herbicides within 200 feet of streams that are within 1,000 feet upstream from a 

public water supply intake, or spot apply herbicides within 100 feet of streams that are within 500 feet 

upstream from a public water supply intake, will include coordination with the Oregon Department of 

Environmental Quality and the municipality to whom the intake belongs (Oregon FEIS Mitigation 

Measure).

• Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on Risk 

Assessment guidance, with minimum widths from water of 25 feet for vehicle, and 10 feet for hand spray 

applications.

Human Health Issue 2 (Not Analyzed in Detail)

What are the hazards to workers treating invasive plants?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2007 and 2016 PEISs (USDI 2010a:345-358, USDI 2007a:4-174 to 4-196, USDI 2016a:4-87 to 4-103) and 

there are no new circumstances or information at the site-specific level that would change the effects anticipated 

for this EA.

As described in the Human Health and Safety section of the Oregon FEIS, there are difficulties in establishing 

correlations between work conditions and disease and only certain illnesses have been linked to occupational 

hazards in national and state-level studies (USDI 2010a:343). Manual, mechanical, and chemical treatments can all 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

126

present health hazards to workers. Hazards could include falling objects (especially when cutting trees66), tripping 

or slipping on hazards on the ground, protruding objects such as branches and twigs, poisonous plants and insects, 

and dangerous wildlife. Workers are subject to heat-related illness (potentially exacerbated by safety equipment 

such as chainsaw chaps or face guards) or hypothermia when working in extreme weather conditions, and may 

incur musculoskeletal injuries related to improper body mechanics (USDI 2010a:343-345). Table 3-14 shows 

herbicides that have some level of risk (greater than 0) to applicators in one or more Risk Assessment-modeled 

scenario.

Table 3-14. Human Health Herbicide Risk Summary, Workers

Herbicides

Risk Category

(worst-case scenario, one or more scenarios)

Treatment Acres over life of plan

(Acres applied at the maximum rate)

No Action 

Alternative Proposed Action Alternative 3 Typical rate Maximum rate Accidental Exposure

2,4-D L L1 M 149 (3.5) 361 (7) 361 (7)

Chlorsulfuron 0 L 0 0 188 (0) 188 (0)

Dicamba 0 L 0 129 (4) 60 (2) 60 (2)

Hexazinone 0 L1 0 0 0 90 (0)

Rimsulfuron 0 0 M-H 0 0 138 (138)

Triclopyr 0 L1 L 0 5,572 (0) 5,572 (0)

1. Limited by Mitigation Measures to typical rate, where feasible.

As described in the Oregon FEIS and 2007 and 2016 PEISs, modeled scenarios indicate that:

• For 2,4-D and triclopyr, workers face moderate risk from wearing contaminated gloves for an hour (USDI 

2010a:349-350).

• Chlorsulfuron and dicamba at the maximum rate can cause temporary skin or eye irritation to applicators 

(USDI 2007a:4-184, USDI 2010a:350)

• Rimsulfuron has risks in accidental scenarios. It may cause reversible eye irritation. Long-term exposure at 

high rates (repeated accidental exposure) can cause health effects targeting multiple organs (USDI 

2010a:348, USDI 2016a:4-102).

Further information about these modeled scenarios can be found in each herbicide’s human health Risk 

Assessment (See Appendix C, Herbicide Risk Assessment Summaries).

No injuries to herbicide applicators from herbicide exposure have been recorded for at least the past 20 years on 

BLM-managed lands in Oregon (Erin McConnell, Oregon BLM State Weed Coordinator, 2018 personal 

communication).

The potential for an injury (from manual, mechanical, or chemical treatments) is exacerbated if workers are 

fatigued, poorly trained, poorly supervised, or do not follow established safety practices. Appropriate training, 

together with monitoring and intervention to correct unsafe practices, minimizes potential for worker injury and 

illness. BLM complies with Standard Operating Procedures, Mitigation Measures, and Occupational Safety and 

Health Administration (OSHA) standards and industry and manufacturers’ recommendations, which reduces 

potential exposure and injury to workers (USDI 2010a:344-345). Herbicide treatments on BLM-managed lands in 

Oregon are done only by BLM certified or state licensed applicators or persons working under their direct 

supervision (USDI 2010a:85). BLM certifications are renewed every three years and completing a one-week 

training course is required.

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2007 and 2016 PEISs. All Standard Operating Procedures and Mitigation 

Measures analyzed in those documents would be applied to all alternatives.

 66 Treatments for woody species, such as tree-of-heaven and locust, are included in Woody Species treatment group (see Table 

2-10).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

127

Human Health Issue 3 (Not Analyzed in Detail)

What are effects to human health of mixing two or more herbicides? Are these combinations more toxic 

than herbicides used individually?

This is not analyzed in detail because the effects discussed in Human Health Issue 1 (incidental/public exposure) 

and Human Health Issue 2 (worker exposure) reflect the potential effects of using two or more herbicides in 

combination. Some formulations (brands) approved for use on BLM-managed lands contain more than one 

herbicide active ingredient (see Table B-2, Herbicide Formulations Approved for use on BLM-managed Lands). 

Others can be mixed in the field (tank mix). Herbicides can only be used in combinations if each one is included on 

the BLM-approved herbicide list and the label allows for the combination. All herbicides included in the 

combination must be registered for the type of land being treated (forestland, rangeland, etc.).

The BLM’s nationally approved herbicide formulations list is based on the herbicide Risk Assessments, which 

considered evaluations of common tank mixes and current research on synergistic effects (with other pollutants 

found in water, for example). Uncertainty is acknowledged in the analysis, and accommodated in part by requiring 

the use of conservative risk ratings and mitigation. The Risk Assessments consider risks from mixing two herbicides 

together in a tank mix, assuming the products act in an additive manner. When two or more active ingredients are 

used, the risk ratings and Mitigation Measures for all ingredients apply; they are not averaged. It is understood 

that the combination may be more hazardous to non-target plants than any of the individual herbicides being 

mixed; for example, a few ounces of 2,4-D are sometimes added to increase effectiveness and decrease the 

likelihood of missing otherwise resistant plants (USDI 2010a:62).

Human Health Issue 4 (Not Analyzed in Detail)

What are effects to human health of using glyphosate, which the International Agency for Research on 

Cancer (IARC) recently declared a cancer hazard and California lists as cancer causing and may be linked 

to non-Hodgkin lymphoma and leukemia?

This issue is not analyzed in detail because effects would be too small to measure. Glyphosate was analyzed in the 

2010 Oregon FEIS to which this EA tiers (USDI 2010a:350), and even considering recent research, effects are not 

likely to change at the site-specific level.

Endocrine disrupting chemicals, predominately found in man-made materials, are suspected of causing endocrinerelated cancers (breast, endometrial, ovarian, prostate, testicular and thyroid) (Bergman et al. 2012). The Oregon 

FEIS discussed the potential for glyphosate to act as an endocrine disruptor as analyzed in the Risk Assessments67. 

The Risk Assessment for glyphosate states, “Three specific tests on the potential effects of glyphosate on the 

endocrine system have been conducted and all of these tests reported no effects. The conclusion that glyphosate 

is not an endocrine disruptor is reinforced by epidemiological studies that have examined relationships between 

occupational farm exposures to glyphosate formulations and risk of spontaneous miscarriage, fecundity, sperm 

quality, and serum reproductive hormone concentrations... the approach taken in the Risk Assessment is highly 

conservative and no recent information has been encountered suggesting that this Risk Assessment is not 

adequately protective of any reproductive effects that might be associated with glyphosate exposure.” However, a 

recent study by Benachour and Seralini (2008) shows potential endocrine disruption, DNA damage, and toxicity of 

POEA and possibly alpha-amino-3-hydroxy-5-methyl-4- isoxazolepropionic acid (AMPA, the major glyphosate 

degradate) in human cell cultures. This is a single study and scientists rely on the weight of evidence of multiple 

studies, which have not identified these adverse effects. These new findings need to be confirmed by other 

studies.” (USDI 2010a:350)

 67 The Oregon FEIS discusses results from a 2002 Risk Assessment. The 2011 Risk Assessment, also done by SERA, include similar 

results (SERA 2011a).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Human Health

128

In March 2015, the IARC, the specialized cancer agency of the World Health Organization (WHO), added glyphosate 

to Group 2A, probably carcinogenic to humans. In May 2016, the Food and Agriculture Committee of the WHO 

held their regular Joint Meeting on Pesticide Residues (JMPR), where they found that glyphosate was “unlikely to 

pose carcinogenic risk from exposure through diet.” The WHO also stated that the conclusions arrived at by the 

JMPR and the IARC were “different, yet complementary” noting that “the IARC reviews published studies to 

identify potential cancer hazards, it does not estimate the level of risk to the population associated with the 

hazard.” The IARC defines a cancer hazard as an agent that is capable of causing cancer under some circumstances, 

while a cancer risk is an estimate of the carcinogenic effects expected from exposure to that substance. The 

distinction between ‘hazard’ and ‘risk’ is important. The IARC identifies cancer hazards even when risks are very 

low at current exposure levels. Their list of carcinogens describes the level of evidence that something can cause 

cancer, not how likely it is that something will cause cancer in any particular person. Other agents listed in Group 

2A include drinking hot beverages (over 149° F), eating red meat, and indoor emissions of burning wood (IARC 

2015, JMPR 2016).

However, in June 2016, Reuters reported that court documents from an ongoing legal case against Monsanto (the 

maker of RoundUp herbicide products) show the scientist leading the IARC’s review of glyphosate knew of data 

showing no link between glyphosate and cancer. The agency did not take the information into account because it 

had yet to be published in a scientific journal. In a deposition given in connection with the case, Aaron Blair, a U.S. 

National Cancer Institute epidemiologist, said the data would have altered IARC’s analysis and made it less likely 

that glyphosate would meet the agency’s criteria for being classed as “probably carcinogenic” (Kelland 2017).

In July 2017, California’s Office of Environmental Health Hazard Assessment added glyphosate to their list of 

chemicals known to cause cancer and made plans to require cancer warnings on products. Monsanto challenged 

the product-labeling as “unwarranted on the basis of science and the law” (Plum 2017) and in February 2018, a 

Federal judge in U.S. District Court ruled that "Given the heavy weight of evidence in the record that glyphosate is 

not in fact known to cause cancer, the required warning is factually inaccurate and controversial" (National 

Association of Wheat Growers et al. v. Lauren Zeise, director of OEHHA, et al., U.S. District Court, Eastern District of 

California, No. 17-cv-02401).

Also in July 2017, the European Food Safety Administration and European Chemicals Agency conducted detailed 

evaluations and found insufficient evidence that glyphosate causes cancer. These evaluations were done in 

response to a request from the European Commission regarding their evaluation of the carcinogenicity of 

glyphosate (EFSA 2017). Similar conclusions were found in a recent review and meta-analysis of available research 

examining glyphosate exposure and the risk of lymphohematopoietic cancers (which includes non-Hodgkin 

lymphoma and leukemia) found a “positive and marginally statistically significant association with the use of 

glyphosate,” but “the overall body of literature is methodologically limited and findings are not strong or 

consistent” and that bias and confounding (the presence of another variable that may influence the results) were 

possible. As a result, the report said a causal relationship between glyphosate and lymphohematopoietic cancers 

could not be established (Chang and Dezell 2016).

The Oregon FEIS describes that it is difficult to quantify the likelihood of some agent causing cancer due to the 

long-time interval between exposure and diagnosis, personal behavior patterns, job changes, and exposure to 

other carcinogens (USDA 2010a:344). This remains true for the analysis in this EA.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Soil

129

Soil

Soil Issue 1 (Not Analyzed in Detail)

Would invasive plant treatments lead to increased soil compaction and erosion?

This issue was not analyzed in detail because effects are unlikely to differ between the alternatives and because 

effects are expected to be negligible. The nature of the disturbance associated with invasive plant treatments 

would have little potential to cause measurable soil compaction or erosion due to the low intensity and limited 

scale of treatments on the Coos Bay District. In addition, if there are site conditions in which adverse effects may 

result, the BLM would apply Protection Measures that minimize the potential for effects; the risk of adverse effects 

would be further minimized as a result of Project Design Features adopted for the Proposed Action and Alternative 

3.

More than 90 percent of Coos Bay soils have a low clay content (less than 25 percent) and a high organic matter, 

which make the soils less susceptible to compaction. There are exceptions; for example, the Dean Creek Elk 

Viewing Area is compacted by elk herds, as well as previous and ongoing management activities. Levels of organic 

matter and clay can vary widely within a small area; however, they are generally described below, using the four 

soils order on the Coos Bay District. Inceptisols are the most widely distributed soils, present on 88 percent of the 

District. They have high infiltration rates, low amounts of clay, and are typical of forested areas. Ultisol soils (11 

percent of the District) have high amounts of organic matter, and good drainage and are typical of forested areas. 

The remaining soils types make up 1 percent or less of the District. The Coos Bay District soils are not prone to 

water erosion, with low to medium average water erosion risk ratings for all soil types. (Soils that do not compact 

easily allow for the water to infiltrate subsurface, which reduces the risk for water erosion. See Range K-Factor, 

Table 3-15.) Less than 1 percent of the District soils have a high risk for water erosion.

Table 3-15. Soil Order Properties and Extent

Soil Order Average % Organic 

Matter1

Average % 

Clay

Range K-Factor [Water Erosion]

(Risk Rating2) 

Approximate 

Acres/Percent of BLMAdministered Lands3

Inceptisols 29 19 0.05 to 0.37 (Low - Medium) 281,300 acres/88%

Ultisols 28 24 0.17 to 0.37 (Low - Medium) 33,600 acres/11%

Entisols 4 8 0.02 to 0.37 (Low - Medium) 2,600 acres/0.8%

Alfisols 3 22 0.28 to 0.43 (Medium - High) 2,200 acres/0.7%

1. Average organic material and clay contents derived from A horizon for all soils within the order, not the entire profile

2. K Factor Erosion Risk Rating: Low = 0.05 to 0.2, Medium = 0.21 to 0.40, High = 0.41+. Erosion factor K appears in the Universal Soil Loss 

Equation (Wischmeier and Smith 1978) as a relative index of susceptibility of bare cultivated soil to particle detachment and transport by 

rainfall.

3. Only represents soil orders that are greater than 0.5% of total acres on District. Therefore, Andisols (940 acres), Histosols (95 acres), Millisols 

(101 acres), and Spodosols (194 acres) are not included in this table.

Seventy-one percent of invasive plant infestations on the District are on sites less than 0.5 acres. Under the No 

Action Alternative, all herbicide treatments would be done as spot treatments with a hand-directed sprayer and 

under the action alternatives, 95 percent of herbicide treatments would be similar spot treatments. These 

treatments would not be expected to create large unvegetated areas that would be prone to compaction or 

erosion. Invasive plants on the District tend to occur in previously disturbed areas; hence, herbicide applications 

are generally made from roads and other previously disturbed surfaces, where compaction or erosion may have 

already occurred. Competitive seeding and planting would be used under all alternatives on larger sites to aid in 

revegetation and to help prevent soil erosion and compaction that could occur in large unvegetated areas. This 

would typically happen on treatment sites larger than 0.5 acres, and the extent of it would not change between 

the alternatives. Competitive seeding and planting may be preceded by tilling to decompact the soil and increase 

the success of the seeding. Targeted grazing with sheep or goats (for forbs and woody vegetation) and cattle
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Soil

130

(grasses) would not be a preferred treatment method for any treatment group, and are proposed for less than one 

percent of treatments. Given its extremely limited use as well as the application of Protection Measures that 

would prevent effects that result from intensive grazing, any erosion or compaction would be negligible and shortterm. Treatment of some small invasive plant sites may be done utilizing a hand held propane torch. Treatments 

would be limited to individual plants, and used primarily in parking lots and other areas where the substrate is 

non-flammable, like sand or paved areas. Because of the limited use and site conditions, propane torches would 

not contribute to erosion or compaction. With the exception of treatments done with tractors, discs, or bulldozers 

(discussed below), mechanical methods such as string trimmers or mowers tend to disturb little or no soil, 

removing the plant at the base and leaving the roots intact. Prescribed fire would be used on approximately 100 

acres annually68. This could lead to compaction if heavy machinery is used to pile vegetation or erosion if large 

amounts of vegetation are removed. However, all prescribed fire treatments would follow Standard Operating 

Procedures (see Appendix A) as well as Fire and Fuels Management Best Management Practices described in the 

Northwestern and Coastal Oregon Resource Management Plan (USDI 2016d:162-167). These Protection Measures 

would minimize the potential for adverse effects.

Sandy soils (in the Entisol soil order) are present in the North Spit and New River area of the District. These soils 

are not prone to compaction due to their uniform grain size. Widespread European beachgrass in these sandy 

areas is removed with tractors, discs, or bulldozers. The exposure of bare sand can lead to increased wind erosion, 

but the movement of sand is natural to that environment. This sand movement will not affect any water bodies or 

existing infrastructure (e.g. Sand Road). The foredunes are a sand ridge that forms parallel to the coast and acts as 

stability feature (like a sea wall) from ocean and wind processes. Under the No Action Alternative and the 

Proposed Action, the stability of the foredune would be protected as described in existing management plans and 

interagency agreements. (See the description of the alternatives in Chapter 2 for further information.) Under the 

Alternative 3, the following Project Design Feature would be adopted to reduce effects:

• All guidelines established in potential future North Spit western snowy plover NEPA would be done in 

conjunction with the U.S. Army Corps of Engineers.

As a result, erosion is not a concern in sandy environments following invasive plant treatments.

Due to the nature of the treatments, the soils present on the District, and the application of Protection Measures, 

invasive plant treatments would not lead to soil compaction or erosion. By removing invasive plants, the normal 

soil protection processes and vegetation and soil armoring are returned over the long term. Improved 

effectiveness in treating invasive plants and retention of larger amounts of non-target vegetation will inhibit 

further invasive plant establishment.

Soil Issues 2 and 3 (Not Analyzed in Detail)

How do herbicides break down and move through soils?

Do herbicides affect soils?

Because both issues discuss how soil characteristics influence the way in which they interact with herbicides, these 

issues are discussed together. These issues were not analyzed in detail because effects were previously described 

in the analysis for the Oregon FEIS and the 2007 and 2016 PEISs (USDI 2010a:178-187, USDI 2007a:4-16, USDI 

2016a:4-10 to 4-13) and there are no new circumstances or information at the site-specific level that would change 

the effects anticipated for this EA. Additional analysis at this site-specific level would not change the conclusions 

from the Oregon FEIS and the 2007 and 2016 PEISs. The type of actions and the amount of treatments under all 

alternatives would be consistent with the actions analyzed in the 2010 Oregon FEIS and the 2007 and 2016 PEISs. The 

same Standard Operating Procedures and Mitigation Measures analyzed in those documents would be applied to all 

alternatives in this EA.

 68 Under the No Action Alternative, this has occurred as a habitat restoration activity. Under the action alternatives, this would 

occur as an invasive plant treatment.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Soil

131

As described in the Oregon FEIS, soil consists of varying levels of sand, silt and clay particles, organic matter, and 

soil organisms. Soil filters, buffers, degrades, immobilizes, and detoxifies organic and inorganic materials, including 

herbicides (USDA 1997 as cited in USDI 2010a:174). The ability of soils to hold and break down herbicides is 

affected by biological processes (organisms and plant uptake), physical parameters (adsorption, volatilization, 

hydrolysis, and leaching), and other parameters (climate and vegetative cover)(see Table 3-16, Fate of Herbicides 

in Soils). Soils in the Coos Bay District weather from a variety of parent materials like sedimentary rock, volcanic 

deposits, and metamorphic rocks. The Coos Bay District also has beach and dune (sand) deposits.

Information about soils and its characteristics on the Coos Bay District comes from the Natural Resources 

Conservation Service’s (NRCS) Soil Web Survey (USDA 2016a). In general, soils on the Coos Bay District are porous 

and have a moderately high to very high69 hydraulic conductivity class. This means that even if the soil is saturated, 

the soil has a high ability to transmit water. Organic matter content is considered the most important soil property 

affecting herbicide adsorption. Pesticides are very strongly attached to the surface of organic matter and less likely 

to leach in soils high in organic matter (USDI 2007a:4-11). Most of the soils on the District (98.5 percent) have a 

high (greater than 4 percent) percentage of organic matter (see Table 3-15, Soil Order Properties and Extent). The 

adsorption affinity of these two conditions (high hydraulic conductivity and high organic matter) are in contrast to 

one another. Therefore, it can be assumed that the adsorption affinity across the District varies, but in general is 

moderate to high. However, some herbicide adsorption rates, like imazapyr, imazapic, and picloram, depend on 

chemical characteristics of the soil. Picloram degrades slower in soils with a pH greater than 7 (1 percent of soils on 

the District), whereas imazapyr and imazapic degrade slower in soils with a pH greater than 5 (42 percent of soils 

on the District) (USDA 2016a, USDA 2000b as cited in USDI 2010a:184 and Tu et al. 2004 as cited in USDI 2015a). 

Table 3-16 shows the fate of herbicides in soils; that is, how long these herbicides would be expected to remain in 

the soil (USDI 2010a:59-61, 181, USDI 2007a:4-15 to 4-21, USDI 2016a:4-10 to 4-13). While herbicides are generally 

not expected to affect the attributes of soil except as described below, this information is presented as context for 

other resources (e.g., water, vegetation, and fish) which could be exposed to herbicides attached to or persisting in 

soil. In the cases where herbicide could move down through the soil, the main concern is groundwater 

contamination (discussed further in Water Issue 1).

The Oregon FEIS describes that herbicides probably affect few soil organisms directly (USDI 2010a:178). While 

there are varying amounts of information available for each herbicide, three (chlorsulfuron, picloram, and 

metsulfuron methyl) may reduce the presence of soil biota for a period of up to three weeks, and the remaining 

have no or slight adverse effect (USDI 2010a:182-185, USDI 2007a:4-16, USDI 2016a:4-11 to 4-13). When adverse

effects were noted (diflufenzopyr, imazapic, or imazapyr), it was at application rates many times higher than those 

used by the BLM (USDI 2010a:178).

Fluazifop-P-butyl, proposed for use in limited areas for research and demonstration under Alternative 3, was not 

analyzed in the EISs to which this document tiers. The Risk Assessment for fluazifop-P-butyl says it could have 

adverse effects on terrestrial arthropods at the treated site, but functional recovery (i.e., repopulation) within one 

year would be expected and no effects would be expected at a distance of 100 feet from the treated site, indicating 

highly localized, temporary effects (SERA 2014).

Herbicides can affect biological soil crusts. Although soils of the Coos Bay District contain concentrations of 

microorganisms, they rarely, if ever, develop biological soil crusts; winter storms are too wet.

Except for applications of imazapic and rimsulfuron on grasses, treatments would be applied to foliage. Vegetation 

would absorb the herbicide and the quantity that might come in contact with the soils would be minimal. 

 69 See also Table 3-17, Median Saturated Hydraulic Conductivity (Ksat) values for BLM land within the Analysis Area. Measured 

in feet per day across BLM-administered land within the Coos Bay District: 69 percent very high (Ksat values above 28), 24 

percent high (Ksat between 2.8 and 28), and 8 percent moderately high (Ksat values between 0.28 and 2.8).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Soil

132

Chlorsulfuron and metsulfuron methyl may reduce populations of microorganisms for a few days to a few weeks. The 

combined treatment areas of these herbicides is 653 acres over the life of the plan. These herbicides would have a 

negligible effect on soil as treatments would be dispersed and organisms would easily recolonize within several 

weeks.

Under Alternative 3, up to 172 acres annually of glyphosate and imazapyr would be used in western snowy plover 

habitat restoration areas. Glyphosate rapidly degrades in soils through microbial degradation. Imazapyr will take 

longer to break down (see Table 3-16, Fate of Herbicides in Soils); however, the pH of the local sand environments 

is between pH 5.3 and pH 6.2, which are below the pH 7 threshold where adsorption is lower.

Only five percent of herbicide treatments of the Proposed Action and Alternative 3 would be broadcast applications 

where contact with the soil could be expected. However, these treatments would occur on dense infestations of 

blackberry. Because the canopy of these infestations is continuous, herbicides are not expected to drift onto soil.

The herbicides that would be most used under the Proposed Action are triclopyr (40 percent), aminopyralid (15 

percent), glyphosate (15 percent), and imazapyr (10 percent). All other herbicides would be used on 5 percent or less 

of treatments (25 acres or less a year, on sites distributed throughout the District) and would cumulatively make up 

20 percent. The fate of the herbicides in soils is summarized in Table 3-16. Triclopyr is rated as moderately persistent 

in soils. Degradation occurs primarily through microbial metabolism, but degradation by water (hydrolysis) and 

light (photolysis) can be important. As plants die, release of triclopyr to the soil can occur and it can then be taken 

up by other plants. Aminopyralid is rated as non-persistent to persistent depending on soil type with low to 

intermediate potential for leaching or runoff. As described above, imazapyr (15 percent) would degrade slowly 

because of the soil pH. Glyphosate (10 percent) is tightly adsorbed to soil and is rapidly degraded by microbes 

(thus, has no soil activity). The use of glyphosate would drop by 75 percent when compared to the No Action 

Alternative. Given the small quantity of the remaining herbicides used and the distribution across the District, 

localized effects to soil function from all other herbicides would be negligible.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Soil

133

Table 3-16. Fate of Herbicides in Soils

Herbicide

Soil Half-life1

Aerobic

(Anaerobic)

Soil Adsorption 

(Koc)2

Fate in Environment

(Persistence Rating3)

SPISP II4 Ratings (potential)

Leaching 

(PLP)5

Solution 

Runoff 

(PSRP)6

Adsorbed 

Particle Runoff 

(PARP)7

Herbicides available under all Alternatives

2,4-D 10

(333)

Acid/Salt: 20 

mL/g

Ester: 100 mL/g 

Rapid microbial degradation within 1-4 weeks. (Non-Persistent) Intermediate

IntermediateIntermediate

Dicamba 14

(141)8 2 mL/g Mobile in soil but is easily degraded by microbes. (Non-Persistent) High Intermediate Low

Glyphosate 47

(12 to 70) 24,000 mL/g

Tightly adsorbed to soil and rapidly degraded by microbes, thus no soil activity. Adsorption 

is governed mainly by binding to the mineral components (PRI 2008 as cited in USDI 

2015a). The sorption is not dependent on the pH level (PRI 2008 as cited in USDI 2015a). 

Penetration into soils depends on soil type, with this herbicide reaching depths of 4 to 12 

inches in clay or loam soils and 8 to 18 inches in sandy soils depending on rainfall events 

(SERA 2011a). (Moderately Persistent)

Very

Low

Intermediate Low

Picloram 20-300

(> 500) 16 mL/g

Very slow microbial degradation and some photo-decomposition. Picloram is persistent for 

a year or more. Persistence is dependent on soil moisture and temperature; warm and 

moist soils degrade this herbicide rapidly. Picloram dissipates most slowly when soils are 

alkaline (> pH 7), fine textured (clay) and low in organic matter (USDA 2000b as cited in 

USDI 2010a:184). (Moderate to Persistent)

High High Intermediate

Herbicides available under the Proposed Action and Alternative 3

Aminopyralid 32 to 533

(462 to 990) 1.05 to 24.3 mL/g 

Broken down in the soil by microbes and sunlight. Main mode of degradation is microbial 

metabolism in soils, which can be slow in some soils, especially at lower soil depths and 

very slow in aquatic systems. Weakly sorbed to soil, so unlikely to be transported off-site by 

wind-blown soil. High potential for surface water runoff. Leaching has not been 

documented at levels below 30 centimeters. (Non-Persistent to Persistent, depending on 

soil type)

Low Intermediate

Intermediate

Chlorsulfuron 40

(109 to 263) 40 mL/g Relatively rapid degradation by microbial and chemical actions, trace amounts have extreme bioactivity (works well at low doses). (Moderately Persistent) High High Intermediate

Clopyralid 40

(> 1000)

6 mL/g, ranges to 

60 mL/g

Biodegradation is rapid in soil, reducing the potential for leaching or runoff. Degraded 

primarily by microbial metabolism. Resistant to degradation by sunlight, hydrolysis, or 

other chemical degradation. Water-soluble, does not bind strongly with soils, and has the 

potential to be highly mobile in soils, especially sandy soil. Not highly volatile. Possible 

release of herbicide from decaying plants with uptake by other plants. (Moderately 

Persistent)

High Intermediate Low

Diflufenzopyr 2 to 14

(20)

18 to 156 mL/g 

(avg. 87)

Biodegradation, photolysis, and hydrolysis are the primary mechanisms that remove 

diflufenzopyr from soil. (Non-Persistent) Low Intermediate Low

Imazapic 120 to 140

(> 1000) 137 mL/g Most imazapic is lost through bio-degradation. Sorption to soil increases with decreasing pH and increasing organic matter and clay content. (Persistent)

IntermediateIntermediate Low
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Soil

134

Herbicide

Soil Half-life1

Aerobic

(Anaerobic)

Soil Adsorption 

(Koc)2

Fate in Environment

(Persistence Rating3)

SPISP II4 Ratings (potential)

Leaching 

(PLP)5

Solution 

Runoff 

(PSRP)6

Adsorbed 

Particle Runoff 

(PARP)7

Imazapyr 25 to 141

(> 500) 100 mL/g

Adsorption is affected by aluminum and iron in soil more than by clay and organic matter, 

subject to microbial degradation except in cool temperatures. Adsorption is lower not only 

in soils with higher pH (> 5), but those with wetter conditions, lower organic matter, and 

sandier substrates (Tu et al. 2004 as cited in USDI 2015a). (Moderate to Persistent)

High High Intermediate

Metsulfuron methyl 30

(338) 35 mL/g Degradation by hydrolysis. (Non-Persistent) High High Intermediate

Sulfometuron methyl 20

(60) 78 mL/g Relatively rapid microbial and chemical degradation. However, trace amounts can be have an impact due to extreme bioactivity (works well at low doses). (Non-Persistent)

Intermediate High Low

Triclopyr 46

(< 1)

20 mL/g (salt)

780 mL/g (ester)

Degradation occurs primarily through microbial metabolism, but photolysis and hydrolysis 

can be important. As plants die, release of triclopyr to the soil can occur and it can then be 

taken up by other plants. (Moderately Persistent)

High High Intermediate

Herbicides available under Alternative 3

Fluroxypyr 7 to 23

(3.5 to 14) 50 to 136 mL/g

Mobile to very mobile in soil, but its movement is reduced by its quick initial microbial 

degradation. Degrades first to the pyridine and then to the methoxypyridine, which is 

persistent and has a high tendency to adsorb to soil, and is slowly degraded by microbial 

degradation and volatilization. Generally not found below a soil depth of 6 inches; varies 

depending on soil type (may be found deeper in coarser (sandy) soils) and rainfall. (Not 

Persistent)

Intermediate High Low

Hexazinone 90 54 mL/g

Soil organic matter content does not affect adsorption. Relatively low affinity for soil 

particles and dissolves in soil water. Biodegradation occurs as the plant uptakes it, and ties 

it up or degrades it. (Moderate to Persistent)

High High Intermediate

Rimsulfuron 5 to 40

(18) 19 to 74 mL/g

Breaks down rapidly in soil, with aerobic metabolism the primary route of degradation. Its 

mobility in soil ranges from moderate in clay and silt loams to very mobile in sandy loams. 

Its tendency to adsorb to soil varies by soil type, and is greatest in soils with high organic 

matter or clay content. Rimsulfuron has a low risk of leaching to groundwater. (Not 

Persistent to Moderately Persistent)

IntermediateIntermediate Low

Allowed in limited areas as part of Research and Demonstration under Alternative 3

Fluazifop-P-butyl 15

(> 2) 5700 mL/g Degraded primarily through microbial metabolism and hydrolysis, but not degraded readily by sunlight. Binds strongly with soils, so it is not highly mobile (Non-Persistent) Low Inter-mediate Intermediate

1. Half-life in days. Aerobic soils are drier and anaerobic soils are wetter (e.g., in riparian areas).

2. Koc: Soil organic carbon sorption coefficient of an active ingredient in mL/g. For a given chemical, the greater the Koc value, the less soluble the chemical is in water and the higher affinity the chemical has for soil organic 

carbon. For most chemicals, a higher affinity for soil organic carbon (greater Koc) results in less mobility in soil.

3. Persistence based on aerobic half-life. Non Persistent: less than 30 days; Moderately Persistent: 30 to 100 days; and Persistent: greater than 100 days (defined by Extoxnet Pesticides)

4. The source for this data is SPISP II = Soil Pesticide Interaction Screening Procedure version II

5. PLP: Pesticide Leaching Potential indicates the tendency of a pesticide to move in solution with water and leach below the root zone. A low rating indicates minimal movement and no need for mitigation.

6. PSRP: Pesticide Solution Runoff Potential indicates the tendency of a pesticide to move in surface runoff in the solution phase. A high rating indicates the greatest potential for pesticide loss in solution runoff.

7. PARP: Pesticide Adsorbed Runoff Potential indicates the tendency of a pesticide to move in surface runoff attached to soil particles. A low rating indicates minimal potential for pesticide movement adsorbed to 

sediment, and no mitigation is required.

8. Source: USEPA (2006)
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

135

Water Quality

Water Quality Issue 1

How would herbicide use affect the quality of surface water and groundwater used for domestic water supply?

Analytical Methods

The BLM bases the following conclusions regarding the risk of herbicide use to water quality on a review of GIS spatial data, State 

and Federal information, professional literature, and herbicide use expertise, both internal and external. The BLM uses Natural 

Resources Conservation Service (NRCS) median depth to highest water table70 (Map 3-1, Depth of Ground Water) and median 

saturated hydraulic conductivity71 data (Map 3-2, Saturated Hydraulic Conductivity and Table 3-17), Oregon Water Resources 

Department (OWRD) and consultant depth to water table data, herbicide movement values and ratings (Table 3-18), and United 

States Geological Survey aquifer descriptions to evaluate the potential for herbicide movement to groundwater. In addition, the BLM 

uses Oregon Department of Environmental Quality (ODEQ) and Oregon Health Authority information on water quality and drinking 

water protection, and OWRD information on water rights to provide a proximity context for herbicide treatments on BLM land and 

the location of source water areas for public water systems and known private points of diversion. The BLM then uses Risk

Assessments (Appendix C) to evaluate how herbicides affect water quality and domestic water supply.

Table 3-17. Median Saturated Hydraulic Conductivity (Ksat) Values for BLM land within the Analysis Area1

Ksat (ft./day)2 105 104 1000 100 10 1 0.1 0.01 0.001 0.0001 10-5 10-6 10-7

Ksat class Very High High Mod. High Mod. Low Low Very Low

Percentage of Acres on District3 0 0 0 0 86.1% 11.8% 2.1% 0 0 0 0 0 0

Relative Permeability Pervious Semi-Pervious Impervious

Aquifer Good Poor None

Soil Texture

Unconsolidated Clay & Organic 

Material Peat Layered Clay Unweathered Clay

Unconsolidated

Sand & Gravel

Well Sorted 

Gravel

Well Sorted Sand or 

Sand and Gravel Very Fine Sand, Silt, Loess, Loam

Consolidated Rocks Highly Fractured Rocks Oil Reservoir Rock Sandstone Limestone, 

Dolomite Granite

1. Table modified from Bear (1972).

2. Map 3-2 shows median saturated hydraulic conductivity values in micrometers per second. The BLM converted the values to feet per day for comparison with the 

other categories in the table.

3. Acres where Ksat value is greater than or equal to the Ksat value listed in header, but less than the next greatest value (e.g., 86.1 percent of acres on BLM land has 

a Ksat greater than or equal to 10 but less than 100.)

The spatial scale of this analysis (i.e., the analysis area) is all land within the Coos Bay District BLM boundary. Use of the term “the 

analysis area” refers to all ownerships, whereas mention of “BLM-managed land” refers only to Coos Bay District BLM-managed 

land.

The BLM bases the temporal scale for this analysis on herbicide persistence (Tables 3-15, Soil Order Properties and Extent and 3-18,

Selected Characteristics that Affect the Fate of Herbicides), the depth to water table, saturated hydraulic conductivity, and proximity 

of treatment locations to domestic water supplies. Triclopyr, for example, has moderate persistence in aerobic soils (half-life 46 

days), is non-persistent in anaerobic soils (half-life < 1 day), and is low risk for leaching. Given triclopyr’s relatively short half-life and 

its other characteristics, short-term (days to weeks) and long-term (months to years) water quality effects would not be expected at 

a domestic water source several miles distant from a dry season treatment area with a relatively deep water table. 

 70 Water table refers to the saturated zone in the soil (NRCS 2017a). 71 Saturated hydraulic conductivity (Ksat) is a quantitative measure of a saturated soil’s ability to transmit water when subjected to a hydraulic 

gradient, or the ease with which pores of a saturated soil permit water movement (NRCS 2017b).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

136

Table 3-18. Selected Characteristics that Affect the Fate of Herbicides

Herbicide Persistence in Water1 Persistence in Soils2

Half-life in 

Soils3

days

(aerobic)

Soil Adsorption 

(Koc) ml/g4

Pesticide Movement 

Rating5

Solubility 

mg/L6 Groundwater 

Leaching6

Surface Water 

Runoff6

Herbicides available under all alternatives

2,4-D Moderate Non-persistent 10 20 to 100 Moderate 33,900 Moderate Low

Dicamba Moderate Non-persistent 14 2 Very High 400,000 High Low

Glyphosate Moderate Moderate 47 24,000 Extremely Low 900,000 Low High

Picloram Moderate Moderate to Persistent 20 to 300 16 High to Very High 200,000 High Low

Herbicides available under the Proposed Action and Alternative 3

Aminopyralid Moderate Moderate to Persistent 32 to 533 1 to 24 High to Very High 2,480 High High

Chlorsulfuron Moderate Moderate 40 40 High 7,000 High Low

Clopyralid Moderate Moderate 40 6 to 60 High to Very High 300,000 High Low

Diflufenzopyr Low Non-persistent 2-14 18 to 156 Very Low to Moderate 5,850 Low Moderate

Imazapic High Persistent 120 to 140 206 High 2,200 Low Low

Imazapyr Moderate Moderate to Persistent 25 to 141 100 Moderate to Very High >11,000 High High

Metsulfuron methyl Moderate Non-persistent 30 35 High 9,500 High Moderate

Sulfometuron methyl Low Non-persistent 20 78 Moderate 70 Moderate Moderate

Triclopyr Moderate Moderate 46 20 to 780 Low to Very High 435 Low High

Herbicides available under Alternative 3

Fluazifop-P-butyl7 High Non-persistent Hours 2,010-5,700 Extremely Low to Very Low 1-2 Low -

Fluroxypyr Low Non-persistent 7 to 23 50 to 136 Low to Moderate 7,300 Low Low

Hexazinone High Moderate to Persistent 90 54 Very High 33,000 High Moderate

Rimsulfuron Low Non-persistent to Moderate 5 to 40 19 to 74 Low to High 7 Low Low

1. From USDI (2010a:199) and USDI (2016a:4-17).

2. From USDI (2010a:181). Persistence based on half-life in soils: non-persistent less than 30 days, moderately persistent 30 to 100 days, and persistent greater than 100 days.

3. In days. From USDI (2010a:181). See Table 3-15 for half-life in anaerobic soils.

4. Koc: Soil organic carbon sorption coefficient of an active ingredient in mL/g. For a given chemical, the greater the Koc value, the less soluble the chemical is in water and the higher affinity the chemical has for soil organic 

carbon. For most chemicals, a higher affinity for soil organic carbon (greater Koc) results in less mobility in soil. From USDI (2010a:59-61), USDI (2007a:4-15), and USDI (2016a:4-17).

5. Pesticide movement rating based on the Groundwater Ubiquity Score (GUS) = log10 (half-life) x [4 – log10 (Koc)] (Gustafson 1989). Pesticide movement rating extremely low (GUS < 0.1), very low (GUS 0.1 to 1.0), low 

(GUS 1.0 to 2.0), moderate (GUS 2.0 to 3.0), high (GUS 3.0 to 4.0), and very high (GUS > 4.0) (Vogue et al. 1994).

6. From USDI (2007a:4-28), and USDI (2016a:4-17).

7. Fluazifop-P-butyl information from SERA (2014).

Three physical properties determine the runoff and leaching potential of an herbicide: persistence (the time a chemical stays active), soil adsorption (the tendency of a chemical 

to bind to soil particles), and solubility (the tendency of a chemical to dissolve in water) (BPA 2000). Table 3-18 lists these properties for the proposed herbicides and provides a 

ranking for surface water runoff and leaching to groundwater potentials. Herbicides must be relatively persistent to have the potential to run off or leach. Herbicides with low 

solubility or that adsorb strongly to soil particles tend to run off with soil movement. Soils high in organic content or clay tend to be the most adsorptive, while sandy soils low in 

organic content are typically the least adsorptive (USDI 1991a as cited in USDI 2007a). Herbicides with low soil adsorption tend to leach down through the soil as do herbicides 

that are highly soluble.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

137

Affected Environment

The Coos Bay District BLM manages a relatively small percentage of the analysis area. There are 32 fifth field 

watersheds within the analysis area and the BLM manages less than 10 percent of the total acres. Two of the 

watersheds have no BLM-managed land, 20 watersheds have less than 5 percent BLM land, 7 watersheds have less 

than one-third BLM-managed land (8 to 28 percent), and 3 watersheds have between 35 and 52 percent BLMmanaged land.

Surface Water

Almost all precipitation in the analysis area occurs as rainfall from October to May and is due to frontal storms 

originating over the Pacific Ocean. Annual stream flow closely correlates with annual precipitation. Fall rains 

recharge soil moisture depleted by summertime evapotranspiration72 and stream flow. In winter, the rapid 

conversion of rainfall to runoff occurs because soils remain wet between frequent storms and evapotranspiration 

diminishes. During the spring, runoff decreases due to less rainfall, increasing transpiration by plants, and 

increasing canopy interception and evaporation of precipitation. Both rainfall and discharge drop to seasonally low 

levels in the summer.

Relatively few streams cross BLM-managed land compared to total stream miles in the analysis area. There are 

roughly 5,135 perennial stream miles and 14,233 intermittent stream miles in the analysis area. Approximately 14 

percent or 738 miles of the perennial streams and 17 percent or 2,442 miles of the intermittent streams cross 

BLM-managed land.

Section 303(d) of the Clean Water Act requires that the ODEQ develop a list of water bodies that do not meet 

water quality standards that protect the beneficial uses of rivers, streams, lakes, and estuaries. For streams 

crossing BLM-managed land, fish and aquatic life is the most common beneficial use, although water originating on 

BLM-managed land also supports public water systems and private residences. Oregon has narrative and numeric 

standards for toxic substances to protect aquatic life and human health (ODEQ 2014). Although there are 4,426 

miles of water quality limited streams and lakes within the analysis area according to the most recent (2012) 

303(d) list (ODEQ 2015), there are no listings for toxic substances, including herbicides.

The ODEQ and the Oregon Health Authority completed source water assessments between 1999 and 2005 for all 

Oregon public water systems that have at least 15 hookups or serve more than 25 people year-round (ODEQ 

2017a). The ODEQ and Oregon Health Authority defined surface water source areas that supply public water 

systems. The BLM manages just under 10 percent of the land, within 8 of the 19 surface water source area public 

water systems (ODEQ 2017b). BLM acreage as a percentage of total acreage is greatest in the North Fork Coquille 

River watershed serving the City of Myrtle Point (44 percent) and the Coquille River watershed serving the City of 

Coquille (14 percent).

The ODEQ recommends that the BLM establish direct communication with public water system operators 

downstream of BLM planned projects with potential to affect water quality. To protect public water systems, the 

ODEQ also generally recommends 100 or 200-foot stream buffers within 500 to 1,000 feet of a public water system 

intake, and suggests that BLM’s management in municipal watersheds/aquifers should support the overall goal of 

providing the highest quality water possible downstream at intakes and wells (USDI 2010a:192).

In addition to public water systems, private residences sometimes use springs and streams on adjacent BLM land 

for domestic water supplies. The BLM requires a valid water right to grant a right-of-way to pipe water from a 

 72 The water lost to the atmosphere from the ground surface, evaporation from the surface of vegetation, and the transpiration 

of groundwater by plants.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

138

point of diversion on BLM-managed land to a place of use on private land. Point of diversion information for the 

analysis area is readily available via a 2016 OWRD GIS layer and the searchable OWRD Water Rights Information 

System (OWRD 2016, OWRD 2017a). Coos Bay District hydrologists consult these resources when working with 

herbicide applicators to make sure that water right holders are aware of proposed herbicide treatments in their 

area, and to eliminate or minimize the risk of surface water contamination. As described in Socioeconomics Issue 4, 

BLM also protects points of diversion on federal land without water rights by notifying adjacent landowners prior 

to herbicide application to give the public the opportunity to disclose the location of water systems that should be 

buffered from herbicide applications.

Groundwater

Shallow wells and unconsolidated aquifer materials increase the likelihood of herbicide detection in groundwater 

(USDI 2016a:4-16). Unconsolidated-deposit aquifers underlie approximately 13 percent of all land and just 6 

percent of BLM-managed land in the analysis area (Whitehead 1994). Groundwater is commonly available from 

shallow wells in unconsolidated-deposit aquifers that primarily consist of sand and gravel with variable quantities 

of clay and silt. Unconsolidated-deposit aquifers are prevalent along present and ancestral stream valleys and in 

lowlands; areas that are generally thousands of feet to miles distant from BLM-managed land and road rights-ofway where herbicides would be applied. Unconsolidated-deposit aquifers are concentrated along the coast, west 

of the Coast Range, primarily between Port Orford to south of Florence. This aquifer type is also associated with 

Coos Bay and the surrounding sloughs as well as the river valleys of the Umpqua and the Smith. In the analysis 

area, greater than 90 percent of the 182 wells mapped by the OWRD occur in unconsolidated-deposit aquifers 

(OWRD 2017b). Only 15 wells are mapped in pre-Miocene (23 to 5.3 million years before present) rock aquifers 

that underlie approximately 87 percent of all land and 94 percent of BLM-managed land in the analysis area 

(Whitehead 1994, OWRD 2017b). These aquifers are in the mountainous areas and they consist on 

undifferentiated volcanic rocks, undifferentiated consolidated sedimentary rocks, and undifferentiated igneous 

and metamorphic rocks.

Groundwater data (i.e., depth to the water table) is relatively limited in the analysis area and based on soil surveys 

and well logs. Generalized estimates of the median depth to highest water table are available from the NRCS (Map 

3-1, NRCS 2016). Map 3-1 displays median depth to highest water table in six different categories ranging from 

shallow (0 to 25 centimeters) to deep (> 200 centimeters). Nearly 82 percent of BLM-managed land falls into the 

deep category, and deeper water tables are less susceptible to herbicide contamination (USDI 2016a:4-16). The 

highest water tables (0 to 25 centimeters) occupy 4 percent of BLM-managed land and are concentrated at the 

Dean Creek Elk Viewing Area, North Spit, and New River. Dean Creek is a diked, tide-gated pasture next to the 

Umpqua River and seasonally high rainfall and river levels retard drainage, leading to higher water tables. The 

North Spit and New River areas are sandy and highly permeable, and their water tables rise relatively quickly in 

response to rainfall.

Wells not on BLM-managed land offer site-specific water table information. Three of the 15 pre-Miocene rock 

aquifer wells and 30 of the 167 unconsolidated-deposit aquifer wells mapped by the OWRD have hydrographs 

showing yearly water table fluctuations (OWRD 2017b). The three pre-Miocene rock aquifer wells are located 

along the Highway 101 corridor and they have water table depths from 55 to 135 feet, 25 to 29 feet, and 29 to 31 

feet. The minimum water table depth ranges from 0 to 75 feet (median 15 feet) and the maximum water table 

depth ranges from 6 to 112 feet (median 34.5 feet) for the 30 unconsolidated-deposit aquifer wells also located 

along the Highway 101 corridor.

Site-specific water table information is also available for North Spit monitoring wells in unconsolidated-deposit 

aquifers both on and off BLM land. A consulting firm measured water depth below the ground surface in 29 wells 

during the wet season between October 4, 2004 and January 25, 2005. Water depths in the 20 wells on BLM land 

ranged from 5.5 to 23.4 feet (median 8.5 feet) and water depths in the 9 wells on private land ranged from 7.1 to 

35.1 feet (median 8.9 feet) (PES Environmental 2005).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

139

The BLM Umpqua Field Office hydrologist measured summertime water depths with continuous data loggers in 

three hand-augured wells in an unconsolidated-deposit aquifer in the field south of the main parking lot at the 

Dean Creek Elk Viewing Area in 2004 and found that maximum depths were 4.3, 4.5, and 4.7 feet below the 

ground surface.

The ODEQ and Oregon Health Authority completed source water assessments between 1999 and 2005 and defined 

groundwater source areas that supply public water systems. The BLM manages land in only 8 of the 95 

groundwater source areas in the analysis area (ODEQ 2017c). Four of the source areas serve BLM recreation sites: 

Loon Lake, Dean Creek Elk Viewing Area, Edson Creek Campground, and the Sixes River Campground. Although 

there are groundwater source areas associated with the Dean Creek Elk Viewing Area and the Sixes River 

Campground, groundwater is no longer used at either site. Dean Creek receives water from the City of Reedsport 

system and the BLM no longer provides water to campers at Sixes. The BLM manages less than 65 acres in 7 of the 

source areas, and manages 3,132 acres or 3 percent of the City of Gold Beach source area.

The ODEQ and Oregon Health Authority inventoried each of the groundwater source areas to determine potential 

sources of contamination. The ODEQ did not specifically identify herbicide use in their GIS layer that shows 

potential contaminants as of October 2005 (ODEQ 2005), but they did assign a higher risk for well contamination in 

one groundwater source area with no BLM land due to industrial pesticide, fertilizer, and petroleum storage, 

handling, and mixing.

Private residences use springs and streams on adjacent BLM land for drinking water, irrigation, and livestock 

watering among other uses, but there are no water rights connected to private wells as points of diversion on 

BLM-managed land (OWRD 2016). There are many exempt uses for groundwater that do not require a water right 

(OWRD 2013) so it is possible that unknown wells exist on BLM land. BLM notification of adjoining landowners 

prior to herbicide application gives the public an opportunity to disclose the location of water systems so the BLM 

can implement water quality protection measures.

Treatments Planned Related to the Issues

No Action Alternative

The BLM would treat approximately 800 gross acres annually with herbicides (80 percent of all noxious weed 

treatments). The BLM would use glyphosate for approximately 95 percent of the herbicide treatments and 2,4-D, 

dicamba, picloram, or a tank mix of two or more of these for 5 percent of the herbicide treatments. The BLM 

would not use herbicides in the New River western snowy plover habitat restoration area and would only use 

limited amounts of glyphosate in the North Spit western snowy plover habitat restoration area.

Proposed Action

The BLM would treat approximately 900 gross acres annually with herbicides (90 percent of all terrestrial invasive 

plant treatments). Nine additional herbicides would be available for use under the Proposed Action compared to 

the No Action Alternative. The BLM would use triclopyr for approximately 40 percent of the herbicide treatments, 

aminopyralid for 15 percent of the treatments, and glyphosate for 15 percent of the treatments. Spot treatments 

would account for 95 percent of herbicide treatments and broadcast treatments would account for 5 percent. 

Similar to the No Action Alternative, the BLM would not use herbicides in the New River western snowy plover

habitat restoration area and would only use limited amounts of glyphosate in the North Spit western snowy plover 

habitat restoration area.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

140

Alternative 3

Alternative 3 is the same as the Proposed Action, except that it also allows the BLM to use the herbicides 

hexazinone, rimsulfuron, fluroxypyr, fluazifop-P-butyl, and allows the BLM to use herbicides other than glyphosate 

in western snowy plover habitat at the North Spit and New River. The BLM would use hexazinone and rimsulfuron 

approximately one percent of the time when herbicides are used, and the BLM would very rarely use fluazifop-Pbutyl and fluroxypyr. In western snowy plover habitat restoration areas, the BLM would use imazapyr + glyphosate 

to treat approximately 100 acres of European beachgrass annually.

Standard Operating Procedures and Mitigation Measures for All 

Alternatives Relevant to the Issue

The BLM would implement Standard Operating Procedures and Mitigation Measures (see Appendix A) to minimize 

the potential for adverse herbicide-related effects to water resources. These include, but are not limited to:

• Review hydrogeologic maps of proposed treatment areas. Note depths to groundwater and areas of shallow 

groundwater and areas of surface water and groundwater interaction. Minimize treating areas with high risk 

for groundwater contamination.

• Buffer intermittent stream channels when there is a prediction of rain (including thunderstorms) within 

48 hours.

• Use drift reduction agents, as appropriate, to reduce the drift hazard.

• Plan to treat between weather fronts (calms) and at appropriate time of day to avoid high winds that 

increase water movements, and to avoid potential stormwater runoff and water turbidity.

• Maintain buffers between treatment areas and water bodies. Buffer widths should be developed based on 

herbicide and site-specific conditions to minimize impacts to water bodies.

• Conduct mixing and loading operations in an area where an accidental spill would not contaminate an 

aquatic body.

• To protect domestic water sources, no herbicide treatments should occur within 100 feet of a well or 200 

feet of a spring or known diversion used as a domestic water source unless a written waiver is granted by 

the user or owner.

• Site-specific analyses for roadside treatments should specifically consider that drainage ditches and

structures lead to streams and that normal buffer distances, herbicide selection, and treatment method 

selection may need to be changed accordingly, particularly where those ditches are connected to streams 

with Federally Listed or other Special Status species.

• Proposals to boom spray herbicides within 200 feet of streams that are within 1,000 feet upstream from a 

public water supply intake, or spot apply herbicides within 100 feet of streams that are within 500 feet 

upstream from a public water supply intake, will include coordination with the Oregon Department of 

Environmental Quality and the municipality to whom the intake belongs.

During preparation of the Annual Treatment Plan, the BLM would identify domestic water sources, areas with 

shallow groundwater, and areas of groundwater-surface water interaction and suggest appropriate treatment 

methods to minimize the risk of herbicide leaching.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

141

Environmental Consequences

Direct and Indirect Effects

Common to All Alternatives

Herbicide treatments under all alternatives have the potential to affect the quality of surface water and 

groundwater on or near BLM land used for domestic purposes. The routes for this potential water contamination 

are drift into streams from spraying, runoff (e.g., from a rainstorm soon after application), and leaching through 

soil into groundwater. The proportion of herbicide that is on or in the plant, soil, and water after application 

influences whether an herbicide will runoff, drift, or leach; application method, weather conditions (application 

timing), herbicide formulation and application rate, and amount and type of vegetation and groundcover influence 

this proportion (Kerle et al. 2007).

Herbicide contamination can also occur because of direct application to water. However, this is not expected 

under any alternative; the BLM is not proposing direct application of herbicides to surface water and accidental 

spills into water are both unlikely due to Protection Measures (see Appendix A), and have not occurred since the

BLM has implemented its integrated invasive plant program (Jeanne Standley, Coos Bay Weed Coordinator, 2018 

personal communication).

The BLM’s application methods decrease the chance that herbicides would redistribute within the application site 

or move off site where they may contaminate surface water or groundwater. The BLM would primarily use handdirected sprayers for herbicide applications because the applicator can target specific plants and minimize 

herbicide contact with the soil or water. Under the No Action Alternative, all applications would be spot 

treatments, whereas under the action alternatives, 95 percent would be spot treatments and 5 percent would be 

broadcast treatments. No aerial application would occur, and drift reduction agents are used when appropriate. A 

Standard Operating Procedure specifies no-herbicide buffer distances from water bodies, which are based on 

herbicide properties and site-specific conditions.

Drift into streams from the proposed invasive plants treatments is of minimal concern under all alternatives. Aerial 

herbicide application is the method most likely to result in herbicides getting onto non-target areas such as stream 

channels (USDI 2010a:65, 200). While this is done on neighboring lands by timber companies, the BLM is not 

proposing aerial applications, but is instead almost exclusively using hand-directed sprayers for targeted spot 

applications. The herbicides that BLM uses have very low vapor pressures and BLM spray mixtures do not produce 

much vapor (see Appendix C, Herbicide Risk Assessment Summaries, for more information). In addition, the BLM 

would apply herbicide between weather fronts and at the time of day when winds are calm. Movement of 

herbicides from wind erosion of soil would be minimal due to the dense groundcover in the analysis area (USDI 

2010a:200) and smaller infestations sizes (see Table 2-2, Summary of Invasive Plants Documented in NISIMS by 

Infestation Size). Drift reduction agents would be used if needed (for example, with sulfonylureas herbicides, which 

can be more prone to drift or in windy areas) to reduce drift.

Application timing also decreases the chance that herbicides would contaminate surface water or groundwater. 

Berg (2004) reported that herbicides applied in or along dry intermittent stream channels may enter streams 

through runoff if a higher intensity or longer duration rainstorm occurs soon after treatment. The BLM would 

buffer dry intermittent stream channels when there is a prediction of rain within 48 hours to reduce the risk that 

herbicide adsorbed to sediment would move within or toward streams. The BLM would apply herbicides primarily 

during the dry season (May through September with some applications outside this period if rainfall is not 

expected) allowing time for microbial, chemical, and photo degradation prior to rainfall. Therefore, the probability 

of a higher intensity or longer duration rainstorm soon after application of herbicides would be low. The rate of 

microbial degradation would be greater during the dry season when the weather is warmer, and herbicides 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

142

applied to foliage during the dry season would be less likely over time to wash off as they incorporate into (leaf) 

surface waxes (Kerle et al. 2007). Hence, it is unlikely that herbicides would run off into surface water. However, if 

rain were to occur following herbicide application, herbicide runoff to surface water is possible, and the potential 

for it to occur varies by herbicide (and hence, varies by alternative).

Herbicide leaching to groundwater is possible, and varies by alternative. However, maximizing the amount of 

herbicide that gets on the plant (and not the soil), using the minimum amount of herbicide necessary, and applying 

herbicide during the dry season when depth to groundwater is greatest, reduces the likelihood of herbicides with 

low soil adsorption or high solubility reaching groundwater. Although the median saturated hydraulic conductivity 

is high or very high for 87 percent of BLM land (see Table 3-17, Median Saturated Hydraulic Conductivity (Ksat) 

Values for BLM land within the Analysis Area), herbicides may not make it to the water table for transport off-site 

or its movement within the saturated zone may be slowed by confining layers of clay and silt. Nearly 82 percent of 

BLM managed-land in the analysis area has a greater than 200 centimeter median depth to highest water table, 

and the summertime water table is deeper. If herbicides make it to the groundwater and move offsite, the 

potentially long distances between treatment sites and public water system and private points of diversion 

together with dilution and chemical degradation make contamination less likely. Most water rights (surface and 

well), cluster in river and stream valleys and lowlands toward the coast where BLM manages relatively little land. 

Most BLM land and road rights-of-way are in headwater areas or higher in watersheds where there are far fewer 

points of diversion. BLM manages just 6 percent of the area with unconsolidated-deposit aquifers where 

groundwater is commonly available from shallow wells. Only 4 percent of the records in the 2016 OWRD points of 

diversion GIS layer overlap BLM land.

Table 3-19 is a summary of the potential risks to water for herbicides considered under all alternatives in this 

analysis.

Table 3-19. Effects of herbicides available under all alternatives1 (Water)

2,4-D

Some forms of 2.4-D are registered for use in aquatic systems. 2,4-D is a known groundwater contaminant 

meaning that it has been detected in groundwater, but not necessarily at levels exceeding any established 

health standard. The pesticide movement rating for 2,4-D is moderate due in part to its relatively short halflife in soils. In terrestrial applications, most formulations of 2,4-D do not bind tightly with soils, and therefore 

have a moderate potential to leach into the soil column and to move off site in surface or subsurface water 

flows (Johnson et al. 1995, cited in Tu et al. 2001). 2,4-D amine (aquatic formulation) is the preferred form and 

it is not persistent under most environmental conditions (Jervais et al. 2008).

Dicamba

Because dicamba is mobile in soil, application of this herbicide can result in groundwater and surface water 

contamination. Biodegradation is the major mechanism for dicamba degradation in water. Dicamba is a 

known groundwater contaminant, and has a high potential to leach into groundwater. The EPA has set health 

advisory concentration levels for dicamba (e.g., 300 μg/L for 1-day exposures), but has not set maximum 

concentration limits for potable water. A regional study of pesticides in shallow groundwater in Delaware, 

Maryland, and Virginia detected dicamba in groundwater at low concentrations, generally less than 3 μg/L 

(ppb) (Koterba et al. 1993).

Glyphosate

While glyphosate is very water soluble, it is unlikely to enter water through surface runoff or subsurface flow 

because it binds strongly to soil particles, except when the soil itself washes away by runoff. Even then, it 

remains bound to soil particles and is generally unavailable (Rueppel et al. 1977, Malik et al. 1989, all cited in 

Tu et al. 2001). The pesticide movement rating for glyphosate is extremely low.

Picloram

Picloram has a high to very high pesticide movement rating because it is persistent in soils and does not bind 

strongly with soil particles. Woodburn et al. (1989, cited in Tu et al. 2001) found that the half-life of picloram 

in water was 2 to 3 days but the EPA reported it stable to hydrolysis (the chemical breakdown of a compound 

due to reaction with water) and unlikely to degrade in groundwater, even over several years (USEPA 1995). 

1. Adapted from the Oregon FEIS (USDI 2010a: 194-198) and the herbicide Risk Assessments.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

143

No Action Alternative

The BLM would use glyphosate for approximately 95 percent of the herbicide treatments and 2,4-D, dicamba, 

picloram, or a tank mix of two or more of these for 5 percent of the herbicide treatments. 2,4-D, dicamba, and 

picloram are known groundwater contaminants, although potentially in different soils or scenarios than found in 

the analysis area. As shown in Table 3-19, glyphosate would tightly bind to soil particles and is hence unlikely to 

leach into groundwater. If it were to run off, it would remain tightly bound to soil particles.

The BLM would use aquatic formulations of herbicides when near water. The aquatic formulations of 2,4-D and 

glyphosate are 0 risk to aquatic organisms under all scenarios, and dicamba (not an aquatic herbicide) is 0 risk 

except in accidental spill scenarios involving aquatic invertebrates. Picloram and ester forms of 2,4-D are not 

labeled for use in riparian areas and in Special Status species habitat. ARBO II requires a 50-foot no-treatment spot 

spray buffer for these herbicides along dry intermittent streams and dry roadside ditches to protect water quality. 

According to Table 2–10, Treatment Key, the BLM would apply 2,4-D, dicamba, picloram, or a combination of two 

of these three herbicides at typical rates or below maximum rates in almost all scenarios. Maximum rate 

applications are proposed for 2,4-D (3.5 gross acres over the life of the plan) and dicamba + 2,4-D (only dicamba at 

maximum rate on 4 gross acres over the life of the plan). Using less of the herbicides known to contaminate 

groundwater, and implementing Protection Measures to prevent application near points of diversion used for 

water supplies minimize risk. If herbicides available under this alternative did reach domestic-use groundwater 

sources despite Protection Measures, Risk Assessments for human consumption of contaminated water show no 

risk at typical rates of application for all herbicides and low risk for dicamba and glyphosate applied at the 

maximum rate (see Human Health Issue 1 for additional detail). Dicamba would be applied at the maximum rate to 

few acres, and glyphosate would be applied at typical and below maximum application rates.

The BLM would not use herbicides in the New River western snowy plover habitat restoration area and would only 

use glyphosate in the North Spit western snowy plover habitat restoration area on up to 24 acres. Use of 

glyphosate on the North Spit would not affect the municipal wells to the north. Glyphosate would be applied to 

minimize contact with the sand/soil. Should it contact the ground, it has a low leaching potential and it would be 

applied after September 15th inside the western snowy plover habitat restoration areas or in late summer outside 

the habitat restoration areas when the water table is at or near maximum depth. The summer water table in the 

plover area is likely relatively deep (10 to 15 or more feet) based on the 2005 North Spit water table data and the 

site topography. The plover area is down gradient from the Coos Bay-North Bend Water Board sand dune wellfield, 

so even if herbicide were to reach the water table, it would not affect the quality of water withdrawn for municipal 

and industrial uses. The southernmost Water Board well, Well 46, is located approximately 4 miles to the 

northeast of the plover area and groundwater flow in the vicinity of this well is south towards Coos Bay (CH2M Hill 

1995:6-14).

The use of glyphosate at the Dean Creek Elk Viewing Area would not affect potable water used on-site or affect 

downriver points of diversion. The water for the Elk Viewing Area comes from the City of Reedsport and not 

surface or groundwater sources at the recreation area. Although the summertime water table is relatively shallow 

in the pastures of the Elk Viewing Area (less than 5 feet), glyphosate contacting the soil would bind to the organic 

rich material and be prevented from leaching to groundwater.

Water quality effects from glyphosate use at Loon Lake and the Edson Creek campground are not anticipated. 

Glyphosate would be applied to minimize contact with the soil, and should it contact the soil, it would not be 

expected to leach to the groundwater. Limited treatment areas at each site (approximately 1⁄4 acre (Jeanne 

Standley, Coos Bay Weed Coordinator, 2018 personal communication)) would be greater than 100 feet from the 

professionally drilled and cased wells that serve these recreation sites.

Short term (days to weeks) and long term (months to years) water quality effects are not expected with herbicide 

applications under the No Action Alternative because BLM would apply herbicides in such a manner to prevent 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

144

water contact during initial application and prevent water contact during herbicide degradation. Glyphosate is 

moderately persistent in soils, but it would be applied to minimize contact with soil and it would not likely move 

off site should it contact soil. 2,4-D and dicamba are non-persistent in soils, would be used over a limited area, and, 

like glyphosate, would be applied to minimize soil contact. Picloram is moderate to persistent in soils, but would 

also be applied over a limited area, applied to minimize soil contact, and applied with appropriate Protection 

Measures in place to protect domestic water supplies. Repeated applications with longer half-life herbicides can 

lead to herbicide persistence in the environment (Hanson et al. 2015). In contrast, several months to one year or 

more would elapse between treatments at any one site under the No Action Alternative, so herbicides would have 

time to break down.

Proposed Action

Nine additional herbicides would be available for use under the Proposed Action. The BLM would use triclopyr for 

approximately 40 percent of the herbicide treatments, aminopyralid for 15 percent, glyphosate for 15 percent, and 

imazapyr for 10 percent. Aquatic formulations of triclopyr, glyphosate, and imazapyr are available and they require 

no buffer when spot spraying near dry intermittent streams, dry intermittent wetlands, and dry roadside ditches 

because they present no risk to aquatic organisms. The non-aquatic form of triclopyr is not registered for use in 

riparian areas or Special Status species habitat, and ARBO II requires a 150-foot spot spray buffer on dry 

intermittent streams and wetlands, and dry roadside ditches to protect aquatic organisms. Aquatic triclopyr, 

glyphosate, and imazapyr would be used at the Dean Creek Elk Viewing Area, Loon Lake, and the Edson Creek 

campground. An acre or less would be treated at each of these recreation sites (Jeanne Standley, Coos Bay Weed 

Coordinator, 2018 personal communication) and Protection Measures would be used to minimize herbicide 

contact with soil and appropriately buffer the wells serving Loon Lake and Edson Creek. Aminopyralid would also 

be used at Dean Creek. Aminopyralid has a high risk for leaching (Table 3-18, Selected Characteristics that Affect 

the Fate of Herbicides). The Dean Creek summertime water table is lower than one foot, but given aminopyralid’s 

moderate to persistent half-life in soil, herbicide residues could come in contact with the wintertime water table; 

however, past studies have not documented leaching of aminopyralid at levels below one foot (Table 3-20) and 

aminopyralid presents no risks to animals or humans (See Fish and Aquatic Organisms Issue 1, Wildlife Issue 1, 

Human Health Issue 1 and Recreation Issue 1). Appropriate Protection Measures (See Appendix A) to protect water 

quality would be identified during review of the Annual Treatment Plan.

Triclopyr and glyphosate have a low risk for leaching (Table 3-18), so applications in headwater areas or higher in 

watersheds would not affect domestic water supplies that are generally thousands of feet to miles distant. 

Treatments would happen during the dry season (May through September) in areas where the water table is feet 

below the surface, and applicators would minimize the amount of herbicide delivered to the soil surface. 

Treatment methods that prevent water contact during herbicide application and the rate of degradation would 

prevent short- and long-term water quality impacts. Aminopyralid and imazapyr can be more persistent in soil than 

triclopyr and glyphosate, and they have a high risk for leaching. Imazapyr, however, is not known to be a 

groundwater contaminant (Table 3-20). The lack of proximity to the summertime water table at the time of 

application and the lack of proximity to domestic water sources would allow time for degradation of these 

moderate to persistent herbicides (Table 3-18).

Chlorsulfuron and clopyralid have a high risk for leaching (Table 3-18), but chlorsulfuron is not known to be a 

groundwater contaminant and clopyralid leaching and subsequent contamination of groundwater appear to be 

minimal (Table 3-20). Both diflufenzopyr and imazapic are low risk for leaching (Table 3-18). Metsulfuron methyl 

and sulfometuron methyl are not known to be groundwater contaminants (Table 3-20) despite having increased 

risk for leaching (Table 3-18). The BLM may use aminopyralid, chlorsulfuron, imazapyr, and metsulfuron methyl (4 

of the 5 Proposed Action herbicides in Table 3-18 with a high risk of leaching) up to the maximum application rate 

on approximately 3,460 gross acres over the life of the plan (see Table D-4, Estimated Treatment Acres, 20-Year 

Analysis Period). The risk of adverse effects to water supplies from these four herbicides or any of the nine 

herbicides available under the Proposed Action would be reduced by using spot treatments to minimize herbicide 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

145

contact with the soil, avoiding areas with points of diversion or increased risk of groundwater contamination, and 

working with adjacent landowners if there are concerns. If herbicides available under the Proposed Action did 

reach domestic-use water sources despite Protection Measures, Risk Assessments for human consumption of 

contaminated water show no risk at typical rates of application for all herbicides and low risk for clopyralid and 

triclopyr applied at the maximum rate (see Human Health Issue 1 for additional detail). Mitigation Measures limit 

triclopyr application to the typical rate where feasible, and BLM would apply clopyralid at typical to below 

maximum application rates, thereby reducing the already low risk associated with these herbicides.

As described under the No Action Alternative, the BLM would not use herbicides in the New River habitat 

restoration area and would only use glyphosate in the North Spit habitat restoration area. As described above, use 

of glyphosate on the North Spit would not affect the municipal wells to the north.

Table 3-20. Effects of herbicides available under the Proposed Action and Alternative 31 (Water)

Aminopyralid

Aminopyralid is moderately persistent and has high mobility in most soils because of its low soil adsorption 

values (USEPA 2005a). Therefore, it is transported to surface water and groundwater. Breakdown by microbes 

in soil is the primary form of dissipation. Aminopyralid’s mobility and high water solubility suggest that the 

herbicide is prone to leaching (Lindenmeyer 2012). However, in past studies, leaching of aminopyralid has not 

been documented at levels below one foot (USEPA 2005b).

Chlorsulfuron Chlorsulfuron is not known to be a groundwater contaminant, but has a high potential to leach.

Clopyralid

Clopyralid does not appear to bind tightly to soil and will leach under favorable conditions. However, leaching 

and subsequent contamination of groundwater appear to be minimal (SERA 2004b), which is consistent with a 

short-term monitoring study of clopyralid in surface water after an aerial application (Rice et al. 1997a, cited in 

SERA 2004b). Clopyralid is not known to be a common groundwater contaminant, and no major off-site 

movement has been documented.

Diflufenzopyr

Diflufenzopyr is not a known groundwater contaminant. Biodegradation, photolysis, and hydrolysis are 

important mechanisms in removing diflufenzopyr from aquatic systems. Its half-life is less than 1 month, with 

hydrolysis and photolysis rates higher in acidic environments. The aquatic dissipation half-life for diflufenzopyr 

is 25 to 26 days in aerobic and 20 days in anaerobic conditions. The expected half-life of diflufenzopyr in small 

ponds is estimated at 24 days. These factors suggest that diflufenzopyr would be removed from an aquatic 

environment relatively rapidly if contamination occurred (USEPA 1999).

Imazapic

Little is known about the occurrence, fate, or transport of imazapic in surface water or groundwater (Battaglin 

et al. 2000). However, according to the herbicide label for Plateau, in which imazapic is the active ingredient, it 

is believed to be a groundwater contaminant (BASF 2008). 

Imazapyr

In their literature review of imazapyr, Tu et al. (2001) found no reports of imazapyr contamination in water, 

despite its potential for mobility. It is not known to be a groundwater contaminant. Battaglin et al. (2000) 

stated that little is known about its occurrence, fate, or transport in surface water or groundwater. In one 

study, imazapyr (from terrestrial applications) was detected in 4 percent of the 133 samples taken from 

streams, but was not detected in reservoirs or groundwater.

Metsulfuron 

methyl Metsulfuron methyl is not known to be a groundwater contaminant, although it has a high potential to leach. 

Sulfometuron 

methyl

Degrades quickly by hydrolysis in acidic water but is stable in neutral water. Aquatic dissipation half-lives are 

estimated at 1 to 3 days to 2 months in aerobic systems and several months in anaerobic sediments (Extoxnet 

1996). It is not known to be a groundwater contaminant. In one surface water study, sulfometuron methyl was 

detected in 2 percent of 133 samples taken from streams. 

Triclopyr

The salt form of triclopyr (TEA) is soluble in water and photodegrades in several hours with adequate sunlight. 

The terrestrial form of triclopyr (BEE) is not water-soluble and can partition into organic materials and be 

transported to sediments, where it is persistent. Alternatively, bound ester forms can degrade through 

hydrolysis or photolysis to triclopyr acid (Smith 1976 cited in Tu et al. 2001), which will diffuse into the water 

column and continue to degrade (Tu et al. 2001).

1. Adapted from the 2007 PEIS (USDI 2007a:4-30 to 4–34), the Oregon FEIS (USDI 2010a:195-198), the 2016 PEIS (USDI 2016a:4-17 to 4-18), and 

the herbicide Risk Assessments.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

146

Alternative 3

Four additional herbicides would be available under Alternative 3, but their use would be limited. BLM would use 

hexazinone and rimsulfuron approximately one percent of the time when herbicides are used, and fluazifop-Pbutyl and fluroxypyr very rarely. The BLM would generally not use fluroxypyr, hexazinone, or rimsulfuron in sandy 

environments due to the potential for groundwater contamination, and the BLM would not use these herbicides in 

other environments where groundwater contamination and source water contamination are concerns.

Use of imazapyr + glyphosate on the North Spit would not affect the municipal wells to the north. Glyphosate has a 

low leaching potential, and imazapyr has a high potential for leaching (Table 3-18), but it is not known to be a 

groundwater contaminant (Table 3-20). Herbicides would be applied to minimize contact with the sand/soil, and 

herbicides would be applied after September 15th when the water table is at or near maximum depth. The western 

snowy plover habitat restoration area is down gradient from the Coos Bay-North Bend Water Board sand dune 

wellfield so even if herbicide were to reach the water table it would not affect the quality of water withdrawn for 

municipal and industrial uses. The southernmost Water Board well, Well 46, is located approximately 4 miles to 

the northeast of the habitat restoration area and groundwater flow in the vicinity of this well is south towards 

Coos Bay (CH2M Hill 1995:6–14).

Use of imazapyr + glyphosate on the foredune west of New River would not affect two water rights to the east of 

New River. There is an irrigation water right with a point of diversion on a tributary approximately 800 feet 

upstream from the confluence with New River, and a recreation water right for an impoundment on a different 

tributary approximately 1,800 feet upstream from the confluence with New River. Spot treatments on calm days 

west of New River would not produce drift that would reach either point of diversion east of New River, and spot 

treatments would minimize the amount of herbicide on the sand/soil surface after application. If herbicide moves 

subsurface or makes it to the water table, it would be downgradient from the points of diversion and therefore 

would have no effect on the quality of surface water used for irrigation and recreation. Even with no threat to 

water quality, the BLM would notify adjacent landowners prior to the use of herbicides and address their concerns.

All other effects remain as described under the Proposed Action.

Table 3-21. Effects of herbicides available only under Alternative 31 (Water)

Fluazifop-PbutylFluazifop-P-butyl is non-persistent in soil, has an extremely low to very low pesticide movement rating, and a 

low risk of leaching (See Table 3-18, Selected Characteristics that Affect the Fate of Herbicides).

Fluroxypyr 

Based on soil adsorption characteristics, fluroxypyr is expected to have a high mobility in soil. However, it has a 

low potential for movement to groundwater because it is rapidly broken down by microbes in the soil (soil 

half-life is 1 to 3 weeks (California Department of Pesticide Regulation 2005, National Library of Medicine 

2011). In field studies submitted to the EPA, fluroxypyr was generally not found below a soil depth of 6 inches 

(USEPA 1998), although this may vary depending on soil type and amount of rainfall. In sandy soils, the 

potential to leach to groundwater is much higher, and has been identified as a concern (NYSDEC 2006). Factors 

that influence the rate of fluroxypyr degradation in soils include soil microbes, organic matter, temperature, 

and soil moisture (Tao and Yang 2011).

Hexazinone

Hexazinone and its degradates persist, are highly mobile, and are readily washed into surface waters. 

Hexazinone has been identified as a groundwater contaminant in seven states. The EPA requires a 

groundwater advisory on all product labels stating that hexazinone must not be used on permeable soils.

Rimsulfuron

Rimsulfuron is unstable in soil, and therefore likely has a low risk of leaching to groundwater. The pH of the 

site conditions is likely a factor, with rimsulfuron less mobile in acidic conditions. Its metabolites may have a 

greater likelihood of contaminating groundwater, particularly the second metabolite, which is not readily 

degraded (Metzger et al. 1998).

There is little available information about rimsulfuron and its metabolites in terms of groundwater and surface 

water contamination. One study in sandy soils found no rimsulfuron in groundwater following an herbicide 

application, but did find the first metabolite in the soil water at a depth of 3.3 feet, for as long as 3 years, in 

concentrations unsafe for drinking water. Concentrations of the second metabolite were much lower 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Water Quality

147

Fluazifop-PbutylFluazifop-P-butyl is non-persistent in soil, has an extremely low to very low pesticide movement rating, and a 

low risk of leaching (See Table 3-18, Selected Characteristics that Affect the Fate of Herbicides).

(Rosenbom et al. 2010). However, neither rimsulfuron nor its two metabolites are included on the EPA’s list of 

drinking water contaminants (USEPA 2013).

1. Adapted from the Oregon FEIS (USDI 2010a:197), the 2016 PEIS (USDI 2016a:4-18 to 4-19), SERA 2014, and the herbicide Risk Assessments.

Summary of Effects

Table 3-22. Summary of Effects (Water)

Alternative Direct Effects Indirect Effects

No Action 

Alternative

Proposed herbicide 

treatments can potentially 

affect surface water and 

groundwater quality on or 

near BLM land. However, 

contamination of domestic 

water supply is unlikely given 

BLM’s application methods, 

rates, and timing.

Surface runoff risk is low,

given high soil infiltration 

capacities, spot treatments 

with no-treatment buffers, 

and implementation of 

Protection Measures.

BLM would mitigate the 

potential for leaching by 

selecting appropriate 

herbicides based on proximity 

to domestic water sources, 

shallow groundwater areas, 

and groundwater-surface 

water interaction areas.

This alternative uses herbicides that are known groundwater contaminants, 

but on far fewer acres than glyphosate. Glyphosate binds tightly to soil and 

has an extremely low pesticide movement rating.

District soils generally have high or very high saturated hydraulic 

conductivity, but saturated zones are relatively deep, and points of 

diversion are generally distant.

Risk Assessments for human consumption of contaminated water show no 

risk at typical rates of application for all herbicides and low risk for dicamba 

and glyphosate applied at the maximum rate. BLM proposes maximum rate 

dicamba application on less than 4 gross acres (see Table 2-10, Treatment 

Key (Perennial Parsley)), and typical to below maximum rate application of 

glyphosate.

Proposed Action

The Proposed Action and Alternative 3 use some herbicides with potential 

to leach to groundwater.

District soils generally have high or very high saturated hydraulic 

conductivity, but saturated zones are relatively deep, and points of 

diversion are generally distant.

Risk Assessments for human consumption of contaminated water show no 

risk at typical rates of application for all herbicides and low risk for 

clopyralid and triclopyr applied at the maximum rate. Mitigation Measures 

limit triclopyr application to the typical rate where feasible, and BLM would 

apply clopyralid at typical to below maximum application rates.

Alternative 3

Cumulative Effects

As described in the Ongoing and Reasonably Foreseeable Actions section in Chapter 2, outside of the invasive plant 

program analyzed in this EA, the BLM injects tanoak with glyphosate or imazapyr on 50 to 100 acres annually to 

prevent the spread of Sudden Oak Death. Potential effects to groundwater from tanoak treatment would only 

occur in the case of an accidental spill, but like the invasive plant management program, precautions and 

restrictions are in place to prevent spills from occurring and minimize spills that may occur.

The Coos Bay BLM proposes to use approximately 0.04 percent (No Action) and 0.03 percent (Proposed Action and 

Alternative 3) of the pounds of pesticide used in the Southern Oregon Coast basin (see Ongoing and Reasonably 

Foreseeable Actions in Chapter 2). Considering the proposed safeguards, this relatively small use is not likely to 

trigger an herbicide related 303(d) stream listing in an analysis area with no current herbicide listings, or to 

contaminate groundwater to the detriment of human health.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Air Quality

148

Air Quality

Air Quality Issue 1 (Not Analyzed in Detail)

How would the alternatives affect air quality?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2016 PEIS (USDI 2010a:166-172, USDI 2016a:4-9) and there are no new circumstances or information at 

the site-specific level that would change the effects anticipated for this EA.

Air quality on the Oregon Coast generally has an Air Quality Index of “good” due to coastal winds and topography 

(areas with air quality problems tend to be inland, concentrated around valleys). There are no non-attainment or 

maintenance areas (areas with a history of nonattainment, but now consistently meeting the National Ambient Air 

Quality Standard) as defined by the Oregon Department of Environmental Quality within the District. The Oregon 

Smoke Management Plan Annual Report (ODF 2016) identifies the population center of Coos Bay and North Bend 

as Smoke Sensitive Receptor Areas, and provides the highest level of protection against smoke intrusion in these 

areas.

The Oregon FEIS showed that emissions from invasive plant treatments on all Oregon BLM-administered lands 

would be less than 0.1 percent of statewide emissions of carbon monoxide (CO), nitrogen oxides (NOx), sulfur 

dioxide (SO2), and Volatile Organic Compound (VOCs) and 0.2 percent of particulate matter (PM) (USDI 2010a:167). 

As described in the Oregon FEIS, emissions from prescribed fire were the primary air quality concern in an 

integrated invasive plant management program (USDI 2010a:165, USDI 2007d); the herbicides analyzed in the 

2010 Oregon FEIS contribute less than 1 percent of the aforementioned SO2, less than 0.1 percent of the CO, and 

less than 0.2 percent of the NOx, VOCs, and PM (USDI 2010a:167). The 2016 PEIS states that annual emissions 

nationwide from a program that included the three additional herbicides would be similar to the program without 

those three herbicides (USDI 2016a:4-9).

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2016 PEIS. All Standard Operating Procedures and Mitigation Measures 

analyzed in those documents would be applied to all alternatives.

On the Coos Bay District, effects from invasive plant treatments on local and regional air quality would be 

undetectable. The amount of herbicides and prescribed fire used would be within the amount analyzed in the 

Oregon FEIS. Standard Operating Procedures such as evaluating weather conditions prior to implementing 

treatments and coordinating with officials to obtain all applicable smoke management permits and ensure that 

burn plans comply with regulations would minimize adverse effects. All alternatives would be relatively benign to 

air quality. In general, control of invasive plants can reduce the effects of wildfire, thereby slowing or preventing 

the degradation of air quality; however, wildfires caused by invasive plants or their treatments are not expected on 

the Coos Bay District (see Fire Issue 1).

Air Quality Issue 2 (Not Analyzed in Detail)

How would the alternatives affect climate change, including greenhouse gas emissions and carbon 

storage?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2007 and 2016 PEISs (USDI 2010a:166-172, USDI 2007a:4-9 and 4-10, USDI 2016a:4-9) and there are no 

new circumstances or information at the site-specific level that would change the effects anticipated for this EA.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Air Quality

149

Along with the general lack of detailed information concerning existing carbon storage and storage capacity, 

climate responses to changes in greenhouse gas emissions and carbon storage rates are non-linear, making any 

assessment of potential effects of the alternatives on climate largely speculative (USDI 2010a:172-173).

The Oregon FEIS discusses that emissions from biocontrols, targeted livestock grazing, and seeding or planting are 

considered to have a negligible effect on climate change (USDI 2010a:166). Acres of mechanical treatments are 

expected to increase from 468 acres [No Action Alternative] to 687 acres [Proposed Action], or remain about the 

same at 460 acres [Alternative 3] over the 20-year analysis period; and associated fugitive dust and exhaust 

emissions would remain the same [Alternative 3] or increase proportionate to the increase in acres of treatments

[Proposed Action]. However, the BLM does not have adequate data to quantify potential greenhouse gas 

emissions from that change.

The 2016 PEIS states that none of the herbicides analyzed in the 2007 or 2016 PEISs were expected to have an 

adverse effect on greenhouse gas emissions given the relatively low amount of greenhouse gas emissions 

associated with herbicide treatments (USDI 2016a:4-9). Effects did not differ because of the herbicide used; rather, 

levels of effects were related to the acres treated and associated trip distance, vehicle exhaust, and fugitive dust. A 

quantitative analysis of carbon sequestration was not completed, as there is no appropriate protocol for evaluating 

impacts (USDI 2016a:4-6).

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2007 and 2016 PEISs. All Standard Operating Procedures and Mitigation 

Measures analyzed in those documents would be applied to all alternatives.

Alternatives that control or reduce invasive plants maintain or enhance net carbon storage capacity and

alternatives that allow invasive plants to spread reduce net carbon storage capacity (USDI 2010a:173). Since the 

annual acres treated would remain the same under all alternatives (1,000 gross acres), there would be no 

difference in carbon storage between the alternatives. The Proposed Action and Alternative 3 would reduce 

invasive plant spread, so there would be a net carbon storage capacity increase associated with those alternatives 

(USDI 2010a:173-174).

Emissions are also discussed above, in Air Quality Issue 1.

Fire

Fire Issue 1 (Not Analyzed in Detail)

How would the treatment of invasive plants affect fuel loading?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

(USDI 2010a:273-278) and there are no new circumstances or information at the site-specific level that would 

change the effects anticipated for this EA. Adverse and beneficial effects are expected to be negligible.

As shown in Table 3-23, as described in the Proposed Resource Management Plan and Final Environmental Impact 

Statement for Resource Management Plans for Western Oregon to which this EA tiers, on the Coos Bay District, 44 

percent of the BLM-administered lands fall into fire regime group 5, where fires are infrequent (greater than 200 

years) (USDI 2016e:225). Although the Coos Bay District has a large portion (39 percent) of lands classified as fire 

regime I within the District boundary, 99.9 percent of the BLM-administered lands in the Coos Bay District are 

classified as moist forest (USDI 2016e:232). Historically, fire was not an important frequent change agent acting to 

influence stand structure distribution of these forested ecosystems. Natural ignitions, weather, and fuel conditions 

to support fires in these areas rarely aligned, and fires that burned were large and of high severity (Morrison and 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Fire

150

Swanson 1990 cited USDI 2016e:224). While lightning ignitions are infrequent in the coastal area, human ignitions 

are prevalent and account for greater than 90 percent of all ignitions. From 1984 to 2013, on the Coos Bay District 

there were 66 human caused ignitions and only 6 lightning caused ignitions (USDI 2016e:227).

Table 3-23. Coos Bay-Administered Lands by Historic Fire Regime Group

Fire Regime Group 1 2 3 4 5

Fire Return Interval (in years) 0-35 0-35 35-200 25-200 > 200

Severity Low and Mixed Replacement Low and Mixed Replacement Varies

Percent of Coos Bay District 39% 0% 16% 0% 44%

The Oregon FEIS describes that invasive plants in the Western Forest Biome (BLM-administered lands on the Coos 

Bay District fall primarily within this biome) are generally neither flammable nor continuous enough to constitute a 

major fuel hazard or to have significantly altered the fire regime. Gorse is an exception; gorse has contributed to 

wildfires in the area, notably in or near the city of Bandon. Reducing fire risk may occasionally be an invasive plant 

treatment objective in this biome, but these exceptions do not produce measurable differences between the 

alternatives (USDI 2010a:274).

Invasive plant infestations and thus treatment areas on the District are small (71 percent of sites are less than 1⁄2 

acre (gross)) and do not have an effect on fuel loading. Of the sites larger than 1⁄2 acre (see Table D-1 in Appendix D, 

Invasive Plant Infestations), none are species that are likely to increase fire risk (Jeanne Standley, Coos Bay District 

Weed Coordinator, 2018 personal communication). While gorse is widespread on the south coast of Oregon, there 

is very little gorse on BLM-administered lands because the threshold for treatment is a single plant, and it is 

treated in the same year as it is detected. The BLM coordinates with the Coos Forest Protective Association 

through the Western Oregon Fire Protection Services to respond to all wildfires, regardless of the source of their 

ignition, to minimize the damage to the forest and watershed environment (CFPA 2017); hence, if a fire were to 

start in an area with invasive plants, fire damage would be minimized.

Archaeological and Cultural Resources

Archaeological and Cultural Resources Issue 1 (Not Analyzed 

in Detail)

How would treatment of invasive plants affect historic and prehistoric cultural sites?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2016 PEIS (USDI 2010a:286-289, USDI 2016a:4-71 and 4-72) and there are no new circumstances or 

information at the site-specific level that would change the effects anticipated for this EA. The risk of adverse 

effects is further minimized as a result of Project Design Features included with the Proposed Action and 

Alternative 3.

Prehistoric occupation of coastal Oregon dates back at least the last 12,000 years, based on archaeological 

research (Aikens et al. 1993). Published research illustrating what is actually known about the human prehistory of 

the Oregon coast consists of very little hard data and limited analysis of a complex archaeological record (Lyman 

1991). Research analysis indicates that the Northwest Coast culture pattern, in which western Oregon participated, 

extended from northern California up the coast through British Columbia to Alaska (Aikens et al. 1992). As 

described in the Proposed Resource Management Plan and Final Environmental Impact Statement for Resource 

Management Plans for Western Oregon to which this EA tiers, archaeological data in western Oregon shows that 

past human activity most often took place on level ground and near freshwater sources, as revealed by the 

location of archaeological sites across the landscape (USDI 2016e), though other sites such as rock shelters, trails, 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Archaeological and Cultural Resources

151

mines, traditional cultural properties, and sacred sites may fall outside these areas. Seasonal places in the uplands 

and interior valleys away from the estuaries and coast were often hunting and food gathering areas used by many 

different Native groups. Exploration into the North Pacific by Europeans began in the early part of the 16th 

century, but increased into the late 18th century with maritime exploration along the southwest Oregon coast. 

Logging, shipbuilding, ranching, and agriculture were the mainstay of the local 19th century economy (Douthit 

1999:18). Coastal interior rivers were harnessed to transport lumber to Coos Bay, where it was used to build ships 

and fill the demand brought on by population growth during the California gold rush. Coastal farming and 

agriculture was supported by local industry. Only 1 percent of the Coos Bay District has been inventoried for 

archaeological resources, with 30 prehistoric and 24 historic sites recorded (USDI 2016e:216, 218).

Proposed invasive plant treatments can be divided into two groups: ground disturbing and non-ground disturbing 

actions (see Table 3-24). Non-ground disturbing actions are considered “exempt” under the 2015 State Protocol 

between the Oregon-Washington BLM and the State Historic Preservation Office (Protocol) which governs the way 

cultural resource compliance work is conducted on BLM-managed lands in Oregon. Appendix E of the Protocol lists 

specific projects or activities that are conditionally exempt from field survey and consultation with the State 

Historic Preservation Office, and includes herbicide application/treatment by spraying “where it is unlikely to affect 

rock art or traditional Native American gathering areas” (Oregon SHPO and USDI 2015).

Table 3-24. Ground Disturbing/Non-Ground Disturbing Actions

Ground Disturbing Actions Non-Ground Disturbing Actions

Manual (pulling and grubbing)

Competitive seeding (when soil preparation required) 

and planting

Biological (targeted grazing)

Prescribed fire

Mechanical (mowing and string trimmers)

Biological control agents (insects)

Herbicide application

Competitive seeding (when soil preparation not required)

A Standard Operating Procedure applicable to all alternatives states:

• Follow standard procedures for compliance with Section 106 of the National Historic Preservation Act as 

implemented through the National Programmatic Agreement and State protocols or 36 CFR Part 800, 

including necessary consultations with the State Historic Preservation Officers and interested Tribes.

The National Historic Preservation Act requires agencies to take into consideration the effects of their actions on 

properties listed or eligible for listing on the National Register of Historic Places (NRHP). As described in Chapter 2, 

Annual Treatment Plans are reviewed by an interdisciplinary team. This happens, in part, to confirm that required 

authorizations, obligations, and commitments (such as archaeological reviews and surveys) are completed prior to 

implementation. Potential effects from ground disturbing treatments under the Proposed Action and Alternative 3 

will be assessed and adverse effects will be resolved or minimized through avoidance of discovered sites and the 

use of Project Design Features prior to project implementation.

Both the Oregon FEIS and 2016 PEIS describe that herbicide applications can increase soil acidity and advance 

artifact deterioration or the surfaces of masonry structure, pictographs, or petroglyphs (USDI 2010a:286, USDI 

2016a:4-72). In addition, cultural resources often occur on or near the ground surface and can be damaged by 

ground disturbing activities such as mechanical invasive plant treatments (USDI 2010a:288-289). Standard 

Operating Procedures have been established to address these potential effects.

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2016 PEIS. All Standard Operating Procedures and Mitigation Measures 

analyzed in those documents would be applied to all alternatives. An additional Project Design Feature included in 

the analysis of the Proposed Action and Alternative 3 would further minimize potential effects:

• Avoid getting herbicides (through drift or accidental direct spray) on rock art or wooden/metal structures 

or artifacts at National Register of Historic Places (NRHP) listed or eligible sites.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Archaeological and Cultural Resources

152

• Avoid repeated use of livestock (more than one grazing episode annually) at National Register of Historic 

Places (NRHP) listed or eligible sites.

Traditional and Cultural Uses (Native American 

Interests)73

Traditional and Cultural Uses Issue 1 (Not Analyzed in Detail)

How would the treatment of invasive plants affect plant resources used by Native Americans for 

medicinal, subsistence, ceremonial, or other purposes, given that these plants (or their locations) may 

not be known by the BLM?

This issue was not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2016 PEIS (USDI 2010a:286-289, USDI 2016a:4-71 and 4-72) and there are no new circumstances or 

information at the site-specific level that would change the effects anticipated for this EA. The risk of adverse 

effects is further minimized as a result of Project Design Features included with the Proposed Action and 

Alternative 3.

Historically, southwest Oregon Indians maintained a detailed ecological knowledge of a tremendous variety of 

plant resources and resource management techniques required to tend and harvest them, such as landscape 

burning (Gray 1987). The Tribes continue to take an active role in the management of their ancestral lands. Many 

areas within the District are locales for culturally significant plants. Tribal members gather plants for edible, 

medicinal, ceremonial, and utilitarian purposes and often keep the location of these sites private; therefore, the 

BLM does not have knowledge of all the sacred sites and places of traditional and cultural importance located 

within or near the District. The BLM manages those sites of which the BLM is aware in consultation with Tribes. In 

preparation of the Resource Management Plans of Western Oregon, Tribes identified an interest in managing for 

culturally important plants within riparian habitat areas along the coast, though Tribal use is not limited to these 

areas (USDI 2016e:801). A list of common cultural plants of importance to Tribes in western Oregon was compiled 

for the Resource Management Plan and is incorporated by reference in this EA (USDI 2016e:1644). The Coos Bay 

District has agreements with the Coquille Indian Tribe and the Confederated Tribes of the Coos, Lower Umpqua, 

and Siuslaw Indians that allow collection of specific plants on designated BLM-administered lands.

Traditionally gathered plants may occur near invasive plant treatments areas. Though these traditionally gathered 

plants are not ones targeted for treatment, they might be exposed to incidental contamination from drift when 

herbicides are used on invasive plants. The Oregon FEIS concluded that having the broader mix of herbicides would 

increase the options for appropriately managing invasive plants while minimizing the risk to humans, including 

Native Americans gathering traditional resources near the treatment areas (USDI 2010a:289). The Human Health 

Issues address the potential risk to human health associated with exposure to herbicide treatments; while there is 

a measurable risk under Risk Assessment modeled scenarios involving some of the herbicides analyzed in this EA 

(see Human Health Issue 1 and Table 3-13, Effects of Herbicides (Human Health)), the actual effects would be 

minimal because of how the herbicides are applied under all alternatives (generally spot sprayed at lower rates 

than analyzed in the Risk Assessments) and because of Protection Measures described in Appendix A that are 

applicable to all alternatives. These include posting treated areas with signs and consulting with Tribes to identify 

areas of vegetation of Tribal significance. The 2016 PEIS stated that aminopyralid, fluroxypyr, and rimsulfuron have 

low to no risk, even under worst case accidental exposures, and would result in less use of other herbicides, such 

as 2,4-D, that have more human health risks (USDI 2016a:4-74; see Human Health Issues for more information). It 

 73 Consultation with the Tribes on this program is ongoing. Additional issues affecting Tribes may be developed through the 

consultation process, as well as additional information about potential effects.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Traditional and Cultural Uses (Native American Interests)

153

is expected that the treatment of invasive plants would improve the habitat for traditionally gathered plants, as 

treatments would reduce habitat competition.

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2016 PEIS. All Standard Operating Procedures and Mitigation Measures 

analyzed in those documents would be applied to all alternatives. Additional Project Design Features included in 

the analysis of the Proposed Action and Alternative 3 would minimize the potential for invasive plant treatments 

affecting plants that may be important to Native Americans:

• At least one month prior to beginning treatments, Annual Treatment Plans will be presented to the Tribes 

showing planned treatments and treatment areas. Any resultant consultation will identify where timing of 

treatments can be modified, where cultural features should be avoided or protected, and where posting 

would help Tribe members avoid areas. Maps of known invasive plant infestations (see Map 2-1, Invasive 

Plants Documented in NISIMS, for example) will also be shared with the tribes at this time.

• Where coordination with the Tribes about the Annual Treatment Plan identifies areas where herbicide use 

would not be consistent with cultural values and uses, alternative control methods will be implemented 

where feasible.

Coordination may occur using a variety of methods. For example, the Tribes could share this information in Tribal 

newsletters and social media or work with the BLM to conduct seasonally appropriate site-specific field trips. 

Additional information about the effects of treatment methods on non-target vegetation can be found in the

Native Vegetation Issues and effects from the consumption of treated vegetation can be found in Human Health 

Issue 1. Socioeconomics Issue 4 discusses how the public and Tribes will be notified of proposed herbicide

treatments. 

Environmental Justice

Environmental Justice Issue 1 (Not Analyzed in Detail)

How would the use of herbicides affect minorities and low-income populations?

This issue was not analyzed in detail because this issue was addressed in the 2010 Oregon FEIS (USDI 2010a: 251-

253). There are no new circumstances or information at the site-specific level that would change the effects 

anticipated for this EA. 

Coos, Curry, and Douglas counties contain lower proportions of Hispanic/Latino residents and higher proportions 

of white residents than are present statewide. Between 89-93 percent of the population in each county is white, 

compared to 85 percent statewide, and between 5 and 6 percent of the residents were of Hispanic or Latino 

ethnicity, compared to 12 percent statewide. However, both Coos and Curry counties have a higher proportion of 

Native American residents (2.3 percent and 2 percent) than the statewide level of 1.1 percent, which is about the 

same in Douglas County (1.2 percent). The Coquille Indian Tribe and the Confederated Tribes of Coos, Lower 

Umpqua, and Siuslaw Indians both have a presence in the District. Coos and Douglas Counties each have a higher 

poverty rate than that for Oregon, and Curry County’s rate is just below, so all three counties could be considered 

as environmental justice populations because of their low-income status. The 2016 per capita income in each 

county ($24,000 in Coos and Douglas, and $25,000 in Curry) is lower than the $29,000 average income for Oregon 

residents. The percentage of people below the poverty level was higher in Coos County (18 percent) and Douglas 

County (19 percent) than the statewide proportion of about 16 percent, but Curry County’s poverty level was 

slightly lower, at about 15 percent. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Environmental Justice

154

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and 2016 PEIS. All Standard Operating Procedures and Mitigation Measures 

analyzed in those documents would be applied to all alternatives. The FEIS analysis found a potential for contract 

and other crews to include a small disproportionate number or minority, poor (defined as below Federal poverty 

standards), or both and that “American Indian and visitors from other racial, ethnic, or low-income backgrounds 

participating in subsistence or cultural uses could be adversely affected by herbicide exposure, or by inadvertent 

effects to non-target culturally important plants, or to wildlife species of value to these groups” (USDI 2010a:333). 

However, that analysis noted such effects would be partially mitigated by treatment designs that attempt to 

minimize exposure of non-target food and water sources, and Standard Operating Procedures requiring 

consultation with tribes to locate any areas of vegetation that are significant to the tribes and that might be 

affected by herbicide treatments. Human Health Issues 1 and 2 address the potential for worker and public 

exposure to herbicide and non-herbicide treatments and finds, that while there is a measurable risk to workers 

under some scenarios, that risk is lower under the Proposed Action and Alternative 3 than under the No Action 

Alternative. The FEIS analysis also noted that the natural resources used for cultural or subsistence purposes would 

be adversely affected by the spread of invasive plants, which would be greater under the No Action Alternative 

(USDI 2010a:333).

Socioeconomics

Socioeconomics Issue 1 (Not Analyzed in Detail)

What are the economic impacts of invasive plants on the Coos Bay District on local area timber 

production, agriculture, and recreation?

This issue is not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and 2016 PEIS (USDI 2010a:309, USDI 2016a:4-82) and there are no new circumstances or information at the sitespecific level that would change the effects anticipated for this EA.

The Coos Bay District manages approximately 311,942 acres of public lands located primarily in Curry, Coos, and 

Douglas Counties with smaller portions in Josephine and Lane Counties74 (see Map 1-1). As described in the 

Proposed Resource Management Plan and Final Environmental Impact Statement for Resource Management Plans 

for Western Oregon to which this EA tiers, Curry County has the highest percentage of Federal lands (61.9 percent, 

including BLM) but the lowest percentage of Coos Bay District-managed lands (3.4 percent). Douglas County (22.8 

percent) and Coos County (15.5 percent) have more BLM-management, but a lower percentage of other Federal 

lands (11.8 and 8.2 percent respectively). Employment and earnings in timber and recreation related industries are 

important components of the Coos Bay economy. Timber production accounts for 6.7 percent of jobs and 10.1 

percent of total earnings, while recreation accounts for 11 percent of employment and 5.5 percent of earnings on 

the Coos Bay District (USDI 2016e:667).

The Oregon FEIS and 2016 PEIS describe how management activities on BLM-managed lands have the potential to 

affect local economies (USDI 2010a:318, USDI 2016a:4-82). Invasive plants can result in direct economic losses and 

control costs. On agriculture and timber lands, invasive plants provide competition to the crop species, which leads 

to lost harvest and land value, as well as costs associated with invasive plant control. Invasive plants can limit 

recreation access and degrade the resource that the recreation relies on (e.g., water, wildlife, etc.). The Oregon 

FEIS states that treatments under the action alternatives would result in improvements in the conditions of BLM 

resources and would lead to increases in commodity, non-commodity, and non-market values (e.g. improved 

recreation opportunities or habitat improvements)(USDI 2010a:323). While there are differences in effectiveness 

 74 Approximately 3,740.5 acres of the Coos Bay District are administered by the Medford District. These acres are analyzed in 

the Medford District’s 2018 Integrated Plant Management Revised EA (USDI 2018a).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Socioeconomics

155

between the alternatives, these differences would not reflect quantifiable changes in socioeconomic impacts (USDI 

2010a:324, USDI 2016a:4-86).

A recent report described the direct negative economic impacts associated with noxious weeds in the state of 

Oregon, the additional costs associated if noxious weeds expand to new areas, and the positive return on 

investment associated with control (The Research Group, LLC 2014). That study estimated annual losses of $83.5 

million to the State's economy from 25 noxious weed species. If left uncontrolled, potential annual losses could 

reach $1.8 billion in personal income and 40,800 jobs (The Research Group, LLC 2014). Two of the 25 selected 

noxious weeds, Himalayan blackberry and Scotch broom (the latter being a particular problem in forests), are 

widespread (state-wide and on the Coos Bay District) and contribute $79.6 million to the current overall economic 

impact. The remaining 23 species are limited in distribution and are under intensive management thus 

contributing to less than five percent of total current impacts. A similar analysis found that in Washington State, 

invasive species created losses of $239.5 million on crops, $120 million in the livestock industry, $125 million in the 

timber industry, and $20 million in recreation. Scotch broom was found to be one of the most costly plant species 

(Community Attributes Inc. 2017). While neither of these studies is specific to the Coos Bay District, they 

demonstrate that invasive species can have an economic effect on valued resources, lands, and opportunities.

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and 2016 PEIS. All Standard Operating Procedures and Mitigation Measures 

analyzed in those documents would be applied to all alternatives. For example, as descried in the Recreation Issue, 

most treatments would be scheduled to avoid peak recreational use times and when treatments with herbicides 

occur in developed recreation sites, they would generally be spot treatments on small sites, which would limit 

potential exposure to visitors. Existing Department of the Interior policy directs the BLM to accomplish pest 

management through cost-effective means that pose the least risk to humans, natural and cultural resources, and 

the environment. This helps to protect local area timber production, crops, livestock, and recreation resource 

values, while also reducing the level of risk of invasive plant infestations negatively affecting these resources. 

Adjacent landowners, county, State, and other Federal lands benefit from the BLM having a broader range of 

herbicides available for consideration. Having more herbicides available would enhance the BLM’s ability to 

prevent the spread of invasive plants from BLM lands to private, county, State, and other Federal lands. The BLM’s 

ability to more closely match existing private land treatments on adjacent areas under the action alternatives 

would be more effective than the No Action Alternative at cooperatively controlling plants so they do not infest or 

re-infest adjacent lands.

Socioeconomics Issue 2 (Not Analyzed in Detail)

Given the checkerboard land ownership pattern, what is the potential for herbicide contamination of 

yards, gardens, organic farms, vineyards, and bee hives on private lands?

This issue is not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2016 PEIS (USDI 2010a:309, USDI 2016a:4-81) and there are no new circumstances or information at the 

site-specific level that would change the effects anticipated for this EA. The type of actions and the amount of 

treatments under all alternatives would be consistent with the actions analyzed in the 2010 Oregon FEIS and 2016 

PEIS. The same Standard Operating Procedures and Mitigation Measures analyzed in those documents would be 

applied to all alternatives in this EA.

In general, BLM and their contractors would not apply herbicides on private lands. (BLM may fund treatments on 

private lands through cooperative management agreements.) The Oregon FEIS stated that residential lands and 

agricultural lands, where crops (including orchards, vineyards, and pastures) are grown are protected from drift of 

BLM applied herbicides by Standard Operating Procedures that include no-spray buffers, drift reduction measures, 

and other practices that minimize or eliminate herbicide drift or off site movement (USDI 2010a:145). Those same 

Standard Operating Procedures were also included in the 2007 and 2016 PEISs and are common to all alternatives.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Socioeconomics

156

County residents can obtain a “No Spray” permit issued by the State or County if they do not wish to have 

herbicides sprayed next to their property. These permits are not binding on the BLM; they are most commonly 

used to prevent State or County road maintenance spraying noxious weeds immediately adjacent to private 

properties, and these crews know where these permits have been issued. BLM spray crews would generally 

respect signs they see; some are intended to protect high-value crops or other things not always apparent at the 

site. Standard Operating Procedures preclude ground spraying within 100 feet of a residence without written 

permission from the owner or occupant.

The herbicides that the BLM uses have very low vapor pressures and would not be found at a distance of 9 to 27 

meters downwind of the application site (Vencill et al. 2002). Further, herbicide application methods used on the 

District are not those that are prone to drift. Under the No Action Alternative, the Coos Bay District has done all of 

their treatments with hand-directed applications, primarily backpack sprayers. Under the Proposed Action and 

Alternative 3, 95 percent of herbicide treatments would be hand-directed, and 5 percent would be broadcast 

primarily along existing roads. Aerial applications have not and would not be used. Drift and methods for control 

are discussed further in Appendix C, Herbicide Risk Assessment Summaries.

Bees are unlikely to be affected by the BLM’s herbicide use; the effects from herbicides to pollinators would 

generally be related to habitat (vegetation) loss and treatments proposed under the alternatives are generally 

small (see Table 2-2, Summary of Invasive Plants Documented in NISIMS by Infestation Size: 71 percent of known 

sites are less than 0.5 acres). The effects of herbicides on pollinators are addressed in Wildlife Issue 3 and the 

effects of herbicides on vegetation are described in the Native Vegetation Issues.

Socioeconomics Issue 3 (Not Analyzed in Detail)

How would the alternatives affect permitted land uses, including rights-of-way and administrative site 

grant and leaseholders?

This is not analyzed in detail because there is no effect to permitted land uses. As described in the Purpose and 

Need, the alternatives are solely intended to evaluate options for improving invasive plant control, thereby 

assisting the BLM in meeting its obligation to manage public lands for multiple uses consistent with the Federal 

Land Policy and Management Act. The alternatives do not propose changes to land uses.

All three alternatives apply to all invasive plant control activities conducted on BLM-managed lands within the 

Coos Bay District, including those undertaken by grant holders and lessees. Grant and leaseholder responsibility for 

control of noxious weeds (not all invasive plants) would continue, but additional herbicides could be used. The 

addition of invasive plants to the species that can be controlled would enable grant and leaseholders to more 

effectively manage the right-of-way and conduct maintenance. In cases where grants or leases specify or limit the 

herbicides to be used, there may be some delay in approving additional herbicides until grants or leases are 

renewed. Holders of long, linear rights-of-way crossing multiple jurisdictions would benefit by being able to use the 

same herbicides over long expanses rather than changing each time they enter BLM-managed lands.

Socioeconomics Issue 4 (Not Analyzed in Detail)

How and when will the public and Tribes be notified of herbicide application?

This issue is not analyzed in detail because there is no difference between the alternatives. There are several 

Standard Operating Procedures and Mitigation Measures that ensure the public will be notified prior to herbicide 

applications and these measures apply equally to all of the alternatives. Changes to these procedures are not 

proposed in this analysis. These Protection Measures include:

• Notify adjacent landowners, grazing permittees, the public, and emergency personnel of treatments.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Socioeconomics

157

• Coordinate with and/or notify neighboring landowners who may want to treat, or are already treating, 

adjacent lands.

• Notify other public land users within or adjacent to the right-of-way proposed for treatment.

• Provide public notification in newspapers or other media where the potential exists for public exposure.

The Coos Bay District sends news releases to local newspapers and signs all treatment areas prior to the 

treatment. A district-wide Annual Treatment Plan will be prepared prior to the beginning of control treatments 

each year and the resulting Determination of NEPA Adequacy, or additional NEPA analysis if warranted, will be 

made available to the public on ePlanning and shared with the Tribes as part of ongoing consultation (see also 

Traditional and Cultural Uses (Native American Interests) Issue 1). In addition, the BLM is in the process of making 

NISIMS, the database that contains spatial information on invasive plant infestations, accessible to the public, 

which will allow the public to access data about invasive plant sites.

Implementation Cost

Implementation Cost Issue 1

How would the increased availability of herbicides to treat European beachgrass in western snowy plover 

habitat restoration areas under Alternative 3 affect treatment costs at the North Spit and New River?

Analytical Methods

As previously described in the analysis for the Oregon FEIS (USDI 2010a:338-343), costs are arguably not a 

potential effect on the human environment and are not required by NEPA. However, an analysis of how 

implementation costs change between the alternatives informs decision making. BLM policy specifies that 

management actions having a high likelihood of improving resource conditions for relatively small expenditures of 

time and money should receive relatively higher priority (USDI 2005f:34).

This issue examines the direct costs of invasive plant treatments at the North Spit and New River. Costs presented 

in this section are in 2018 dollars not adjusting for inflation, and include equipment, materials (including 

herbicides), wages, and contract costs; they do not include program planning (e.g., NEPA or the creation of Annual 

Treatment Plans). As shown in Table 3-25, the direct cost of treating an acre of invasive plants varies by density of 

infestation. Manual treatments on the Coos Bay District range from $68/acre (low density, pull and scatter invasive 

plants) to $370 (high density pull and bag invasive plants).

Table 3-25. Direct Costs of Invasive Plant Treatments, by Gross Acre1

Density levels are defined as follows:

• Low concentrations consist of a few 

scattered plants, patches, clumps, or 

concentrations, generally less than 20 

percent ground coverage within each 

treatment site.

• Medium concentrations consist of many 

plants, patches, clumps, or 

concentrations of specified species that 

have approximately 21 to 59 percent 

ground coverage within each treatment 

site.

Activity1 Density Cost

Herbicide Spot Spray Low $68.00

Herbicide Spot Spray Medium $96.00

Herbicide Spot Spray High $204.00

Herbicide Wicking/Wiping Application Low $98.00

Herbicide Wicking/Wiping Application Medium $160.00

Herbicide Wicking/Wiping Application High $280.00

Bulldozers or tractors with discs or plows2 Any $963.00

1. Herbicides costs based on recent District contracts for invasive plant 

control projects. Per acre costs do not include a supplemental fee for 

walk-ins more than 1⁄4 mile of $38 per person

2. Costs for mechanical removal are based on past project 

implementation costs at North Spit and New River by the BLM from Fiscal 

Year 2017.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Implementation Cost

158

• High concentrations consist of large, dense, heavy, concentrations of the specified species that have 60 to 

100 percent ground coverage within each treatment site with only a few or occasional open areas.

European beachgrass is a fast-growing species that forms dense rhizomes that crowds out other plant species. As 

much as 80 percent of the North Spit is covered with European beachgrass and would be considered high density 

infestations. 

Under all alternatives, plover access cuts through European beachgrass on ocean foredunes would be treated with 

methods that would avoid the removal of the root system. This has been accomplished with youth crews, manually 

pulling the beachgrass, at a cost $7,700 to $8,500 per week (Kip Wright, Coos Bay Wildlife Biologist / ACEC 

Coordinator, 2018 personal communication). This would not change between alternatives and is not analyzed

further.

Treatments Planned Related to the Issue

No Action Alternative and Proposed Action

In habitat restoration areas at New River and the North Spit, approximately 100 acres of European beachgrass 

would primarily be treated mechanically twice a year, with non-selective heavy equipment such as discs or 

bulldozers. At New River, no herbicides would be used in the plover habitat restoration area. At the North Spit, the 

BLM would treat up to 24 acres annually with glyphosate.

Alternative 3

In these habitat restoration areas, imazapyr, glyphosate, or imazapyr mixed with glyphosate would be used to 

treat European beachgrass. While this could occur on all 172 acres in one year, it would generally happen on 

approximately 100 acres annually. The use of these more effective herbicides on European beachgrass would 

reduce the treatments done by heavy equipment. In the next five years, this is anticipated to result in greater than 

75 percent reduction in the use of bulldozers or tractors with discs or plows (or approximately once every two 

years).

Environmental Consequences

Table 3-26 shows the average direct cost of invasive plant treatments as it varies by alternative over a 20-year 

analysis period.

Table 3-26. Average Direct Cost of Treatments

Alternative Herbicide Mechanical Total Cost Cost/Acre Cost/Acre Acres Treated Cost/Acre Acres treated

No Action Alternative and Proposed Action

Year 1 to 5 $204 24 $963 200 $197,496 $1,975

Year 6 to 10 $204 24 $963 200 $197,496 $1,975

Year 11 to 20 $204 24 $963 200 $197,496 $1,975

Alternative 31

Year 1 to 5 $204 100 $963 50 $68,550 $686

Year 6 to 10 $98 100 $963 50 $57,950 $580

Year 11 to 20 $68 100 $963 50 $54,950 $550

1. Costs conservatively assume mechanical treatments in western snowy plover habitat restoration areas will occur once every two years. As 

described below, mechanical treatments may occur every two to three years. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3 – Affected Environment and Environmental Consequences

Implementation Cost

159

No Action Alternative and Proposed Action

Existing Endangered Species Act consultation limits the treatment methods that can be used under the No Action 

Alternative and Proposed Action to mechanical and manual methods at both sites, and 24 acres of glyphosate use 

at the North Spit. This restriction means that bulldozers have been the primary method of treatment. Due to the 

deep rhizomes and rapid regrowth of European beachgrass, this has meant two treatments are needed each year 

to reduce the beachgrass cover to maintain nesting habitat for the western snowy plover. The treatments are time 

consuming and expensive since large equipment must be mobilized and operated, causing 6 weeks of disturbance 

annually (see Wildlife Issue 1) at a cost of $963 per acre. Treating 100 acres twice a year mechanically costs 

$192,600. Herbicide use is limited to 24 acres annually at the North Spit, at a cost of $4,896 assuming spot spraying 

on a high density infestation. These treatment methods have been estimated to be only 10 percent effective at 

treating beachgrass, therefore the infestation density would remain high even with annual treatment. 

Implementation costs would remain the same over time (no reduction in infestations with treatment). The total 

implementation costs to treat European beachgrass at the North Spit and New River would be $197,496, or $1,975 

per acre.

Alternative 3

The availability of herbicides (imazapyr and glyphosate) would reduce the need for mechanical treatments from 

twice a year to once every 2 to 3 years. Herbicide treatments are less than one quarter of the cost per acre of 

mechanical treatments since much less equipment and people are required to implement the treatment. The 

herbicide cost per acre would remain the same, but the total acres treated would increase, thus the total cost of 

herbicide use would increase to $20,400. However, mechanical treatments would decrease in frequency from 

twice a year to once every two years, reducing the average annual treatment cost for that treatment method by 75 

percent. Total implementation costs would decrease to $68,555 ($686/acre), 65 percent less compared to the No 

Action Alternative and Proposed Action.

Over time, it is reasonable to assume that European beachgrass density would decrease with annual herbicide 

treatments, and thus treatment costs would decrease (USDI 2015a). After 5 years, it is assumed that effective 

treatment with imazapyr and glyphosate would reduce densities to medium, and eventually to low density by year 

20. This would further reduce treatment costs for a total of a 71 percent reduction (compared to the No Action

Alternative and Proposed Action) by year 5, and a 72 percent reduction (compared to the No Action Alternative 

and Proposed Action) by year 20.

Summary of Effects

Table 3-27. Summary of Effects (Implementation Cost Issue 1)

Alternative Cost/Acre

Year 1-5

Cost/Acre

Year 6-10

Cost/Acre

Year 11-20 Comments

No Action 

Alternative/

Proposed Action

$1,975 $1,975 $1,975

Mechanical treatments of European beachgrass are needed twice a 

year. Infestations remain at high densities, leaving treatment costs 

unchanged over time.

Alternative 3 $686 $580 $550

Treatment of European beachgrass with herbicides, reduces need 

for mechanical treatments to once every 2 years and lowers costs. 

Effective treatment methods decreases invasive plant densities, 

further reducing costs over time.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3- Affected Environment and Environmental Consequences

Recreation

160

Recreation

Recreation Issue 1 (Not Analyzed in Detail)

How would herbicide treatments at recreation sites affect visitor access and recreational experiences?

This issue is not analyzed in detail because effects were previously described in the analysis for the Oregon FEIS 

and the 2016 PEIS (USDI 2010a:309, USDI 2016a:4-81) and there are no new circumstances or information at the 

site-specific level that would change the effects anticipated for this EA.

As described in the Oregon FEIS, manual methods would be the primary form of treatment of invasive plants in 

developed recreation sites (USDI 2010a:309). When herbicides are used, recreation sites may be temporarily 

closed, potentially inconveniencing public land visitors, but reducing herbicide exposure. Access to a site treated 

with an herbicide may be restricted for a few hours or days, depending on the requirements of the herbicide label. 

When recreation sites are closed, BLM posts signs noting the exclusion area, the duration of the exclusion, and 

nearby alternative recreation areas that would provide substantially similar recreation opportunities. The Oregon 

FEIS also notes that the additional herbicides would “often allow the use of an herbicide that is more target

specific and generally less toxic to humans, and more effective in lower doses, thereby reducing the adverse 

effects of herbicide use on the recreational resource and reducing the chance for accidental exposure to 

recreationists” (USDI 2010a:308-309). The Oregon FEIS did not discuss the effects of aminopyralid, fluroxypyr, or 

rimsulfuron. The effects of these three herbicides were discussed in the 2016 PEIS, where it states that impacts to 

recreation nationwide from a program that included these three herbicides would be similar to the program 

without those three herbicides (USDI 2016a:4-81).

The type of actions and the amount of treatments under all alternatives would be consistent with the actions 

analyzed in the 2010 Oregon FEIS and the 2016 PEIS. All Standard Operating Procedures and Mitigation Measures 

analyzed in those documents would be applied to all alternatives.

Popular recreation sites on the District include Loon Lake Campground, Dean Creek Elk Viewing Area, Edson 

Campground, Sixes Campground, New River, Smith River Falls Campground, Vincent Creek Campground, Park 

Creek Campground, Bastendorff Beach, North Spit Boat Ramp, North Spit Trails, and Blue Ridge Trails. Invasive 

plant species of concern in these areas include brooms, blackberry, knotweeds, and ivy. The District has over 

700,000 visitors a year (USDI 2016d). The majority of BLM-administered lands on the District are managed to 

accommodate and provide for a multitude of developed, semi-developed, and dispersed recreation uses. As stated 

in a Standard Operating Procedure, most treatments would be scheduled to avoid peak recreational use times. 

When treatments with herbicides occur in developed recreation sites, they would generally be spot treatments (95 

percent in the action alternatives and 100 percent in the No Action Alternative) on small sites, which would limit 

potential exposure to visitors.

The effects of herbicides on human health in situations that are applicable to visitors are discussed in the Human 

Health Issue 1 earlier in this EA and the effects of recreation to the spread of invasive plants is described in Invasive 

Plants Issue 1. Recreation is also discussed in Socioeconomic Issue 2 and Water Issue 1.

Recreation Issue 2 (Not Analyzed in Detail)

What are the effects of herbicides on horses, dogs, and other pets that accompany recreationists?

This issue is not analyzed in detail because treatments under all alternatives would have no potential to adversely 

affect pets and other animals that accompany recreationists (e.g., horses, dogs, llamas). As described in Recreation

Issue 1, existing Protection Measures (Appendix A) would limit the exposure of recreationists to herbicides. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Chapter 3- Affected Environment and Environmental Consequences

Recreation

161

Although animals that accompany recreationists could potentially be exposed, BLM assumes that pets would be 

controlled by their owners. When feasible, treatments would be scheduled to avoid peak use and most treatments 

are spot treatments targeting individual plants in small areas (71 percent of sites are less than 1⁄2 gross acre) 

minimizing the likelihood that people and animals would be exposed. As required by existing Protection Measures 

(see Appendix A), treatment areas are posted to alert people to avoid areas and further minimize exposure 

potential.

Risk Assessments (summarized in Appendix C) indicate potential risks to small and large mammals. While there is 

some level of risk to some mammals under certain scenarios, these particular scenarios are unlikely to be 

applicable to pets or other domesticated animals. The Risk Assessments indicate that there is 0 risk to mammals 

under all direct spray scenarios (dermal exposure to herbicides) except for 100 percent absorption scenarios for 

2,4-D, clopyralid, glyphosate, metsulfuron methyl, and triclopyr, where there would be a low risk. There is a 

potential for moderate or high risks to large mammals (e.g. horses) if they were to consume grass treated with 

dicamba or triclopyr, but dicamba and triclopyr would not be used to treat invasive grasses (see Table 2-10, 

Treatment Key) and the scenario assumed that the large mammal would feed on contaminated grass for an entire 

day (see Appendix C). Scenarios that involve small or large mammals consuming contaminated insects or smaller 

mammals are all 0 or low risk (see Appendix C). Because of the level of risk to mammals from these herbicides, the 

nature of invasive plant treatments, and Protection Measures applicable to all alternatives, adverse effects to pets 

because of exposure would not occur under any alternative.

As described in Chapter 2’s Category II, Spread from Existing Invasive Plant Sites section, like the recreationists that 

they accompany, pets and other animals can also spread invasive plants. As described in the Prevention, Education, 

and Awareness section in Chapter 2, the District requires weed-free forage for any livestock fed on BLM-managed 

lands.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Consultation and Coordination

162

Consultation and Coordination

The EA has been made available for a 30-day comment period.

List of Preparers

Core Team

Team Lead and Coos Bay District Invasive Plant Coordinator Jeanne Standley

Planning and Environmental Coordinator (Coos Bay) Aimee Hoefs

Management Representative and Umpqua Resource Area Field Manager Glenn Harkleroad

Project Manager and Oregon State Office Invasive Plant Coordinator Erin McConnell

Planner (Oregon State Office) Richard Hardt

GIS Specialist (Oregon State Office) Maria Fiorella

Denton and Denton Environmental (Contractor) Christi Denton

Denton and Denton Environmental (Contractor) Carolyn Sharp

Other Specialists (all Coos Bay District unless otherwise specified)

Socioeconomic Specialist (Oregon State Office) Stewart Allen 

Hydrologist John Colby

Geographic Information Specialist Tristan Holland

Outdoor Recreation Planner John Harper

Archaeologist William Kerwin

Geologist and Soil Scientist Greta Krost

Fire Management Officer Jamie Lilienthal

Fish Biologist Stephanie Messerle

Botanist Tim Rodenkirk 

Cartographer (Oregon State Office) Gabriel Rousseau 

ACEC Coordinator/Wildlife Biologist Kip Wright

Reviewers

Thanks to Carol Aron, Tom Beaucage (no longer on District), Catherine Bounds, Megan Harper, Scott Hoefs, Tristan 

Huff, Jim Kirkpatrick, Teresa Stutesman, and Kathy Westenskow-Davis in the Coos Bay District Office and Lee 

Folliard, Mike Kinsey, Mark Mousseaux, Scott Lightcap, Bruce Hollen, Angel Dawson, Robert Hopper, Mike Brown, 

Jerry Magee, Leanne Mruzik, Dave Johnson, and Kristin Martine in the Oregon State Office.

Review Opportunity

The EA and Finding of No Significant Impact (FONSI) were made available for a 30-day review period (July 2018) on 

BLM’s ePlanning website. A legal notice was also published in the Coos Bay World announcing the availability of 

the documents for review and the comment period end date. Agencies, Native American Tribes, and interested 

members of the public were notified of the availability of the EA and FONSI for review. The mailing list is contained 

in the project record file.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

163

Glossary

Acetolactate synthase (ALS): A plant enzyme that facilitates the development of amino acids needed for plant 

growth.

Acetolactate synthase (ALS)-inhibitor: An herbicide that starves plants by reducing ALS. In this EA, the ALSinhibitors include four sulfonylureas (chlorsulfuron, metsulfuron methyl, rimsulfuron, and sulfometuron methyl) 

and two imidazolinones (imazapic and imazapyr).

Acid equivalent (a.e.): That portion of a formulation that theoretically could be converted back to the 

corresponding or parent acid. Or, the theoretical yield of parent acid from an active ingredient that has been 

formulated as a derivative (esters, salts, and amines are examples of derivatives).

Active ingredient (a.i.): The ingredient in an herbicide that prevents, destroys, repels, desiccates, or otherwise 

controls the target plant.

Acute effect: An adverse effect on any living organism in which symptoms develop rapidly and often subside after 

the exposure stops.

Acute toxicity: The quality or potential of a substance to cause injury or illness shortly after exposure through a 

single or short-term exposure.

Adjuvant: A chemical that is added to the pesticide formulation to enhance the toxicity or effectiveness of the 

active ingredient or to make the active ingredient easier to handle or apply.

Administrative site: A reservation of public land for use as a site for a public building or other administrative 

facility. On BLM-managed lands in Oregon, this may include seasonal fire stations, wild horse corrals, rock quarries, 

bulk material and equipment storage areas, seed orchards, BLM-managed airstrips and helipads, BLM range 

improvements and water source developments, sanitary systems, BLM communication sites, remote automated 

weather stations, etc.

Adsorption: 1) The adhesion of substances to the surface of solids or liquids. 2) The attraction of ions of 

compounds to the surface of solids or liquids.

Aerobic: Life or processes that require, or are not destroyed by, the presence of oxygen (Also see anaerobic).

Affected environment: Existing biological, physical, social, and economic conditions of an area subject to change, 

both directly and indirectly, as the result of a proposed human action.

Air quality: The composition of air with respect to quantities of pollution therein. Used most frequently in 

connection with “standards” of maximum acceptable pollutant concentrations.

Ambient air: Any unconfined portion of the atmosphere; open air, surrounding air, or “outdoor air.”

Anadromous fish: Fish that mature in the sea and swim up freshwater rivers and streams to spawn. Examples 

include salmon, steelhead, and sea-run cutthroat trout.

Anaerobic: Life or processes, such as the breakdown of organic contaminants by microorganisms, which take place 

without oxygen. Anaerobic soils are generally found in riparian areas.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

164

Aquatic: Growing, living in, frequenting, or taking place in water; used to indicate habitat, vegetation, or wildlife in 

freshwater.

Area of Critical Environmental Concern (ACEC): Type of special land use designation specified within the Federal 

Land Policy and Management Act. Used to protect areas with important resource values in need of special 

management.

Bioaccumulation: The process of a plant or animal selectively taking in or storing a persistent substance. Over 

time, a higher concentration of the substance is found in the organism than in the organism’s environment.

Biological assessment: Information prepared by a Federal agency to determine whether a proposed action is likely 

to: (1) adversely affect listed species or designated critical habitat; (2) jeopardize the continued existence of 

species that are proposed for listing; or (3) adversely modify proposed critical habitat.

Biological control: The use of nonnative agents including invertebrate parasites and predators (usually insects, 

mites, and nematodes), and plant pathogens to reduce populations of invasive plants.

Boom (herbicide spray): A tubular device that conducts an herbicide mixture from a tank to a series of spray 

nozzles designed to deliver equal amounts across a bar. Usually mounted to a truck, or behind a tractor or allterrain vehicle oriented perpendicular to the direction of travel.

Broadcast application: An application of an herbicide that uniformly covers an entire area.

Buffer: A space or distance left between the application and a non-target area.

Candidate species: Plants and animals for which the U.S. Fish and Wildlife Service or National Marine Fisheries 

Service has sufficient information on their biological status and threats to propose them as endangered or 

threatened under the Endangered Species Act, but for which development of a proposed listing regulation is 

precluded by other higher priority listing activities.

Chronic exposure: Exposures that extend over a long period. Chronic exposure studies are used to evaluate the 

carcinogenic potential of chemicals and other long-term health effects.

Chronic toxicity: The ability of a substance or mixture of substances to cause harmful effects over an extended 

period, usually upon repeated or continuous exposure sometimes lasting for the entire life of the exposed 

organism.

Clay: In soil, particles smaller than 0.002 mm in diameter. Fine textured sediment, with particles smaller than silt.

Conservation Measures: Measures adopted with the 2007 Vegetation Treatments using Herbicides on BLM Lands 

in 17 Western States Biological Assessment to prevent or reduce herbicide effects to federally listed species. A 

Mitigation Measure adopted with the 2007 and 2016 PEISs also applies these measures to any species in the 

Special Status Species Program. These measures include (but are not limited to) herbicide-by-herbicide buffer 

distances from Special Status species, dependent on taxa and application method.

Consultation: Exchange of information and interactive discussion; usually refers to consultation mandated by 

statute or regulation that has prescribed parties, procedures, and timelines (e.g., Consultation under National 

Environmental Policy Act or Section 7 of the Endangered Species Act, or consultation with Tribes under Section 106 

of the National Historic Preservation Act).

Control: Eradicating, suppressing, or reducing vegetation.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

165

Critical habitat: 1) Specific areas within a species’ habitat that are critically important to its life functions; 2) an 

area designated by the U.S. Fish and Wildlife Service under rule-making as being critical to the needs of a federally 

listed species, and which then carries special protection and consultation requirements.

Cultural resources: Nonrenewable evidence of human occupation or activity as seen in any area, site, building, 

structure, artifact, ruin, object, work of art, architecture, or natural feature, which was important in human history 

at the national, state, or local level.

Cumulative effect: The effect that results from identified actions when they are added to other past, present, and 

reasonably foreseeable future actions regardless of who undertakes such other actions. Cumulative effects can 

result from individually minor but collectively significant actions taking place over a period of time.

Degradates: Compounds resulting from degradation.

Drift: That part of a sprayed herbicide that is moved from the target area by wind while it is still airborne.

Ecological amplitude: The limits of environmental conditions within which an organism can live and function.

Effect: Change resulting from a proposed action. Direct effects are caused by the action and occur at the same 

time and place, while indirect effects are caused by the action but are later in time, further removed in distance, or 

secondary. Effect and impact are synonymous as used in this document.

Endangered species: Any species listed under the Endangered Species Act as being in danger of extinction 

throughout all or a significant portion of its range.

Endangered Species Act: A law passed in 1973 to conserve species of wildlife and plants determined by the 

Director of the U.S. Fish and Wildlife Service or the National Marine Fisheries Service to be endangered or 

threatened with extinction in all or a significant portion of its range. Among other measures, the Endangered 

Species Act requires all Federal agencies to conserve these species and consult with the U.S. Fish and Wildlife 

Service or National Marine Fisheries Service on Federal actions that may affect these species or their designated 

critical habitat.

Endemic: Being unique to a defined geographic location, such as an island, nation, country or other defined zone, 

or habitat type.

Endocrine: Relating to several glands that secrete hormones or products directly into the bloodstream.

Environmental assessment (EA): A public document that serves to document an examination of the potential 

environmental effects of a proposed project, and from that, documents whether to prepare an environmental 

impact statement or a finding of no significant impact.

Ephemeral stream: A stream that contains running water only sporadically, such as during and following storm 

events.

Erosion: The wearing away of the land surface by running water, wind, ice, or other geological agents.

Fate: The course of an applied herbicide in an ecosystem or biological system, including metabolism, microbial 

degradation, leaching, and photodecomposition.

Federal Land Policy and Management Act of 1976 (FLPMA): Public Law 94-579. Provides the majority of the BLM’s 

legislated authority, direction, policy, and basic management guidance.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

166

Federally listed: Species listed as threatened or endangered under the Endangered Species Act.

Forage: Vegetation eaten by animals, especially grazing and browsing animals.

Forb: Broad-leaved herbaceous plant.

Formulation: The commercial mixture of an herbicide that includes both the active and inactive (inert) ingredients.

Fungi: Molds, mildews, yeasts, mushrooms, and puffballs, a group of organisms that lack chlorophyll and therefore 

are not photosynthetic.

Gastropod: A class of mollusks typically having a one-piece coiled shell and flattened muscular foot with a head 

bearing stalked eyes; includes snails, slugs, limpets and cowries.

Gross infested area or treatment area: An area of land occupied by one or more invasive plant species; the area of 

land defined by drawing a line around the general perimeter of the infestation, not the canopy cover of the plants; 

the gross area of a logical treatment unit. May contain large parcels of land that are not occupied by the weed.

Groundwater: Subsurface water that is in the zone of saturation; the top surface of the groundwater is the “water 

table”; source of water for wells, seeps, and springs.

Groundwater contaminant: Chemical detected in ground waters. Does not necessarily infer levels are toxic or 

harmful.

Groundwater transmissivity: The rate at which groundwater flows horizontally through an aquifer.

Habitat: The natural environment of a plant or animal, including all biotic, climatic, and soil conditions, or other 

environmental influences affecting living conditions; the place where an organism lives.

Half-life: The amount of time required for half of a compound to degrade.

Hazard quotient (HQ): The ratio of the estimated level of exposure to a specific substance from a specific pesticide 

application to the reference dose (RfD) for that substance, or to some other index of acceptable exposure or 

toxicity. An HQ less than or equal to 1 is presumed to indicate an acceptably low level of risk for that specific 

application. Analogous to BLM risk quotient.

Herbicide: A pesticide used to control, suppress, or kill vegetation, or severely interrupt normal growth processes.

Herbicide resistance: Naturally occurring heritable characteristics that allow individual invasive plants to survive 

and reproduce, producing a population, over time, in which the majority of the plants of the weed species have the 

resistant characteristics.

Hydrologic: The properties, distribution, and effects of water on the earth's surface, in the soil and underlying 

rocks, and in the atmosphere.

Hydrolysis: The chemical breakdown of a compound due to reaction with water.

Inert ingredients: Ingredients that are added to the commercial product (formulation) of an herbicide and are not 

herbicidally active.

Infested: An area having one or more of the subject invasive plant species – either plants or plant pathogens. 

Infested areas are not necessarily 100 percent infested.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

167

Integrated vegetation (or) weed management (IVM or IWM): A long-standing, science-based, decision-making 

process that identifies and reduces risks from vegetation and vegetation management related strategies. It 

coordinates the use of vegetation biology, environmental information, and available technology to prevent 

unacceptable levels of damage by the most economical means, while posing the least possible risk to people, 

property, resources, and the environment. IVM provides an effective strategy for managing vegetation in all arenas 

from developed agricultural, residential, and public areas to wild lands. IVM serves as an umbrella to provide an 

effective, all encompassing, low-risk approach to manage problem vegetation. A sustainable approach to managing 

vegetation by combining biological, cultural, physical, and chemical tools in a way that minimizes economic, health, 

and environmental risks.

Interagency Special Status/Sensitive Species Program (ISSSSP): The BLM and Forest Service collaboration to 

coordinate record keeping and other management of the Bureau Special Status and Forest Service Sensitive 

species programs. See also Special Status species.

Intermittent stream: Any non-permanent flowing drainage feature having a definable channel and evidence of 

annual scour or deposition. This includes what are sometimes referred to as ephemeral streams if they meet these 

two criteria.

Invasive plants: Nonnative, aggressive plants with the potential to cause significant damage to native ecosystems, 

cause significant economic losses, or both. This Oregon FEIS definition differs from the 2007 PEIS definition by not 

including species native to the ecosystem under consideration.

Issue: A matter of controversy, dispute, or general concern over resource management activities or land uses.

Koc: Organic carbon-water partition coefficient. A measure of a material's tendency to adsorb to soil particles. High 

Koc values indicate a tendency for the material to be adsorbed by soil particles rather than remain dissolved in the 

soil solution. Strongly adsorbed molecules will not leach or move unless the soil particle to which they are 

adsorbed moves (as in erosion).

Label: All printed material attached to or part of the pesticide container, and which contains instructions for the 

legal application of the pesticide.

LC50 (median lethal concentration): A concentration of a chemical in air or water to which exposure for a specific 

length of time is expected to cause death in 50 percent of a defined experimental animal population.

LD50 (median lethal dose): The dose of a chemical calculated to cause death in 50 percent of a defined 

experimental animal population over a specified observation period. The observation period is typically 14 days.

Leaching: The movement of chemicals through the soil by water; may also refer to the movement of herbicides out 

of leaves, stems, or roots into the air or soil.

Level of concern (LOC): The concentration or other estimate of exposure above which there may be effects.

Listed species: Formally listed as a threatened or endangered species under the Endangered Species Act. 

Designations are made by the U.S. Fish and Wildlife Service or National Marine Fisheries Service.

Lowest observed adverse effect level (LOAEL): The lowest dose of a chemical in a study, or group of studies, that 

produces statistically or biologically significant increases in frequency or severity of adverse effects between the 

exposed and control populations.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

168

Maximum application rate: The maximum application rate analyzed in risk scenarios in the Risk Assessments. The 

rate may be the same as the rate on the label of the formulated product, but in certain cases, the maximum 

application rate is lower. For example, herbicide products that include 2,4-D list 4 lbs./acre as the maximum rate

on the label, but Risk Assessments analyze a maximum application rate of 2 lbs./acre. Therefore, the maximum 

allowable rate of application on BLM-administered lands is 2 lbs./acre.

Mechanical control: The use of any mechanized approach to control or eliminate invasive plants (e.g., mowing, 

weed whipping, or cutting with a chainsaw).

Mitigation: Actions that would: 1) avoid an impact altogether by not taking a certain action or parts of an action; 2) 

minimize an impact by limiting the degree or magnitude of the action and its implementation; 3) rectify an impact 

by repairing, rehabilitating, or restoring the affected environment; 4) reduce or eliminate an impact over time by 

preserving and maintaining operations during the life of the action; or, 5) compensate for an impact by replacing 

or providing substitute resources or environments.

Mitigation Measures: Measures adopted with the 2007 Vegetation Treatments using Herbicides on BLM Lands in 

17 Western States EIS and Record of Decision, the 2016 Vegetation Treatments using Aminopyralid, Fluroxypyr, 

and Rimsulfuron PEIS and Record of Decision, or the 2010 Vegetation Treatments using Herbicides on BLM Lands in 

Oregon FEIS and Record of Decision to prevent or reduce herbicide effects. These measures all apply to this 

analysis and are included in Appendix A.

Monoculture: A population dominated by a single species; a prevailing culture marked by homogeneity.

Monitoring: The orderly collection, analysis, and interpretation of resource data to evaluate progress toward 

meeting management objectives.

Nematode: Any of a phylum (Nematoda or Nemata) of elongated cylindrical worms parasitic in animals or plants 

or free-living in soil or water —also called roundworm.

No Action Alternative: The most likely condition to exist in the future if current management direction were to 

continue unchanged.

No observed adverse effect level (NOAEL): The exposure level at which there are no statistically or biologically

significant differences in the frequency or severity of any adverse effect between the exposed and control 

populations.

No observed effect level (NOEL): Exposure level at which there are no statistically or biologically significant 

differences in the frequency or severity of any effect between the exposed and control populations.

Non-selective herbicide: An herbicide that is generally toxic to plants without regard to species or group.

Non-target: Any organism that is not the objective of a control treatment.

Noxious weed: A subset of invasive plants that are County, State, or federally listed as injurious to public health, 

agriculture, recreation, wildlife, or any public or private property.

Parent material: The unconsolidated and more or less chemically weathered mineral or organic matter from which 

the soil has developed.

Particulate matter (PM): A complex mixture consisting of varying combinations of dry solid fragments, solid cores 

with liquid coatings, and small droplets of liquid. These tiny particles vary greatly in shape, size, and chemical 

composition, and can be made up of many different materials such as metals, soot, soil, and dust.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

169

Pathogen: Any disease-producing agent, especially a virus, bacterium, or other microorganism.

Perennial: A plant with a life cycle lasting more than two years; a stream that flows year round.

Persistence: The length of time a compound, once introduced into the environment, stays there.

Pesticide: Any substance used for controlling, preventing, destroying, repelling, or mitigating any pest. Includes 

fungicides, herbicides, fumigants, insecticides, nematicides, rodenticides, desiccants, defoliants, plant growth 

regulators, and so forth. Any material used in this manner is a pesticide and must be registered as such, even if it 

has other non-pesticide uses.

pH: A measure of how acidic or alkaline (basic) a solution is on a scale of 0 to 14 with 0 being very acidic, 14 being 

very alkaline, and 7 being neutral. The abbreviation stands for the potential of hydrogen.

Photo degradation: The photochemical transformation of a molecule into lower molecular weight fragments, 

usually in an oxidation process. This term is widely used in the destruction (oxidation) of pollutants by ultravioletbased processes.

Photolysis: The chemical breakdown of a compound due to reaction with light.

Post-emergent (herbicide): Herbicide used to kill invasive plants after they have germinated and are growing.

Pre-emergent (herbicide): An herbicide applied to the soil to keep seeds from germinating.

Prescribed fire: A wildland fire that burns under specified conditions and in a predetermined area, to produce the 

fire behavior and fire characteristics required to attain resource management objectives.

Prevention: To detect and ameliorate conditions that cause or favor the introduction, establishment, or spread of 

invasive organisms or conditions.

Project Design Features: Features included as part of this analysis to prevent adverse effects from invasive plant 

treatments.

Propagule: A part of a plant, e.g., a bud, spore, or root fragment, capable of producing a new plant.

Proposed threatened or endangered species: Plant or animal species proposed by the U.S. Fish and Wildlife 

Service or National Marine Fisheries Service to be biologically appropriate for listing as threatened or endangered 

and that is published in the Federal Register. It is not a final designation. Proposed species are, at minimum, 

managed as Bureau Sensitive until a decision is made about Federal listing.

Rangeland: Land on which the native vegetation is predominantly grasses, grass-like plants, forbs, or shrubs; not 

forests.

Receptor: A biological entity such as a human, fish, plant, or invertebrate; used in the context of herbicide Risk 

Assessments and the organisms that are used to assess the potential affects of the herbicide. 

Research Natural Areas (RNAs): Parts of a national network of reserved areas under various ownerships, 

containing important ecological and scientific values that are managed for minimum human disturbance. They are 

established and managed to protect ecological processes, conserve biological diversity, and provide opportunities 

for observation for research and education.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

170

Residue: Herbicide or its metabolites remaining in or on soil, water, plants, animals, or other surfaces.

Restricted Use Pesticide: A classification assigned by the EPA to prevent unreasonable adverse effects from a 

pesticide product. The classification restricts a product, or its uses, to use by a certified applicator. They are not 

available to the general public.

Resource Management Plan: Current generation of land use plans developed by BLM under the FLPMA; replaces 

the older generation management framework plans; provides long-term (up to 20 years) direction for the 

management of a particular area of land, usually corresponding to a BLM field office, and its resources.

Revegetation: Establishing or re-establishing desirable plants where desirable plants are absent or of inadequate 

density, either by controlling site conditions (including the suppression of unwanted competition) so existing 

vegetation can reseed and spread, or by direct seeding or transplanting.

Right-of-way: A permit or an easement that authorizes the use of lands for certain specified purposes, such as the 

construction of forest access roads, gas pipelines, or power lines.

Riparian area: Those terrestrial areas where the vegetation complex and microclimate conditions are products of 

the combined presence and influence of perennial or intermittent water, associated high water tables, and soils 

that exhibit some wetness characteristics. Normally used to refer to the zone within which plants grow rooted in 

the water table of these rivers, streams, lakes, ponds, reservoirs, springs, marshes, seeps, bogs, and wet meadows.

Riparian buffer: A strip of vegetation along the bank of a body of water that slows the rate of flow of runoff from 

adjoining uplands, causing sediment and other materials to deposit onto the land before the runoff enters and 

pollutes the body of water.

Riparian habitat: Areas adjacent to rivers and streams with a high density, diversity, and productivity of plant and 

animal species relative to nearby uplands.

Risk: The likelihood that a given exposure to an item or substance (e.g., herbicide dose) will produce illness or 

injury.

Risk Assessment: The process of gathering data and making assumptions to estimate short- and long-term harmful 

effects to human health or elements of the environment from particular products or activities. See Appendix C, 

Herbicide Risk Assessment Summaries.

Risk quotient: The Estimated Environmental Concentration (EEC), as calculated through computer modeling, 

divided by the LD50 (lethal dose where 50 percent of test population dies) or LC50 (lethal concentration for aquatic 

forms, where 50 percent of the test population dies). RQs were developed to provide a more realistic scenario of 

herbicide exposure. Even so, results assume 100 percent exposure and animals confined to the treatment area. For 

species that are at all mobile, such exposures are unlikely from the applications proposed by the action 

alternatives. Analogous to Hazard Quotient. An RQ less than or equal to 1 is presumed to indicate an acceptably 

low level of risk for a specific application.

Runoff: Overland flow; the part of precipitation, as well as any other flow contributions that does not soak into soil 

or stay held on the site for evaporation or transpiration, but runs into streams.

Safety data sheet (SDS): A compilation of information required under the Occupational Safety and Health 

Administration Communication Standard on the identity of hazardous chemicals, health and physical hazards, 

exposure limits, and precautions.

Salmonids: Fishes of the family Salmonidae, including salmon, trout, chars, whitefish, ciscoes, and grayling.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

171

Sand: Individual rock or mineral fragments that range in diameter from 0.05 to 2 mm in diameter.

Scoping: A process at the beginning of a NEPA analysis whereby the public is asked to provide oral or written 

comments about the scope of the analysis and the range of alternatives, to help ensure the analysis appropriately 

addresses potential effects on individuals, communities, and the environment.

Secondary invasion: An increase in abundance of non-target invasive plants following treatment of targeted 

invasive plants.

Sediments: Unweathered geologic materials generally laid down by or within water bodies; the rocks, sand, mud, 

silt, and clay at the bottom and along the edge of lakes, streams, and oceans.

Selective herbicide: A chemical designed to affect only certain groups or types of plants, leaving other tolerant 

plants unharmed.

Sensitive species (Bureau Sensitive): Native species designated by the BLM State Director as sensitive because 

they are found on BLM-managed lands for which the BLM has the capability to significantly affect the conservation 

status of the species through management, and either: 1. There is information that a species has recently 

undergone, is undergoing, or is predicted to undergo a downward trend such that the viability of the species or a 

distinct population segment of the species is at risk across all or a significant portion of the species range, or 2. The 

species depends on ecological refugia or specialized or unique habitats on BLM-managed lands, and there is 

evidence that such areas are threatened with alteration such that the continued viability of the species in that area 

would be at risk.

Serpentine soil or substrate: Serpentine soils are unique for their low amounts of calcium and high amounts of 

magnesium, high concentrations of metals, and low levels of nitrogen.

Significant: The description of an impact that exceeds a certain threshold level. Requires consideration of both 

context and intensity. The significance of an action must be analyzed in several contexts, such as society as a 

whole, and the affected region, interests, and locality. Intensity refers to the severity of effects, which should be 

weighed along with the likelihood of its occurrence. Determination of significance for effects is a management 

decision considering multiple factors, and not one made by technical specialists to indicate the quantity of effects 

are above or below some level.

Silt: Individual mineral particles that range in diameter from between 0.002 and 0.05 mm in diameter.

Site-specific: At the site, area, or project level.

Socioeconomic: Pertaining to, or signifying the combination or interaction of social and economic factors.

Special Status species: Federally listed threatened, endangered, proposed, or candidate species, and species 

managed as sensitive species by the BLM.

Spot treatment: An application of an herbicide to a small selected area such as an individual plant, as opposed to a 

broadcast application.

Standard Operating Procedures: Procedures that would be followed by the BLM to ensure that risk to human 

health and the environment from treatment actions were kept to a minimum. See Appendix A. Since they originate 

from Manual and other direction, they may appear in resource management and other plans under other titles.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

172

Subsistence: Customary and traditional uses of wild renewable resources (plants and animals) for food, shelter, 

fuel, clothing, tools, etc.

Sulfonylurea: A group of herbicides that interfere with acetolactate synthase (ALS), an enzyme needed for plant 

cell growth.

Surfactant: A material that improves the emulsifying, dispersing, spreading, wetting, droplet size, or other surfacemodifying properties of liquids.

Target species: A species (in this EA, a plant species) that is a target or goal of a treatment or control effort.

Targeted grazing: The carefully controlled grazing of livestock, such as cattle, sheep, or goats, to accomplish 

specific vegetation management objectives. Livestock can be used as a tool for improving land health by 

performing weed control and aiding in restoration projects.

Threatened species: A plant or animal species federally listed as threatened under the Endangered Species Act, 

and status defined as likely to become an endangered species throughout all or a significant portion of its range 

within the foreseeable future.

Toxicity: A characteristic of a substance that makes it injurious.

Traditional use areas (Native American plant gathering): Areas where Tribes continue to gather plant materials 

for food, basketry, and other traditional uses. These may or may not be treaty reserved rights or areas.

Transmissivity: See Groundwater Transmissivity.

Treaty rights: Tribal rights or interests reserved in treaties, by Native American Tribes for the use and benefit of 

their members. The uses include such activities as described in the respective treaty document. Only Congress may 

abolish or modify treaties or treaty rights.

Tribe: Term used to designate any Native American band, nation, or other organized group or community.

Typical rate or typical application rate: One of two application rates considered in many Risk Assessments (the 

other being Maximum Rate); a rate based upon a general summary of actual applications that have been made of 

the different formulations of a particular active ingredient on BLM-managed lands. Under some situations, this 

value may be higher or lower than what is going to be applied for a specific job. The rate of application of any 

pesticide is based upon several factors, including, but not limited to, the species to be controlled, the environment 

for which the application is to be made, the timing of the application, and other factors. For example, a typical rate 

of application for imazapic is about 2.0 fluid ounces of Plateau, which, when taking into the concentration of the 

formulated product (2.0 pounds acid equivalent/per gallon) equates to 0.0313 lb. a.e./acre. It is known that 2.0 

fluid ounces of Plateau will achieve a specific level of control under a specific set of conditions. Rates around 4.0 to 

6.0 fluid ounces of imazapic appear to be the more common range for activity, based on the experience of 

researchers, for cheatgrass. The rate is based upon what is identified as what is normally considered for 

application under a normal condition. 

Uncertainty factor: A multiplier used in Risk Assessments to compensate for unknown risks due to limitations in 

the research.

Volatilization: The conversion of a solid or liquid into a gas or vapor; evaporation of herbicide before they are 

bound to a plant or ground.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Glossary

173

Weed: When not preceded by “noxious,” this term generally means invasive plants (including noxious weeds) in 

this EA. Its use in this EA is avoided except when it is used in citations and paraphrases of other documents, or is 

part of titles or common phrases. Within such documents, the intent is usually noxious weeds and other invasive 

plants.

Wetlands: An area that is saturated by surface or ground water with vegetation adapted for life under those soil 

conditions, as swamps, bogs, fens, marshes, and estuaries.

Wild and Scenic Rivers: Rivers designated in the National Wild and Scenic Rivers System that are classified in one 

of three categories (wild, scenic, or recreational), depending on the extent of development and accessibility along 

each section. In addition to being free flowing, these rivers and their immediate environments must possess at 

least one outstandingly remarkable value: scenic, recreational, geologic, fish and wildlife, historical, cultural, or 

other similar values.

Wilderness: Land designated by Congress as a component of the National Wilderness Preservation System.

Wildfire: Unplanned ignitions or prescribed fires that are declared wildfires. Wildfires may be managed to meet 

one or more objectives as specified in Resource Management Plans and the objectives can change as the fire 

spreads across the landscape.

Wildland fires: Fires occurring on wildlands, regardless of ignition source, damages, or benefits, and including 

wildfire and prescribed fire.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

174

References

Cited As Reference

AECOM 2014a AECOM. 2014. Fluroxypyr Ecological Risk Assessment Final Report. Prepared for USDI BLM. Manchester, 

New Hampshire.

AECOM 2014b AECOM. 2014. Rimsulfuron Ecological Risk Assessment Final Report. Prepared for USDI BLM. Manchester, 

New Hampshire.

AECOM 2014c AECOM. 2014. Final Human Health Risk Assessment Final Report. Prepared for USDI BLM. Manchester, 

New Hampshire.

AECOM 2014d AECOM. 2014. Clopyralid Ecological Risk Assessment Final Report. Prepared for USDI BLM. Manchester, 

New Hampshire.

AECOM 2014e AECOM. 2014. 2,4-D Ecological Risk Assessment Final Report. Prepared for USDI BLM. Manchester, New 

Hampshire.

AECOM 2015 AECOM. 2015. Aminopyralid Ecological Risk Assessment Final Report. Prepared for USDI BLM. 

Manchester, New Hampshire.

Aikens et al. 1992 Aikens et al. 1993. Archaeology of Oregon. USDI-BLM Publication, Oregon State Office Publication. Pp. iii. 

Preface by Richard Hanes. Pp. iii. Cited in Archaeology of Oregon.

Aikens et al. 1993 Aikens et al. 1993. Archaeology of Oregon. USDI-BLM Publication, Oregon State Office Publication. Pp. iii. 

Preface by Richard Hanes. Pp. iii. Cited in Archaeology of Oregon.

Amsberry et al. 

2016

Amsberry, K., Brown J. and R. J. Meinke. 2016. The effect of the herbicide imazapyr on seedling 

emergence and survival of Abronia umbellata var. breviflora (pink sand verbena). Oregon Department of 

Agriculture, Native Plant Conservation Program, 14p.

ASI 2006

American Sheep Industry. 2006. Targeted Grazing: A Natural Approach to Vegetation Management and 

Landscape Enhancement. Karen Launchbaugh (ed.). American Sheep Industry Assoc. Available at 

http://www.fs.fed.us/rm/pubs/rmrs_gtr292/2006_launchbaugh_k002.pdf

Bahm and Barnes 

2011

Bahm, M.A. and T.G. Barnes. 2011. Native grass and forb response to pre-emergent treatment of 

imazapic and imazapyr. Natural Areas Journal 31:75-79.

Balbuena et al. 

2015

Balbuena M.S., Tison L., Hahn M.L., Greggers U., Menzel R., Farina W.M. 2015. Effects of sublethal doses 

of glyphosate on honeybee navigation. Journal of Experimental Biology. 218:2799-2805. Available at 

http://jeb.biologists.org/content/218/17/2799

BASF 2008 BASF. 2008. Plateau Herbicide Label. Research Triangle Park, North Carolina.

Battaglin et al. 

2000

Battaglin, W.A., E.T. Furlong, M.R. Burkhardt, and C.J. Peter. 2000. Occurrence of Sulfonylurea, 

Sulfonamide, Imidazolinone, and Other Herbicides in Rivers, Reservoirs and Ground Water in the 

Midwestern United States, 1998. Science of the Total Environment 248:123-133.

Bear 1972 Bear, J. 1972. Dynamics of fluids in porous media. Dover Publications. ISBN 0-486-65675-6. 

Bell et al. 2012 Bell, J.L., M.R. Manucheri, H. Malone., and I.C. Burke. 2012. Absorption and translocation of aminopyralid 

and clopyralid in rush skeletonweed. Proceedings – Western Society of Weed Science 65.

Benachour and 

Seralini 2008

Benachour, N. and Seralini, G-E. 2008. Glyphosate formulations induce apoptosis and necrosis in human 

umbilical, embryonic, and placental cells. Chemical Research in Toxicology, DOI: 10.1021/tx800218n. 

December 23, 2008. Available at http://pubs.acs.org/doi/abs/10.1021/tx800218n

Berg 2004 Berg, N. 2004. Assessment of herbicide best management practices: Status of our knowledge of BMP 

effectiveness. Pacific Southwest Research Station. USDA Forest Service. Albany, CA. 

Bergman et al. 

2012

Bergman, A., JJ Heindel, S Jobling, KA Kidd and RT Zoeller, eds. 2012. State of the Science of Endocrine 

Disrupting Chemicals Summary for Decision Makers. Geneva, Switzerland. Available at 

http://apps.who.int/iris/bitstream/10665/78102/1/WHO_HSE_PHE_IHE_2013.1_eng.pdf?ua=1

Black and Vaughan 

2005

Black, S. H., and D. M. Vaughan. 2005. Species Profile: Polites mardon. In Shepherd, M. D., D. M. 

Vaughan, and S. H. Black (Eds). Red List of Pollinator Insects of North America. CD-ROM Version 1 (May 

2005). Portland, OR: The Xerces Society for Invertebrate Conservation.

Black et al. 2010

Black, S.H., L. Beyer, S. Jepsen, C. Mazzacano, M. Shepherd, A. Minnerath. 2010. Management plans for 

all Southern Oregon Cascade mardon skipper (Polites mardon klamathensis) sites on BLM lands. Final 

Report to the Forest Service and BLM from The Xerces Society. Portland, OR: The Xerces Society.

BPA 2000 Bonneville Power Administration. 2000. Transmission System Vegetation Management Program 

Environmental Impact Statement. Portland, OR. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

175

Cited As Reference

Brooks et al. 1995

Brooks, J.J., J.L. Rodrigues, M.A. Cone, KV Miller, B.R. Chapman and others. 1995. Small mammal and 

avian communities on chemically-prepared sites in the Georgia Sandhills. Gen. Tech. Rpt. Southern 

Research Station USDA Forest Service; pp 21-23.

California 

Department of 

Pesticide 

Regulation 2005

California Department of Pesticide Regulation. 2005. Public Report 2005-01. Fluroxypyr. Tracking ID

197141 N. Available at http://www.cdpr.ca.gov/docs/registration/ais/publicreports/5768.pdf

CFPA 2017 Coos Forest Protective Association. (website) 2017 Available at http://www.coosfpa.net/aboutcfpa.asp. 

Accessed February 12, 2018.

CH2M Hill 1995 CH2M Hill. 1995. Sand dune aquifer groundwater availability study. Prepared for the Coos Bay-North 

Bend Water Board.

Chang and Dezell 

2016

Chang, E.T. and E.D. Delzell. 2016. Systematic review and meta-analysis of glyphosate exposure and risk 

of lymphohematopoietic cancers. Journal of Environmental Science and Health. 51(6):402-434. Available 

at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4866614/

Community 

Attributes Inc. 

2017

Community Attributes Inc. 2017. Economic Impact of invasive Species: Direct Costs Estimates and 

Economic Impacts for Washington State. Report prepared for State of Washington. Available at

http://www.invasivespecies.wa.gov/council_projects/economic_impact/Invasive%20Species%20Econom

ic%20Impacts%20Report%20Jan2017.pdf

DiTomaso and 

Kyser 2006

DiTomaso, J.M. and G.B. Kyser. 2006. Evaluation of Imazapyr and Aminopyralid for Invasive Plant 

Management. Proceedings of the California Weed Science Society. 58:107-109.

DiTomaso et al. 

2013

DiTomaso, J.M., G.B. Kyser et al. 2013. Weed Control in Natural Areas in the Western United States. 

Weed Research and Information Center, University of California. 

Douthit 1999 Douthit, Nathan. 1999. A Guide to the Oregon South Coast History: Traveling the Jedediah Smith Trail. 

Canada: Oregon State University Press. Corvallis, OR. 

EFSA 2017

European Food Safety Authority. July 6th, 2017. Letter to Dr. Portier. Subject: your letter: Review of the 

carcinogenicity of Glyphosate by ECHA, EFSA, and BrF. Available at

https://echa.europa.eu/documents/10162/23294236/portier_echa_efsa_response.pdf/9e199eca-af2f96bb-9e61-d6bae2588f4b

Enloe et al. 2007

Enloe, S.F., R.G. Lym, R. Wilson, P. Westra, S. Nissen, G. Beck, M. Moechnig, V. Peterson, R.A. Masters, 

and M. Halstvedt. 2007. Canada thistle (Cirsium arvense) control with aminopyralid in range, pasture, 

and non-crop areas. Weed Technology. 21:890-894.

Enloe et al. 2008

Enloe, S.F., G.B. Kyser, S.A. Dewey, V. Peterson, and J.M. DiTomaso. 2008. Russian knapweed (Acroptilon 

repens) control with low Rates of Aminopyralid on Range and Pasture. Invasive Plant Science and 

Management 1(4):385-389.

ENSR 2005c

ENSR. 2005. Vegetation Treatments Programmatic EIS – Chlorsulfuron Ecological Risk Assessment Final 

Report. Prepared for the U.S. Department of the Interior Bureau of Land Management, Nevada State 

Office, Reno, Nevada. Westford, Massachusetts.

ENSR 2005d

ENSR. 2005. Vegetation Treatments Programmatic EIS – Diflufenzopyr Ecological Risk Assessment Final 

Report. Prepared for the U.S. Department of the Interior Bureau of Land Management, Nevada State 

Office, Reno, Nevada. Westford, Massachusetts.

ENSR 2005g

ENSR. 2005. Vegetation Treatments Programmatic EIS – Fluridone Ecological Risk Assessment Final 

Report. Prepared for the U.S. Department of the Interior Bureau of Land Management, Nevada State 

Office, Reno, Nevada. Westford, Massachusetts.

ENSR 2005h

ENSR. 2005. Vegetation Treatments Programmatic EIS – Imazapic Ecological Risk Assessment Final 

Report. Prepared for the U.S. Department of the Interior Bureau of Land Management, Nevada State 

Office, Reno, Nevada. Westford, Massachusetts.

ENSR 2005i 

ENSR. 2005. Vegetation Treatments Programmatic EIS – Overdrive® Ecological Risk Assessment Final 

Report. Prepared for the U.S. Department of the Interior Bureau of Land Management, Nevada State 

Office, Reno, Nevada. Westford, Massachusetts.

ENSR 2005j

ENSR. 2005. Vegetation Treatments Programmatic EIS – Sulfometuron Methyl Ecological Risk Assessment 

Final Report. Prepared for the U.S. Department of the Interior Bureau of Land Management, Nevada 

State Office, Reno, Nevada. Westford, Massachusetts.

ENSR 2005l ENSR. 2005. Vegetation Treatment Programmatic Environmental Impact Statement Human Health Risk 

Assessment Final Report. Prepared for BLM Nevada State Office, Reno, NV.

Extoxnet 1996 Extension Toxicology Network (Extoxnet). 1996. Sulfometuron methyl. Pesticide Information Profiles. 

Extension Technology Network. Available at http://extoxnet.orst.edu/pips/sulfomet.htm
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

176

Cited As Reference

Farm Service 

Genetics 2008 Farm Service Genetics. 2008. SS 200 BMR Sorghum Sudangrass.

Fletcher et al. 

1996

Fletcher JS, Nellessen JE, Pfleeger TG (1994) Literature Review And Evaluation Of The Epa Food-Chain 

(Kenaga) Nomogram, An Instrument For Estimating Pesticide Residues On Plants. Environmental 

Toxicology and Chemistry: Vol. 13, No. 9 pp. 1383–1391

Fletcher et al. 

1996

Fletcher, J.S., T.G. Pfleeger, H.C. Ratsch, and R. Hayes. 1996. Potential impact of low levels of 

chlorsulfuron and other herbicides on growth and yield of nontarget plants. Environmental Toxicology 

and Chemistry 15:1189-1196.

Gordon 1998 Gordon, D. 1998. Effects on invasive, non-indigenous plant species on ecosystem processes: lessons from 

Florida. Ecological Society of America. 8(4):975-989.

Gray 1987 Gray, D.J. The Takelma and Their Athapaskan Neighbors: A New Ethnograophic Synthesis for the Upper 

Rogue River Area of Southwestern Oregon. University of Oregon Anthropological Papers:37.

Gustafson 1989

Gustafson, D.I. 1989. Groundwater Ubiquity Score: A Simple Method for Assessing Pesticide Leachability. 

Enviromental Toxicology and Chemistry, 8, 339-357. Available at 

http://dx.doi.org/10.1002/etc.5620080411

Halofsky and 

Peterson 2016

Halofsky, J.E. and D. L. Peterson. 2016. Climate Change Vulnerabilities and Adaptation Options for Forest 

Vegetation Management in the Northwestern USA. Atmosphere 7(3), 46. Available at 

doi:10.3390/atmos7030046.

Hanson et al. 2015 Hanson, B., C. Bond, K. Buhl, D. Stone. 2015. Pesticide half-life fact sheet. National Pesticide Information 

Center, Oregon State University Extension Service. http://npic.orst.edu/factsheets/half-life.html

Herbert et al. 2014

Herbert LT, Vázquez DE, Arenas A, Farina WM. 2014. Effects of field-realistic doses of glyphosate on 

honeybee appetitive behavior. Journal of Experimental Biology 217:3457-3464. Available at 

http://jeb.biologists.org/content/217/19/3457

IARC 2015

International Agency for Research on Cancer. 2016. IARC Monographs Volume 112: evaluation of five 

organophosphate insecticides and herbicides. March 2015. Lyon, France. Available at 

http://www.iarc.fr/en/media-centre/iarcnews/pdf/MonographVolume112.pdf

Jervais et al. 2008

Jervais, G.; Luukinen, B.; Buhl, K.; Stone, D. 2008. 2,4-D Technical Fact Sheet; National Pesticide 

Information Center, Oregon State University Extension Services. Available at 

http://npic.orst.edu/factsheets/archive/2,4-DTech.html

JMPR 2016

Joint Food and Agriculture Organization of the United Nations/World Health Organization Meeting on 

Pesticide Residues Summary Report. May 9-13, 2016. Geneva, Switzerland. Available at 

http://www.who.int/foodsafety/jmprsummary2016.pdf?ua=1

Kelland 2017 Kelland, Kate. June 14, 2017. Cancer agency left in the dark over glyphosate evidence. Reuters. Available 

at http://www.reuters.com/investigates/special-report/glyphosate-cancer-data/

Kerle et al. 2007 Kerle, E. A., J. J. Jenkins, P. A. Vogue. 2007. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561-E.

Koterba et al. 1993 Koterba, M.T., W.S.L. Banks, and R.J. Shedlock. 1993. Pesticides in Shallow Groundwater in the Delmarva 

Peninsula. Journal of Environmental Quality. 22:500-518.

Lauten et al 2015

Lauten D.J., K.A. Castelein, J.D. Farrar, A.A. Kotaich, E. Krygsman, and E.P.Gaines. 2015. The Distribution 

and Reproductive Success of the Western Snowy Plover along the Oregon Coast – 2015. Oregon 

Biodiversity Information Center Institute for Natural Resources Portland State University. Portland State 

University. 56 pp.

Lindenmeyer 2012 Lindenmayer, R.B. 2012. Understanding aminocyclopyrachlor behavior in soil and plants. Ph.D. thesis, 

Colorado State University, Fort Collins, CO. 82 pp.

Lyman 1991 Lyman R.L. 1991. Prehistory of the Oregon Coast. The effects of Excavation Strategies and Assemblage 

Size on Archaeological Inquiry. Academic Press, San Diego, CA. Ch.2. pp.16.

Mesnage et al. 

2015

Mesnage, R., M. Arno, M. Costanzo, M. Malatesta, G.E. Séralini, and M.N. Antoniou. Transcriptome 

profile analysis reflects rat liver and kidney damage following chronic ultra-low dose Roundup exposure. 

Environmental Health. 2015;14:70. doi:10.1186/s12940-015-0056-1.

Metzger et al. 

1998

Metzger, L.O.Y., C. Munier-Lamy, T. Choné, F. Andreux, M.J. Belgy, J.M.F. Martins, and A. Mermoud. 

1998. Fate of the Sulfonylurea Herbicide Rimsulfuron in Soil: Mobility and Interactions with Soil 

Constituents (Poster). Proceedings of the 16th World Congress of Soil Science.

National Library of 

Medicine 2011

National Library of Medicine. 2011. Fluroxypyr. Toxicology Data Network HSDB Database. Available at 

http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+6655

NMFS 2013 National Marine Fisheries Service. 2013. Endangered Species Act – Section 7 Programmatic Consultation 

Conference and Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

177

Cited As Reference

Essential Fish Habitat Response for Reinitiation of Aquatic Restoration Activities in States of Oregon and 

Washington (ARBO II). NMFS Consultation Number: NWR-2013-9664. 

NRCS 2016 Natural Resources Conservation Service (NRCS). 2016. Soil data viewer. Available at 

https://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/soils/home/?cid=nrcs142p2_053620.

NRCS 2017a

Natural Resources Conservation Service (NRCS). 2017. TSSH Part 617 Water table determinations. 

Available at https://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/ref/?cid=nrcs142p2_053385. (14 

January).

NRCS 2017b Natural Resources Conservation Service (NRCS). 2017. Soil Survey Technical Note 6. Available at 

https://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/ref/?cid=nrcs142p2_053573. (14 January).

NYSDEC 2006

New York State Department of Environmental Conservation (NYSDEC). 2006. Registration of Vista and 

Spotlight Herbicide (EPA Reg. No. 62719-308) Which Contain the New Active Ingredient: Fluroxypyr 

(Chemical Code: 128968). Letter to Jim Baxter, Dow AgroSciences, LLC Dated May 2, 2006. Albany, New 

York.

OCCRI 2017

Oregon Climate Change Research Institute. 2017 Third Oregon Climate Assessment Report. Oreson State 

University. Corvallis, OR. Available at http://www.occri.net/publications-and-reports/third-oregonclimate-assessment-report-2017/

ODA 2009 Oregon Department of Agriculture. 2009. Annual Report: Pesticide Use Reporting System for 2008. 

Salem, OR.

ODA 2014

Oregon Department of Agriculture. 2014. Economic Impact From Selected Noxious Weeds in Oregon. 

Salem, OR. Available at 

https://www.oregon.gov/ODA/shared/Documents/Publications/Weeds/ORNoxiousWeedEconomicImpac

t.pdf 

ODA 2017

Oregon Department of Agriculture. 2017. Oregon Noxious Weed Policy and Classification. Salem, 

OR.Available at 

http://www.oregon.gov/ODA/shared/Documents/Publications/Weeds/NoxiousWeedPolicyClassification.

pdf

ODEQ 2005 Oregon Department of Environmental Quality (ODEQ). 2005. Potential contaminant sources as of 

October 2005. Available at http://www.oregon.gov/deq/wq/programs/Pages/DWP-Maps.aspx.

ODEQ 2014

Oregon Department of Environmental Quality (ODEQ). 2014. Methodology for Oregon’s 2012 water 

quality report and list of water quality limited waters. Available at 

http://www.oregon.gov/deq/FilterDocs/AssessmentMethodologyRep.pdf.

ODEQ 2015 Oregon Department of Environmental Quality (ODEQ). 2015. 2012 Integrated Report Assessment 

Geodatabase. Available at http://www.oregon.gov/deq/Data-and-Reports/Pages/GIS.aspx

ODEQ 2017a Oregon Department of Environmental Quality (ODEQ). 2017. Introduction to Oregon’s Drinking Water 

Protection Program. Available at https://services.oregon.gov/deq/FilterDocs/dwpIntro.pdf

ODEQ 2017b Oregon Department of Environmental (ODEQ). 2017. Surface water drinking water source areas in 

Oregon Version 5. Available at http://www.oregon.gov/deq/wq/programs/Pages/DWP-Maps.aspx

ODEQ 2017c Oregon Department of Environmental Quality (ODEQ). 2017. Groundwater drinking water source areas 

in Oregon Version 5. Available at http://www.oregon.gov/deq/wq/programs/Pages/DWP-Maps.aspx

ODF 2011 Oregon Department of Forestry. 2011. Elliot State Forest Management Plan.

ODF 2014

Oregon Department of Forestry. 2017. Data provided to the Oregonian for article: In Oregon, helicopters 

spray weed killers near people under West Coast's weakest protections. Rob Davis, October 23, 2014. 

Available at 

http://www.oregonlive.com/environment/index.ssf/2014/10/in_oregon_helicopters_spray_we.html

ODF 2016 Oregon Department of Forestry. 2016. Oregon Smoke Management Annual Report. Salem, OR. Available 

at http://www.oregon.gov/ODF/Board/Documents/SMAC/2016AnnualReport.pdf

ODFW 2016 Oregon Department of Fish and Wildlife. 2016. Oregon Conservation Strategy. Available at 

http://oregonconservationstrategy.org

ODOT 2016

Oregon Department of Transportation. 2016. ODOT Herbicide Reduction Final Report. Maintenance and 

Operations Branch. Available at 

http://www.oregon.gov/ODOT/Maintenance/Documents/Herbicide%20Reduction%20Final%20Report%

20April%202016.pdf 

Oregon SHPO and 

USDI 2015

Oregon State Historic Preservation Office and USDI Bureau of Land Management. 2015. State Protocol 

between the Oregon BLM and the Oregon SHPO regarding the manner in which the Bureau of Land 

Management will meet its responsibilities under the National Historic Preservation Act and the National 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

178

Cited As Reference

Programmatic Agreement among the BLM, the Advisory Council on Historic Preservation, and The 

National Conference of State Historic Preservation Officers.

OSU 2017 Oregon State University. 2017. Pacific Northwest Weed Management Handbook. Editor: Ed Peachey. 

Available at http://weeds.ippc.orst.edu/pnw/weeds?01W_INTR06.dat

OWRD 2013 Oregon Water Resources Department (OWRD). 2013. Water Rights in Oregon An introduction to 

Oregon’s water laws. Available at http://www.oregon.gov/owrd/PUBS/docs/aquabook.pdf

OWRD 2016 Oregon Water Resources Department (OWRD). 2016. Water Right Data/GIS Themes. Available at 

http://www.oregon.gov/owrd/pages/maps/index.aspx#Water_Right_Data_GIS_Themes

OWRD 2017a Oregon Water Resources Department (OWRD). 2017. Water Right Information Search. Available at 

http://www.oregon.gov/owrd/pages/wr/wris.aspx. (14 January).

Pacific Coast Seed 

2010

Pacific Coast Seed. 2010. Native Perennial Grasses: Planning, Seeding, Establishing, and Maintaining. 

Available at http://www.pcseed.com/docs/NATIVE%20PERENNIAL%20GRASSES-1.pdf

PES Environmental 

2005

PES Environmental, Inc. 2005. Monitoring well decommissioning and repair Weyerhaeuser 

containerboard mill North Bend, Oregon.

Pickart 2008

Pickart, A.J., 2008. Restoring the Grasslands of Northern California’s Coastal Dunes. California Native 

Grassland Association. Available at 

http://www.fws.gov/uploadedFiles/Region_8/NWRS/Zone_1/Humboldt_Bay_Complex/Humbolt_Bay/Se

ctions/Documents/grasslandsarticle.pdf

Plum 2017 Plum, K. June 27 2017. California to list herbicide as cancer-causing; Monsanto vows fight. Reuters. 

Available at http://www.reuters.com/article/us-usa-glyphosate-california-idUSKBN19H2K1

Radtke and Davis 

2000

Radtke, Hans D. and Shannon W. Davis. 2000. Economic Analysis of Containment Programs, Damages, 

and Production Losses From Noxious Weeds in Oregon. Oregon Department of Agriculture, Plant 

Division, Noxious Weed Control Program.

Relyea 2005b Relyea, R.A. 2005. The lethal impact of Roundup® on aquatic and terrestrial amphibians. Ecological 

Applications 15:1118-1124. Available at https://www.nrc.gov/docs/ML1434/ML14345A564.pdf

Rosenbom et al. 

2010

Rosenbom, A.E., J.K. Jaer, and P. Olsen. 2010. Long-term leaching of rimsulfuron degradation products 

through sandy agricultural soils. Chemosphere 79(2010):830-838

SERA 1997

Syracuse Environmental Research Associates, Inc. (SERA). 1997. Selected Commercial Formulations of 

Hexazinone – Human Health and Ecological Risk Assessment Final Draft. SERA TR 95-21-04-01b. March 4, 

1997.

SERA 2003a 

Syracuse Environmental Research Associates, Inc. (SERA). 2003. Glyphosate – Human Health and 

Ecological Risk Assessment Final Report. SERA TR 02-43-09-04a. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2003b 

Syracuse Environmental Research Associates, Inc. (SERA). 2003. Picloram – Revised Human Health and 

Ecological Risk Assessment Final Report. SERA TR 03-43-16-01b. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2003c

Syracuse Environmental Research Associates, Inc. (SERA). 2003. Triclopyr – Revised Human Health and 

Ecological Risk Assessment Final Report. SERA TR 02-43-13-03b. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2004a 

Syracuse Environmental Research Associates, Inc. (SERA). 2004. Chlorsulfuron – Human Health and 

Ecological Risk Assessment Final Report. SERA TR 04-43-18-01c. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York. 

SERA 2004b

Syracuse Environmental Research Associates, Inc. (SERA). 2004. Clopyralid (Transline) – Human Health 

and Ecological Risk Assessment Final Report. SERA TR 04 43-17- 03c. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2004c 

Syracuse Environmental Research Associates, Inc. (SERA). 2004. Imazapic Plateau and Plateau Dg –

Human Health and Ecological Risk Assessment Final Report. SERA TR 04-43- 17-04b. Prepared for the U.S. 

Department of Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York. 

SERA 2004d

Syracuse Environmental Research Associates, Inc. (SERA). 2004. Imazapyr – Human Health and Ecological 

Risk Assessment Final Report. SERA TR 04-43-17-05b. Prepared for the U.S. Department of Agriculture 

Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2004e 

Syracuse Environmental Research Associates, Inc. (SERA). 2004. Metsulfuron Methyl – Human Health and 

Ecological Risk Assessment Final Report. SERA TR 04-43-17- 01c. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

179

Cited As Reference

SERA 2004f

Syracuse Environmental Research Associates, Inc. (SERA). 2004. Sulfometuron Methyl – Human Health 

and Ecological Risk Assessment Final Report. SERA TR 03-43-17- 02c. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2004g

Syracuse Environmental Research Associates, Inc. (SERA). 2004. Dicamba - Human Health and Ecological 

Risk Assessment Final Report. SERA TR 04-43-17-06d. Prepared for the U.S. Department of Agriculture 

Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2005c

Syracuse Environmental Research Associates, Inc. (SERA). 2005c. Hexazinone – Human Health and 

Ecological Risk Assessment Final Report. SERA TR 05-43-20-03d. Prepared for the U.S. Department of 

Agriculture Forest Service, Arlington, Virginia. Fayetteville, New York.

SERA 2006 

Syracuse Environmental Research Associates, Inc. (SERA). 2006 2,4 Dichlorophenoxyacetic Acid 

Formulations – Human Health and Ecological Risk Assessment Final Report. Prepared for the U.S. 

Department of Agriculture Forest Service. Arlington, Virginia. Fayetteville, New York.

SERA 2007

Syracuse Environmental Research Associates, Inc. (SERA). 2007. Aminopyralid Human Health and 

Ecological Risk Assessment. Final Report. Prepared for USDA Forest Service and National Park Service. 

Syracuse, New York.

SERA 2008

Syracuse Environmental Research Associates, Inc. (SERA). 2008. Fluridone Human Health and Ecological 

Risk Assessment. Final Report. Prepared for USDA Forest Service and National Park Service. Syracuse, 

New York.

SERA 2009 Syracuse Environmental Research Associates, Inc. (SERA). 2009. Fluroxypyr Human Health and Ecological 

Risk Assessment. Final Report. Prepared for USDA Forest Service, Southern Region. Syracuse, New York.

SERA 2011a 

Syracuse Environmental Research Associates, Inc. (SERA). 2011. Glyphosate – Human Health and 

Ecological Risk Assessment Final Report. SERA TR 052-22-03b. Prepared for the U.S. Department of 

Agriculture Forest Service, Atlanta, Georgia.

SERA 2011b

Syracuse Environmental Research Associates, Inc. (SERA). 2011. Imazapyr– Human Health and Ecological 

Risk Assessment Final Report. SERA TR 052-29-03b. Prepared for the U.S. Department of Agriculture 

Forest Service, Atlanta, Georgia.

SERA 2011c 

Syracuse Environmental Research Associates, Inc. (SERA). 2011. Picloram– Human Health and Ecological 

Risk Assessment Final Report. SERA TR 052-27-03b. Prepared for the U.S. Department of Agriculture 

Forest Service, Atlanta, Georgia.

SERA 2011d

Syracuse Environmental Research Associates, Inc. (SERA). 2011. Triclopyr. Human Health and Ecological 

Risk Assessment Final Report. SERA TR 052-25-03b. Prepared for the U.S. Department of Agriculture 

Forest Service, Atlanta, Georgia.

SERA 2014

Syracuse Environmental Research Associates, Inc. (SERA). 2014. Fluazifop-P-butyl. Human Health and 

Ecological Risk Assessment Final Report. SERA TR 052-25-03b. Prepared for the U.S. Department of

Agriculture Forest Service, Atlanta, Georgia.

Sheley et al. 2007 Sheley, R.L., M.F. Carpinelli, and K.J. Reever Morghan. 2007. Effects of imazapic on target and nontarget 

vegetation during revegetation. Weed Technology 21:1071-1081.

Tao and Yang 2011 Tao, L., and H Yang. 2011. Fluroxypyr Biodegradation in Soils by Multiple Factors. Environmental 

Monitoring and Assessment (2011) 175:227-238.

The Research 

Group, LLC 2014

The Research Group, LLC. 2014. Economic Impact From Selected Noxious Weeds in Oregon. Prepared for 

Oregon Department of Agriculture Noxious Weed Control Program. 

http://www.oregon.gov/ODA/shared/Documents/Publications/Weeds/ORNoxiousWeedEconomicImpact

.pdf

Thompson et al. 

2004

Thompson, D.G., B.F. Wojtaszek, B. Staznik, D.T. Chartrand, and G.R. Stephenson. 2004. Chemical and 

biomonitoring to assess potential acute effects of Vision herbicide on native amphibian larvae in forest 

wetlands. Environmental Contamination and Toxicology 23:843–849. 

Tu et al. 2001

Tu, M., C. Hurd, and J.M. Randall. 2001. Weed Control Methods Handbook: Tools & Techniques for 

Natural Areas. The Nature Conservancy. Available at http://www.invasive.org/gist/handbook.html. June 

2001.

University of Idaho 

2011

University of Idaho. 2011. Herbicide-Resistant Weeds and Their Management, PNW 437, a Pacific 

Northwest Extension publication (University of Idaho, revised 2011). Joan Campbell, University of Idaho; 

Carol Mallory-Smith and Andy Hulting, Oregon State University; Donn Thill, University of Idaho. Available 

at http://www.cals.uidaho.edu/edComm/pdf/pnw/pnw0437.pdf

USDA 1995 USDA Forest Service. 1995b. Interim strategies for managing fish-producing watersheds in eastern 

Oregon and Washington, Idaho, western Montana, and portions of Nevada (INFISH).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

180

Cited As Reference

USDA 2005 USDA Forest Service. 2005. Pacific Northwest Region Invasive Plant Program: Preventing and Managing 

Invasive Plants. Environmental Impact Statement. Available at http://www.fs.fed.us/r6/invasiveplant-eis/

USDA 2006 USDA Agricultural Research Service. 2006. Poisonous Plant Research. Larkspur: Available at 

http://www.ars.usda.gov/Services/docshtm?docid=9943 

USDA 2016a USDA Natural Resources Conservation Service. 2016. Soil Web Survey, online database. Available at 

https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx

USDA and USDI 

1994b

USDA Forest Service and USDI Bureau of Land Management. 1994. Northwest Forest Plan and Record of 

Decision.

USDA and USDI 

1995

USDA Forest Service and USDI Bureau of Land Management. 1995. Decision Notice/Decision Record, 

Finding of No Significant Impact, Environmental Assessment for the Interim Strategies for Managing 

Anadromous Fish Producing Watersheds in Eastern Oregon and Washington, Idaho, and Portions of 

California (PACFISH). February. Washington, DC.

USDA and USDI 

2015a

USDA Forest Service and USDI Bureau of Land Management. 2015. Pollinator-Friendly Best Management 

Practices for Federal Lands (Draft). Available at 

http://www.fs.fed.us/wildflowers/pollinators/BMPs/documents/PollinatorFriendlyBMPsFederalLandsDR

AFT05152015.pdf

USDA et al. 2013

USDA Forest Service. Pacific Northwest Region, USDI-Bureau of Land Management, Oregon State Office, 

and USDI-Bureau of Indian Affairs. 2013. Biological Assessment for fish habitat restoration activities 

affecting ESA-Listed animal and plant species and their designated or proposed critical habitat and 

designated essential fish habitat under MSA found in Oregon, Washington and parts of California, Idaho 

and Nevada. January 28.

USDI 1985 USDI Bureau of Land Management. 1985. Northwest Area Noxious Weed Control Program Final 

Environmental Impact Statement. BLM Oregon State Office. Portland, OR. 

USDI 1987 USDI Bureau of Land Management. 1987. Supplemental Record of Decision Northwest Area Noxious 

Weed Control Program. Washington, D. C.

USDI 1989 USDI Bureau of Land Management. 1989. Coos Bay Shorelands Draft Management Plan. Coos Bay, OR.

USDI 1992a USDI Bureau of Land Management. 1992. Manual 9011. Chemical Pest Control Handbook. Available at 

http://www.blm.gov/ca/st/en/prog/weeds/9011.html 

USDI 1992b USDI Bureau of Land Management. 1992. Manual 9015. Integrated Weed Management. Release 9-321. 

Available at http://www.blm.gov/ca/st/en/prog/weeds/9015.html

USDI 1994 USDI Bureau of Land Management. 1994. Coos Bay Shorelands Draft Management Plan and 

Environmental Assessment. Coos Bay, OR.

USDI 1996 USDI Bureau of Land Management. 1996. Partners Against Weeds: An Action Plan for the Bureau of Land 

Management. Washington, D.C.

USDI 1997 USDI Bureau of Land Management. 1997. Integrated Noxious Weed Program on the Coos Bay District 

Environmental Assessment. Coos Bay, OR.

USDI 2005 USDI Bureau of Land Management. 2005. North Spit Plan. Coos Bay, OR.

USDI 2006

USDI Bureau of Land Management. 2006. Integrated Pest Management Provolt Seed Orchard, Grants 

Pass (Jackson & Josephine Counties), OR, Charles A. Sprague Seed Orchard, Merlin (Josephine County), 

OR Record of Decision. Available at https://www.blm.gov/or/districts/medford/plans/files/ProvoltSprague_eis_ROD_acc.pdf

USDI 2007a

USDI Bureau of Land Management. 2007. Vegetation Treatments using Herbicides on Bureau of Land 

Management Lands in 17 Western States Programmatic Environmental Impact Statement. Available at 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html 

USDI 2007b

USDI Bureau of Land Management. 2007. Vegetation Treatments using Herbicides on Bureau of Land 

Management Lands in 17 Western States Record of Decision. Available at 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html 

USDI 2007c USDI Bureau of Land Management. 2007. Vegetation Treatments on Bureau of Land Management Lands 

in 17 Western States. Biological Assessment BLM, Nevada State Office, Reno, NV.

USDI 2007d USDI Bureau of Land Management. 2007. Vegetation Treatments on Bureau of Land Management Lands 

in 17 Western States. Final Programmatic Environmental Report. BLM, Nevada State Office, Reno, NV.

USDI 2007e

USDI. Office of Environmental Policy and Compliance. 2007. Departmental Manual. Part 517. Pesticides 

Chapter 1 Integrated Pest Management Policy. Available at 

https://elips.doi.gov/ELIPS/DocView.aspx?id=1744

USDI 2007f USDI Bureau of Land Management. 2007. Biological Assessment of the BLM’s North Spit Plan as it may 

affect the Threatened Western Snowy Plover and its Critical Habitat. Coos Bay, OR. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

181

Cited As Reference

USDI 2007g

USDI Fish and Wildlife Service. 2007. Recovery Plan for the Pacific Coast Population of the Western 

Snowy Plover. Volume 1: Recovery Plan. Sacramento, CA. Available at: 

https://www.fws.gov/carlsbad/SpeciesStatusList/RP/20070813_RP_WSP.pdf

USDI 2008a

USDI Bureau of Land Management. 2008. BLM Manual H1740-2 Integrated Vegetation Management. 

Washington D.C. Available at 

https://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/blm_handbo

ok.Par.59510.File.dat/H-1740-2.pdf

USDI 2008b USDI Bureau of Land Management. 2008. BLM Manual 6840, Special Status Species Management. IM

2009-039. https://www.blm.gov/sites/blm.gov/files/uploads/mediacenter_blmpolicymanual6840.pdf

USDI 2008c USDI Fish and Wildlife Service. 2008. Migratory Bird Program Strategic Plan.

USDI 2008d

USDI Fish and Wildlife Service. 2007. Biological Opinion on the Management of the North Spit of Coos 

Bay for Effects on Western Snowy Plovers and Their Critical Habtiat on Bureau of Land Management 

Lands. Newport, OR. 

USDI 2009a

USDI Bureau of Land Management. 2009. New River Foredune Management Environmental Assessment, 

Finding of No Significant Impact, and Decision Record. OR128-06-01. Coos Bay District Office, North 

Bend, OR. 

USDI 2009b USDI Bureau of Land Management. 2009. Biological Assessment for the New River Foredune 

Management Environmental Assessment. Coos Bay District Office, North Bend, OR. 

USDI 2010a

USDI Bureau of Land Management. 2010. Vegetation Treatments Using Herbicides on BLM Lands in 

Oregon Final Environmental Impact Statement. Available at 

http://www.blm.gov/or/plans/vegtreatmentseis/

USDI 2010b USDI Bureau of Land Management. 2010. Vegetation Treatments Using Herbicides on BLM Lands in 

Oregon Record of Decision. Available at http://www.blm.gov/or/plans/vegtreatmentseis/

USDI 2011

USDI Bureau of Land Management. 2011. Management of the Western Snowy Plover on Federal Lands 

Within the New River Area of Critical Environmental Concern during the 2011-2021 Nesting and 

Wintering Seasons Biological Opinion.

USDI 2013a

USDI Fish and Wildlife Service. 2013. Endangered Species Act - Section 7 Consultation Programmatic 

Biological Opinion for Aquatic Restoration Activities in the States of Oregon, Washington and portions of 

California, Idaho and Nevada (ARBO II). 

USDI 2013b USDI Fish and Wildlife Service. 2013. Bandon Marsh National Wildlife Refuge Comprehensive 

Conservation Plan.

USDI 2014a USDI Bureau of Land Management and Bureau of Indian Affairs. 2014. Biological Assessment for the FY 

2014-2018 Programmatic Activities for Coos Bay BLM and Coquille Indian Tribe, May 2014.

USDI 2014b

USDI Fish and Wildlife. 2014. Biological Opinion titled Fiscal Years 2014-2018 Programmatic Suite of 

Activities that May Affect Spotted Owls, Murrelets and their designated Critical Habitats (FWS Reference 

Number 01EOFW00-2014-F-0163). June 2014.

USDI 2015a

USDI National Park Service. 2015. Coastal Dune Restoration EA. Point Reyes National Seashore, Marin 

County CA. Available at 

https://www.nps.gov/pore/learn/management/upload/planning_dunerestoration_project_ea_150109.p

df

USDI 2015b USDI Bureau of Land Management. 2016. Final Oregon/Washington State Director Special Status Species 

List - July 13, 2015. Portland, OR. 

USDI 2016a USDI Bureau of Land Management. 2016. Final Programmatic Environmental Impact Statement for 

Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron. Washington Office.

USDI 2016b USDI Bureau of Land Management. 2016. Record of Decision for Vegetation Treatments Using 

Aminopyralid, Fluroxypyr, and Rimsulfuron. Washington Office.

USDI 2016c USDI Bureau of Land Management. 2016. Biological Assessment for Vegetation Treatments Using 

Aminopyralid, Fluroxypyr, and Rimsulfuron. Washington Office.

USDI 2016d USDI Bureau of Land Management. 2016. Northwestern and Coastal Oregon Resource Management Plan 

and Record of Decision.

USDI 2016e USDI Bureau of Land Management. 2016. Proposed Resource Management Plan and Final Environmental 

Impact Statement for Resource Management Plans for Western Oregon. 

USDI 2016f

USDI Fish and Wildlife Service. 2016. Programmatic Suite of Activities that May Affect Spotted Owls, 

Murrelets and their designated Critical Habitats Proposed by The Coos Bay District BLM and the Coquille 

Indian Tribe Biological Opinion.

USDI 2017 USDI Bureau of Land Management. 2017. BLM Facts Oregon and Washington 2016.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

References

182

Cited As Reference

USDI 2018a USDI Bureau of Land Management. 2018. Integrated Invasive Plant Management for the Medford District 

Revised Environmental Assessment.

USDI 2018b USDI Fish and Wildlife Service. 2018. New Carissa Oil Spill: From Response to Restorarion. 

https://www.fws.gov/oregonfwo/Contaminants/Spills/NewCarissa/

USDI et al. 2006

USDI Bureau of Land Management, UDSA Forest Service, and Oregon Parks and Recreation District. 2006. 

Conservation strategy for pink sand-verbena (abronia umbellata ssp. Breviflora). Available at: 

https://appliedeco.org/wp-content/uploads/ABUM_CS-Final7-28-06.pdf

USEPA 1995 US Environmental Protection Agency. 1995. Reregistration Eligibility Decision Facts: Picloram. 11pp.

USEPA 1998 US Environmental Protection Agency 1998. Fluroxypyr Pesticide Fact Sheet. Available at 

https://www3.epa.gov/pesticides/chem_search/reg_actions/registration/fs_PC-128959_30-Sep-98.pdf

USEPA 1999 

US Environmental Protection Agency. 1999. Pesticide Fact Sheet: Diflufenzopyr United States 

Environmental Protection Agency. Office of Prevention, Pesticides and Toxic Substances. Washington, 

D.C.

USEPA 2001b Environmental Protection Agency. 2001b. Office of Pesticide Programs. General Principles for Performing 

Aggregate Exposure and Risk Assessments.

USEPA 2004 US Environmental Protection Agency 2004. Human Health Risk Assessment for 2,4-D.

USEPA 2005a

US Environmental Protection Agency 2005. Environmental Fate and Ecological Risk Assessment for the 

Registration of Aminopyralid. Available at 

https://archive.epa.gov/pesticides/chemicalsearch/chemical/foia/web/pdf/005100/005100-2005-05-

10a.pdf

USEPA 2005b

US Environmental Protection Agency 2005. Office of Prevention, Pesticides and Toxic Substances: 

Pesticide Fact Sheet – Aminopyralid. Available at 

https://www3.epa.gov/pesticides/chem_search/reg_actions/registration/fs_PC-005100_10-Aug-05.pdf

USEPA 2006 US Environmental Protection Agency. 2006. Reregistration Eligibility Decision for Dicamba and associated 

Salts.

USEPA 2007

Environmental Protection Agency. 2007b. Inert (other) Pesticide Ingredients in Pesticide Products -

Categorized List of Inert (other) Pesticide Ingredients (outdated). Available at 

http://www.epa.gov/opprd001/inerts/oldlists.html

USEPA 2013 US Environmental Protection Agency 2013. Drinking Water Contaminants. Available at 

https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations

USFWS 2018 USDI Fish and Wildlife Service. 2018/Oregon Fish & Wildlife Office website - New Carissa Oil Spill. 

Accessed March 6, 2018. Available at https://www.fws.gov/oregonfwo/Contaminants/Spills/NewCarissa/

Vencill et al. 2002 Vencill, W.K. (ed). 2002. Herbicide Handbook, 8th ed. Weed Science Society of America, Lawrence, KS. 

155-157.

Vogue et al. 1994 Vogue P.A., Kerle E.A., Jenkins J. 1994. Oregon State University Extension Pesticide Properties Database, 

Corvallis, Oregon. Available at http://npic.orst.edu/ppdmove.htm

Whitehead 1994 Whitehead, R.L. 1994. Ground Water Atlas of the United States Idaho, Oregon, Washington. United 

States Geological Survey. HA 730-H. Available at https://pubs.usgs.gov/ha/ha730/ch_h/

Wilcove et al. 1998 Wilcove, D.S., D. Rothstein, J. Dubow, A. Phillips and E. Losos. 1998. Quantifying threats to imperiled 

species in the United States. BioScience 48(8):607(9).

Wischmeier and 

Smith 1978

Wischmeier, W.H. and D.D. Smith. 1978. Predicting rainfall erosion losses: guide to conservation 

planning. USDA, Agriculture Handbook 537. U.S. Government Printing Office, Washington, DC.

Woodward et al. 

1997

Woodrow J.E., Seiber J.N., and Baker L.W. 1997. Correlation techniques for estimating pesticide 

volatilization flux and downwind concentrations. Environ. Sci. Technol. 31(2), 523–529.

Zarnetske et al. 

2010

Zarnetske, P.L., E.W. Seabloom, S.D. Hacker. 2010. Non-target effects of invasive species management: 

beachgrass, birds, and bulldozers in coastal dunes. Ecosphere, An ESA Open Access Journal. Available at 

http://onlinelibrary.wiley.com/doi/10.1890/ES10-00101.1/full
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

183 

Appendix A – Protection Measures

Information included in this Appendix is a compilation of information originally presented in:

• Chapters 2 and 3 of this EA;

• the 2007 Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States PEIS (USDI 2007a), 

Record of Decision (USDI 2007b), and Biological Assessment (USDI 2007c);

• the Vegetation Treatments on BLM Lands in 17 Western States Programmatic Environmental Report (USDI 

2007d);

• the 2010 Vegetation Treatments on BLM Lands in Oregon FEIS (USDI 2010a) and Record of Decision (USDI 

2010b); and,

• the 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron PEIS (USDI 2016a), 

Record of Decision (USDI 2016b), and Biological Assessment (USDI 2016c); and,

• the 2013 National Marine Fisheries Service’s Aquatic Restoration Biological Opinion II (ARBO II, NMFS 

2013)

• the 2013 U.S. Fish and Wildlife Service’s Aquatic Restoration Biological Opinion II (ARBO II, USDI 2013a)

Project Design Features

Project Design Features of the Proposed Action

The following Project Design Features are included to reduce effects of the Proposed Action: 

Bureau Sensitive Species (Plants, Fish, and Wildlife)

• Follow the Bureau Sensitive Species Treatment Conditions flowchart (Figure 3-2, Bureau Sensitive Species 

Treatment Conditions) when working in potential habitat for Bureau Sensitive species.

Special Status Plants

• When using prescribed fire in western snowy plover habitat restoration areas, reseed with pink sand 

verbena or other appropriate native species in areas where revegetation will not occur through natural 

processes.

Fish and Aquatic Organisms

• Apply the aquatic no-herbicide application buffers specified in the Aquatic Restoration Biological Opinion 

II (NMFS 2013) from the National Marine Fisheries Service to all waterbodies with known or suitable 

habitat for Bureau Sensitive or Strategic fish and other aquatic species (see Appendix A). 

Wildlife

• In listed species habitat, follow all Project Design Criteria outlined in the Coos Bay BLM District Bureau of 

Indian Affairs/Coquille Indian Tribe FY2014 – 2018 Land Management Activities That May Affect Northern 

Spotted Owls or Marbled Murrelets (USDI 2014a) or future updates.

• Conservation Measures applicable to butterflies and moths will be applied, as appropriate, for other 

Special Status insects.

Archaeological and Cultural Resources 

• Avoid getting herbicides (through drift or accidental direct spray) on rock art or wooden/metal structures 

or artifacts at National Register of Historic Places (NRHP) listed or eligible sites.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

184 

• Avoid repeated use of livestock (more than one grazing episode annually) at National Register of Historic 

Places (NRHP) listed or eligible sites.

Traditional and Cultural Uses (Native American Interests)

• At least one month prior to beginning treatments, Annual Treatment Plans will be presented to the Tribes 

showing planned treatments and treatment areas. Any resultant consultation will identify where timing of 

treatments can be modified, where cultural features should be avoided or protected, and where posting 

would help Tribe members avoid areas. Maps of known invasive plant infestations (see Map 2-1A,

Invasive Plants Documented in NISIMS, for example) will also be shared with the Tribes at this time.

• Where coordination with the Tribes about the Annual Treatment Plan identifies areas where herbicide use 

would not be consistent with cultural values and uses, alternative control methods will be implemented 

where feasible.

Project Design Features of Alternative 3

In addition to Project Design Features included with the Proposed Action, the following Project Design Features are 

included to reduce effects of Alternative 3:

Fish and Aquatic Organisms

• All applicable Project Design Criteria identified in potential future consultations with the National Marine 

Fisheries Service will be incorporated into all treatments in listed anadromous fish habitat.

• The use of fluazifop-P-butyl will be confined to flat dry ground located greater than 1,500 feet from any 

aquatic features to prevent runoff to surface water or leaching to groundwater.

• Use only ARBO II (NMFS 2013) approved herbicides, adjuvants, and buffer distances in the New River 

western snowy plover habitat restoration areas (see Appendix A). 

Wildlife

• Do not use dicamba, triclopyr, or fluazifop-P-butyl (herbicides with a low or moderate risk to birds) in 

areas that are currently capable of supporting western snowy plovers. (Dicamba in formulation with 

diflufenzopyr has no risk to birds and can be used in these areas.)

• Implement all current and future reasonable and prudent measures and terms and conditions identified 

by the U.S. Fish and Wildlife Service through consultation on western snowy plovers. 

• Do not use fluroxypyr at known Mardon skipper sites.

Soil

• All guidelines established in potential future North Spit western snowy plover NEPA would be done in 

conjunction with the U.S. Army Corps of Engineers.

Standard Operating Procedures and Mitigation 

Measures

In the following section, Standard Operating Procedures applicable to non-herbicide treatments are listed first 

under each resource, followed by the Standard Operating Procedures, Mitigation Measures, and Oregon FEIS 

Mitigation Measures applicable to herbicide applications.

Standard Operating Procedures have been identified to reduce adverse effects to environmental and human 

resources from vegetation treatment activities based on guidance in BLM manuals and handbooks, regulations, 

and standard BLM and industry practices. The list is not all encompassing, but is designed to give an overview of 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

185

practices that would be considered when designing and implementing a vegetation treatment project on public 

lands (USDI 2007b:2-29). Effects described in this EA are predicated on application of the Standard Operating 

Procedures or equivalent, unless an on-site determination is made that their application is unnecessary to achieve 

their intended purpose or protection. For example, the Standard Operating Procedure to “Provide alternative 

forage sites for livestock, if possible” would not need to be applied where livestock are not present.

2007 PEIS Mitigation Measures (marked as MMs in the list below) were identified for all potential adverse effects 

identified for herbicide applications in the Vegetation Treatments Using Herbicides on Bureau of Land 

Management Lands in 17 Western States Programmatic Environmental Impact Statement (USDI 2007a), and 

adopted by its Record of Decision. In other words, no potentially significant adverse effect identified in the 17 

States analysis remained at the programmatic scale after the PEIS Mitigation Measures were adopted. Like the 

Standard Operating Procedures, application of the Mitigation Measures is assumed in the analysis in this EA.

2016 PEIS Mitigation Measures (marked as 2016 MMs in the list below) were identified for all potential adverse 

effects identified for herbicide applications in the Vegetation Treatments Using Aminopyralid, Fluroxypyr, and 

Rimsulfuron PEIS (USDI 2016a), and adopted by its Record of Decision. In other words, no potentially significant 

adverse effect identified in the analysis remained at the programmatic scale after the PEIS Mitigation Measures 

were adopted. Like the Standard Operating Procedures, application of the Mitigation Measures is assumed in the 

analysis in this EA.

Oregon FEIS Mitigation Measures (marked as Oregon FEIS MMs in the list below) were identified and adopted for 

adverse effects identified in the Final Vegetation Treatments Using Herbicides on BLM Lands in Oregon 

Environmental Impact Statement (Oregon Final EIS; BLM 2010a). Application of these measures is also assumed in 

the analysis in this EA. Again, no potentially significant adverse effect was identified at the programmatic scale in 

the Oregon FEIS with the Standard Operating Procedures and Mitigation Measures assumed.

Additional guidance, direction, orders, and protection measures can be found in numerous other BLM or 

Department of the Interior handbooks, manual, and management plans. Exclusion from this Appendix does not 

indicate that these additional measures are not also potentially applicable. BLM manuals and handbooks are 

available online.

Since Standard Operating Procedures, Conservation Measures, and some Mitigation Measures are taken from 

national level documents, not all attributes are applicable to conditions on the Coos Bay District. For example, 

Alaska Natives would not be consulted with (see Social and Economic Values Standard Operating Procedures) and 

Alaskan crab and scallop habitat does not exist on the District (see Fish Conservation Measures). However, 

reference to herbicides analyzed in the 2007 or 2016 PEISs (i.e., bromacil, diquat, diuron, fluridone, or tebuthiuron) 

and application methods (i.e., aerial herbicide application) that are not proposed for use on the Coos Bay District 

have been removed, as appropriate, to avoid confusion with the alternatives proposed in this EA. For example, the 

reference to aerial application was removed from the following Standard Operating Procedure:

• Take precautions to minimize drift by not applying herbicides when winds exceed >10 mph or a serious 

rainfall event is imminent.

In addition, Standard Operating Procedures and Mitigation Measures for wild horse and burro herds, livestock, 

Designated Wilderness, Wilderness Study Areas, and Wild and Scenic Rivers are not included in this Appendix, as 

they are not present on the Coos Bay District.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

186 

Guidance Documents

Fire Use

BLM handbooks H-9211-1 (Fire Management Activity Planning Procedures) and H-9214-1 (Prescribed Fire

Management), and manuals 1112 (Safety), 9210 (Fire Management), 9211 (Fire Planning), 9214 

(Prescribed Fire), and 9215 (Fire Training and Qualifications).

Mechanical

BLM Handbook H-5000-1 (Public Domain Forest Management), and manuals 1112 (Safety) and 9015 

(Integrated Weed Management).

Manual

BLM Domain Forest Management, and manuals 1112 (Safety), and 9015 (Integrated Weed Management).

Biological

BLM manuals 1112 (Safety), 4100 (Grazing Administration), 9014 (Use of Biological Control Agents on 

Public Lands), and 9015 (Integrated Weed Management) and Handbook H-4400-1 (Rangeland Health 

Standards).

Chemical

BLM Handbook H-9011-1 (Chemical Pest Control), and manuals 1112 (Safety), 9011 (Chemical Pest 

Control), 9015 (Integrated Weed Management), and 9220 (Integrated Pest Management).

General

Fire Use

• Prepare fire management plan.

• Use trained personnel with adequate equipment.

• Minimize frequent burning in arid environments.

• Avoid burning herbicide-treated vegetation for at least 6 months.

Mechanical

• Ensure that power cutting tools have approved spark arresters.

• Ensure that crews have proper fire-suppression tools during the fire season.

• Wash vehicles and equipment before leaving weed infested areas to avoid infecting weed-free areas.

• Keep equipment in good operating condition.

Manual

• Ensure that crews have proper fire-suppression tools during fire season.

• Minimize soil disturbance, which may encourage new weeds to develop.

Biological

• Use only biological control agents that have been tested and approved to ensure they are host specific.

• If using domestic animals, select sites with weeds that are palatable and non-toxic to the animals.

• Manage the intensity and duration of containment by domestic animals to minimize overutilization of 

desirable plant species.

• Utilize domestic animals to contain the target species in the treatment areas prior to weed seed set. Or if 

seed set has occurred, do not move the domestic animals to uninfested areas for a period of 7 days.

Chemical

• Prepare an operational and spill contingency plan in advance of treatment.

• Conduct a pretreatment survey before applying herbicides.

• Select the herbicide that is least damaging to the environment while providing the desired results.

• Select herbicide products carefully to minimize additional impacts from degradates, adjuvants, other 

ingredients, and tank mixtures.

• Apply the least amount of herbicide needed to achieve the desired result.

• Follow herbicide product label for use and storage.

• Have licensed or certified applicators or State-licensed “trainees” apply herbicides, or they can be applied 

by BLM employees under the direct supervision of a BLM-certified applicator.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

187

• Use only USEPA-approved herbicides and follow product label directions and “advisory” statements.

• Review, understand, and conform to the “Environmental Hazards” section on the herbicide product label. 

This section warns of known herbicide risks to the environment and provides practical ways to avoid harm 

to organisms or to the environment.

• Minimize the size of application area, when feasible.

• Comply with herbicide-free buffer zones to ensure that drift will not affect crops or nearby 

residents/landowners.

• Post treated areas and specify reentry or rest times, if appropriate.

• Notify adjacent landowners prior to treatment, if appropriate.

• Keep a copy of Material Safety Data Sheets (MSDSs) at work sites. MSDSs are available for review at 

http://www.cdms.net.

• Keep records of each application, including the active ingredient, formulation, application rate, date, time, 

and location.

• Avoid accidental direct spray and spill conditions to minimize risks to resources.

• Take precautions to minimize drift by not applying herbicides when winds exceed >10 mph or a serious 

rainfall event is imminent.

• Use drift control agents and low volatile formulations.

• Conduct pre-treatment surveys for sensitive habitat and Special Status species within or adjacent to 

proposed treatment areas.

• Consider site characteristics, environmental conditions, and application equipment in order to minimize 

damage to non-target vegetation.

• Use drift reduction agents, as appropriate, to reduce the drift hazard to non-target species.

• Turn off application equipment at the completion of spray runs and during turns to start another spray 

run.

• Refer to the herbicide product label when planning revegetation to ensure that subsequent vegetation 

would not be injured following application of the herbicide.

• Clean OHVs to remove plant material.

The BLM has suspended the use of the adjuvant R-11.

Land Use

Fire Use

• Carefully plan fires in the WUI to avoid or minimize loss of structures and property.

• Notify nearby residents and landowners who could be affected by smoke intrusions or other fire effects.

Mechanical

• Collaborate on project development with nearby landowners and agencies.

Manual

• Collaborate on project development with nearby landowners and agencies.

Biological

• Notify nearby residents and landowners who could be affected by biological control agents.

Chemical

• Comply with herbicide-free buffer zones to ensure that drift will not affect crops or nearby residents and 

landowners.

• Post treated areas and specify reentry times, if appropriate
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

188

Air Quality

Standard Operating Procedures for air quality are taken from BLM’s Soil, Water, and Air Management Manual

(7000).

Fire Use

• Have clear smoke management objectives.

• Evaluate weather conditions, including wind speed and atmospheric stability, to predict effects of burn 

and impacts from smoke.

• Burn when weather conditions favor rapid combustion and dispersion.

• Burn under favorable moisture conditions.

• Use backfires, when applicable.

• Burn small vegetation blocks, when appropriate.

• Manage smoke to prevent air quality violations and minimize impacts to smoke-sensitive areas.

• Coordinate with air pollution and fire control officials, and obtain all applicable smoke management 

permits, to ensure that burn plans comply with federal, state, and local regulations.

Mechanical

• Maintain equipment in optimal working order.

• Conduct treatment activities during the wetter seasons.

• Use heavy equipment under adequate soil moisture conditions to minimize soil erosion.

• Minimize vehicle speeds on unpaved roads.

• Minimize dust impacts to the extent practicable.

Manual

• Maintain equipment in optimal working order.

• Conduct treatment activities during the wetter seasons.

• Minimize vehicle speeds on unpaved roads.

• Minimize dust impacts to the extent practicable.

Chemical

• Consider the effects of wind, humidity, temperature inversions, and heavy rainfall on herbicide 

effectiveness and risks.

• Apply herbicides in favorable weather conditions to minimize drift. For example, do not treat when winds 

exceed 10 mph or rainfall is imminent.

• Use drift reduction agents, as appropriate, to reduce the drift hazard.

• Select proper application equipment (e.g., spray equipment that produces 200- to 800-micron diameter 

droplets [spray droplets of 100 microns and less are most prone to drift]).

• Select proper application methods (e.g., set maximum spray heights, use appropriate buffer distances 

between spray sites and non-target resources).

Soil Resources

Standard Operating Procedures for soil resources are taken from BLM’s Soil, Water, and Air Management Manual

(7000).

General

• Assess the susceptibility of the treatment site to soil damage and erosion prior to treatment.

Fire Use

• Prescribe broadcast and other burns that are consistent with soil management activities.

• Plan burns so as to minimize damage to soil resources.

• Conduct burns when moisture content of large fuels, surface organic matter, and soil is high to limit the 

amount of heat penetration into lower soil surfaces and protect surface organic matter.

• Time treatments to encourage rapid recovery of vegetation.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

189

• Further facilitate revegetation by seeding or planting following treatment.

• When appropriate, reseed following burning to re- introduce species, or to convert a site to a less 

flammable plant association, rather than to specifically minimize erosion.

Mechanical

• Time treatments to avoid intense rainstorms.

• Time treatments to encourage rapid recovery of vegetation.

• Further facilitate revegetation by seeding or planting following treatment.

• Use equipment that minimizes soil disturbance and compaction.

• Minimize use of heavy equipment on slopes >20%.

• Conduct treatments when the ground is sufficiently dry to support heavy equipment.

• Implement erosion control measures in areas where heavy equipment use occurs.

• Conduct mechanical treatments along topographic contours to minimize runoff and erosion.

• When appropriate, leave plant debris on site to retain moisture, supply nutrients, and reduce erosion.

• Prevent oil and gas spills to minimize damage to soil.

Manual

• Time treatments to avoid intense rainstorms.

• Time treatments to encourage rapid recovery of vegetation.

• Further facilitate revegetation by seeding or planting following treatment.

• Minimize soil disturbance and compaction.

Biological

• Minimize use of domestic animals if removal of vegetation may cause significant soil erosion or impact 

biological soil crusts.

• Closely monitor timing and intensity of biological control with domestic animals.

• Avoid grazing on wet soil to minimize compaction and shearing.

Chemical

• Minimize treatments in areas where herbicide runoff is likely, such as steep slopes when heavy rainfall is 

expected.

• Minimize use of herbicides that have high soil mobility, particularly in areas where soil properties increase 

the potential for mobility.

• Do not apply granular herbicides on slopes of more than 15% where there is the possibility of runoff 

carrying the granules into non-target areas.

Water Resources

Standard Operating Procedures for water resources are taken from BLM’s Soil, Water, and Air Management 

Manual (7000).

Fire Use

• Prescribe burns that are consistent with water management objectives.

• Plan burns to minimize negative impacts to water resources.

• Minimize burning on hillslopes, or revegetate hillslopes shortly after burning.

• Maintain a vegetated buffer between treatment areas and water bodies.

Mechanical

• Minimize removal of desirable vegetation near residential and domestic water sources.

• Do not wash equipment or vehicles in water bodies.

• Maintain minimum 25 foot wide vegetated buffer near streams and wetlands.

Manual

• Maintain vegetated buffer near residential and domestic water sources.

• Minimize removal of desirable vegetation near residential and domestic water sources.

• Minimize removal of desirable vegetation near water bodies.

• Minimize use of domestic animals near residential or domestic water sources.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

190

• Minimize use of domestic animals adjacent to water bodies if trampling or other activities are likely to 

cause soil erosion or impact water quality.

Chemical

• Consider climate, soil type, slope, and vegetation type when developing herbicide treatment programs.

• Select herbicide products to minimize impacts to water. This is especially important for application 

scenarios that involve risk from active ingredients in a particular herbicide, as predicted by Risk 

Assessments.

• Use local historical weather data to choose the month of treatment.

• Considering the phenology of target aquatic species, schedule treatments based on the condition of the 

water body and existing water quality conditions.

• Plan to treat between weather fronts (calms) and at appropriate time of day to avoid high winds that 

increase water movements, and to avoid potential stormwater runoff and water turbidity.

• Review hydrogeologic maps of proposed treatment areas. Note depths to groundwater and areas of 

shallow groundwater and areas of surface water and groundwater interaction. Minimize treating areas 

with high risk for groundwater contamination.

• Conduct mixing and loading operations in an area where an accidental spill would not contaminate an 

aquatic body.

• Do not rinse spray tanks in or near water bodies.

• Do not broadcast pellets where there is danger of contaminating water supplies.

• Minimize the potential effects to surface water quality and quantity by stabilizing terrestrial areas as 

quickly as possible following treatment.

• Establish appropriate (herbicide-specific) buffer zones for species/populations (Tables A-1 and A-2). (MM)

• Areas with potential for groundwater for domestic or municipal use shall be evaluated through the 

appropriate, validated model(s) to estimate vulnerability to potential groundwater contamination, and 

appropriate Mitigation Measures shall be developed if such an area requires the application of herbicides 

and cannot otherwise be treated with non-herbicide methods. (MM)

• Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on Risk 

Assessment guidance, with minimum widths from water of 25 feet for vehicle, and 10 feet for hand spray 

applications.

• Maintain buffers between treatment areas and water bodies. Buffer widths should be developed based 

on herbicide and site-specific conditions to minimize impacts to water bodies.

• To protect domestic water sources, no herbicide treatments should occur within 100 feet of a well or 200 

feet of a spring or known diversion used as a domestic water source unless a written waiver is granted by 

the user or owner. (Oregon FEIS MM)

• Site-specific analyses for roadside treatments should specifically consider that drainage ditches and

structures lead to streams and that normal buffer distances, herbicide selection, and treatment method 

selection may need to be changed accordingly, particularly where those ditches are connected to streams 

with Federally Listed or other Special Status species. (Oregon FEIS MM)

• Buffer intermittent stream channels when there is a prediction of rain (including thunderstorms) within 

48 hours. (Oregon FEIS MM)

• Proposals to boom spray herbicides within 200 feet of streams that are within 1,000 feet upstream from a 

public water supply intake, or spot apply herbicides within 100 feet of streams that are within 500 feet 

upstream from a public water supply intake, will include coordination with the Oregon Department of 

Environmental Quality and the municipality to whom the intake belongs. (Oregon FEIS MM)

Wetlands and Riparian Areas

Fire Use

• Following treatment, reseed or replant with native vegetation if the native plant community cannot 

recover and occupy the site sufficiently.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

191

Mechanical

• Manage riparian areas to provide adequate shade, sediment control, bank stability, and recruitment of 

wood into stream channels.

• Following treatment, reseed or replant with native vegetation if the native plant community cannot 

recover and occupy the site sufficiently.

Manual

• Following treatment, reseed or replant with native vegetation if the native plant community cannot 

recover and occupy the site sufficiently.

Biological

• Manage animals to prevent overgrazing and minimize damage to wetlands.

• Following treatment, reseed or replant with native vegetation if the native plant community cannot 

recover and occupy the site sufficiently.

Chemical

• Use a selective herbicide and a wick or backpack sprayer.

• Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on Risk 

Assessment guidance, with minimum widths from water of 25 feet for vehicle, and 10 feet for hand spray 

applications.

• See mitigation for Water Resources and Vegetation. (MM)

Vegetation

Standard Operating Procedures for vegetation are taken from Handbook H-4410-1 (National Range Handbook), 

and manuals 5000 (Forest Management) and 9015 (Integrated Weed Management).

General

• Use weed-free feed for horses and pack animals. Use weed-free straw and mulch for revegetation and 

other activities.

Fire Use

• Keep fires as small as possible to meet the treatment objectives.

• Conduct low intensity burns to minimize adverse impacts to large vegetation.

• Limit area cleared for fire breaks and clearings to reduce potential for weed infestations.

• Where appropriate, use mechanical treatments to prepare forests for the reintroduction of fire.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting 

revegetation activities.

Mechanical

• Power wash vehicles and equipment to prevent the introduction and spread of weed and exotic species.

• Remove damaged trees and treat woody residue to limit subsequent mortality by bark beetles.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting 

revegetation activities.

• Identify and implement any temporary domestic livestock grazing and/or supplemental feeding 

restrictions needed to enhance desirable vegetation recovery following treatment.

Manual

• Remove damaged trees and treat woody residue to limit subsequent mortality by bark beetles.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting 

revegetation activities.

Biological

• Use domestic animals at the time they are most likely to damage invasive species.

• Manage animals to prevent overgrazing and minimize damage to sensitive areas.

• Identify and implement any temporary domestic livestock grazing and/or supplemental feeding 

restrictions needed to enhance desirable vegetation recovery following treatment.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

192

• Consider adjustments in the existing grazing permit, including the application of state or regional grazing 

administration guidelines, needed to maintain desirable vegetation on the treatment site.

• Use plant stock or seed from the same seed zone and from sites of similar elevation when conducting 

revegetation activities.

Chemical

• Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation would not 

be injured following application of the herbicide.

• Use native or sterile plants for revegetation and restoration projects to compete with invasive plants until 

desired vegetation establishes.

• Minimize the use of terrestrial herbicides (especially sulfometuron methyl) in watersheds with 

downgradient ponds and streams if potential impacts to aquatic plants are identified. (MM)

• When necessary to protect Special Status plant species, implement all Conservation Measures for plants 

presented in the 2007 Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

and 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron Biological Assessments 

(see Conservation Measures later in this Appendix). (MM, 2016 MM)

• Establish appropriate (herbicide-specific) buffer zones (Tables A-1 and A-2) around downstream water 

bodies, habitats, and species/populations of interest. Consult the Risk Assessments prepared for the PEIS 

for more specific information on appropriate buffer distances under different soil, moisture, vegetation, 

and application scenarios. (MM)

• Use Table A-4 to establish herbicide-specific buffer zones around downstream water bodies, and 

associated habitats and non-target plant species/populations of interest for aminopyralid, fluroxypyr, and 

rimsulfuron. Consult the Risk Assessments for more specific information on appropriate buffer distances 

under different soil, moisture, vegetation, and application scenarios. (2016 MM)

Pollinators

Chemical

• Complete vegetation treatments seasonally before pollinator foraging plants bloom.

• Time vegetation treatments to take place when foraging pollinators are least active both seasonally and 

daily.

• Design vegetation treatment projects so that nectar and pollen sources for important pollinators and 

resources are treated in patches rather than in one single treatment.

• Minimize herbicide application rates. Use typical rather than maximum rates where there are important 

pollinator resources.

• Maintain herbicide free buffer zones around patches of important pollinator nectar and pollen sources.

• Maintain herbicide free buffer zones around patches of important pollinator nesting habitat and 

hibernacula.

• Make special note of pollinators that have single host plant species, and minimize herbicide spraying on 

those plants and in their habitats.

Fish and Other Aquatic Species

Standard Operating Procedures for fish and other aquatic organisms are taken from BLM Manuals, including 

Manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

Fire Use

• Maintain vegetated buffers near fish-bearing streams to minimize soil erosion and soil runoff into 

streams.

• Minimize treatments near fish-bearing streams during periods when fish are in sensitive life stages (e.g., 

embryo).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

193

Mechanical

• Minimize treatments adjacent to fish-bearing waters.

• Do not wash vehicles in streams or wetlands.

• Refuel and service equipment at least 100 feet from water bodies to reduce the chance for pollutants to 

enter water.

• Maintain adequate vegetated buffer between treatment area and water body to reduce the potential for 

sediments and other pollutants to enter the water body.

Manual

• Refuel and service equipment at least 100 feet from water bodies to reduce the chance for pollutants to 

enter water.

• Minimize removal of desirable vegetation near fish-bearing streams and wetlands.

Biological

• Limit access of domestic animals to streams and other water bodies to minimize sediments entering 

water and potential for damage to fish habitat.

Chemical

• Use appropriate buffer zones based on label and Risk Assessment guidance.

• Minimize treatments near fish-bearing water bodies during periods when fish are in life stages most 

sensitive to the herbicide(s) used, and use spot rather than broadcast treatments.

• Use appropriate application equipment/method near water bodies if the potential for off-site drift exists.

• For treatment of aquatic vegetation, 1) treat only that portion of the aquatic system necessary to meet 

vegetation management objectives, 2) use the appropriate application method to minimize the potential 

for injury to desirable vegetation and aquatic organisms, and 3) follow water use restrictions presented 

on the herbicide label.

• Limit the use of terrestrial herbicides in watersheds with characteristics suitable for potential surface 

runoff that have fish-bearing streams during periods when fish are in life stages most sensitive to the 

herbicide(s) used. (MM)

• To protect Special Status fish and other aquatic organisms, implement all Conservation Measures for 

aquatic animals presented in the 2007 Vegetation Treatments on Bureau of Land Management Lands in 

17 Western States and 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron 

Biological Assessments (see Conservation Measures later in this Appendix). (MM, 2016 MM)

• Establish appropriate herbicide-specific buffer zones for water bodies, habitats, or fish or other aquatic 

species of interest (Table A-3 and recommendations in individual Ecological Risk Assessments). (MM)

• Consider the proximity of application areas to salmonid habitat and the possible effects of herbicides on 

riparian and aquatic vegetation. Maintain appropriate buffer zones around salmonid-bearing streams. 

(MM)

• At the local level, consider effects to Special Status fish and other aquatic organisms when designing 

treatment programs. (MM)

• Use of adjuvants with limited toxicity and low volumes is recommended for applications near aquatic 

habitats. (Oregon FEIS MM)

Wildlife Resources

Standard Operating Procedures for wildlife resources are taken from BLM Manuals, including Manuals 6500 

(Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

Fire Use

• Minimize treatments during nesting and other important periods for birds and other wildlife.

• Minimize treatments of important forage areas immediately prior to important use period(s), unless the 

burn is designed to stimulate forage growth.

Mechanical

• Minimize treatments during nesting and other important periods for birds and other wildlife.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

194

• Retain wildlife trees and other unique habitat features where practical.

Manual

• Minimize treatments during nesting and other important periods for birds and other wildlife.

• Retain wildlife trees and other unique habitat features where practical.

Biological

• Minimize the use of livestock grazing as a vegetation control measure where and/or when it could impact 

nesting and/or other important periods for birds and other wildlife.

• Consider and minimize potential adverse impacts to wildlife habitat and minimize the use of livestock 

grazing as a vegetation control measure where it is likely to result in removal or physical damage to 

vegetation that provides a critical source of food or cover for wildlife.

Chemical

• Use herbicides of low toxicity to wildlife, where feasible.

• Use spot applications or low-boom broadcast operations where possible to limit the probability of 

contaminating non-target food and water sources, especially non-target vegetation over areas larger than 

the treatment area.

• Use timing restrictions (e.g., do not treat during critical wildlife breeding or staging periods) to minimize 

impacts to wildlife.

• To minimize risks to terrestrial wildlife, do not exceed the typical application rate for applications of 

dicamba, glyphosate, hexazinone or triclopyr, where feasible. (MM)

• Minimize the size of application areas, where practical, when applying 2,4-D and Overdrive® to limit 

impacts to wildlife, particularly through contamination of food items. (MM)

• Where practical, limit glyphosate and hexazinone to spot applications in grazing land and wildlife habitat 

areas to avoid contamination of wildlife food items. (MM)

• Do not use the adjuvant R-11 (MM)

• To protect Special Status wildlife species, implement Conservation Measures for terrestrial animals 

presented in the 2007 Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

and 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron Biological Assessments 

(see Conservation Measures later in this Appendix). (MM, 2016 MM)

• Impacts to wildlife from herbicide applications can be reduced by treating habitat during times when the 

animals are not present or are not breeding, migrating or confined to localized areas (such as crucial 

winter range). (Oregon FEIS MM)

• When treating native plants in areas where herbivores are likely to congregate, choose herbicides with 

lower risks due to ingestion. This Mitigation Measure is applicable if large areas of the herbivores’ feeding 

range would be treated, either because the treatment areas are large or the feeding area for an individual 

animal is small. (Oregon FEIS MM)

• Where there is a potential for herbivore consumption of treated vegetation, apply dicamba, imazapyr, 

and metsulfuron methyl at the typical, rather than maximum, application rate to minimize risks. (Oregon 

FEIS MM)

• Where possible, design native vegetation treatment areas to mimic natural disturbance mosaics. 

Patchiness is usually beneficial to most wildlife, and patchiness is usually tolerated by species that prefer 

contiguous habitat. (Oregon FEIS MM)

• Use of adjuvants with limited toxicity and low volumes is recommended for applications near aquatic 

habitats. (Oregon FEIS MM)

• When conducting herbicide treatments in or near habitats used by special status and listed terrestrial 

arthropods, design treatments to avoid the use of fluroxypyr, where feasible. If pre-treatment surveys 

determine the presence of listed terrestrial arthropods, do not use fluroxypyr to treat vegetation. (2016 

MM)
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

195

Threatened and Endangered Species

Standard Operating Procedures for threatened and endangered species are taken from BLM Manual 6840 (Special 

Status Species) and Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States Programmatic 

Biological Assessment.

Fire Use

• Survey for Special Status species of concern if project may impact federally- and state-listed species.

• Minimize direct impacts to species of concern, unless studies show that species will benefit from fire.

Mechanical

• Minimize use of ground- disturbing equipment near Special Status species of concern.

• Survey for species of concern if project could impact these species.

• Use temporary roads when long-term access is not required.

Manual

• Survey for Special Status species of concern if project could impact these species.

Biological

• Survey for Special Status species of concern if project could impact these species.

Chemical

• Provide clearances for Special Status species before treating an area as required by Special Status Species 

Program policy. Consider effects to Special Status species when designing herbicide treatment programs.

• Use a selective herbicide and a wick or backpack sprayer to minimize risks to Special Status plants.

• Avoid treating vegetation during time-sensitive periods (e.g., nesting and migration, sensitive life stages) 

for Special Status species in area to be treated.

Cultural Resources

Standard Operating Procedures for cultural resources are taken from:

• BLM handbook H-8120-1 (Guidelines for Conducting Tribal Consultation);

• BLM manual 8100 (The Foundations for Managing Cultural Resources); and,

• BLM manual 8120 (Tribal Consultation Under Cultural Resource Authorities)75

See also:

• The 1997 Programmatic Agreement among the Bureau of Land Management, the Advisory Council on 

Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the 

Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act;

• The 2015 State Protocol between the Oregon-Washington State Director of the BLM and the Oregon State 

Historic Preservation Officer regarding the manner in which the Bureau of Land Management will meet its 

responsibilities under the National Historic Preservation Act; and,

• The 2012 National Programmatic Agreement among the BLM, the Advisory Council on Historic 

Preservation, and the National Conference of State Historic Preservation Officers.

General

• Follow standard procedures for compliance with Section 106 of the National Historic Preservation Act as 

implemented through the National Programmatic Agreement and state protocols or 36 CFR Part 800, 

including necessary consultations with the State Historic Preservation Officers and affected Tribes.

• Identify opportunities to meet Tribal cultural use plant objectives for projects on public lands.

 75 This manual has been superseded by Handbook H-1780-1 (Improving and Sustaining BLM-Tribal Relations). Guidance from 

this new handbook does not change Standard Operating Procedures described in this section.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

196

Fire Use

• Identify cultural resource types at risk from fire use and design inventories that are sufficient to locate 

these resources. Provide measures to minimize impacts. 

Mechanical

• Identify cultural resource types at risk from mechanical treatments and design inventories that are 

sufficient to locate these resources. Provide measures to minimize impacts.

• Consult with Tribes to locate any areas of vegetation that are of significance to the Tribe and that might 

be affected, adversely or beneficially, by mechanical treatments.

Manual

• Identify cultural resource types at risk from manual treatments and design inventories that are sufficient 

to locate these resources. Provide measures to minimize impacts.

• Consult with Tribes to locate any areas of vegetation that are of significance to the Tribe and that might 

be affected, adversely or beneficially, by manual treatments.

Biological

• Consult with Tribes to locate any areas of vegetation that are of significance to the Tribe and that might 

be affected, adversely or beneficially, by biological treatments.

Chemical

• Consult with Tribes to locate any areas of vegetation that are of significance to the Tribe and that might 

be affected by herbicide treatments; work with Tribes to minimize impacts to these resources.

• Follow guidance under Human Health and Safety in the PEIS in areas that may be visited by Native 

peoples after treatments.

• Do not exceed the typical application rate when applying 2,4-D, hexazinone and triclopyr in known 

traditional use areas. (MM)

Paleontological Resources

Standard Operating Procedures for paleontological resources are taken from BLM handbook H-8270-1 (General 

Procedural Guidance for Paleontological Resource Management) and BLM manual 8270 (Paleontological Resource 

Management).

General

• Follow BLM Handbook H-8270-1 to determine known Condition 1 and Condition 2 paleontological areas, 

or collect information through inventory to establish Condition 1 and Condition 2 areas, determine 

resource types at risk from the proposed treatment, and develop appropriate measures to minimize or 

mitigate adverse impacts.

Fire Use

• Monitor significant paleontological and cultural resources for potential looting of materials where they 

have been exposed by fire.

Visual Resources

Standard Operating Procedures for visual resources are taken from BLM handbooks H-8410-1 (Visual Resource 

Inventory) and H-8431-1 (Visual Resource Contrast Rating), and Manual 8400 (Visual Resource Management).

General

• At areas such as visual overlooks, leave sufficient vegetation in place, where possible, to screen views of 

vegetation treatments.

• Design activities to repeat the form, line, color, and texture of the natural landscape character

Fire Use

• Minimize use of fire in sensitive watersheds to reduce the creation of large areas of browned vegetation.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

197

• Consider the surrounding land use before assigning fire as a treatment method. Avoid use of fire near 

agricultural or densely populated areas, where feasible.

• Lessen visual effects in Class I and Class II visual resource areas.

Mechanical

• Minimize dust drift, especially near recreational or other public use areas.

• Minimize loss of desirable vegetation near high public use areas.

• Minimize earthwork and locate away from prominent topographic features.

• Revegetate treated sites.

• Lessen visual effects in Class I and Class II visual resource areas.

Manual

• Minimize dust drift, especially near recreational or other public use areas.

• Minimize loss of desirable vegetation near high public use areas.

• Lessen visual effects in Class I and Class II visual resource areas.

Biological

• At areas such as visual overlooks, leave sufficient vegetation in place, where possible, to screen views of 

vegetation treatments.

• Lessen visual effects in Class I and Class II visual resource areas.

Chemical

• Minimize the use of broadcast foliar applications in sensitive watersheds to avoid creating large areas of 

browned vegetation.

• Minimize off-site drift and mobility of herbicides (e.g., do not treat when winds exceed 10 mph; minimize 

treatment in areas where herbicide runoff is likely; establish appropriate buffer widths between 

treatment areas and residences) to contain visual changes to the intended treatment area.

• If the area is a Class I or II visual resource, ensure that the change to the characteristic landscape is low 

and does not attract attention (Class I), or if seen, does not attract the attention of the casual viewer 

(Class II).

• Lessen visual impacts by: 1) designing projects to blend in with topographic forms; 2) leaving some low 

growing trees or planting some low-growing tree seedlings adjacent to the treatment area to screen 

short-term effects; and 3) revegetating the site following treatment.

• When restoring treated areas, design activities to repeat the form, line, color, and texture of the natural 

landscape character conditions to meet established Visual Resource Management (VRM) objectives.

Recreation

Standard Operating Procedures for recreation are taken from BLM Handbook H-1601-1 (Land Use Planning 

Handbook).

General

• Notify the public of treatment methods, hazards, times, and nearby alternative recreation areas.

Fire Use

• Control public access to potential burn areas.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak 

times to maximize effectiveness.

Mechanical

• Control public access until potential treatment hazards no longer exist.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak 

times to maximize effectiveness.

Manual

• Control public access until potential treatment hazards no longer exist.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak 

times to maximize effectiveness.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

198

Biological

• Control public access in areas with control agents to ensure that agents are effective.

• Schedule treatments to avoid peak recreational use times, unless treatments must be timed during peak 

times to maximize effectiveness.

• Notify the public of treatment methods, hazards, times, and nearby alternative recreation areas.

Chemical

• Schedule treatments to avoid peak recreational use times, while taking into account the optimum 

management period for the targeted species.

• Adhere to entry restrictions identified on the herbicide product label for public and worker access.

• Post signs noting exclusion areas and the duration of exclusion, if necessary.

• Mitigation Measures that may apply to recreational resources are associated with human and ecological 

health (see Mitigation Measures for Vegetation, Fish and Other Aquatic Species, Wildlife Resources, and 

Human Health and Safety). (MM)

Social and Economic Values

General

• Post treatment areas.

• Notify adjacent landowners, grazing permittees, the public, and emergency personnel of treatments.

• Control public access to treatment areas.

• Consult with Native American Tribes and Alaska Natives whose health and economies might be affected 

by the project.

• To the extent feasible, hire local contractors and purchase supplies locally.

Chemical

• Post treated areas and specify reentry or rest times, if appropriate.

• Notify grazing permittees of livestock feeding restrictions in treated areas, if necessary, as per herbicide 

product label instructions.

• Notify the public of the project to improve coordination and avoid potential conflicts and safety concerns 

during implementation of the treatment.

• Control public access until potential treatment hazards no longer exist, per herbicide product label 

instructions.

• Observe restricted entry intervals specified by the herbicide product label.

• Notify local emergency personnel of proposed treatments.

• Use spot applications or low-boom broadcast applications where possible to limit the probability of 

contaminating non-target food and water sources.

• Consult with Native American Tribes to locate any areas of vegetation that are of significance to the Tribes 

and Native groups and that might be affected by herbicide treatments.

• To the degree possible within the law, hire local contractors and workers to assist with herbicide

application projects and purchase materials and supplies for herbicide treatment projects (including the 

herbicides) through local suppliers.

• To minimize fears based on lack of information, provide public educational information on the need for 

vegetation treatments and the use of herbicides in an integrated vegetation management program for 

projects proposing local use of herbicides.

• For herbicides with label-specified re-entry intervals, post information at access points to recreation sites 

or other designated public use or product collection areas notifying the public of planned herbicide 

treatments in languages known to be used by persons likely to be using the area to be treated. Posting 

should include the date(s) of treatment, the herbicide to be used, the date or time the posting expires, 

and a name and phone number of who to call for more information. (Oregon FEIS MM)

• Consider the potential for treatments to affect communities from herbicide-contaminated resources 

originating from the BLM, such as subsistence resources or water used downstream for human or 

agricultural uses. (Oregon FEIS MM)
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

199

• Coordinate with and/or notify neighboring landowners who may want to treat, or are already treating, 

adjacent lands. (Oregon FEIS MM)

• To the extent permitted by normal contracting authority, ensure materials safety data sheets and other 

informational or precautionary materials are available in languages spoken by the work crews 

implementing treatments. This includes but is not limited to material such as Occupational Safety and 

Health Administration standards along with agency, industry and manufacturers’ recommendations and 

Human Health and Safety Standard Operating Procedures and Mitigation Measures or equivalent. 

(Oregon FEIS MM)

Rights-of-way

General

• Coordinate vegetation management activities where joint or multiple use of a ROW exists.

• Notify other public land users within or adjacent to the ROW proposed for treatment.

Fire Use

• Manage burns under powerlines so as to avoid negative impacts to the powerline.

Mechanical

• Apply appropriate safety measures when operating equipment within utility ROW corridors.

• Minimize exposed soil areas during treatment.

• Keep operations within prescribed ROW.

Manual

• Always use appropriate safety equipment and operating procedures.

• Utilize methods for disposal of vegetation that prevent spreading or reinfestation of unwanted 

vegetation.

Chemical

• Use only herbicides that are approved for use in ROW areas.

Human Health and Safety

General

• Wear appropriate safety equipment and clothing, and use equipment that is properly maintained.

Fire Use

• Use some form of pretreatment, such as mechanical or manual treatment, in areas where fire cannot be 

safely introduced because of hazardous fuel buildup.

• Notify nearby residents who could be affected by smoke.

• Maintain adequate safety buffers between treatment area and residences/structures.

• Burn vegetation debris off ROWs to ensure that smoke does not provide a conductive path from the 

transmission line or electrical equipment to the ground.

Mechanical

• Cut all brush and tree stumps flat, where possible, to eliminate sharp points that could injure a worker or 

the public.

• Ensure that only qualified personnel cut trees near powerlines.

Manual

• Cut all brush and tree stumps flat, where possible, to eliminate sharp points that could injure a worker or 

the public.

Chemical

• Establish a buffer between treatment areas and human residences based on guidance given in the HHRA, 

with a minimum buffer of 100 feet for ground applications, unless a written waiver is granted.

• Use protective equipment as directed by the herbicide product label.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

200

• Post treated areas with appropriate signs at common public access areas.

• Observe restricted entry intervals specified by the herbicide product label.

• Provide public notification in newspapers or other media where the potential exists for public exposure.

• Store herbicides in secure, herbicide-approved storage.

• Have a copy of MSDSs at work site.

• Notify local emergency personnel of proposed treatments.

• Contain and clean up spills and request help as needed.

• Secure containers during transport.

• Follow label directions for use and storage.

• Dispose of unwanted herbicides promptly and correctly.

• Use the typical application rate, where feasible, when applying 2,4-D, hexazinone, and triclopyr to reduce 

risk to workers and the public. (MM)

• Limit application of chlorsulfuron via ground broadcast applications at the maximum application rate. 

(MM)

• Do not apply hexazinone with an over-the-shoulder broadcast applicator (backpack sprayer). (MM)

• Consideration should be given to herbicides other than 2,4-D; use of 2,4-D should be limited to situations 

where other herbicides are ineffective or in situations in which the risks posed by 2,4-D can be mitigated 

(Oregon FEIS MM).

• Do not apply triclopyr by any broadcast method (Oregon FEIS MM).

Table A-1. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of BLM-Evaluated Herbicides

Application

Scenario Chlorsulfuron Imazapic Diflufenzopyr + dicamba Sulfometuron methyl

Buffer Distance (feet) from Non-target Aquatic Plants

Typical Application Rate

Low Boom1

High Boom1

0

0

0

0

100

900

900

900

Maximum Application Rate

Low Boom2

High Boom2

0

0

0

0

900

900

900

900

Buffer Distance (feet) from Non-target Terrestrial Plants

Typical Application Rate

Low Boom1

High Boom1

900

900

0

0

0

100

0

0

Maximum Application Rate

Low Boom1

High Boom1

1,000

1,000

0

0

100

100

0

0

Buffer Distance (feet) from Threatened, Endangered, and Sensitive Plants

Typical Application Rate

Low Boom1

High Boom1

1,000

1,000

0

0

100

900

1,100

1,000

Maximum Application Rate

Low Boom1

High Boom1

1,050

1,000

0

0

900

900

1,100

1,000

1 High boom is 50 inches above ground and low boom is 20 inches above ground.

NE =Not evaluated and NA =not applicable.

Buffer distances are the smallest modeled distance at which no risk was predicted. In some cases, buffer distances were extrapolated if the 

largest distance modeled still resulted in risk, or interpolated if greater precision was required.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

201

Table A-2. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of Forest Service-Evaluated 

Herbicides

Application

Scenario 2,4-D Dicamba Clopyralid Glyphosate Hexazinone Imazapyr Metsulfuronmethyl Picloram Triclopyr

Buffer Distance (feet) from Susceptible Plants1

Typical Application Rate

Low Boom NE 300 900 50 NE 900 900 >900 300

Maximum Application Rate

Low Boom NE 900 1 000 300 NE >900 >900 >900 >900

Buffer Distance (feet) from Tolerant Terrestrial Plants

Typical Application Rate

Low Boom NE 0 0 25 0 25 25 25 NE

Maximum Application Rate

Low Boom NE 0 25 25 100 50 25 25 NE

NE = Not evaluated.

Buffer distances are the smallest modeled distance at which no risk was predicted. In some cases, buffer distances were extrapolated if the 

largest distance modeled still resulted in risk, or interpolated if greater precision was required.

1 Mitigation Measures for Bureau Sensitive or federally listed species use these buffer distances

Table A-3. Buffer Distances to Minimize Risk to Fish and Aquatic Invertebrates from Off-Site Drift of BLM-Evaluated 

Herbicides 

Application

Scenario Chlorsulfuron Imazapic Overdrive Sulfometuron methyl

Minimum Buffer Distance (feet) from Fish and Aquatic Invertebrates

Typical Application Rate

Low boom 0 0 0 0

High boom 0 0 0 0

Maximum Application Rate

Low boom 0 0 0 0

High boom 0 0 0 0

NA Not applicable. Boom height= The Tier I ground application model allows selection of a low (20 inches) or a high (50 inches) boom height.

Table A-4. Buffer Distances (in feet) to Minimize Risk to Non-target Vegetation from Off-site Drift

Application Scenario Aminopyralid Fluroxypyr Rimsulfuron

Buffer Distance (feet) from Non-Target Terrestrial Plants

Typical Application Rate

High Boom1 200 400 400

Low Boom1 25 100 100

Maximum Application Rate

High Boom 400 600 700

Low Boom 100 400 400

Buffer Distance (feet) from Terrestrial Threatened, Endangered, and Sensitive Plants

Typical Application Rate

High Boom 400 400 400

Low Boom 100 100 100

Maximum Application Rate

High Boom 600 700 700

Low Boom 400 600 400

Buffer Distance (feet) from Non-Target Aquatic Plants3

Typical Application Rate

High Boom NA NA 200

Low Boom NA NA 100

Maximum Application Rate

High Boom NA NA 300

Low Boom NA NA 100

2 High boom is 50 inches above ground and low boom is 20 inches above ground.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

202

3 Aquatic plants in ponds and streams were considered in the Ecological Risk Assessments. The largest buffer distances are presented in this 

table.

4 NA means that no buffers are required, since direct spray of plants was not predicted to result in adverse effects. However, a direct spray into 

an aquatic habitat is not an approved use of these herbicides.

Buffer distances are the smallest modeled distance at which no risk was predicted. In some cases, buffer distances were extrapolated if the 

largest distance modeled still resulted in risk, or interpolated if greater precision was required.

Protection Measures for Federally Listed Species

The Coos Bay District has seven federally listed species that are known to occur on the District (see Table A-5).

Table A-5. Listed Species on the Coos Bay District 

Taxon Common Name Scientific Name Population Status

Plant Western lily Lilium occidentale Endangered

Bird Marbled murrelet Brachyramphus marmoratus Threatened

Bird Western snowy plover Charadrius nivosus nivosus Pacific Coastal Population Threatened

Bird Northern spotted owl Strix occidentalis caurina Threatened

Anadromous Fish Coho Salmon Oncorhynchus kisutch S. Oregon/N. California Coast Threatened Oregon Coast

Anadromous Fish Green Sturgeon Acipenser medirostris Southern Threatened

Anadromous Fish Pacific Eulachon Thaleichthys pacificus Southern DPS Threatened

Formal and informal consultation that covers herbicides and other invasive plant treatments on the Coos Bay 

District has occurred with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) on 

numerous occasions (see Table A-6).

Table A-6. Endangered Species Act Consultation

Program and Biological Assessment Treatment Methods Agency - Area Year Consultation

Vegetation Treatments Using 

Herbicides on BLM Lands in 17 Western 

States PEIS (USDI 2007a) and 

Vegetation Treatments on BLM Lands 

in 17 Western States Programmatic 

Environmental Report (USDI 2007d) 

and Vegetation Treatments on BLM 

Lands in 17 Western States Biological 

Assessment (USDI 2007c)

Integrated Invasive Plant 

Management. Includes all 

herbicides in this EA 

except aminopyralid, 

fluroxypyr, and 

rimsulfuron.

BLM - 17 

Western States 2007

Letter of Concurrence 

(FWS)

Biological Opinion 

(NMFS)

Biological Assessment of the Effects of 

the New River Foredune Management 

Project (USDI 2009b)

Heavy equipment, 

burning, and hand pulling 

to remove European 

beachgrass

BLM - Coos Bay 

District, New 

River ACEC

2009 Letter of Concurrence 

(NMFS)

Biological Assessment of the BLM’s 

North Spit Plan

as it may affect the Threatened 

Western Snowy Plover and its Critical 

Habitat (USDI 2007e)

Integrated Vegetation 

Management, including 

glyphosate

BLM - Coos Bay 

District, North 

Spit

2008-2018, 

extended 

to 2022

Biological Opinion (FWS)

Vegetation Treatments Using 

Herbicides on BLM Lands in Oregon 

(USDI 2010a) and Vegetation 

Treatments on BLM Lands in 17 

Western States Biological Assessment 

(USDI 2007c)

Integrated Invasive Plant 

Management. Includes all 

herbicides in this EA 

except aminopyralid, 

fluroxypyr, and 

rimsulfuron.

BLM - Oregon 2010

Letter of Concurrence 

(FWS)

Biological Opinion 

(NMFS)

Management of the Western Snowy 

Plover on Federal Lands Within the 

New River Area of Critical 

Heavy equipment, 

burning, and hand pulling 

BLM – Coos Bay 

District, New 

River ACEC

2011-2021 Biological Opinion (FWS)
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

203

Program and Biological Assessment Treatment Methods Agency - Area Year Consultation

Environmental Concern during the 

2011-2021 Nesting and Wintering 

Seasons (USDI 2011)

to remove European 

beachgrass

Aquatic Restoration Biological 

Assessment II (USDA et al. 2013, NMFS 

2013)

Integrated Invasive Plant 

Management. Includes all 

herbicides in this EA 

except fluridone, fluazifopP-butyl, Pseudomonas 

fluorescens, fluroxypyr, 

and rimsulfuron

BLM and Forest 

Service - OR, 

WA, plus parts 

of CA, NV, and 

ID

2013

Aquatic Restoration 

Biological Opinion (ARBO 

II – FWS and NMFS)

Fiscal Years 2014-2018 Programmatic 

Suite of Activities that May Affect 

Spotted Owls, Murrelets and their 

designated Critical Habitats Proposed 

by The Coos Bay District BLM and the 

Bureau of Indian Affairs/Coquille Indian 

Tribe Biological Assessment (USDI 

2014a)1

Integrated Vegetation 

Management

BLM - Coos Bay 

District

2014 -

2018 Biological Opinion (FWS)

Vegetation Treatments Using 

Aminopyralid, Fluroxypyr, and 

Rimsulfuron PEIS (USDI 2016a) and 

Biological Assessment (USDI 2016c)

Aminopyralid, fluroxypyr, 

and rimsulfuron.

BLM - 17 

Western States 2016

Letter of Concurrence 

(FWS)

Biological Opinion 

(NMFS)

1. Amended by the 2016 Programmatic Suite of Activities that May Affect Spotted Owls, Murrelets and their designated Critical Habitats 

Proposed by The Coos Bay District BLM and the Coquille Indian Tribe Biological Opinion (USDI 2016f).

Endangered Species Act consultation with FWS and NMFS occurred at the national level with the 2007 and 2016 

PEISs and at the Oregon level with the 2010 Oregon FEIS. Consultation has also been done with the Services for 

aquatic restoration work in Oregon and Washington and portions of neighboring states for the BLM and the Forest 

Service, resulting in the Aquatic Restoration Biological Opinion (ARBO II).

For the 2007 PEIS, the BLM consulted with the FWSNMFS as required under Section 7 of the Endangered Species 

Act. The BLM prepared the Biological Assessment for Vegetation Treatments on Bureau of Land Management 

Lands in 17 Western States (USDI 2007c), with a determination of “may affect, not likely to adversely affect.” That 

Biological Assessment evaluated the likely impacts to federally listed species, species proposed for listing, and 

critical habitats from the proposed use of herbicides and other treatment methods, and identified management 

practices to minimize impacts to these species and habitats.

The FWS issued a Letter of Concurrence that concurred that the proposed action as described in the 2007 PEIS and 

Biological Assessment, with all Standard Operating Procedures and PEIS Mitigation Measures, would not likely 

adversely affect any federally listed species under the jurisdiction of the FWS. In addition, the FWS recognized that 

any future site-specific actions carried out under the PEIS would undergo additional consultation as appropriate 

(USDI 2007b). In 2010, the FWS reviewed the 2010 Oregon FEIS and 2007 Biological Assessment (USDI 2007c) and 

issued a similar Letter of Concurrence (USDI 2010b). In 2016, after reviewing the 2016 PEIS and Biological 

Assessment, the FWS issued a similar Letter of Concurrence (USDI 2016b).

The Biological Opinion issued by the NMFS in 2007 concluded that the proposed action as described in the 2007 

PEIS and Biological Assessment was not likely to jeopardize the continued existence of listed anadromous fish. 

There is no incidental take76 identified or exempted by the Biological Opinion. If take is anticipated for site-specific 

treatments, then the amount or extent of take will be identified during subsequent consultation for those 

proposed treatments. Similarly, the Biological Opinion issued by the NMFS in 2010 – based on the 2010 Oregon 

FEIS and 2007 Biological Assessment – concluded that the proposed action was not likely to jeopardize the 

 76 “Take” means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such

conduct (16 U.S.C. 1532(19).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

204

continued existence of listed anadromous fish in the State or result in the destruction or adverse modification of 

designated critical habitat. The Biological Assessment stated that incidental take is likely but not precisely 

quantifiable (USDI 2010b:143). Hence, the NMFS concluded that, “vegetation treatments within a 1,500 feet buffer 

will undergo a site-specific consultation. Vegetation treatments outside of the 1,500-foot buffer should not result 

in take if minimization measures are used” (USDI 2010b:143). Similar to the 2007 Biological Opinion, the 2016 

Biological Opinion concluded that herbicide use was not likely to jeopardize the continued existence of 

endangered and threatened salmon and trout, threatened Green Sturgeon, and threatened southern resident 

killer whales and did not identify any incidental take.

The effects from terrestrial invasive plant control actions on the listed anadromous fish species present on the 

District were also analyzed in the Aquatic Restoration Biological Assessment II (ARBA II), with a determination of 

“may affect, likely to adversely affect” and were provided Endangered Species Act and Magnuson-Stevens Fishery 

Conservation Act coverage under the National Marine Fisheries Service’s Aquatic Restoration Biological Opinion 

(ARBO II, NMFS 2013).

In ARBO II, NMFS determined that the proposed action was not likely to jeopardize the continued existence of the 

Coho Salmon (threatened, Oregon Coast and Southern Oregon/Northern California Coast Evolutionary Significant 

Units) or result in the destruction or adverse modification of designated critical habitat. Project design criteria for 

invasive plant control outlined in NMFS’s ARBO II were fully incorporated into Project Design Features of this EA,

and the extent of take authorized in ARBO II correlates to the extent of treated areas outlined in the project design 

criteria of ARBO II (i.e. less than, or equal to, 10 percent of the acres in a riparian reserve within a sub-watershed, 

or 6th field Hydrologic Unit Code (HUC)/year).

ARBO II does not cover the use of fluazifop-P-butyl, fluroxypyr, hexazinone, or rimsulfuron (four of the herbicides 

analyzed this analysis as part of Alternative 3). However, all herbicide treatments included in ARBO II are 

consistent with those included in the Proposed Action; therefore, ARBO II provides consultation coverage for the 

Proposed Action.

The BLM has engaged in multiple consultations with the FWS and NMFS over time addressing habitat restoration 

activities, including invasive plant treatments, for western snowy plover at North Spit and New River. The most 

recent consultations with the FWS are addressed in two biological assessments: the Biological Assessment of the 

BLM’s North Spit Plan as it may affect the Threatened Western Snowy Plover and its Critical Habitat (USDI 2007e) 

and the Management of the Western Snowy Plover on Federal Lands Within the New River Area of Critical 

Environmental Concern during the 2011-2021 Nesting and Wintering Seasons (USDI 2011). The resulting biological 

opinions expect the condition of critical habitat in the project areas to stay the same or improve, relative to 

current conditions as a result of the management actions. The FWS determined the actions are not likely to 

jeopardize the continued existence of the western snowy plover and are not likely to adversely modify critical 

habitat. In 2009, the BLM consulted with NMFS on these same restoration activities with a determination of “may 

affect, not likely to adversely affect” for Coho Salmon and no effect for other listed species and received a letter of 

concurrence from NMFS. 

In 2014, the BLM prepared a Biological Assessment (USDI 2014a) addressing effects to northern spotted owls and 

marbled murrelets from routinely occurring management activities on the Medford District, including invasive 

plant management. BLM determined that noxious weed management and native plant reestablishment would not 

effect habitat and the disturbance would “may affect, not likely to adversely affect” the northern spotted owl or 

marbled murrelet. The U.S. Fish and Wildlife Service concurred with this determination on June 30, 2014 in a 

Biological Opinion (USDI 2014b). The U.S. Fish and Wildlife Service issued an amendment to this opinion in May 

2016 (USDI 2016f) associated with an increase in the planned quantity of acres of herbicide treatments. The 

Service found that the increase in treatment acres was consistent with the original determination with the 

inclusion of mitigation measures designed to avoid adverse effects to both species. Project Design Criteria 

identified to protect the northern spotted owl and marbled murrelet are included in the Proposed Action as a 

Project Design Feature to minimize potential effects.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

205

Additional consultation with the National Marine Fisheries Service and the U.S. Fish and Wildlife Service would 

occur before the BLM could select Alternative 3. Specifically—

Additional consultation with the National Marine Fisheries Service would occur if:

• The use of hexazinone, fluroxypyr, rimsulfuron, or fluazifop-P-butyl is proposed within 1,500 feet 

from listed fish habitat.

Additional consultation with the U.S. Fish and Wildlife Service would occur if:

• Any herbicide use is proposed in western snowy plover habitat, with the exception of 24 acres annually of 

glyphosate on the Coos Bay North Spit.

• The use of hexazinone, fluroxypyr, rimsulfuron, or fluazifop-P-butyl is proposed within the same 

watershed77 as western snowy plover or western lily habitat.

Consultation resulted in Conservation Measures and Project Design Criteria identified to protect Coos Bay District

listed species from treatments are listed below.

Conservation Measures from the 2007 and 2016 PEISs 

Biological Assessments

Mitigation Measures (above) include “when necessary to protect Special Status [plant/fish/wildlife species], 

implement all Conservation Measures for [plant/fish/wildlife species] presented in the Vegetation Treatments on 

Bureau of Land Management Lands in 17 Western States Programmatic Biological Assessment” (USDI 2007c). 

Those Conservation Measures are presented here for use with Special Status species as needed. Conservation 

Measures for mammals, birds, arthropods, and terrestrial mollusks are generally species specific. Special Status 

species with Conservation Measures are included below; not all Bureau Sensitive species have Conservation 

Measures. However, Conservation Measures for similar species can be found in the 2007 and 2016 PEIS Biological 

Assessments (for example, there are no Conservation Measures to protect the Bureau Sensitive American white 

pelican, but, when necessary, implementation of Conservation Measures for the brown pelican may be 

appropriate).

Given the low toxicity of aminopyralid, fluroxypyr, and rimsulfuron to fauna; likely uses of the herbicides; and, 

Standard Operating Procedures for minimizing the risk of spills, no new aquatic or terrestrial animal Conservation 

Measures have been developed for herbicide treatments using aminopyralid, fluroxypyr, or rimsulfuron. Additional 

plant Conservation Measures were adopted as part of the Biological Assessment for Vegetation Treatments Using 

Aminopyralid, Fluroxypyr, and Rimsulfuron (USDI 2016c) and are included below.

Plant Conservation Measures

As dictated in BLM Manual 6840 (Special Status Species Management), local BLM offices are required to develop 

and implement management plans and programs that will conserve listed species and their habitats. In addition, 

NEPA documentation related to treatment activities (i.e., projects) will be prepared that identify any TEP78 plant 

species or their critical habitat that are present in the proposed treatment areas, and that list the measures that 

will be taken to protect them.

 77 Fifth field hydrological unit code (HUC)

78 Federally listed as threatened or endangered, or proposed for such listing.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

206

Many local BLM offices already have management plans in place that ensure the protection of these plant species 

during activities on public land. However, a discussion of these existing plans is outside the scope of this 

programmatic BA. The following general guidance applies to all management plans developed at the local level.

Required steps include the following:

• A survey of all proposed action areas within potential habitat by a botanically qualified biologist, botanist, 

or ecologist to determine the presence/absence of the species.

• Establishment of site-specific no activity buffers by a qualified botanist, biologist, or ecologist in areas of 

occupied habitat within the proposed project area. To protect occupied habitat, treatment activities 

would not occur within these buffers.

• Collection of baseline information on the existing condition of TEP plant species and their habitats in the 

proposed project area.

• Establishment of pre-treatment monitoring programs to track the size and vigor of TEP populations and 

the state of their habitats. These monitoring programs would help in anticipating the future effects of 

vegetation treatments on TEP plant species.

• Assessment of the need for site revegetation post treatment to minimize the opportunity for noxious 

weed invasion and establishment.

At a minimum, the following must be included in all management plans:

• Given the high risk for damage to TEP plants and their habitat from burning, mechanical treatments, and 

use of domestic animals to contain weeds, none of these treatment methods should be utilized within 

330 feet of sensitive plant populations UNLESS the treatments are specifically designed to maintain or 

improve the existing population.

• Off-highway use of motorized vehicles associated with treatments should be avoided in suitable or 

occupied habitat.

• Biological control agents (except for domestic animals) that affect target plants in the same genus as TEP 

species must not be used to control target species occurring within the dispersal distance of the agent.

• Prior to use of biological control agents that affect target plants in the same family as TEP species, the 

specificity of the agent with respect to factors such as physiology and morphology should be evaluated, 

and a determination as to risks to the TEP species made.

• Post-treatment monitoring should be conducted to determine the effectiveness of the project.

In addition, the following guidance must be considered in all management plans in which herbicide treatments are 

proposed to minimize or avoid risks to TEP species. The exact Conservation Measures to be included in 

management plans would depend on the herbicide that would be used, the desired mode of application, and the 

conditions of the site. Given the potential for off-site drift and surface runoff, populations of TEP species on lands 

not administered by the BLM would need to be considered if they are located near proposed herbicide treatment 

sites.

• Herbicide treatments should not be conducted in areas where TEP plant species may be subject to direct 

spray by herbicides during treatments.

• Applicators should review, understand, and conform to the “Environmental Hazards” section on herbicide 

labels (this section warns of known pesticide risks and provides practical ways to avoid harm to organisms 

or the environment).

• To avoid negative effects to TEP plant species from off-site drift, surface runoff, and/or wind erosion, 

suitable buffer zones should be established between treatment sites and populations (confirmed or 

suspected) of TEP plant species, and site-specific precautions should be taken (refer to the guidance 

provided below).

• Follow all instructions and Standard Operating Procedures to avoid spill and direct spray scenarios into 

aquatic habitats that support TEP plant species.

• Follow all BLM operating procedures for avoiding herbicide treatments during climatic conditions that 

would increase the likelihood of spray drift or surface runoff.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

207

The following Conservation Measures refer to sites where broadcast spraying of herbicides is desired. Manual spot 

treatment of undesirable vegetation can occur within the listed buffer zones if it is determined by local biologists 

that this method of herbicide application would not pose risks to TEP plant species in the vicinity. Additional 

precautions during spot treatments of vegetation within habitats where TEP plant species occur should be 

considered while planning local treatment programs, and should be included as Conservation Measures in locallevel NEPA documentation.

The buffer distances provided below are conservative estimates, based on the information provided by Ecological 

Risk Assessments, and are designed to provide protection to TEP plants. Some Ecological Risk Assessments used 

regression analysis to predict the smallest buffer distance to ensure no risks to TEP plants. In most cases, where 

regression analyses were not performed, suggested buffers extend out to the first modeled distance from the 

application site for which no risks were predicted. In some instances, the jump between modeled distances was 

quite large (e.g., 100 feet to 900 feet). Regression analyses could be completed at the local level using the 

interactive spreadsheets developed for the Ecological Risk Assessments, using information in Ecological Risk 

Assessments and for local site conditions (e.g., soil type, annual precipitation, vegetation type, and treatment 

method), to calculate more precise, and possibly smaller buffers for some herbicides.

2,4-D

• Because the risks associated with this herbicide were not assessed, do not spray within 1⁄2 mile of 

terrestrial plant species or aquatic habitats where TEP aquatic plant species occur.

• Do not use aquatic formulations in aquatic habitats where TEP aquatic plant species occur.

• Assess local site conditions when evaluating the risks from surface water runoff to TEP plants located 

within 1⁄2-mile downgradient from the treatment area.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Aminopyralid

• If using a low boom at the typical application rate, do not apply within 100 feet of TEP terrestrial plants79.

• If using a low boom at the maximum application rate or a high boom at the typical application rate, do not 

apply within 400 feet of TEP terrestrial plants.

• If using a high boom at the maximum application rate, do not apply within 600 feet of TEP terrestrial 

plants.

• In areas where wind erosion is likely, do not apply within 1.2 miles of TEP plant species (an alternative 

suitable buffer may be developed at the local level based on an analysis of site conditions).

Chlorsulfuron

• Do not apply by ground methods within 1,200 feet of terrestrial TEP species.

• Do not apply by ground methods within 25 feet of aquatic habitats where TEP plant species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Clopyralid

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which TEP 

plant species occur.

• Do not apply by ground methods at the typical application rate within 900 feet of terrestrial TEP species.

• Do not apply by ground methods at the typical application rate within 1⁄2 mile of terrestrial TEP species.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

 79 Note that buffers for terrestrial plants may be appropriate for plant species that root in water but have foliage extending 

above the surface of the water.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

208

Dicamba

• If using a low boom at the typical application rate, do not apply within 1,050 feet of terrestrial TEP plant 

species.

• If using a low boom at the maximum application rate, do not apply within 1,050 feet of terrestrial TEP 

plant species.

• If using a high boom, do not apply within 1,050 feet of terrestrial TEP plant species.

• Do not apply within 25 feet of aquatic habitats where TEP plant species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Diflufenzopyr

• If using a low boom at the typical application rate, do not apply within 100 feet of terrestrial TEP plant 

species.

• If using a high boom, or a low boom at the maximum application rate, do not apply within 900 feet of 

terrestrial TEP plant species.

• If using a high boom, do not apply within 500 feet of terrestrial TEP plant species.

• Do not apply within 25 feet of aquatic habitats where TEP plant species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Fluroxypyr

• If using a low boom at the typical application rate, do not apply within 100 feet of TEP terrestrial plants.

• If using a low boom at the maximum application rate, do not apply within 600 feet of TEP terrestrial 

plants.

• If using a high boom at the typical application rate, do not apply within 400 feet of TEP terrestrial plants.

• If using a high boom at the maximum application rate, do not apply within 700 feet of TEP terrestrial 

plants.

• In areas where wind erosion is likely, do not apply within 1.2 miles of TEP plant species (an alternative 

suitable buffer may be developed at the local level based on an analysis of site conditions).

Glyphosate

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species.

• Do not apply by ground methods at the typical application rate within 50 feet of terrestrial TEP plant 

species.

• Do not apply by ground methods at the maximum application rate within 300 feet of terrestrial TEP plant 

species.

•

Hexazinone

• Since the risks associated with using a high boom are unknown, only apply this herbicide by ground 

methods using a low boom within 1⁄2 mile of terrestrial TEP plant species and aquatic habitats that support 

aquatic TEP species.

• Do not apply by ground methods at the typical application rate within 300 feet of terrestrial TEP plant 

species or aquatic habitats that support aquatic TEP plant species.

• Do not apply by ground methods at the maximum application rate within 900 feet of terrestrial TEP plant 

species or aquatic habitats that support aquatic TEP plant species.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Imazapic

• Do not apply by ground methods within 25 feet of terrestrial TEP species or aquatic habitats where TEP 

plant species occur.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

209

Imazapyr

• Since the risks associated with using a high boom are unknown, use only a low boom for ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which TEP 

plant species occur.

• Do not apply at the typical application rate within 900 feet of terrestrial TEP plant species or aquatic 

habitats in which aquatic TEP species occur.

• Do not apply at the maximum application rate within 1⁄2 mile of terrestrial TEP plant species or aquatic 

habitats in which aquatic TEP species occur.

• Do not use aquatic formulations in aquatic habitats where TEP aquatic plant species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Metsulfuron Methyl

• Since the risks associated with using a high boom are unknown, use only a low boom for ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which TEP 

plant species occur.

• Do not apply at the typical application rate within 900 feet of terrestrial TEP plant species or aquatic 

habitats in which aquatic TEP species occur.

• Do not apply at the maximum application rate within 1⁄2 mile of terrestrial TEP plant species or aquatic 

habitats in which aquatic TEP species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Overdrive®

• If using a low boom at the typical application rate, do not apply within 100 feet of terrestrial TEP plant 

species.

• If using a low boom at the maximum application rate, do not apply within 900 feet of terrestrial TEP plant 

species.

• If using a high boom, do not apply within 900 feet of terrestrial TEP plant species.

• Do not apply within 25 feet of aquatic habitats where TEP plant species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Picloram

• Do not apply by ground methods, at any application rate, within 1⁄2 mile of terrestrial TEP plant species.

• Assess local site conditions when evaluating the risks from surface water runoff to TEP plants located 

within 1⁄2-mile downgradient from the treatment area.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Rimsulfuron

• If using a low boom at the typical application rate, do not apply within 200 feet of TEP terrestrial plants.

• If using a low boom at the maximum application rate or a high boom at the typical application rate, do not 

apply within 400 feet of TEP terrestrial plants.

• If using a high boom at the maximum application rate, do not apply within 700 feet of TEP terrestrial 

plants.

• In areas where wind erosion is likely, do not apply within 1.2 miles of TEP plant species (an alternative 

suitable buffer may be developed at the local level based on an analysis of site conditions).

• Do not use in watersheds where annual precipitation exceeds 50 inches.

• In watersheds where annual precipitation exceeds 10 inches, prior to use of rimsulfuron conduct a locallevel analysis of site conditions and develop suitable conservation measures for protection of TEP plant 

species from surface runoff.

Sulfometuron Methyl

• Do not apply by ground methods within 1,500 feet of terrestrial TEP species.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

210

• Do not apply by ground methods within 900 feet of aquatic habitats where TEP plant species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Triclopyr Acid

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species.

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications at the maximum application rate of this herbicide within 1⁄2 mile of aquatic habitats in which 

TEP plant species occur.

• Do not apply by ground methods at the typical application rate within 300 feet of terrestrial TEP plant 

species.

• Do not apply by ground methods at the maximum application rate within 1⁄2 mile of terrestrial TEP plant 

species or aquatic habitats in which TEP plant species occur.

• If applying to aquatic habitats in which aquatic TEP plant species occur, do not exceed the targeted water 

concentration on the product label.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

Triclopyr BEE

• Since the risks associated with using a high boom are unknown, use only a low boom for ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which TEP 

plant species occur.

• Do not apply by ground methods at the typical application rate within 300 feet of terrestrial TEP plant 

species or aquatic habitats in which TEP plant species occur.

• Do not apply by at the maximum application rate within 1⁄2 mile of terrestrial TEP plant species or aquatic 

habitats in which TEP plant species occur.

• Do not use aquatic formulations in aquatic habitats where TEP aquatic plant species occur.

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species.

If a tank mix of one of these chemicals with another approved herbicide is desired, an additional assessment of 

potential effects to non-target TEP species must be made with the assumption that effects of the herbicides are at 

a minimum additive. Larger buffers may be warranted. At the local level, the BLM must make determinations as to 

the suitability of herbicide treatments for the populations of TEP species that are managed by local offices. The 

following information should be considered: the timing of the treatment in relation to the phenology of the TEP 

plant species; the intensity of the treatment; the duration of the treatment; and the tolerance of the TEP species 

to the treatment. When information about species tolerance is unavailable or is inconclusive, local offices must 

assume an adverse effect to plant populations, and protect those populations from direct or indirect exposure to 

the treatment in question. Treatment plans must also address the presence of and expected impacts on noxious 

weeds on the project site. These plans must be coordinated with BLM weed experts and/or appropriate county

weed supervisors to minimize the spread of weeds.

The information provided in Table 4-4 (of the 2007 PEIS Biological Assessment, USDI 2007c:4-113 to 4-126) 

provides a general guideline as to the types of habitats in which treatments (particularly fire) may be utilized to 

improve growing conditions for TEP plant species. However, at the local level, the BLM must make a further 

determination as to the suitability of vegetation treatments for the populations of TEP species that are managed 

by local offices. The following information should be considered: the timing of the treatment in relation to the 

phenology of the TEP plant species; the intensity of the treatment; the duration of the treatment; and the 

tolerance of the TEP species to the particular type of treatment to be used. When information about species 

tolerance is unavailable or is inconclusive, local offices must assume a negative effect to plant populations, and 

protect those populations from direct exposure to the treatment in question.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

211

Treatment plans must also address the presence of and expected impacts on noxious weeds on the project site. 

These plans must be coordinated with BLM weed experts and/or appropriate county weed supervisors to minimize 

the spread of weeds. In order to prevent the spread of noxious weeds and other unwanted vegetation in occupied 

or suitable habitat, the following precautions should be taken:

• Cleared areas that are prone to downy brome [cheatgrass] or other noxious weed invasions should be 

seeded with an appropriate seed mixture to reduce the probability of noxious weeds or other undesirable 

plants becoming established on the site.

• Where seeding is warranted, bare sites should be seeded as soon as appropriate after treatment, and at a 

time of year when it is likely to be successful.

• In suitable habitat for TEP species, nonnative species should not be used for revegetation.

• Certified noxious weed - free seed must be used in suitable habitat, and preference should be given to 

seeding appropriate plant species when rehabilitation is appropriate.

• Straw and hay bales used for erosion control in suitable habitat must be certified weed- and seed-free.

• Vehicles and heavy equipment used during treatment activities should be washed prior to arriving at a 

new location to avoid the transfer of noxious weeds.

When BAs are drafted at the local level for treatment programs, additional Conservation Measures may be added 

to this list. Where BLM plans that consider the effects of vegetation treatments on TEP plant species already exist, 

these plans should be consulted, and incorporated (e.g., any guidance or Conservation Measures they provide) 

into local level BAs for vegetation treatments.

Aquatic Animals Conservation Measures

Many local BLM offices already have management plans in place that ensure the protection of these species, and 

have completed formal or informal consultations on similar treatment activities. These consultations have 

identified protection zones alongside aquatic habitats that support these species. The Conservation Measures 

discussed below are probable steps required of the BLM to ensure that vegetation treatments would minimize 

impacts to TEP species. These Conservation Measures are intended as broad guidance at the programmatic level; 

further analysis of treatment programs and species habitats at the local level is required to better reduce potential 

impacts from proposed vegetation treatments. Completion of consultation at the local level will fine-tune 

Conservation Measures associated with treatment activities and ensure consistency of the treatments with ESA 

requirements.

The aquatic TEP species considered in the programmatic BA occur in varied habitats, over a large geographic area. 

The Conservation Measures guidance presented below is intended to apply broadly to aquatic species and habitats 

over the entire region covered by the BA, based on the common features found in nearly all aquatic and riparian 

habitats. Some species with alternate or unusual habitat requirements may require additional Conservation 

Measures to ensure a Not Likely to Adversely Affect determination at the local level. Such additional Conservation 

Measures are outside the scope of the BA, and will be completed at the local level.

Some local BLM plans have delineated protected riparian areas, or portions of watersheds where ripariandependent resources receive primary emphasis, and management activities are subject to specific standards and 

guidelines. These protected riparian areas include traditional riparian corridors, wetlands, intermittent streams, 

and other areas that help maintain the integrity of aquatic ecosystems by 1) influencing the delivery of coarse 

sediment, organic matter, and woody debris to streams; 2) providing root strength for channel stability; 3) shading 

the stream; and 4) protecting water quality. Examples of protected riparian areas are the BLM’s Riparian Reserves 

of the Pacific Northwest. The term “riparian areas,” as used in the Conservation Measures guidance below, refers 

to riparian protected areas, wherever such designations apply. However, since not all local BLM plans have made 

such designations, “riparian areas,” when the above-mentioned use is not applicable, generally refers to: 1) for 

streams, the stream channel and the extent of the 100-year floodplain; and 2) for wetlands, ponds, and lakes, and 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

212

other aquatic habitats, the area extending to the edges of the riparian vegetation, provided it is no less than the 

minimum buffer distance for a given site established by local BLM biologists.

Conservation Measures for Site Access and Fueling/Equipment Maintenance

For treatments occurring in watersheds with TEP species or designated or undesignated critical habitat (i.e., 

unoccupied habitat critical to species recovery):

• Where feasible, access work site only on existing roads, and limit all travel on roads when damage to the 

road surface will result or is occurring.

• Where TEP aquatic species occur, consider ground-disturbing activities on a case by case basis, and 

implement Standard Operating Procedures to ensure minimal erosion or impact to the aquatic habitat.

• Within riparian areas, do not use vehicle equipment off of established roads.

• Outside of riparian areas, allow driving off of established roads only on slopes of 20% or less.

• Within 150 feet of wetlands or riparian areas, do not fuel/refuel equipment, store fuel, or perform 

equipment maintenance (locate all fueling and fuel storage areas, as well as service landings outside of 

protected riparian areas).

• Do not conduct biomass removal (harvest) activities that will alter the timing, magnitude, duration, and 

spatial distribution of peak, high, and low flows outside the range of natural variability.

Conservation Measures Related to Revegetation Treatments

• Outside riparian areas, avoid hydro-mulching within buffer zones established at the local level. This 

precaution will limit adding sediments and nutrients and increasing water turbidity.

• Within riparian areas, engage in consultation at the local level to ensure that revegetation activities 

incorporate knowledge of site-specific conditions and project design.

Conservation Measures Related to Herbicide Treatments

The complexity of this action within riparian areas requires local consultation, which will be based on herbicide 

Risk Assessments.

Possible Conservation Measures:

• Maintain equipment used for transportation, storage, or application of chemicals in a leak proof 

condition.

• Do not store or mix herbicides, or conduct post-application cleaning within riparian areas.

• Ensure that trained personnel monitor weather conditions at spray times during application.

• Strictly enforce all herbicide labels.

• Do not broadcast spray within 100 feet of open water when wind velocity exceeds 5 mph.

• Do not broadcast spray when wind velocity exceeds 10 mph.

• Do not spray if precipitation is occurring or is imminent (within 24 hours).

• Do not broadcast spray herbicides in riparian areas that provide habitat for TEP aquatic species. 

Appropriate buffer distances should be determined at the local level to ensure that overhanging 

vegetation that provides habitat for TEP species is not removed from the site. Buffer distances provided as 

Conservation Measures in the assessment of effects to plants (Chapter 4 of this BA) and fish and aquatic 

invertebrates should be consulted as guidance. (Note: the Forest Service did not determine appropriate 

buffer distances for TEP fish and aquatic invertebrates when evaluating herbicides in Forest Service 

Ecological Risk Assessments; buffer distances were only determined for non-TEP species.)

• Do not use terrestrial formulations of glyphosate, or triclopyr BEE, to treat aquatic vegetation in habitats 

where aquatic TEP species occur or may potentially occur.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

213

• Follow all instructions and Standard Operating Procedures to avoid spill and direct spray scenarios into 

aquatic habitats. Special care should be followed when transporting and applying 2,4-D, clopyralid, 

glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr.

• Do not broadcast spray glyphosate, picloram, or triclopyr BEE in upland habitats adjacent to aquatic 

habitats that support (or may potentially support) aquatic TEP species under conditions that would likely 

result in off-site drift.

• In watersheds that support TEP species or their habitat, do not apply triclopyr BEE in upland habitats 

within 1⁄2 mile upslope of aquatic habitats that support aquatic TEP species under conditions that would 

likely result in surface runoff.

Numerous Conservation Measures were developed from information provided in Ecological Risk Assessments. The 

measures listed below would apply to TEP fish and other aquatic species at the programmatic level in all 17 

western states. However, local BLM field offices could use interactive spreadsheets and other information 

contained in the Ecological Risk Assessments to develop more site-specific Conservation Measures and 

management plans based on local conditions (soil type, rainfall, vegetation type, and herbicide treatment method). 

It is possible that Conservation Measures would be less restrictive than those listed below if local site conditions 

were evaluated using the Ecological Risk Assessments when developing project-level Conservation Measures.

Conservation Measures Related to Prescribed Fire

Within riparian areas, in watersheds with TEP species or their habitats:

• Conduct prescribed burning only when long-term maintenance of the riparian area is the primary 

objective, and where low intensity fires can be maintained.

• Do not construct black lines, except by non-mechanized methods.

• Utilize/create only the following firelines: natural barriers; hand-built lines parallel to the stream channel 

and outside of buffer zones established at the local level; or hand built lines perpendicular to the stream 

channel with waterbars and the same distance requirement.

• Do not ignite fires using aerial methods.

• In forested riparian areas, keep fires to low severity levels to ensure that excessive vegetation removal 

does not occur.

• Do not camp, unless allowed by local consultation.

• Have a fisheries biologist determine whether pumping activity can occur in streams with TEP species.

• During water drafting/pumping, maintain a continuous surface flow of the stream that does not alter 

original wetted stream width.

• Do not alter dams or channels in order to pump in streams occupied by TEP species.

• Do not allow helicopter dipping from waters occupied by TEP species, except in lakes outside of the 

spawning period.

• Consult with a local fisheries biologist prior to helicopter dipping in order to avoid entrainment and 

harassment of TEP species.

Conservation Measures Related to Mechanical Treatments

Note: these measures apply only to treatments occurring in watersheds that support TEP species or in unoccupied 

habitat critical to species recovery (including but not limited to critical habitat, as designated by USFWS).

Outside riparian areas in watersheds with TEP species or designated or undesignated critical habitat (i.e., 

unoccupied habitat critical to species recovery):

• Conduct soil-disturbing treatments only on slopes of 20% or less, where feasible.

• Do not conduct log hauling activities on native surface roads prone to erosion, where feasible.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

214

Within riparian areas in these watersheds, more protective measures will be required to avoid negatively affecting 

TEP species or their habitat:

• Do not use vehicles or heavy equipment, except when crossing at established crossings.

• Do not remove large woody debris or snags during mechanical treatment activities.

• Do not conduct ground disturbing activities (e.g., disking, drilling, chaining, and plowing).

• Ensure that all mowing follows guidance to avoid negative effects to streambanks and riparian vegetation 

and major effects to streamside shade.

• Do not use equipment in perennial channels or in intermittent channels with water, except at crossings

that already exist.

• Leave suitable quantities (to be determined at the local level) of excess vegetation and slash on site.

• Do not apply fertilizer within 25 feet of streams and supersaturated soils; apply fertilizer following labeling 

instructions.

• Do not apply fertilizer in desert habitats.

• Do not completely remove trees and shrubs.

Conservation Measures Related to Biological Control Treatments using Livestock

For treatments occurring in watersheds that support TEP species or in critical habitat:

• Where terrain permits, locate stock handling facilities, camp facilities, and improvements at least 300 feet 

from lakes, streams, and springs.

• Educate stock handlers about at-risk fish species and how to minimize negative effects to the species and 

their associated habitat.

• Employ appropriate dispersion techniques to range management, including judicial placement of 

saltblocks, troughs, and fencing, to prevent damage to riparian areas but increase weed control.

• Equip each watering trough with a float valve.

Within riparian areas of these watersheds, more protective measures are required.

• Do not conduct weed treatments involving domestic animals, except where it is determined that these 

treatments will not damage the riparian system, or will provide long-term benefits to riparian and 

adjacent aquatic habitats.

• Do not locate troughs, storage tanks, or guzzlers near streams with TEP species, unless their placement 

will enhance weed-control effectiveness without damaging the riparian system.

Terrestrial Animals

Butterfly or Moth Conservation Measures

Many local BLM offices already have management plans in place that ensure the protection of these species during 

activities on public lands. The following Conservation Measures are the minimum steps required of the BLM to 

ensure that treatment methods would be unlikely to negatively affect TEP species.

Each local BLM office is required to draw up management plans related to treatment activities that identify any 

TEP butterfly or moth species or their critical habitat that are present in the proposed treatment areas, as well as 

the measures that will be taken to protect these species.

Management plans should, at a minimum, follow this general guidance:

• Use an integrated pest management approach when designing programs for managing pest outbreaks.

• Survey treatment areas for TEP butterflies/moths and their host/nectar plants (suitable habitat) at the 

appropriate times of year.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

215

• Minimize the disturbance area with a pre-treatment survey to determine the best access routes. Areas 

with butterfly/moth host plants and/or nectar plants should be avoided.

• Minimize mechanical treatments and OHV activities on sites that support host and/or nectar plants.

• Carry out vegetation removal in small areas, creating openings of 5 acres or less in size.

• Avoid burning all of a species’ habitat in any 1 year. Limit area burned in butterfly/moth habitat in such a 

manner that the unburned units are of sufficient size to provide a refuge for the population until the 

burned unit is suitable for recolonization. Burn only a small portion of the habitat at any one time, and 

stagger timing so that there is a minimum 2-year recovery period before an adjacent parcel is burned.

• Where feasible, mow or wet around patches of larval host plants within the burn unit to reduce impacts 

to larvae.

• In TEP butterfly/moth habitat, burn while butterflies and/or moths of concern are in the larval stage, 

when the organisms would receive some thermal protection.

• Wash equipment before it is brought into the treatment area.

• Use a seed mix that contains host and/or nectar plant seeds for road/site reclamation.

• To protect host and nectar plants from herbicide treatments, follow recommended buffer zones and 

other Conservation Measures for TEP plants species when conducting herbicide treatments in areas 

where populations of host and nectar plants occur.

• Do not broadcast spray herbicides in habitats occupied by TEP butterflies or moths; do not broadcast 

spray herbicides in areas adjacent to TEP butterfly/moth habitat under conditions when spray drift onto 

the habitat is likely.

• Do not use 2,4-D in TEP butterfly/moth habitat.

• When conducting herbicide treatments in or near habitat used by TEP butterflies or moths, avoid use of 

the following herbicides, where feasible: clopyralid, glyphosate, hexazinone, imazapyr, picloram, and 

triclopyr.

• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in TEP 

butterfly or moth habitat, utilize the typical, rather than the maximum, application rate.

Amphibians and Reptiles Conservation Measures

Many local BLM offices already have management plans in place that ensure the protection of these species during 

activities on public lands. In addition, the following Conservation Measures are the minimum steps required of the 

BLM to ensure that treatment methods would be unlikely to negatively affect TEP species.

• Survey all areas that may support TEP amphibians and/or reptiles prior to treatments.

• Conduct burns during periods when the animals are in aquatic habitats or are hibernating in burrows.

• For species with extremely limited habitat, such as the desert slender salamander, avoid prescribed 

burning in known habitat.

• Do not use water from aquatic habitats that support TEP amphibians and/or reptiles for fire abatement.

• Install sediment traps upstream of aquatic habitats to minimize the amount of ash and sediment entering 

aquatic habitats that support TEP species.

• Do not conduct prescribed burns in desert tortoise habitat.

• In habitats where aquatic herpetofauna occur, implement all Conservation Measures identified for 

aquatic organisms in Chapter 4.

• Within riparian areas, wetlands, and aquatic habitats, conduct herbicide treatments only with herbicides 

that are approved for use in those areas.

• Do not broadcast spray herbicides in riparian areas or wetlands that provide habitat for TEP 

herpetofauna.

• Do not use glyphosate, or triclopyr BEE to treat aquatic vegetation in habitats where TEP amphibians 

occur or may potentially occur.

• In desert tortoise habitat, conduct herbicide treatments during the period when desert tortoises are less 

active.

• To the greatest extent possible, avoid desert tortoise burrows during herbicide treatments.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

216

• When conducting herbicide treatments in upland areas adjacent to aquatic or wetland habitats that 

support TEP herpetofauna, do not broadcast spray during conditions under which off-site drift is likely.

• In watersheds where TEP amphibians occur, do not apply triclopyr BEE in upland habitats upslope of 

aquatic habitats that support (or may potentially support) TEP amphibians under conditions that would 

likely result in surface runoff.

• Follow all instructions and Standard Operating Procedures to avoid spill and direct spray scenarios into 

aquatic habitats that support TEP herpetofauna.

• Do not use 2,4-D in terrestrial habitats occupied by TEP herpetofauna; do not broadcast spray 2,4-D 

within 1⁄4 mile of terrestrial habitat occupied by TEP herpetofauna.

• When conducting herbicide treatments in or near terrestrial habitat occupied by TEP herpetofauna, avoid

using the following herbicides, where feasible: clopyralid, glyphosate, hexazinone, imazapyr, metsulfuron 

methyl, picloram, and triclopyr.

• When conducting herbicide treatments in upland habitats occupied by TEP herpetofauna, do not 

broadcast spray 2,4-D, clopyralid, glyphosate, hexazinone, picloram or triclopyr; do not broadcast spray 

these herbicides in areas adjacent to habitats occupied by TEP herpetofauna under conditions when spray 

drift onto the habitat is likely.

• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in upland 

habitats occupied by TEP herpetofauna, utilize the typical, rather than the maximum, application rate.

• If spraying imazapyr or metsulfuron methyl in or adjacent to upland habitats occupied by TEP 

herpetofauna, apply at the typical, rather than the maximum, application rate.

• If conducting herbicide treatments in or near upland habitats occupied by TEP herpetofauna, consult 

Table 6-3 on a species by species basis to determine additional Conservation Measures that should be 

enacted to avoid negative effects via ingestion of contaminated prey.

Bird Conservation Measures

Sand Nesters: Western Snowy Plover, Piping Plover, and Least Tern

• Survey for western snowy plovers, piping plovers, and interior least terns (and their nests) in suitable 

areas on proposed treatment areas, prior to developing treatment plans.

• Do not treat vegetation in nesting areas during the breeding season (as determined by a qualified 

biologist).

• Do not allow human (or domestic animal) disturbance within 1⁄4 mile of nest sites during the nesting 

period.

• Ensure that nest sites are at least 1 mile from downwind smoke effects during the nesting period.

• Conduct beachgrass treatments during the plant’s flowering stage, during periods of active growth.

• Closely follow all application instructions and use restrictions on herbicide labels; in wetland habitats use 

only those herbicides that are approved for use in wetlands.

• Do not use 2,4-D in western snowy plover, piping plover, or interior least tern habitats; do not broadcast 

spray 2,4-D within 1⁄4 mile of western snowy plover, piping plover, or interior least tern habitat.

• Where feasible, avoid use of the following herbicides in western snowy plover and piping plover habitat: 

clopyralid, glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr; in interior least 

tern habitat avoid the use of clopyralid, glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, 

and triclopyr.

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in western snowy plover 

or piping plover habitat; do not broadcast spray these herbicides in areas adjacent to western snowy 

plover or piping plover habitat under conditions when spray drift onto the habitat is likely.

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in interior least tern 

habitat; do not broadcast spray these herbicides in areas adjacent least tern habitat under conditions 

when spray drift onto the habitat is likely.

• If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to western snowy plover, piping 

plover, or interior least tern habitat, apply at the typical, rather than the maximum, application rate.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

217

• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in western 

snowy plover, piping plover, or interior least tern habitat, utilize the typical, rather than the maximum, 

application rate.

Mature-forest Nesters: Marbled Murrelet, Northern Spotted Owl

• Survey for marbled murrelets and northern spotted owls (and their nests) on suitable proposed treatment 

areas, prior to developing treatment plans.

• Delineate a 100-acre buffer around nests prior to mechanical treatments or prescribed burns.

• Do not allow human disturbance within 1⁄4 mile of nest sites during the nesting period (as determined by a 

local biologist).

• Ensure that nest sites are at least 1 mile from downwind smoke effects during the nesting period.

• Protect and retain the structural components of known or suspected nest sites during treatments; 

evaluate each nest site prior to treatment and protect it in the most appropriate manner.

• Maintain sufficient dead and down material during treatments to support spotted owl prey species 

(minimums would depend on forest types, and should be determined by a wildlife biologist).

• Do not conduct treatments that alter forest structure in old-growth stands.

• Do not use 2,4-D in marbled murrelet or northern spotted owl habitats; do not broadcast spray 2,4-D 

within 1⁄4 mile of marbled murrelet or northern spotted owl habitat.

• Where feasible, avoid use of the following herbicides in northern spotted owl habitat: clopyralid, 

glyphosate, imazapyr, metsulfuron methyl, picloram, and triclopyr.

• Where feasible, avoid use of the following herbicides in marbled murrelet habitat: clopyralid, glyphosate, 

hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr.

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in marbled murrelet or 

northern spotted owl habitat; do not broadcast spray these herbicides in areas adjacent to marbled 

murrelet or northern spotted owl habitat under conditions when spray drift onto the habitat is likely.

• If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to marbled murrelet, northern 

spotted owl habitat, apply at the typical, rather than the maximum, application rate.

• If broadcast spraying bromacil or diquat in or adjacent to northern spotted owl habitat, apply at the 

typical, rather than the maximum, application rate.

• If conducting manual spot applications of glyphosate hexazinone, or triclopyr to vegetation in marbled 

murrelet, or northern spotted owl habitat, utilize the typical, rather than the maximum, application rate.

• Follow all instructions and SOPs to avoid spill and direct spray scenarios into aquatic habitats, particularly 

marine habitats where murrelets forage for prey.

Bald Eagles

The following programmatic level conservation measures are the minimum steps required of the BLM to ensure 

that treatment methods would not negatively affect the bald eagle or its habitat. Additional, site-specific 

conservation measures would also be developed at the local level, as appropriate.

• Do not allow human disturbance within a suitable buffer distance of known bald eagle nest sites during 

the breeding season (as determined by a qualified wildlife biologist). For active bald eagle nests in open 

country, buffer distances should be 1 mile. In other habitats, with a shorter line-of-site distance, buffer 

distances may be reduced, based on consultation with the USFWS.

• Do not allow ground disturbing activities within 1⁄2 mile of active roost sites year round,

• Avoid human disturbance within 1 mile of a winter roost during the wintering period (as determined by a 

qualified wildlife biologist).

• Complete treatment activities that must occur within 1 mile of a winter roost within the hours of 9 a.m. to 

3 p.m., during the winter roosting period.

• Conduct prescribed burn activities in a manner that ensures that nest and winter roost sites are greater 

than 1 mile from downwind smoke effects.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

218

• Do not cut trees within 1⁄4 mile of any known nest trees.

• Do not use 2,4-D in bald eagle habitats; do not broadcast spray 2,4-D within 1⁄4 mile of bald eagle habitat.

• Where feasible, avoid use of the following herbicides in bald eagle habitat: clopyralid, glyphosate, 

hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr.

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in bald eagle habitat; do 

not broadcast spray these herbicides in areas adjacent to bald eagle habitat under conditions when spray 

drift onto the habitat is likely.

• If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to bald eagle habitat, apply at the 

typical, rather than the maximum, application rate.

• If conducting manual spot applications of glyphosate, hexazinone or triclopyr to vegetation in bald eagle 

habitat, utilize the typical, rather than the maximum, application rate.

Riparian Birds

To minimize or avoid negative effects to riparian bird species (such as the yellow-billed cuckoo), the BLM would be 

required to implement the following programmatic-level conservation measures in habitats utilized by these three 

species.

• Conduct surveys prior to vegetation treatments within potential or suitable habitat.

• Where surveys detect birds, do not burn, broadcast spray herbicides, use domestic animals to control 

weeds, or conduct mechanical treatments.

• Do not conduct vegetation treatments within 1⁄2 mile (or further if deemed necessary to prevent smoke 

from inundating the nest area) of known nest sites or unsurveyed suitable habitat during the breeding 

season (as determined by a qualified wildlife biologist).

• Adjust spatial and temporal scales of treatments to that not all suitable habitat is affected in any given 

year.

• Following treatments, replant or reseed treated areas with native species, if needed.

• Closely follow all application instructions and use restrictions on herbicide labels; in wetland habitats use 

only those herbicides that are approved for use in wetlands.

• Do not use 2,4-D in least Bell’s vireo, Inyo California towhee, or southwestern willow flycatcher habitats; 

do not broadcast spray 2,4-D within 1⁄4 mile of least Bell’s vireo, Inyo California towhee, or southwestern 

willow flycatcher habitat.

• Where feasible, avoid use of the following herbicides in least Bell’s vireo, Inyo California towhee, and 

southwestern willow flycatcher habitat: clopyralid, glyphosate, hexazinone, imazapyr, metsulfuron 

methyl, picloram, and triclopyr.

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in least Bell’s vireo or 

southwestern willow flycatcher habitat; do not broadcast spray these herbicides in areas adjacent to least 

Bell’s vireo or southwestern willow flycatcher habitat under conditions when spray drift onto the habitat 

is likely.

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in Inyo California towhee 

habitat; do not broadcast spray these herbicides in areas adjacent to Inyo California towhee habitat under 

conditions when spray drift onto the habitat is likely.

• If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to least Bell’s vireo or southwestern 

willow flycatcher habitat, apply at the typical, rather than the maximum, application rate.

• If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to Inyo California towhee habitat, 

apply at the typical, rather than the maximum, application rate.

• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in least Bell’s 

vireo, Inyo California towhee, or southwestern willow flycatcher habitat, utilize the typical, rather than 

the maximum, application rate.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

219 

Mammal Conservation Measures

Bats

In order to prevent or minimize the potential effects to bats from vegetation treatments, the following 

conservation measures should be followed:

• Prior to treatments, survey all potentially suitable habitat for the presence of bats or their nectar plants.

• At the local level, incorporate protection of lesser and Mexican long-nosed bats into management plans 

developed for proposed treatment programs.

• Instruct all field personnel on the identification of bat nectar plants and the importance of their 

protection.

• Protect nectar plants from modification by treatment activities to the greatest extent possible. Do not 

remove nectar plants during treatments. Avoid driving over plants, piling slash on top of plants, burning, 

and using domestic animals to control weeds.

• Do not burn within a mile upwind of known bat roosts.

• To protect nectar plants and roost trees from herbicide treatments, follow recommended buffer zones 

and other conservation measures for TEP plant species in areas where populations of nectar plants and 

roost trees occur.

• Do not use 2,4-D in lesser or Mexican long-nosed bat habitats; do not broadcast spray within 1⁄4 mile of 

lesser or Mexican long-nosed bat habitat.

• Where feasible, avoid use of the following herbicides in lesser and Mexican long-nosed bat habitat: 

clopyralid, glyphosate, imazapyr, metsulfuron methyl, picloram, and triclopyr.

• Do not broadcast spray clopyralid, glyphosate, picloram, or triclopyr in lesser or Mexican long-nosed bat 

habitat; do not broadcast spray these herbicides in areas adjacent to lesser or Mexican long-nosed bat 

habitat under conditions when spray drift onto the habitat is likely.

• If broadcast spraying imazapyr or metsulfuron methyl in or near lesser or Mexican long-nosed bat habitat, 

apply at the typical, rather than the maximum, application rate.

• If conducting manual spot applications of glyphosate, or triclopyr to vegetation in lesser or Mexican longnosed bat habitat, utilize the typical, rather than the maximum, application rate.

• If conducting spot treatments of herbicides in lesser or Mexican long-nosed bat habitats, avoid potential 

roost sites.

Essential Fish Habitat Conservation Measures

Conservation Measures have been incorporated into the Proposed Action and Alternative 3 to reduce negative 

effects to the point where they do not reduce the quantity or quality of essential fish habitat (EFH). For the 

purposes of developing Conservation Measures for salmon, riparian areas include traditional riparian corridors, 

wetlands, intermittent streams, and other areas that help maintain the integrity of aquatic ecosystems by 1) 

influencing the delivery of coarse sediment, organic matter, and woody debris to streams, 2) providing root 

strength for channel stability, 3) shading the stream, and 4) protecting water quality.

Activities associated with the proposed vegetation treatments would have the potential to negatively affect 

salmonids, pelagic fish and groundfish, and Alaskan crabs and scallops and their habitat. Implementation of the 

measures listed below would minimize these potential impacts to a negligible level such that the quantity and 

quality of EFH is not reduced.

General Measures

• Establish riparian, estuarine, and coastal buffer strips adjacent to salmonid, groundfish and pelagic fish, 

and Alaskan crab and scallop habitats to reduce direct impacts to the various life stages of these species. 

Buffers widths should depend on the specific ecological function for which protection is desired (e.g., 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

220

streambanks stabilization, control of sediment inputs from surface erosion, or maintenance of shade to 

stream channels). Local BLM field offices would consult BLM and Forest Service Ecological Risk 

Assessments prepared for the BA and PEIS to obtain programmatic guidance on appropriate buffer 

distances. Field offices can also input information on local site conditions (e.g., soil type, vegetation type, 

precipitation, treatment method) into interactive spreadsheets developed for the Ecological Risk 

Assessments to develop more site-specific, and in most cases less restrictive, buffers for individual 

projects.

• Implement Standard Operating Procedures to minimize sedimentation and disturbance of riparian, 

estuarine, and coastal vegetation.

• To avoid erosion and future recreational uses within close vicinity of aquatic areas, limit or exclude 

construction of new permanent or temporary roads within the boundary of treatment riparian areas.

• Where possible, to avoid increased instream sedimentation, choose low-intensity burns and manual 

treatment methods over mechanical treatment methods and use of domestic animals.

Prescribed Burning Treatments

• Where feasible, avoid ignition of fires within buffer strips.

Mechanical Treatments

• Minimize the use of mechanical treatment methods (including timber harvest and timber salvage) within 

buffer strips.

• To avoid damaging potential spawning areas, do not use mechanical equipment in perennial channels, or 

in intermittent channels with water, except at crossings that already exist. Do not use mechanical 

equipment in estuaries.

• Minimize log hauling during wet weather, and on non-paved roads.

• Minimize skidding or ground-based yarding within buffer strips.

• Do not remove large woody debris from buffer strips

Herbicide Treatments

• Where feasible, minimize spray operations around aquatic habitats to days when winds are > 10 miles per 

hour for ground applications, to avoid wind drift or direct application of herbicides into these habitats.

• Where feasible, minimize the use of terrestrial herbicides in watersheds with downgradient ponds and 

streams if potential impacts to salmonids are of concern.

• Time herbicide applications near salmonid-bearing streams, and estuaries and coastal/marine habitats 

used by salmon and FMP species so that they do not overlap with sensitive life-history stages of these fish 

(would vary at the local level). 

Biological Treatments

• In watersheds that support salmonids or that flow into watersheds where salmonids occur, to minimize 

the cumulative effect of grazing in areas that have been burned, do not conduct weed control by 

domestic animals in burned areas until they have recovered enough to control ash and sediment 

produced by the treatment.

• Prohibit livestock grazing in estuaries. 

Project Design Criteria for Listed Anadromous Fish from ARBO 

II (NMFS 2013)

Project Design Criteria established through consultation with NMFS for ARBO II are adopted as a Project Design 

Feature for federally listed fish for the analysis in this EA. The Project Design Criteria are taken from:
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

221

• National Marine Fisheries Service. 2013. Endangered Species Act – Section 7 Programmatic Consultation 

Conference and Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act 

Essential Fish Habitat Response for Reinitiation of Aquatic Restoration Activities in States of Oregon and 

Washington (ARBO II). NMFS Consultation Number: NWR-2013-9664 (NMFS 2013)

Text (in gray italics) was added to the ARBO II Project Design Criteria below for clarification purposes

1.3 Proposed Action

1.3.1 Program Administration

33. Nonnative Invasive Plant Control includes manual, mechanical, biological, and chemical methods to 

remove invasive nonnative plants within Riparian Reserves, Riparian Habitat Conservation Areas, or

equivalent and adjacent uplands. In monoculture areas (e.g., areas dominated by blackberry or knotweed)

heavy machinery can be used to help remove invasive plants. This activity is intended to improve the

composition, structure, and abundance of native riparian plant communities important for bank stability, 

stream shading, LW [large wood], and other organic inputs into streams, all of which are important 

elements to fish habitat and water quality. Manual and hand-held equipment will be used to remove

plants and disperse chemical treatments. Heavy equipment, such as bulldozers, can be used to remove

invasive plants, primarily in areas with low slope values. (Invasive plant treatments included in this 

opinion are to serve BLM, USFS [Forest Service], and BIA administrative units until such units complete a

local or provincial consultation for this activity type.)

a. Project Extent – Nonnative invasive plant control projects will not exceed 10% of acres within a

Riparian Reserve under the Northwest Forest Plan (USDA and USDI 1994b) or RHCA under

PACFISH/INFISH (USDA 1995; USDA and USDI 1995) within a 6th HUC/year.

b. Manual Methods – Manual treatments are those done with hand tools or hand held motorized 

equipment. These treatments typically involve a small group of people in a localized area. Vegetation 

disturbance varies from cutting or mowing to temporarily reduce the size and vigor of plants to 

removal of entire plants. Soil disturbance is minimized by managing group size and targeting

individual plants.

c. Mechanical Methods – Mechanical treatments involve the use of motorized equipment and vary in 

intensity and impact from mowing to total vegetation removal and soil turnover (plowing and seed 

bed preparation). Mechanical treatments reduce the number of people treating vegetation. Impacts

could be lessened by minimizing the use of heavy equipment in riparian areas, avoiding treatments 

that create bare soil in large or extensive areas, reseeding and mulching following treatments, and 

avoiding work when soils are wet and subject to compaction.

d. Biological Methods – Release of traditional host specific biological control agents (insects and 

pathogens) consists of one or two people depositing agents on target vegetation. This results in 

minimal impact to soils and vegetation from the actual release. Over time, successful biological 

control agents will reduce the size and vigor of host noxious weeds with minimal or no impact to 

other plant species.

e. Chemical Methods – Invasive plants, including state-listed noxious weeds, are particularly aggressive

and difficult to control and may require the use of herbicides for successful control and restoration of

riparian and upland areas. Herbicide treatments vary in impact to vegetation from complete removal 

to reduced vigor of specific plants. Minimal impacts to soil from compaction and erosion are

expected.

i. General Guidance

1. Use herbicides only in an integrated weed or vegetation management context where all 

treatments are considered and various methods are used individually or in concert to 

maximize the benefits while reducing undesirable effects.

2. Carefully consider herbicide impacts to fish, wildlife, non-target native plants, and other

resources when making herbicide choices.

3. Treat only the minimum area necessary for effective control. Herbicides may be 

applied by selective, hand-held, backpack, or broadcast equipment in accordance with 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

222

state and federal law and only by certified and licensed applicators to specifically target 

invasive plant species.

4. Herbicide application rates will follow label direction, unless site- specific analysis 

determines a lower maximum rate is needed to reduce non-target impacts.

5. An herbicide safety/spill response plan is required for all projects to reduce the 

likelihood of spills, misapplication, reduce potential for unsafe practices, and to take 

remedial actions in the event of spills. Spill plan contents will follow agency direction.

6. Pesticide applicator reports must be completed within 24 hours of application.

ii. Herbicide Active Ingredients – Active ingredients are restricted to the following (some common 

trade names are shown in parentheses; use of trade names does not imply endorsement by the 

US government):80

1. aminopyralid (e.g., terrestrial: Milestone VM)

2. chlorsulfuron (e.g., terrestrial: Telar, Glean, Corsair) (c) clopyralid (e.g., terrestrial: 

Transline)

3. clopyralid (e.g., terrestrial: Transline)

4. dicamba (e.g., terrestrial: Vanquish, Banvel)

5. diflufenzopyr + dicamba (e.g., terrestrial: Overdrive)

6. glyphosate (e.g., aquatic: Aquamaster, AquaPro, Rodeo, Accord) (g) imazapic (e.g., 

terrestrial: Plateau)

7. imazapic (e.g., terrestrial: Plateau)

8. imazapyr (e.g., aquatic: Habitat; terrestrial: Arsenal, Chopper)

9. metsulfuron methyl (e.g., terrestrial: Escort)

10. picloram (e.g., terrestrial: Tordon, Outpost 22K)

11. sethoxydim (e.g., terrestrial: Poast, Vantage)81

12. sulfometuron methyl (e.g., terrestrial: Oust, Oust XP)

13. triclopyr (e.g., aquatic: Garlon 3A, Tahoe 3A, Renovate 3, Element 3A; terrestrial: Garlon 

4A, Tahoe 4E, Pathfinder II)

14. 2,4-D (e.g., aquatic: 2,4-D Amine, Clean Amine; terrestrial: Weedone, Hi-Dep)

iii. Herbicide Adjuvants – When recommended by the label, an approved aquatic surfactant would

be used to improve uptake. When aquatic herbicides are required, the only surfactants and 

adjuvants permitted are those allowed for use on aquatic sites, as listed by the Washington State 

Department of Ecology: http://www.ecy.wa.gov/programs/wq/pesticides/regpesticides.html.

(Oregon Department of Agriculture also often recommends this list for aquatic site applications).

The surfactants R-11, Polyethoxylated tallow amine (POEA), and herbicides that contain POEA

(e.g., Roundup) will not be used.

iv. Herbicide Carriers – Herbicide carriers (solvents) are limited to water or specifically labeled 

vegetable oil.

v. Herbicide Mixing – Herbicides will be mixed more than 150 feet from any natural waterbody to

minimize the risk of an accidental discharge. Impervious material will be placed beneath mixing

areas in such a manner as to contain any spills associated with mixing/refilling. Spray tanks shall 

be washed further than 300 feet away from surface water. All hauling and application equipment 

shall be free from leaks and operating as intended.

vi. Herbicide Application Methods – Liquid forms of herbicides will be applied as follows:

1. Broadcast spraying using booms mounted on ground-based vehicles (this consultation 

does not include aerial applications).

2. Spot spraying with hand held nozzles attached to back pack tanks or vehicles and handpumped sprayers to apply herbicide directly onto small patches or individual plants.

 80 The use of trade, firm, or corporation names in this opinion is for the information and convenience of the action agency and 

applicants and does not constitute an official endorsement or approval by the U.S. Department of the Interior or U.S. Fish and 

Wildlife Service of any product or service to the exclusion of others that may be suitable. 81 Sethoxydim is not proposed for use in this analysis.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

223

3. Hand/selective through wicking and wiping, basal bark, frill (“hack and squirt”), stem 

injection, or cut-stump.

4. Dyes or colorants, (e.g., Hi-Light, Dynamark) will be used to assist in treatment 

assurance and minimize over-spraying within 100 feet of live water.

vii. Minimization of Herbicide Drift and Leaching – Herbicide drift and leaching will be minimized as 

follows:

1. Do not spray when wind speeds exceed 10 miles per hour to reduce the likelihood of

spray/dust drift. Winds of 2 mph or less are indicative of air inversions. The applicator

must confirm the absence of an inversion before proceeding with the application 

whenever the wind speed is 2 mph or less.

2. Be aware of wind directions and potential for herbicides to affect aquatic habitat area

downwind.

3. Keep boom or spray as low as possible to reduce wind effects. (d) Avoid or minimize

drift by utilizing appropriate equipment and settings (e.g., nozzle selection, adjusting

pressure, drift reduction agents, etc.). Select proper application equipment (e.g., spray 

equipment that produces 200-800 micron diameter droplets [Spray droplets of 100 

microns or less are most prone to drift]).

4. Follow herbicide label directions for maximum daytime temperature permitted (some

types of herbicides volatilize in hot temperatures).

5. Do not spray during periods of adverse weather conditions (snow or rain imminent, fog,

etc.). Wind and other weather data will be monitored and reported for all pesticide

applicator reports.

6. Herbicides shall not be applied when the soil is saturated or when a precipitation event 

likely to produce direct runoff to fish-bearing waters from a treated site is forecasted by

NOAA National Weather Service or other similar forecasting service within 48 hours 

following application. Soil-activated herbicides can be applied as long as label is 

followed. Do not conduct any applications during periods of heavy rainfall.

viii. Herbicide buffer distances – The following no-application buffers— which are measured in feet 

and are based on herbicide formula, stream type, and application method—will be observed 

during herbicide applications (Table 4). Herbicide applications based on a combination of 

approved herbicides will use the most conservative buffer for any herbicide included. Buffer

widths are measured as map distance perpendicular to the bankfull for streams, the upland 

boundary for wetlands, or the upper bank for roadside ditches.

Table 4. No-application buffer widths1 in feet for herbicide application, by stream types and application methods.

Herbicide

Perennial Streams and Wetlands, and 

Intermittent Streams and Roadside Ditches 

with flowing or standing water present

Dry Intermittent Streams, Dry Intermittent 

Wetlands, Dry Roadside Ditches

Broadcast 

Spraying

Spot 

Spraying Hand Selective Broadcast Spraying

Spot 

Spraying Hand Selective

Labeled for Aquatic Use

Aquatic Glyphosate 100 waterline waterline 50 0 0

Aquatic Imazapyr 100 waterline waterline 50 0 0

Aquatic Triclopyr-TEA Not 

Allowed 15 waterline Not Allowed 0 0

Aquatic 2,4-D (amine) 100 waterline waterline 50 0 0

Low Risk to Aquatic Organisms

Aminopyralid 100 waterline waterline 50 0 0

Dicamba 100 15 15 50 0 0

Dicamba + diflufenzopyr 100 15 15 50 0 0

Imazapic 100 15 bankfull elevation 50 0 0

Clopyralid 100 15 bankfull elevation 50 0 0

Metsulfuron methyl 100 15 bankfull elevation 50 0 0
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

224

Herbicide

Perennial Streams and Wetlands, and 

Intermittent Streams and Roadside Ditches 

with flowing or standing water present

Dry Intermittent Streams, Dry Intermittent 

Wetlands, Dry Roadside Ditches

Broadcast 

Spraying

Spot 

Spraying Hand Selective Broadcast Spraying

Spot 

Spraying Hand Selective

Moderate Risk to Aquatic Organisms

Imazapyr 100 50 bankfull elevation 50 15 bankfull elevation

Sulfometuron-methyl 100 50 5 50 15 bankfull elevation

Chlorsulfuron 100 50 bankfull elevation 50 15 bankfull elevation

High Risk to Aquatic Organisms

Triclopyr-BEE Not 

Allowed 150 150 Not Allowed 150 150

Picloram 100 50 50 100 50 50

Sethoxydim1 100 50 50 100 50 50

2,4-D (ester) 100 50 50 100 50 50

Project Design Criteria for Listed Plants from ARBO II (USDI 

2013a)

Project Design Criteria established through consultation with U.S. Fish and Wildlife Service for ARBO II are adopted 

as a Project Design Feature for federally listed fish for the analysis in this EA. The Project Design Criteria are taken 

from:

• USDI Fish and Wildlife Service. 2013. Endangered Species Act - Section 7 Consultation Programmatic 

Biological Opinion for Aquatic Restoration Activities in the States of Oregon, Washington and portions of 

California, Idaho and Nevada (ARBO II)

1.4 General Conservation Measures and Project Design Criteria for All Terrestrial and Fish Species

1.4.3. Plants: For threatened or endangered plant species that may occur in project areas within the scope of 

this ARBO II, the following criteria will be applied:

a. All Listed Plant Species

• PL1: A unit botanist will have the following input in all project designs: (a) the botanist will determine 

whether there are known listed plants or suitable habitat for listed plants in the project area; (b) If a 

known site of a listed plant is within 0.25-mile of the project action area, or that suitable or potential 

habitat may be affected by project activities, then a botanist will conduct a site visit/vegetation survey to 

determine whether listed plants are within the project area. This visit and survey will be conducted at the 

appropriate time of year to identify the species and determine whether individual listed plants or 

potential habitat are present and may be adversely affected by project activities (see Table 8).

• PL2: If one or more listed plants are present and likely to be adversely affected by the project, then the 

project is not covered by this BO and consultation with the FWS under Section 7 of the ESA must be 

initiated. If a project will have no effect or is NLAA listed plants it is covered under this ARBA II. Project 

design criteria should address both the critical life cycle of listed plant species as well as the effective 

biotic and abiotic environmental factors sustaining rare plant taxa.

• PL3: Due to soil disturbance that may occur during aquatic restoration activities and use of heavy 

equipment that could carry seeds and plant parts into project areas, all appropriate prevention measures 

will be incorporated into contract or equipment rental agreements to avoid introduction of invasive plants 

and noxious weeds into project areas.

Table 8. Optimal Survey Times for Flowering Periods of Listed Plants in Oregon and Washington

Species Optimal Survey Time Period1

Western lily June to July

1. This is a guideline. The local botanist will survey when the time is appropriate.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

225 

Reasonable and Prudent Measures and Terms and Conditions 

for Western Snowy Plover at New River and North Spit

Taken from the Biological Opinions associated with the Management of the Western Snowy Plover on Federal 

Lands Within the New River Area of Critical Environmental Concern during the 2011-2021 Nesting and Wintering 

Seasons (USDI 2011) and the Biological Assessment of the BLM’s North Spit Plan as it may affect the Threatened 

Western Snowy Plover and its Critical Habitat (USDI 2007e). Some terms and conditions are specific to either the 

North Spit or New River area and these are indicated by (North Spit) and (New River). 

A. Reasonable and Prudent Measures

The Service believes the following reasonable and prudent measures are necessary and appropriate to minimize 

take of western snowy plovers:

1. Avoid disturbance and minimize potential loss of nests or nesting plovers.

2. Reduce impacts on foraging and resting plovers and broods.

3. Maintain productivity of at least 1 fledged chick per male over three consecutive years.

B. Terms and Conditions

In order to be exempt from the prohibitions of section 9 of the Act, the BLM must comply with the following terms 

and conditions, which implement the reasonable and prudent measures described above and outline required 

reporting/monitoring requirements. These terms and conditions are non-discretionary.

1. Avoid disturbance and minimize potential loss of nests or nesting plovers:

a. Ensure efforts to manage recreation are enforced and effective:

i. Work with OPRD to reduce dog and vehicle violations on the New River ACEC (New River) / South 

Beach (North Spit) during the nesting season.

ii. Ensure staff, including law enforcement officers and volunteers that patrol beaches, are trained 

in plover biology and required measures to reduce potential harm or disturbance to plovers. In 

addition, ensure plover monitors and law enforcement officers participate in coordinated law 

enforcement/plover training and coordination meetings when available (e.g., workshops, 

refresher courses, video training).

iii. Compliance Monitors/Interpretive Specialists shall continue to inform law enforcement 

personnel about the location of plover nests and activities. Officers should focus their attention 

and time on areas where and periods when plovers may be particularly vulnerable.

iv. Continue to work with the plover working group to improve signage and resolve law 

enforcement issues.

b. Monitor and evaluate compliance of recreation:

i. Monitor compliance with recreational restrictions and continue to collect data on standardized 

forms for comparison between years.

ii. Reduce impacts to plovers by using visitor compliance data (i.e., number or percent of violations 

relative to number of people/dogs during the course of the breeding season) during the season 

to strategically target areas that are a concern for public education and enforcement; and

iii. Ensure nests outside roped areas are protected. Either rope and sign the exposed nest, or 

contact the Service immediately to determine if any protection strategy is necessary.

2. Reduce impacts on foraging and resting plovers and broods:

a. Disseminate information about the restrictions prior to 15 March of each year over the term of the 

proposed action.

b. Continue to conduct public outreach during compliance patrols.

c. Implement strategies for minimizing disturbance by targeting days and hours when disturbance and 

violations are most likely to occur, and by providing a Law Enforcement or Compliance Monitoring 

presence during those times. (North Spit)

3. Maintain productivity of at least 1.0 fledged chick per male over three consecutive years (New River): 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix A – Protection Measures

226

a. Based on the productivity data observed at New River (see pp. 33-35), the breeding population will 

maintain a mean hatch rate of at least 49 percent and a fledging success rate of at least 39 percent 

over three consecutive years at New River ACEC (i.e., the lower confidence interval calculated for the 

mean hatch and fledge rates over 2002-2010).

b. Conduct or fund annual monitoring on BLM lands on the New River ACEC, that measures productivity 

in the following ways: hatch rate, fledging success rate, number of breeding adults, and number of 

fledged chicks per male. This project produces data essential to plover recovery efforts, management 

actions, and assessment of productivity and take of the western snowy plover.

c. Participate in annual predator management action planning for plover areas.

d. Manage predators of the western snowy plover on the New River ACEC.

e. Continue to implement habitat restoration, maintenance, and breaching activities as described in Fish 

and Wildlife Service (2008) and the New River Health EA OR 128-03-11.

(New River): By December 31 of each year, provide an annual written report to the Service detailing the extent and 

effectiveness of habitat maintenance/restoration activities, the location and extent of habitat protection measures 

(i.e., ropes and signs), public education efforts conducted, and the results of compliance monitoring. In order to 

evaluate plover productivity, visitor use along the Oregon Coast Trail, and violations in plover and non-plover 

areas, please include the following in your report:

1. The three-year mean rate for hatch success, fledging success, and number of fledged chicks per 

male at New River ACEC, along with an explanation of why goals were or were not met; 

2. 2. The location of compliance monitoring and law enforcement efforts (i.e., New River HRAs, CMA, 

Floras Lake to CMA, etc.) and associated statistics for each area; and

3. 3. Continue to provide an estimate of the number of hikers/backpackers (registered and 

unregisters) using the Oregon Coast Trail within the New River ACEC

3. Maintain snowy plover productivity at nesting areas: (North Spit) 

a. Fund annual monitoring on BLM lands at CBNS, conducted by the Oregon Natural Heritage 

Information Center and cooperatively funded by State and Federal agencies. This project produces 

data essential to plover recovery efforts, management actions, and assessment of productivity and 

take of the western snowy plover. 

b. Participate in the development of predator action planning annually. 

c. Manage predators of the western snowy plover on BLM lands at CBNS. 

d. By December 31 of each year, provide an annual written report to the Service detailing the extent 

and effectiveness of habitat maintenance/restoration activities, the location and extent of habitat 

protection measures (i.e., ropes and signs), public education efforts conducted, and the results of 

compliance monitoring. 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

227

Appendix B – The Herbicides, 

Formulations, and Adjuvants

The Herbicides - The herbicides proposed for use in Oregon are a subset of the hundreds of herbicides registered 

for use in the U.S. They were chosen by the BLM nationally for maximum effectiveness against wildland weeds and 

least environmental and non-target species’ risks. Table 2-5 in Chapter 2 shows the herbicides with some sample 

trade names, common plant targets, plant types it is selective for, how it is used, land types it is registered for, and

typical and maximum rates. Table B-1, General Constraints from Herbicide Labels, supplements the Table 2-5 

information by listing a summary of general label constraints.

Herbicides can be categorized as selective or non-selective (see Table 2-5). Selective herbicides kill only a specific 

type of plant. For example, an herbicide selective for broadleaved plants can be used to manage such species while 

maintaining desirable grass species in rangeland communities. Non-selective herbicides kill all types of plants, and 

thus must be applied only to the target species. Herbicides can be used selectively to control specific types of 

vegetation (e.g., killing a specific invasive plant species), or non-selectively in monocultures of invasive plants 

where there is no objective to retain some plants. Some herbicides are post-emergent, which means they can be 

used to kill existing vegetation; others are pre-emergent, which stops vegetation before it grows (e.g., prohibiting 

seeds from germinating) (Table 2-5).

Herbicides are classified as either “general use” or “restricted use” by the EPA. Restricted use means that a 

product, or its uses, may have higher risks of adverse effects and thus can only be used by a certificated pesticide 

applicator with the appropriate training or under the direct supervision of a certified applicator (defined in 40 CFR 

152.175). A license is required to purchase and apply the product and the label on the herbicide must clearly state 

that it is a “Restricted Use Pesticide.” A general use pesticide, when applied in accordance with its directions for 

use, will generally not cause unreasonable adverse effects to humans or the environment, and thus is not 

restricted to certified applicators. They can be purchased and used by the public. Picloram is the only restricted use 

herbicide analyzed in this EA.

Table B-2, Herbicide Formulations Approved for use on BLM-Administered Lands, displays the BLM national list of 

approved herbicides, which is reviewed and updated at least annually. This list identifies herbicides that are known 

to be consistent with the formulations analyzed in the Risk Assessments (see Appendix C) and otherwise suitable 

for wildland use.

Table B-3, Adjuvants Approved for Use on BLM Administered Lands, displays the adjuvants approved for use on 

BLM-administered lands nationally. This list is also reviewed at least annually. This list identifies adjuvants that are 

known to be consistent with the formulations analyzed in the Risk Assessments (see Appendix C) and are known 

not to contain R-11, POEA, petroleum, and other products prohibited by Mitigation Measures (see Appendix A), or 

that are otherwise considered unsuitable for wildland use. Table B-3 also identifies those adjuvants identified by 

the National Marine Fisheries Service and U.S. Fish and Wildlife Service in their 2013 Biological Opinion for Fish 

Habitat Restoration Activities Affecting ESA-listed Animal and Plant Species and their Designated Critical Habitat 

found in Oregon, Washington and parts of California, Idaho and Nevada (USDI 2013a, NMFS 2013) as appropriate 

for use near streams with listed fish. These adjuvants are designated under the column “ARBO II,” for the second 

programmatic Aquatic Restoration Biological Opinion.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

228

Table B-1. General Constraints from Herbicide Labels

Herbicides General Constraints from Labels

(follow all label requirements)

2,4-D

• Some formulations are toxic to aquatic invertebrates.

• Only use approved formulations for streamside and aquatic applications.

• Drift or runoff from terrestrial applications may adversely affect aquatic invertebrates and non-target plants.

• For terrestrial uses, do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water 

mark. Do not contaminate water when disposing of equipment washwaters.

Aminopyralid

• After grazing aminopyralid-treated forage, livestock must graze for 3 days in an untreated pasture without desirable broadleaf plants before 

returning to an area where desirable broadleaf plants are present.

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Do not contaminate water when disposing of equipment wash-water or rinsate.

• Do not treat inside banks or bottoms of irrigation ditches, either dry or containing water, or other channels that carry water that may be used 

for irrigation or domestic purposes.

Chlorsulfuron 

• Do not apply more than 1.33 oz/acre per year in pasture, range, and Conservation Reserve Program treatments.

• Do not treat frozen soil.

• Applications to powdery, dry soil when there is low likelihood of rain soon may result in off-site damage by wind-borne soil particles.

Clopyralid

• Do not apply where soils have a rapid to very rapid permeability close to aquifers.

• Do not contaminate irrigation ditches or water used for irrigation or domestic uses.

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Do not contaminate water when disposing of equipment wash-water.

• Avoid spray drift.

• After grazing clopyralid-treated forage, livestock must graze for 3 days in an untreated pasture without desirable broadleaf plants before 

returning to an area where desirable broadleaf plants are present.

• Do not use plant residues, including hay or straw from treated areas, or manure or bedding straw from animals that have grazed or consumed 

forage from treated areas, for composting or mulching, where susceptible plants may be grown the following season.

• Do not spread manure from animals that have grazed or consumed forage or hay from treated areas on land used for growing susceptible 

broadleaf crops, ornamentals, orchards, or other susceptible desirable plants.

Dicamba

• To prevent point source contamination, do not mix or load this pesticide within 50 feet of wells (including abandoned wells and drainage 

wells), sink holes, perennial or intermittent streams and rivers, and natural or impounded lakes and reservoirs. Do not apply this pesticide 

within 50 feet of wells.

• Do not apply under conditions that favor runoff. Do not apply to impervious substrates such as paved or highly compacted surfaces in areas 

with high potential for ground water contamination. Ground water contamination may occur in areas where soils are permeable or coarse and 

ground water is near the surface.

Dicamba + 

Diflufenzopyr

• Do not load, mix, or apply within 50 feet of wells.

• Do not apply directly to water, where surface water is present, or to intertidal areas. Do not contaminate water when disposing of equipment 

washwaters.

• Do not apply to impervious substrates or under conditions that favor runoff. Do not apply to soils that classify as sand.

• Be cognizant of leaching where soils are permeable or where water table is shallow.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

229

Herbicides General Constraints from Labels

(follow all label requirements)

Fluroxypyr

• Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark.

• Do not contaminate water when cleaning equipment or disposing of equipment washwaters.

• Do not apply where drift may be a problem due to proximity to susceptible crops or other non-target broadleaf plants.

Glyphosate

• Only use approved aquatic formulations for aquatic applications.

• Do not contaminate water when cleaning equipment or disposing of equipment washwaters.

• Treatment of aquatic weeds can result in oxygen depletion or loss due to decomposition of plants that can cause fish suffocation.

• This is a non-selective herbicide.

• Avoid drift.

Hexazinone

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not 

contaminate water when disposing of equipment wash-water.

• Use care where soils are permeable to avoid groundwater contamination.

• Will kill grasses.

Imazapic 

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Do not contaminate water when disposing of equipment wash-water.

• To reduce run-off, avoid applications when rain is forecast w/in 48 hours.

Imazapyr

• Aquatic applications (with approved products) can only be made within the restrictions outlined on the label.

• Otherwise, do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Do not contaminate water when disposing of equipment wash-water.

Metsulfuron 

methyl

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Do not contaminate water when disposing of equipment wash-water.

• This herbicide is injurious to plants at extremely low concentrations. Non-target plants may be adversely affected from drift and run-off.

Picloram

• Do not use manure from animals grazing treated areas or feeding on treated hay on land used for growing broadleaf crops, ornamentals, 

orchards or other susceptible, desirable plants. Manure may contain enough picloram to cause injury to susceptible plants.

• Do not use grass or hay from treated areas for composting or mulching of susceptible broadleaf plants or crops.

• Do not transfer livestock from treated grazing areas (or feeding of treated hay) onto sensitive broadleaf crop areas without first allowing 7 days 

of grazing on an untreated grass pasture (or feeding of untreated hay). Otherwise, urine and manure may contain enough picloram to cause 

injury to sensitive broadleaf plants.

• Restricted use. May injure susceptible, non-target plants. This herbicide is injurious to plants at extremely low concentrations. Non-target 

plants may be adversely affected from drift and run-off.

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Do not make application when circumstances favor movement from treatment site. Do not contaminate water or water sources when mixing, 

loading, or disposing of equipment wash-water.

• May leach thru soil and contaminate ground water where soils are permeable, particularly where water table is shallow.

• Do not apply within the root zone of desirable trees unless such injury can be tolerated.

Rimsulfuron

• Do not graze treated sites or cut for forage or hay for a minimum of 1 year after application in order to allow newly emerged grasses sufficient 

time to become established.

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Do not contaminate water by cleaning of equipment or disposal of equipment washwaters or rinsate.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

230

Herbicides General Constraints from Labels

(follow all label requirements)

• Rainfall or irrigation is needed for herbicide activation.

Sulfometuron 

methyl 

• Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not 

contaminate water when disposing of equipment wash-water.

• Applications to powdery, dry soil when there is low likelihood of rain soon may result in off-site damage by wind-borne soil particles.

• Do not treat frozen soil.

• Do not apply in or on irrigation ditches or canals, including their outer banks.

Triclopyr

• Treatment of aquatic weeds can result in oxygen depletion or loss due to decomposition of plants in certain situations, which can cause fish 

suffocation.

• Certain approved products can be used in and around standing water sites. Minimize overspray to open water (streams, lakes, etc.) when 

treating vegetation growing at water edge. Do not contaminate water when disposing of equipment wash-water.

Herbicides analyzed for Research and Demonstration

Fluazifop-P-butyl

• This product is toxic to fish and aquatic invertebrates. Do not apply to areas where runoff into water bodies is expected.

• Do not apply when weather conditions favor drift from target areas.

• Do not apply directly to water, to areas where surface water is present, or to intertidal areas below the mean high water mark.

• Fluazifop-P-butyl is known to leach through soil into ground water under certain conditions as a result of label use. This chemical may leach 

into ground water if used in areas where soils are permeable, particularly where the water table is shallow.

• This product may impact surface water quality due to runoff of rain water. This is especially true for poorly draining soils and soils with shallow 

ground water.

• This product is classified as having high potential for reaching surface water via runoff for several months or more after application. A level, 

welI-maintained vegetative buffer strip between areas to which this product is applied and surface water features such as ponds, streams, and 

springs will reduce the potential loading of fluazifop-P-butyl from runoff water and sediment. Runoff of this product will be reduced by 

avoiding applications when rainfall is forecasted to occur within 48 hours.

• Do not treat areas while unprotected humans or domestic animals are present in the treatment areas. Do not allow entry into treated areas 

without protective clothing until sprays have dried.

• Do not apply if rainfall is expected within 1 hour.

• Do not use flood type or other spray nozzle tips that deliver coarse, large droplet sprays.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

231

Table B-2. Herbicide Formulations Approved for Use on BLM-Administered Lands1

Active Ingredient Trade Name Manufacturer EPA Registration 

Number

2,4-D 2,4-D 4# Amine Weed Killer UAP-Platte Chem. Co. 34704-120

2,4-D 2,4-D Amine Helena Chemical Company 5905-72

2,4-D 2,4-D Amine Setre (Helena) 5905-72

2,4-D 2,4-D Amine 4 Albaugh, Inc./Agri Star 42750-19

2,4-D 2,4-D Amine 4 Helena Chemical Company 42750-19-5905

2,4-D 2,4-D LV 4 Albaugh, Inc./Agri Star 42750-15

2,4-D 2,4-D LV4 Setre (Helena) 5905-90

2,4-D 2,4-D LV 6 Albaugh, Inc./Agri Star 42750-20

2,4-D 2,4-D LV6 Helena Chemical Company 4275-20-5905

2,4-D 2,4-D LV6 Setre (Helena) 5905-93

2,4-D 2,4-D LV 6 Ester Nufarm Americas Inc. 228-95

2,4-D Agrisolution 2,4-D Amine 4 Agriliance, LLC 1381-103

2,4-D Agrisolution 2,4-D Amine 4 Winflied Solutions, LLC 1381-103

2,4-D Agrisolution 2,4-D LV4 Agriliance, LLC 1381-102

2,4-D Agrisolution 2,4-D LV4 Winflied Solutions, LLC 1381-102

2,4-D Agrisolution 2,4-D LV6 Agriliance, LLC 1381-101

2,4-D Agrisolution 2,4-D LV6 Winflied Solutions, LLC 1381-101

2,4-D Alligare 2,4-D Amine Alligare, LLC 81927-38

2,4-D Alligare 2,4-D LV 6 Alligare, LLC 81927-39

2,4-D Amine 4 Wilbur-Ellis Co. 2935-512

2,4-D Aqua-Kleen Nufarm Americas Inc. 228-378

2,4-D Aqua-Kleen Nufarm Americas Inc. 71368-4

2,4-D Barrage HF Helena Chemical Company 5905-529

2,4-D Barrage LV Ester Setre (Helena) 5905-504

2,4-D Base Camp Amine 4 Wilbur-Ellis Co. 71368-1-2935

2,4-D Base Camp LV6 Wilbur-Ellis Co. 2935-553

2,4-D Broadrange 55 Wilbur-Ellis Co. 2217-813-2935

2,4-D Clean Amine Loveland Products, Inc. 34704-120

2,4-D Clean Crop Amine 4 UAP-Platte Chem. Co. 34704-5 CA

2,4-D Clean Crop Low Vol 6 Ester UAP-Platte Chem. Co. 34704-125

2,4-D Clean Crop LV-4 ES UAP-Platte Chem. Co. 34704-124

2,4-D Cornbelt 4 lb. Amine Van Diest Supply Co. 11773-2

2,4-D Cornbelt 4# LoVol Ester Van Diest Supply Co. 11773-3

2,4-D Cornbelt 6# LoVol Ester Van Diest Supply Co. 11773-4

2,4-D D-638 Albaugh, Inc./Agri Star 42750-36

2,4-D De-Amine 4 Drexel Chemical Company 19713-650

2,4-D De-Amine 6 Drexel Chemical Company 19713-651

2,4-D De-Ester LV4 Drexel Chemical Company 19713-345

2,4-D De-Ester LV6 Drexel Chemical Company 19713-655

2,4-D Esteron 99C Nufarm Americas Inc. 62719-9-71368

2,4-D Five Star Albaugh, Inc./Agri Star 42750-49

2,4-D Formula 40 Nufarm Americas Inc. 228-357

2,4-D HardBall Helena Chemical Company 5905-549

2,4-D Hi-Dep PBI/Gordon Corporation 2217-703

2,4-D Lo Vol-4 Wilbur-Ellis Co. 228-139-2935

2,4-D Low Vol 4 Ester Weed Killer Loveland Products, Inc. 34704-124

2,4-D Lo Vol-6 Ester Wilbur-Ellis Co. 228-95-2935

2,4-D Low Vol 6 Ester Weed Killer Loveland Products, Inc. 34704-125

2,4-D Opti-Amine Helena Chemical Company 5905-501

2,4-D Phenoxy 088 Winfield Solutions, LLC 42750-36-9779

2,4-D Platoon Nufarm Americas Inc. 228-145

2,4-D Rugged Winfield Solutions, LLC 1381-247

2,4-D Saber Loveland Products, Inc. 34704-803
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

232

Active Ingredient Trade Name Manufacturer EPA Registration 

Number

2,4-D Salvo Loveland Products, Inc. 34704-609

2,4-D Salvo LV Ester UAP-Platte Chem. Co. 34704-609

2,4-D Savage DS Loveland Products, Inc. 34704-606

2,4-D Savage DS UAP-Platte Chem. Co. 34704-606

2,4-D Shredder 2,4-D LV4 Winfield Solutions, LLC 1381-102

2,4-D Shredder Amine 4 Winfield Solutions, LLC 1381-103

2,4-D Shredder E-99 Winfield Solutions, LLC 1381-195

2,4-D Solution Water Soluble Nufarm Americas Inc. 228-260

2,4-D Solve 2,4-D Albaugh, Inc./Agri Star 42750-22

2,4-D Unison Helena Chemical Company 5905-542

2,4-D Weedar 64 Nufarm Americas Inc. 71368-1

2,4-D WEEDestroy AM-40 Nufarm Americas Inc. 228-145

2,4-D Weedone LV-4 Nufarm Americas Inc. 228-139-71368

2,4-D Weedone LV-4 Solventless Nufarm Americas Inc. 71368-14

2,4-D Weedone LV-6 Nufarm Americas Inc. 71368-11

2,4-D Whiteout 2,4-D Loveland Products, Inc. 34704-1032

Aminopyralid Milestone Dow AgroSciences 62719-519

Aminopyralid + Metsulfuron 

Methyl Chaparral Dow AgroSciences 62719-597

Aminopyralid + Metsulfuron 

Methyl Opensight Dow AgroSciences 62719-597

Chlorsulfuron Alligare Chlorsulfuron Alligare, LLC 81927-43

Chlorsulfuron Chlorsulfuron 75 Alligare, LLC 81927-43

Chlorsulfuron Chlorsulfuron E-Pro 75 WDG Nufarm Americas Inc. 79676-72

Chlorsulfuron Nufarm Chlorsulf SPC 75 WDG 

Herbicide Nufarm Americas Inc. 228-672

Chlorsulfuron Telar DF DuPont Crop Protection 352-522

Chlorsulfuron Telar XP Bayer Environmental Science 432-1561

Chlorsulfuron Telar XP DuPont Crop Protection 352-654

Clopyralid CleanSlate Nufarm Americas Inc. 228-491

Clopyralid Clopyralid 3 Alligare, LLC 42750-94-81927

Clopyralid Clopyralid 3 Alligare, LLC 81927-14

Clopyralid Pyramid R&P Albaugh, Inc. 42750-94

Clopyralid Reclaim Dow AgroSciences 62719-83

Clopyralid Spur Albaugh, Inc. 42750-89

Clopyralid Stinger Dow AgroSciences 62719-73

Clopyralid Transline Dow AgroSciences 62719-259

Clopyralid + 2,4-D Cody Herbicide Alligare, LLC 81927-28

Clopyralid + 2,4-D Commando Albaugh, Inc. 42750-92

Clopyralid + 2,4-D Curtail Dow AgroSciences 62719-48

Clopyralid + 2,4-D Cutback Nufarm Americas Inc. 71368-72

Dicamba Banvel Arysta LifeScience N.A. Corp. 66330-276

Dicamba Banvel Micro Flo Company 51036-289

Dicamba Clarity BASF Corporation 7969-137

Dicamba Cruise Control Alligare, LLC 42750-40-81927

Dicamba Diablo Nufarm Americas Inc. 228-379

Dicamba Dicamba DMA Albaugh, Inc./Agri Star 42750-40

Dicamba Kam-Ba Drexel Chemical Company 19713-624

Dicamba Rifle Loveland Products, Inc. 34704-861

Dicamba Sterling Blue Winfield Solutions, LLC 7969-137-1381

Dicamba Vanquish Syngenta Professional Products 100-884

Dicamba Vanquish Herbicide Nufarm Americas Inc. 228-397

Dicamba Vision Albaugh, Inc. 42750-98

Dicamba Vision Helena Chemical Company 5905-576
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

233

Active Ingredient Trade Name Manufacturer EPA Registration 

Number

Dicamba + 2,4-D Brash Winfield Solutions, LLC 1381-202

Dicamba + 2,4-D Brush-Rhap Helena Chemical Company 5905-568

Dicamba + 2,4-D Dicamba + 2,4-D DMA Alligare, LLC 81927-42

Dicamba + 2,4-D KambaMaster Nufarm Americas Inc. 71368-34

Dicamba + 2,4-D Latigo Helena Chemical Company 5905-564

Dicamba + 2,4-D Outlaw Helena Chemical Company 5905-574

Dicamba + 2,4-D Range Star Albaugh, Inc./Agri Star 42750-55

Dicamba + 2,4-D Rifle-D Loveland Products, Inc. 34704-869

Dicamba + 2,4-D Weedmaster BASF Ag. Products 7969-133

Dicamba + 2,4-D Weedmaster Nufarm Americas Inc. 71368-34

Dicamba + 2,4-D Veteran 720 Nufarm Americas Inc. 228-295

Dicamba + Diflufenzopyr Distinct BASF Corporation 7969-150

Dicamba + Diflufenzopyr Overdrive BASF Corporation 7969-150

Fluroxypyr Alligare Fluroxypyr Alligare, LLC 66330-385-81927

Fluroxypyr Comet Selective Nufarm Americas Inc. 71368-87

Fluroxypyr Vista XRT Dow AgroSciences 62719-586

Glyphosate Accord Concentrate Dow AgroSciences 62719-324

Glyphosate Accord SP Dow AgroSciences 62719-322

Glyphosate Accord XRT Dow AgroSciences 62719-517

Glyphosate Accord XRT II Dow AgroSciences 62719-556

Glyphosate Agrisolutions Cornerstone Winfield Solutions, LLC 1381-191

Glyphosate Agrisolutions Cornerstone 5 Plus Winfield Solutions, LLC 1381-241

Glyphosate Agrisolutions Cornerstone Plus Winfield Solutions, LLC 1381-192

Glyphosate Agrisolutions Rascal Winfield Solutions, LLC 1381-191

Glyphosate Agrisolutions Rascal Plus Winfield Solutions, LLC 1381-192

Glyphosate Aqua Neat Nufarm Americas Inc. 228-365

Glyphosate Aqua Star Albaugh, Inc./Agri Star 42750-59

Glyphosate Aquamaster Monsanto 524-343

Glyphosate AquaPro Aquatic Herbicide SePRO Corporation 62719-324-67690

Glyphosate Buccaneer Tenkoz 55467-10

Glyphosate Buccaneer Plus Tenkoz 55467-9

Glyphosate ClearOut 41 Plus Chem. Prod. Tech., LLC 70829-3

Glyphosate Credit Xtreme Nufarm Americas Inc. 71368-81

Glyphosate Foresters Nufarm Americas Inc. 228-381

Glyphosate Forest Star Albaugh, Inc./Agri Star 42570-61

Glyphosate Four Power Plus Loveland Products, Inc. 34704-890

Glyphosate Gly Star Gold Albaugh, Inc./Agri Star 42750-61

Glyphosate Gly Star Original Albaugh, Inc./Agri Star 42750-60

Glyphosate Gly Star Plus Albaugh, Inc./Agri Star 42750-61

Glyphosate Gly Star Pro Albaugh, Inc./Agri Star 42750-61

Glyphosate Gly-4 Universal Crop Protection 

Alliance, LLC 42750-60-72693

Glyphosate Gly-4 Plus Universal Crop Protection 

Alliance, LLC 72693-1

Glyphosate Gly-4 Plus Universal Crop Protection 

Alliance, LLC 42750-61-72693

Glyphosate Glyfos Cheminova 4787-31

Glyphosate Glyfos Aquatic Cheminova 4787-34

Glyphosate Glyfos PRO Cheminova 67760-57

Glyphosate GlyphoMate 41 PBI/Gordon Corporation 2217-847

Glyphosate Glyphosate 4 Vegetation Man., LLC 73220-6-74477

Glyphosate Glyphosate 4 + Alligare, LLC 81927-9

Glyphosate Glyphosate 4 PLUS Alligare, LLC 81927-9

Glyphosate Glyphosate 5.4 Alligare, LLC 81927-8
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

234

Active Ingredient Trade Name Manufacturer EPA Registration 

Number

Glyphosate Glypro Dow AgroSciences 62719-324

Glyphosate Glypro Plus Dow AgroSciences 62719-322

Glyphosate Honcho Monsanto 524-445

Glyphosate Honcho Plus Monsanto 524-454

Glyphosate Imitator 25% Concentration Drexel Chemical Company 19713-628

Glyphosate Imitator Aquatic Drexel Chemical Company 19713-623

Glyphosate Imitator DA Drexel Chemical Company 19713-586

Glyphosate Imitator Plus Drexel Chemical Company 19713-526

Glyphosate Imitator RTU Drexel Chemical Company 19713-607

Glyphosate KleenUp Pro Loveland Products, Inc. 34704-890

Glyphosate Mad Dog Plus Loveland Products, Inc. 34704-890

Glyphosate Makaze Loveland Products, Inc. 34704-890

Glyphosate Mirage Loveland Products, Inc. 34704-889

Glyphosate Mirage Herbicide UAP-Platte Chem. Co. 524-445-34704

Glyphosate Mirage Plus Loveland Products, Inc. 34704-890

Glyphosate Mirage Plus Herbicide UAP-Platte Chem. Co. 524-454-34704

Glyphosate Rattler Setre (Helena) 524-445-5905

Glyphosate Razor Nufarm Americas Inc. 228-366

Glyphosate Razor Pro Nufarm Americas Inc. 228-366

Glyphosate Rodeo Dow AgroSciences 62719-324

Glyphosate Roundup Custom Monsanto 524-343

Glyphosate Roundup Original Monsanto 524-445

Glyphosate Roundup Original II Monsanto 524-454

Glyphosate Roundup Original II CA Monsanto 524-475

Glyphosate Roundup PRO Monsanto 524-475

Glyphosate Roundup PRO Concentrate Monsanto 524-529

Glyphosate Roundup PRO Dry Monsanto 524-505

Glyphosate Roundup PROMAX Monsanto 524-579

Glyphosate Showdown Helena Chemical Company 71368-25-5905

Glyphosate + 2,4-D Campaign Monsanto 524-351

Glyphosate + 2,4-D Imitator Plus D Drexel Chemical Company 19713-635

Glyphosate + 2,4-D Landmaster BW Albaugh, Inc./Agri Star 42570-62

Glyphosate + 2,4-D Landmaster BW Monsanto 524-351

Hexazinone Pronone 10G Pro-Serve 33560-21

Hexazinone Pronone 25G Pro-Serve 33560-45

Hexazinone Pronone MG Pro-Serve 33560-21

Hexazinone Pronone Power Pellet Pro-Serve 33560-41

Hexazinone Velossa Helena Chemical Company 5905-579

Hexazinone Velpar DF DuPont Crop Protection 352-581

Hexazinone Velpar DF VU Bayer Environmental Science 432-1576

Hexazinone Velpar L DuPont Crop Protection 352-392

Hexazinone Velpar L VU Bayer Environmental Science 432-1573

Hexazinone Velpar ULW DuPont Crop Protection 352-450

Hexazinone + Sulfometuron 

methyl Oustar Bayer Environmental Science 432-1553

Hexazinone + Sulfometuron 

methyl Oustar DuPont Crop Protection 352-603

Hexazinone + Sulfometuron 

methyl Westar Bayer Environmental Science 432-1558

Hexazinone + Sulfometuron 

methyl Westar DuPont Crop Protection 352-626

Imazapic Nufarm Imazapic 2SL Nufarm Americas Inc. 71368-99

Imazapic Panoramic 2SL Alligare, LLC 66222-141-81927

Imazapic Plateau BASF 241-365
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

235

Active Ingredient Trade Name Manufacturer EPA Registration 

Number

Imazapic + Glyphosate Journey BASF 241-417

Imazapyr Arsenal BASF 241-346

Imazapyr Arsenal Applicators Conc. BASF 241-299

Imazapyr Arsenal PowerLine BASF 241-431

Imazapyr Arsenal Railroad Herbicide BASF 241-273

Imazapyr Chopper BASF 241-296

Imazapyr Ecomazapyr 2SL Alligare, LLC 81927-22

Imazapyr Ecomazapyr 2 SL Vegetation Man., LLC 74477-6

Imazapyr Habitat BASF 241-426

Imazapyr Habitat Herbicide SePRO Corporation 241-426-67690

Imazapyr Imazapyr 2 SL Vegetation Man., LLC 74477-4

Imazapyr Imazapyr 2SL Alligare, LLC 81927-23

Imazapyr Imazapyr 4 SL Vegetation Man., LLC 74477-5

Imazapyr Imazapyr 4SL Alligare, LLC 81927-24

Imazapyr Polaris Nufarm Americas Inc. 228-534

Imazapyr Polaris AC Nufarm Americas Inc. 241-299-228

Imazapyr Polaris AC Nufarm Americas Inc. 228-480

Imazapyr Polaris AC Complete Nufarm Americas Inc. 228-570

Imazapyr Polaris AQ Nufarm Americas Inc. 241-426-228

Imazapyr Polaris Herbicide Nufarm Americas Inc. 241-346-228

Imazapyr Polaris RR Nufarm Americas Inc. 241-273-228

Imazapyr Polaris SP Nufarm Americas Inc. 228-536

Imazapyr Polaris SP Nufarm Americas Inc. 241-296-228

Imazapyr Rotary 2 SL Alligare, LLC 81927-6

Imazapyr SSI Maxim Arsenal 0.5G SSI Maxim Co., Inc. 34913-23

Imazapyr SSI Maxim Arsenal 5.0G SSI Maxim Co., Inc. 34913-24

Imazapyr Stalker BASF 241-398

Metsulfuron methyl AmTide MSM 60DF Herbicide AmTide, LLC 83851-3

Metsulfuron methyl Escort DF DuPont Crop Protection 352-439

Metsulfuron methyl Escort XP Bayer Environmental Science 432-1549

Metsulfuron methyl Escort XP DuPont Crop Protection 352-439

Metsulfuron methyl Metsulfuron Methyl DF Vegetation Man., LLC 74477-2

Metsulfuron methyl MSM 60 Alligare, LLC 81927-7

Metsulfuron methyl MSM E-AG 60 EG Herbicide Etigra, LLC 81959-14

Metsulfuron methyl MSM E-Pro 60 EG Herbicide Etigra, LLC 81959-14

Metsulfuron methyl Patriot Nufarm Americas Inc. 228-391

Metsulfuron methyl PureStand Nufarm Americas Inc. 71368-38

Picloram Grazon PC Dow AgroSciences 62719-181

Picloram OutPost 22K Dow AgroSciences 62719-6

Picloram Picloram 22K Alligare, LLC 81927-18

Picloram Picloram K Alligare, LLC 81927-17

Picloram Tordon 22K Dow AgroSciences 62719-6

Picloram Tordon K Dow AgroSciences 62719-17

Picloram Triumph 22K Albaugh, Inc. 42750-79

Picloram Triumph K Albaugh, Inc. 42750-81

Picloram Trooper 22K Nufarm Americas Inc. 228-535

Rimsulfuron Laramie 25DF Alligare, LLC 81927-57

Rimsulfuron Matrix SG Dupont Crop Protection 352-768

Sulfometuron methyl Oust DF DuPont Crop Protection 352-401

Sulfometuron methyl Oust XP Bayer Environmenatl Science 432-1552

Sulfometuron methyl Oust XP DuPont Crop Protection 352-601

Sulfometuron methyl SFM 75 Alligare, LLC 81927-26

Sulfometuron methyl SFM 75 Vegetation Man., LLC 72167-11-74477

Sulfometuron methyl SFM E-Pro 75EG Etigra, LLC 79676-16
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

236

Active Ingredient Trade Name Manufacturer EPA Registration 

Number

Sulfometuron methyl Spyder Nufarm Americas Inc. 228-408

Triclopyr Boulder 6.3 Alligare, LLC 81927-54

Triclopyr Ecotriclopyr 3 SL Vegetation Man., LLC 72167-49-74477

Triclopyr Element 3A Dow AgroSciences 62719-37

Triclopyr Element 4 Dow AgroSciences 62719-40

Triclopyr Forestry Garlon XRT Dow AgroSciences 62719-553

Triclopyr Garlon 3A Dow AgroSciences 62719-37

Triclopyr Garlon 4 Dow AgroSciences 62719-40

Triclopyr Garlon 4 Ultra Dow AgroSciences 62719-527

Triclopyr Pathfinder II Dow AgroSciences 62719-176

Triclopyr Relegate Nufarm Americas Inc. 228-521

Triclopyr Relegate RTU Nufarm Americas Inc. 228-522

Triclopyr Remedy Dow AgroSciences 62719-70

Triclopyr Remedy Ultra Dow AgroSciences 62719-552

Triclopyr Renovate 3 SePRO Corporation 62719-37-67690

Triclopyr Renovate OTF SePRO Corporation 67690-42

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-384

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-518

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-520

Triclopyr Tahoe 4E Nufarm Americas Inc. 228-385

Triclopyr Tahoe 4E Herbicide Nufarm Americas Inc. 228-517

Triclopyr Triclopry 4 Alligare, LLC 81927-11

Triclopyr Triclopyr 3 Alligare, LLC 81927-13

Triclopyr Triclopyr 3 SL Vegetation Man., LLC 72167-53-74477

Triclopyr Triclopyr RTU Albaugh, LLC 42750-173

Triclopyr Triclopyr RTU Alligare, LLC 81927-33

Triclopyr Trycera Helena Chemical Company 5905-580

Triclopyr Vastlan Dow AgroSciences 62719-687

1. Approved list as of January 6, 2017.

Table B-3. Adjuvants Approved for Use on BLM Administered Lands1

Adjuvant Type Trade Name Manufacturer ARBO2

Surfactants

Non-ionic Surfactant 90-10 Surfactant Brewer International

Non-ionic Surfactant A-90 Alligare, LLC

Non-ionic Surfactant Activate Plus Winfield Solutions, LLC

Non-ionic Surfactant Activator 90 Loveland Products, Inc.

Non-ionic Surfactant Ad Spray 90 Helena Chemical Company

Non-ionic Surfactant Alligare Surface Alligare, LLC

Non-ionic Surfactant Alligare Surface West Alligare, LLC

Non-ionic Surfactant Alligare Trace Alligare, LLC

Non-ionic Surfactant Aquafact Crop Production Services

Non-ionic Surfactant Aqufact Aqumix, Inc.

Non-ionic Surfactant Audible 80 Exacto, Inc.

Non-ionic Surfactant Audible 90 Exacto, Inc.

Non-ionic Surfactant Brewer 90-10 Brewer International

Non-ionic Surfactant Chempro S-820 Chemorse Ltd.

Non-ionic Surfactant Chempro S-910 Chemorse Ltd.

Non-ionic Surfactant Chemsurf 80 Chemorse Ltd.

Non-ionic Surfactant Chemsurf 90 Chemorse Ltd.

Non-ionic Surfactant Cornbelt Premier 90 Van Diest Supply Co.

Non-ionic Surfactant Cornbelt Trophy Gold Van Diest Supply Co.

Non-ionic Surfactant Denali-EA Wilbur-Ellis Co.

Non-ionic Surfactant Elite Platinum Red River Specialties, Inc.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

237

Adjuvant Type Trade Name Manufacturer ARBO2

Non-ionic Surfactant EP-90 Eco-Pak, LLC

Non-ionic Surfactant Haf-Pynt Drexel Chemical Company

Non-ionic Surfactant Hum-AC 820 Drexel Chemical Company

Non-ionic Surfactant Induce Setre (Helena)

Non-ionic Surfactant Induce Helena Chemical Company

Non-ionic Surfactant Induce pH Helena Chemical Company

Non-ionic Surfactant Inlet Helena Chemical Company

Non-ionic Surfactant LI-700 Loveland Products, Inc. 

Non-ionic Surfactant Magnify Monterey AgResources 

Non-ionic Surfactant NIS 90:10 Precision Laboratories, LLC

Non-ionic Surfactant NIS-EA Wilbur-Ellis Co.

Non-ionic Surfactant No Foam A Creative Marketing & Research, Inc.

Non-ionic Surfactant Optima Helena Chemical Company

Non-ionic Surfactant PAS-800 Drexel Chemical Company

Non-ionic Surfactant Preference Winfield Solutions, LLC

Non-ionic Surfactant R-900 Wilbur-Ellis Co.

Non-ionic Surfactant Rainer-EA Wilbur-Ellis Co.

Non-ionic Surfactant Range Master ORO Agri Inc.

Non-ionic Surfactant Red River 90 Red River Specialties, Inc.

Non-ionic Surfactant Red River NIS Red River Specialties, Inc.

Non-ionic Surfactant Scanner Loveland Products, Inc.

Non-ionic Surfactant Spec 90/10 Helena Chemical Company

Non-ionic Surfactant Spray Activator 85 Van Diest Supply Co.

Non-ionic Surfactant Spreader 90 Loveland Products, Inc.

Non-ionic Surfactant Spret Helena Chemical Company

Non-ionic Surfactant Super Spread 90 Wilbur-Ellis Co.

Non-ionic Surfactant Super Spread 7000 Wilbur-Ellis Co.

Non-ionic Surfactant Surf-Ac 910 Drexel Chemical Company

Non-ionic Surfactant Surf-Ac 820 Drexel Chemical Company

Non-ionic Surfactant UAP Surfactant 80/20 Loveland Products, Inc.

Non-ionic Surfactant Wetcit ORO Agri Inc.

Non-ionic Surfactant X-77 Loveland Products, Inc.

Spreader/Sticker Agri-Trend Spreader Agri-Trend

Spreader/Sticker Attach Loveland Products, Inc.

Spreader/Sticker Aqua-King Plus Winfield Solutions, LLC

Spreader/Sticker Bond Loveland Products, Inc. 

Spreader/Sticker Bond Max Loveland Products, Inc.

Spreader/Sticker Chempro S-196 Chemorse Ltd.

Spreader/Sticker Cohere Helena Chemical Company

Spreader/Sticker CWC 90 CWC Chemical, Inc.

Spreader/Sticker Gulfstream Winfield Solutions, LLC

Spreader/Sticker Insist 90 Wilbur-Ellis Co.

Spreader/Sticker Lastick Setre (Helena)

Spreader/Sticker Nu-Film-IR Miller Chem. & Fert. Corp.

Spreader/Sticker Nu Film 17 Miller Chem. & Fert. Corp.

Spreader/Sticker Nu Film P Miller Chem. & Fert. Corp.

Spreader/Sticker Onside Kick Exacto, Inc.

Spreader/Sticker Pinene II Drexel Chemical Company

Spreader/Sticker Protyx Precision Laboratories, LLC

Spreader/Sticker R-56 Wilbur-Ellis Co.

Spreader/Sticker Rocket DL Monterey AgResources

Spreader/Sticker Tactic Loveland Products, Inc. 

Spreader/Sticker TopFilm Biosorb, Inc.

Spreader/Sticker Widespread Max Loveland Products, Inc.

Silicone-based Aero Dyne-Amic Helena Chemical Company
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

238

Adjuvant Type Trade Name Manufacturer ARBO2

Silicone-based Aircover Winfield Solutions, LLC

Silicone-based Alligare OSS/NIS Alligare, LLC

Silicone-based Chempro S-172 Chemorse Ltd.

Silicone-based Dyne-Amic Helena Chemical Company 

Silicone-based Elite Marvel Red River Specialties, Inc.

Silicone-based Freeway Loveland Products, Inc.

Silicone-based Kinetic Setre (Helena) 

Silicone-based Phase Loveland Products, Inc.

Silicone-based Phase II Loveland Products, Inc.

Silicone-based Scrimmage Exacto, Inc.

Silicone-based SilEnergy Brewer International

Silicone-based Sil-Fact Drexel Chemical Company

Silicone-based Sil-MES 100 Drexel Chemical Company

Silicone-based Silnet 200 Brewer International

Silicone-based Silwet L-77 Loveland Products, Inc.

Silicone-based Speed Precision Laboratories, LLC

Silicone-based Sun Spreader Red River Specialties, Inc.

Silicone-based Syl-coat Wilbur-Ellis Co.

Silicone-based Sylgard 309 Wilbur-Ellis Co.

Silicone-based Syl-Tac Wilbur-Ellis Co.

Oil-based

Crop Oil Concentrate 60/40 Crop Oil Concentrate Chemorse Ltd.

Crop Oil Concentrate Agri-Dex Helena Chemical Company 

Crop Oil Concentrate Alligare Forestry Oil Alligare, LLC

Crop Oil Concentrate Brewer 83-17 Brewer International

Crop Oil Concentrate Cornbelt Crop Oil Concentrate Van Diest Supply Co.

Crop Oil Concentrate Cornbelt Premium Crop Oil Concentrate Van Diest Supply Co.

Crop Oil Concentrate Crop Oil Concentrate Helena Chemical Company

Crop Oil Concentrate Crop Oil Concentrate Loveland Products, Inc.

Crop Oil Concentrate CWR Herbicide Activator Creative Marketing & Research, Inc.

Crop Oil Concentrate Exchange Precision Laboratories, LLC

Crop Oil Concentrate Herbimax Loveland Products, Inc.

Crop Oil Concentrate Maximizer Crop Oil Conc. Loveland Products, Inc.

Crop Oil Concentrate Monterey M.S.O. Monterey AgResources

Crop Oil Concentrate Mor-Act Wilbur-Ellis Co.

Crop Oil Concentrate Peptoil Drexel Chemical Company

Crop Oil Concentrate Power-Line Crop Oil Land View Inc.

Crop Oil Concentrate Primary Drexel Chemical Company

Crop Oil Concentrate Prime Oil Winfield Solutions, LLC

Crop Oil Concentrate R.O.C. Rigo Oil Conc. Wilbur-Ellis Co.

Crop Oil Concentrate Red River Forestry Oil Red River Specialties, Inc.

Crop Oil Concentrate Red River Pacer Crop Oil Red River Specialties, Inc.

Crop Oil Concentrate Superb HC Winfield Solutions, LLC 

Methylated Seed Oil 60/40 MSO Chemorse Ltd.

Methylated Seed Oil Alligare MSO Alligare, LLC

Methylated Seed Oil Alligare MSO West Alligare, LLC

Methylated Seed Oil Atmos Winfield Solutions, LLC

Methylated Seed Oil Conquer Chemorse Ltd.

Methylated Seed Oil Cornbelt Base Van Diest Supply Co.

Methylated Seed Oil Cornbelt Methylates Soy-Stik Van Diest Supply Co.

Methylated Seed Oil Destiny HC Winfield Solutions, LLC 

Methylated Seed Oil Elite Supreme Red River Specialties, Inc.

Methylated Seed Oil Hasten Wilbur-Ellis Co.

Methylated Seed Oil Hasten-EA Wilbur-Ellis Co.

Methylated Seed Oil Hot MES Drexel Chemical Company
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

239

Adjuvant Type Trade Name Manufacturer ARBO2

Methylated Seed Oil Kixyt Precision Laboratories, LLC.

Methylated Seed Oil MES-100 Drexel Chemical Company

Methylated Seed Oil Methylated Spray Oil Conc. Helena Chemical Company

Methylated Seed Oil Monterey M.S.O. Monterey AgResources

Methylated Seed Oil MSO Concentrate Alligare, LLC

Methylated Seed Oil MSO Concentrate Loveland Products, Inc.

Methylated Seed Oil Premium MSO Helena Chemical Company

Methylated Seed Oil Persist Ultra Precision Laboratories, LLC.

Methylated Seed Oil Red River Supreme Red River Specialties, Inc.

Methylated Seed Oil Renegade 2.0 Wilbur-Ellis Co.

Methylated Seed Oil Renegade-EA Wilbur-Ellis Co.

Methylated Seed Oil Sunburn Red River Specialties, Inc.

Methylated Seed Oil SunEnergy Brewer International

Methylated Seed Oil Sunset Red River Specialties, Inc.

Methylated Seed Oil Sun Wet Brewer International

Methylated Seed Oil Super Kix Wilbur-Ellis Co.

Methylated Seed Oil Super Spread MSO Wilbur-Ellis Co.

Methylated Seed Oil + Organosilicone Alligare MVO Plus Alligare, LLC

Methylated Seed Oil + Organosilicone Syl-Tac-EA Wilbur-Ellis Co.

Methylated Seed Oil + Organosilicone Turbulence Winfield Solutions, LLC

Vegetable Oil Amigo Loveland Products, Inc.

Vegetable Oil BeanOil Drexel Chemical Company

Vegetable Oil Competitor Wilbur-Ellis Co. 

Vegetable Oil Elite Natural Red River Specialties, Inc.

Vegetable Oil Motion Exacto, Inc.

Vegetable Oil Noble Winfield Solutions, LLC

Vegetable Oil Vegetoil Drexel Chemical Company

Fertilizer-based

Nitrogen-based Actamaster Soluble Spray Adjuvant Loveland Products, Inc.

Nitrogen-based Actamaster Spray Adjuvant Loveland Products, Inc.

Nitrogen-based Alliance Winfield Solutions, LLC

Nitrogen-based AMS-All Drexel Chemical Company

Nitrogen-based AMS-Supreme Drexel Chemical Company

Nitrogen-based AMS-Xtra Drexel Chemical Company

Nitrogen-based Bronc Wilbur-Ellis Co.

Nitrogen-based Bronc Max Wilbur-Ellis Co. 

Nitrogen-based Bronc Max EDT Wilbur-Ellis Co.

Nitrogen-based Bronc Plus Dry Wilbur-Ellis Co.

Nitrogen-based Bronc Plus Dry EDT Wilbur-Ellis Co. 

Nitrogen-based Bronc Total Wilbur-Ellis Co.

Nitrogen-based Cayuse Plus Wilbur-Ellis Co.

Nitrogen-based Class Act NG Winfield Solutions, LLC 

Nitrogen-based Cornbelt Gardian Van Diest Supply Co.

Nitrogen-based Cornbelt Gardian Plus Van Diest Supply Co.

Nitrogen-based Corral AMS Liquid Winfield Solutions, LLC

Nitrogen-based Dispatch Loveland Products, Inc.

Nitrogen-based Dispatch 111 Loveland Products, Inc.

Nitrogen-based Dispatch 2N Loveland Products, Inc.

Nitrogen-based Dispatch AMS Loveland Products, Inc.

Nitrogen-based Flame Loveland Products, Inc.

Nitrogen-based Holzit Drexel Chemical Company

Nitrogen-based Nitro-Surf Drexel Chemical Company

Nitrogen-based Quest Helena Chemical Company

Nitrogen-based TransActive HC Helena Chemical Company
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

240

Special Function

Buffering Agent Brimstone Wilbur-Ellis Co.

Buffering Agent BS-500 Drexel Chemical Company

Buffering Agent Buffers P.S. Helena Chemical Company

Buffering Agent Oblique Red River Specialties, Inc.

Buffering Agent Spray-Aide Miller Chem. & Fert. Corp.

Buffering Agent Tri-Fol Wilbur-Ellis Co.

Buffering Agent Yardage Exacto, Inc.

Colorants/Dyes Alligare Super Marking Dye Alligare, LLC

Colorants/Dyes BullsEye Milliken Chemical

Colorants/Dyes Elite Ruby Red River Specialties, Inc.

Colorants/Dyes Elite Sapphire Red River Specialties, Inc.

Colorants/Dyes Elite Sapphire WSB Red River Specialties, Inc.

Colorants/Dyes Elite Splendor Red River Specialties, Inc.

Colorants/Dyes Hash Mark Blue Liquid Exacto, Inc.

Colorants/Dyes Hash Mark Blue Liquid HC Exacto, Inc.

Colorants/Dyes Hash Mark Blue Powder Exacto, Inc.

Colorants/Dyes Hash Mark Green Liquid Exacto, Inc.

Colorants/Dyes Hash Mark Green Powder Exacto, Inc.

Colorants/Dyes Hi-Light Becker-Underwood

Colorants/Dyes Hi-Light WSP Becker-Underwood

Colorants/Dyes Marker Dye Loveland Products, Inc.

Colorants/Dyes Mark-It Blue Monterey AgResources

Colorants/Dyes Mark-It Red Monterey AgResources

Colorants/Dyes Mystic HC Winfield Solutions, LLC

Colorants/Dyes Signal Precision Laboratories, LLC

Colorants/Dyes SPI-Max Blue Spray Marker PROKoZ

Colorants/Dyes Spray Indicator XL Helena Chemical Company

Colorants/Dyes TurfTrax Loveland Products, Inc.

Colorants/Dyes TurfTrax Blue Spray Indicator Loveland Products, Inc.

Compatibility/Suspension Agent Blendex VHC Setre (Helena)

Compatibility/Suspension Agent Convert Precision Laboratories, LLC

Compatibility/Suspension Agent E Z MIX Loveland Products, Inc.

Compatibility/Suspension Agent Mix Drexel Chemical Company

Compatibility/Suspension Agent Support Loveland Products, Inc.

Defoaming Agent Alligare Anti-Foamer Alligare, LLC

Defoaming Agent Alligare Defoamer Alligare, LLC

Defoaming Agent Cornbelt Defoamer Van Diest Supply Co.

Defoaming Agent Defoamer Brewer International

Defoaming Agent Fast Break Winfield Solutions, LLC

Defoaming Agent Fighter-F 10 Loveland Products, Inc.

Defoaming Agent Fighter-F Dry Loveland Products, Inc.

Defoaming Agent Foam Buster Setre (Helena)

Defoaming Agent Foambuster Max Helena Chemical Company

Defoaming Agent Foam Fighter Miller Chem. & Fert. Corp.

Defoaming Agent Fome-Kil Drexel Chemical Company

Defoaming Agent FTF Defoamer Wilbur-Ellis Co.

Defoaming Agent Gundown Max Precision Laboratories, LLC

Defoaming Agent No Foam Wilbur-Ellis Co.

Defoaming Agent Red River Defoamer Red River Specialties, Inc.

Defoaming Agent Reverse Exacto, Inc.

Defoaming Agent Suppression Chemorse, Ltd

Defoaming Agent Tripleline Creative Marketing & Research, Inc.

Defoaming Agent Unfoamer Loveland Products, Inc.

Deposition Aid Agripharm Drift Control Walco International

Deposition Aid Alligare Downforce Alligare, LLC
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

241

Deposition Aid Alligare Pattern Alligare, LLC

Deposition Aid Bivert Wilbur-Ellis Co.

Deposition Aid Border AQ Precision Laboratories, LLC

Deposition Aid Chem-Trol Chemorse, Ltd

Deposition Aid Clasp Helena Chemical Company

Deposition Aid Compadre Loveland Products, Inc.

Deposition Aid Coverage G-20 Wilbur-Ellis Co.

Deposition Aid Crosshair Wilbur-Ellis Co.

Deposition Aid CWC Sharpshooter CWC Chemical, Inc.

Deposition Aid Cygnet Plus Brewer International 

Deposition Aid Direct Precision Laboratories, LLC

Deposition Aid Droplex Winfield Solutions, LLC

Deposition Aid EDT Concentrate Wilbur-Ellis Co.

Deposition Aid Elite Secure Ultra Red River Specialties, Inc.

Deposition Aid Exit Miller Chem. & Fert. Corp.

Deposition Aid Grounded Helena Chemical Company

Deposition Aid Grounded - CA Helena Chemical Company

Deposition Aid Infuse Loveland Products, Inc.

Deposition Aid Intac Plus Loveland Products, Inc.

Deposition Aid Interlock Winfield Solutions, LLC 

Deposition Aid Liberate Loveland Products, Inc. 

Deposition Aid LOX Drexel Chemical Company

Deposition Aid LOX PLUS Drexel Chemical Company

Deposition Aid Mist-Control Miller Chem. & Fert. Corp.

Deposition Aid Offside Exacto, Inc.

Deposition Aid Pointblank Helena Chemical Company

Deposition Aid Poly Control 2 Brewer International

Deposition Aid ProMate Impel Helena Chemical Company

Deposition Aid Reign Loveland Products, Inc.

Deposition Aid Reign LC Loveland Products, Inc.

Deposition Aid Secure Ultra Red River Specialties, Inc.

Deposition Aid Sta’-Put Setre (Helena)

Deposition Aid Strike Zone DF Helena Chemical Company

Deposition Aid Sustain Miller Chem. & Fert. Corp.

Deposition Aid Syndetic Chemorse, Ltd

Deposition Aid Volare DC Precision Laboratories, LLC

Deposition Aid Weather Gard Loveland Products, Inc.

Diluent/Deposition Agent Bark Oil Crop Production Services

Diluent/Deposition Agent Bark Oil EC Crop Production Services

Diluent/Deposition Agent Elite Premier Red River Specialties, Inc.

Diluent/Deposition Agent Elite Premier Blue Red River Specialties, Inc.

Diluent/Deposition Agent Hy-Grade EC CWC Chemical, Inc.

Diluent/Deposition Agent Hy-Grade I CWC Chemical, Inc.

Diluent/Deposition Agent Improved JLB Oil Plus Brewer International

Diluent/Deposition Agent In-Place Wilbur-Ellis Co.

Diluent/Deposition Agent JLB Oil Plus Brewer International

Diluent/Deposition Agent Red River Basal Oil Red River Specialties, Inc.

Diluent/Deposition Agent Thinvert TRU Waldrum Specialties, Inc.

Diluent/Deposition Agent Thinvert Concentrate Waldrum Specialties, Inc.

Diluent/Deposition Agent W.E.B. Oil Wilbur-Ellis Co.

Foam Marker Align Helena Chemical Company

Foam Marker F.M.-160 Drexel Chemical Company

Foam Marker R-160 Wilbur-Ellis Co.

Foam Marker Red River Foam Marker Red River Specialties, Inc.

Foam Marker Trekker Trax Loveland Products, Inc.

Foam Marker Tuff Trax Foam Concentrate Loveland Products, Inc.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix B – The Herbicides, Formulations, and Adjuvants

242

Invert Emulsion Agent Redi-vert II Wilbur-Ellis Co.

Tank Cleaner All Clear Loveland Products, Inc.

Tank Cleaner Back Field Exacto, Inc.

Tank Cleaner Cornbelt Tank-Aid Van Diest Supply Co.

Tank Cleaner Elite Vigor Red River Specialties, Inc.

Tank Cleaner Kutter Wilbur-Ellis Co.

Tank Cleaner Neutral-Clean Wilbur-Ellis Co.

Tank Cleaner Pro Tank Winfield Solutions, LLC

Tank Cleaner Red River Tank Cleaner Red River Specialties, Inc.

Tank Cleaner SSC-11 Wilbur-Ellis Co.

Tank Cleaner Tank and Equipment Cleaner Loveland Products, Inc.

Tank Cleaner Wipe Out Helena Chemical Company

Water Conditioning AccuQuest WM Helena Chemical Company

Water Conditioning Alligare Water Conditioner Alligare, LLC

Water Conditioning Blendmaster Loveland Products, Inc.

Water Conditioning Breeze Winfield Solutions, LLC

Water Conditioning Choice Loveland Products, Inc.

Water Conditioning Choice Weather Master Loveland Products, Inc.

Water Conditioning Choice Xtra Loveland Products, Inc.

Water Conditioning Climb Wilbur-Ellis Co.

Water Conditioning Completion Exacto, Inc.

Water Conditioning Cornbelt N-Tense Van Diest Supply Co.

Water Conditioning Cut-Rate Wilbur-Ellis Co. 

Water Conditioning Elite Imperial Red River Specialties, Inc.

Water Conditioning Hel-Fire Helena Chemical Company

Water Conditioning Import Precision Laboratories, LLC

Water Conditioning Sequestra Drexel Chemical Company

Water Conditioning Smoke Helena Chemical Company

Water Conditioning Transport LpH Precision Laboratories, LLC

Water Conditioning Transport Plus Precision Laboratories, LLC

1. Approved list as of January 6, 2017.

2. Approved for use near water under ARBO II
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

243 

Appendix C - Herbicide Risk Assessment 

Summaries

See the Human Health and Ecological Risk Assessments

section in Chapter 2 for an introduction to the Risk 

Assessments. The risk tables presented in this Appendix are 

used in the individual analysis in Chapter 3.

Risk82

EPA Labels

The Federal Insecticide, Fungicide and Rodenticide Act

(FIFRA) establishes procedures for the registration, 

classification, and regulation of all herbicides. Before any 

herbicides may be sold legally, the EPA must register it. The 

EPA may classify an herbicide for general use if it determines 

that the herbicide is not likely to cause unreasonable adverse 

effects to applicators or the environment, or it may be 

classified for restricted use if the herbicide must be applied by a certified applicator and in accordance with other 

restrictions. Aquatic herbicides require extra testing over and above what is required for the normal registration 

process before they can be registered for aquatic application. This includes dissipation studies in water and aquatic 

sediments, accumulation in non-target organisms 

and fish and shellfish tolerances. The herbicide label 

is a legal document specifying allowable uses; all 

applicators that apply herbicides on public lands 

must comply with the application rates, uses, 

handling, and all other instructions on the herbicide 

label, and where more restrictive, the rates, uses, 

and handling instructions developed by the BLM.

In addition to sub-chronic and chronic toxicity, EPA 

herbicide registration looks at the acute toxicity of 

an herbicide. Acute toxicity is the most common basis for comparing the relative toxicities of herbicides. Acute 

toxicity can be measured by LD5083. LD50 (LD = lethal dose) represents the amount of herbicide that results in the 

death of 50 percent of a test population. Therefore, the lower the LD50, the more toxic the herbicide. Table C-1 

shows the three categories that the EPA uses for classifying herbicides (USDI 1992a).

82 Adapted from the Oregon FEIS (USDI 2010a:85-91). 83 or LC50 (lethal concentration) in the case of aquatic organisms.

EPA terms

LD50 Lethal Dose to 50% of the population

LOC Level of Concern

NOAEL No Observed Adverse Effect Level

LOAEL Lowest Observed Adverse Effect Level

BLM terms

RQ Risk Quotient

ECC Estimated Exposure Concentration

TRV Toxicity Reference Value

ARI Aggregated Risk Index

Forest Service terms

HQ Hazard Quotient

RfD Reference Dose

TI Toxicity Index

Acute toxicity: The quality or potential of a substance 

to cause injury or illness shortly after exposure through 

a single or short-term exposure.

Chronic toxicity: The ability of a substance or mixture of 

substances to cause harmful effects over an extended 

period, usually upon repeated or continuous exposure 

sometimes lasting for the entire life of the exposed 

organism.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

244 

Table C-1. Herbicide Label Categories

Categories Signal Word 

Required on Label

Oral LD50

(mg./kg.) 

Dermal LD50

(mg./kg.) 

Inhalation LD50

(mg./kg.) 

Probable Oral Lethal 

Dose for 150 lb. 

Human

I – Highly Toxic DANGER, POISON, 

skull & crossbones

Up to and 

including 50

Up to and 

including 200

Up to and 

including 0.2

A few drops to a 

teaspoonful

II – Moderately 

Toxic WARNING From 50 to 500 From 200 to 2,000 From 0.2 to 2 Over one teaspoonful to one ounce

III – Slightly Toxic CAUTION From 500 to 

5,000

From 2,000 to 

20,000 From 2 to 20 Over one ounce to one pint or one pound.

In addition, the EPA has established Levels of Concern (LOC) for herbicides, which is the dose of the herbicide 

above which effects would be expected. The LOCs are used by EPA for registration, and to indicate potential risk to 

non-target organisms and the need to consider regulatory action (USEPA 2007). In the absence of information 

indicating otherwise, the LOC is generally 1/10th of the Lowest Observed Adverse Effect Level (LOAEL); that is, the 

lowest dose level where there was a statistically significant increase in frequency or severity of adverse effects84 to 

the test organism. In some cases, no adverse reaction happens at any dose (or at any reasonable dose), and the 

LOC is the No Observed Adverse Effect Level (NOAEL). LOCs include uncertainty factors based on the amount and 

nature of the toxicity testing on which they are based.

Risk Assessments

One of the Purposes identified in Chapter 1 of this EA is: d. Prevent control treatments from having unacceptable 

adverse effects to applicators and the public, to desirable flora and fauna, and to soil, air, and water. To help 

address this Purpose, this EA relies on BLM and Forest Service-prepared Human Health and Ecological Risk 

Assessments for the herbicides analyzed in this EA. These complete Risk Assessments are included in the Oregon 

FEIS as Appendix 8: Risk Assessments (uncirculated) and the 2007 and 2016 PEISs. The Risk Assessments are used 

to quantitatively evaluate the probability (i.e., risk) that herbicide use in wildland settings might pose harm to 

humans or other species in the environment. As such, they address many of the risks that would be faced by 

humans, plants, and animals, including federally listed and other Special Status species, from the use of the 

herbicides. The level of detail in the Risk Assessments far exceeds that normally found in EPA’s registration 

examination.

Risk is defined as the likelihood that an effect (injury, disease, death, or environmental damage) may result from a 

specific set of circumstances. It can be expressed in quantitative or qualitative terms. While all human activities 

carry some degree of risk, some risks are known with a relatively high degree of accuracy because data have been 

collected on the historical occurrence of related problems (e.g., lung cancer caused by smoking, auto accidents 

caused by alcohol impairment, and fatalities resulting from airplane travel). For several reasons, risks associated 

with exposure to herbicides (at least in wildland settings) cannot be so readily determined. The Risk Assessments 

help evaluate the risks resulting from these situations.

Risk Assessments are necessarily done on a surrogate species in laboratory conditions, identified to represent a 

species group, as toxicological data does not exist for most native non-target species. Survival, growth, 

reproduction, and other important sub-lethal processes of both terrestrial and aquatic non-target species were 

considered. Assessments considered acute and chronic toxicity data. Exposures of receptors85 to direct spray, 

surface runoff, wind erosion, and accidental spills were analyzed.

The Human Health and Ecological Risk Assessments were developed by the BLM for the 2007 PEIS, the 2016 PEIS, 

or by the Forest Service for the 2005 Pacific Northwest Region Invasive Plant Program EIS (see Table C-2). The Risk 

84 Lethal or sub-lethal. 85 An ecological entity such as a human, fish, plant, or slug.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

245 

Assessments, related separate analyses, and the PEISs include analysis of degradates and other ingredients for 

which information is available and not constrained by confidential business information restrictions. Preparing a 

Risk Assessment for every conceivable combination of herbicide, tank mix, adjuvants (including surfactants), and 

other possible mixtures is not feasible, as the BLM cannot prepare hundreds of Risk Assessments, and the cost 

would be exorbitant. To the degree a toxic substance is known to pose a human or ecological risk, the BLM has 

undertaken analysis to assess its impacts through Risk Assessments. More detailed information about uncertainty 

in the Risk Assessment process is included in Appendix 13 of the Oregon FEIS.

Table C-2. Human Health and Ecological Risk Assessment Sources

When evaluating risks from the use of herbicides 

proposed in a NEPA planning document, reliance 

on EPA’s herbicide registration process as the sole 

demonstration of safety is insufficient. The U.S. 

Forest Service and BLM were involved in court 

cases in the early 1980s that specifically addressed 

this question (principally Save Our Ecosystems v.

Clark, 747 F.2d 1240, 1248 (9th Cir. 1984) and

Southern Oregon Citizens v. Clark, 720 F. 2d 1475,

1480 (9th Cir. 1983)). These court decisions and

others affirmed that although the BLM can use

EPA toxicology data, it is still required to do an 

independent assessment of the potential risks of 

using herbicides rather than relying on FIFRA 

registration alone. The Courts have also found that 

FIFRA does not require the same examination of 

impacts that the BLM is required to undertake 

under NEPA. Further, Risk Assessments consider 

data collected from both published scientific 

literature and data submitted to EPA to support 

FIFRA product registration, whereas EPA utilizes the latter data only. The EPA also considers many wildland 

herbicide uses to be minor. Thus, the project-specific application rates, spectrum of target and non-target 

organisms, and specialized exposure scenarios evaluated by the BLM are frequently not evaluated by EPA in its

generalized registration assessments.

The Risk Assessments and their distillation in the PEIS and Oregon FEIS are the source for much of the individual 

herbicide information presented in each of the resource sections in this EA, including the high-moderate-low risk 

categories shown in the tables in this Appendix.

Drift

Assuming non-target animals and plants are not directly sprayed, drift is the process most likely to result in 

herbicides getting onto non-target plants and animals, as well as herbicides moving outside the treatment area. 

Drift, defined as that part of a sprayed herbicide that is moved from the target area by wind while it is still 

airborne, is primarily dependent upon the elevation of the spray nozzle, droplet size, and air movement. The 

smaller the droplet, the longer it stays suspended and the farther it can travel. Drift is one exposure scenario 

examined in the Risk Assessments and summarized on the risk tables at the end of this Appendix. 

Spray drift can be reduced by increasing droplet size since wind will move large droplets less than small droplets. 

Droplet size can be increased by: 1) reducing spray pressure; 2) increasing nozzle orifice size; 3) using special drift 

reduction nozzles; and 4) using additives that increase spray viscosity. Commercial drift reduction agents are 

available that are designed to reduce drift beyond the capabilities of the determinants described above. These 

Human Health Ecological

2,4-D BLM (2016)

Aminopyralid BLM (2016)

Chlorsulfuron Forest Service BLM (2007)

Clopyralid BLM (2016)

Dicamba Forest Service

Dicamba + diflufenzopyr NA BLM (2007)

Diflufenzopyr BLM (2007) NA

Fluroxypyr BLM (2016)

Glyphosate Forest Service

Hexazinone Forest Service

Imazapic BLM (2007)

Imazapyr Forest Service

Metsulfuron methyl Forest Service

Picloram Forest Service

Rimsulfuron BLM (2016)

Sulfometuron methyl BLM (2007)

Triclopyr Forest Service

Herbicides analyzed for Research and Demonstration

Fluazifop-P-butyl Forest Service1

1. Scoping/screening level Risk Assessment, not adopted by the BLM.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

246 

products create larger and more cohesive droplets that are less apt to break into small particles as they fall 

through the air. They reduce the percentage of smaller, lighter particles, which are most apt to drift. Standard 

Operating Procedures for air quality provide techniques for controlling drift, including specifying selection of 

equipment that produces 200 to 800-micron diameter droplets.

Drift includes droplets and vapor. In general, however, herbicides have very low vapor pressures and BLM spray 

mixtures do not produce much vapor. One study showed that with more volatile insecticides, little or no vapor 

drift was detected 9-27 meters downwind for insecticides with vapor pressures less than 1x10-4 mm Hg (Woodward 

et al. 1997). All of the herbicides covered by the EIS have very low vapor pressures (maximum is 4x10-6 mm Hg and 

they range to as low as 5.5x10-16 mm Hg; Vencill et al. 2002).

High, Moderate, and Low Risk in BLM and Forest Service Risk 

Assessments

The Risk Assessments attempt to measure both acute toxicity and chronic toxicity. Chronic toxicity is difficult to 

measure, especially in humans, but shows the results of sub-lethal doses that could result in cumulative deposits 

that could cause long-term problems in a vital body function. There is no standard measure for chronic toxicity.

BLM Ecological Risk Assessments

The BLM Ecological Risk Assessments established a Risk Quotient (RQ) for every herbicide and defined risk 

categories as follows:

0 No Risk RQ < most conservative LOC for the species 

L Low Risk RQ = 1 to 10 times the most conservative LOC for the species 

M Moderate Risk RQ = 10 to 100 times the most conservative LOC for the species 

(generally equal to LOAEL to 10-times LOAEL) 

H High Risk RQ > 100 times the most conservative LOC for the species 

The RQ is calculated using the Estimated Exposure Concentration (EEC) and the Toxicity Reference Value (TRV). The 

EEC is the dose that an organism would be exposed to under the test scenario; e.g., consumption would indicate 

the amount of herbicide eaten on a sprayed material (a cow eating only sprayed grass for a day, for example), and 

direct spray indicates that the organism was sprayed directly with a wand or was in a flight path (a non-target plant 

species, for example). The TRV is the toxicity of the herbicide – usually the LOAEL or NOAEL. The RQ is the EEC 

divided by the TRV. An uncertainty factor can be brought in if it is thought that a species (or a particular individual 

within the species) is particularly susceptible to herbicide use, or that the single dose does not represent long-term 

exposure.

For example, the TRV (the dose that can be consumed with a potentially adverse effect) for a mule deer consuming 

vegetation contaminated with bromacil86 is 170 milligrams per kilogram of body weight per day (a mule deer 

weighs an estimated 70 kg.). Assuming a daily consumption rate of 6.2 kg. of forage, all contaminated with 

bromacil sprayed at the typical application rate (4 lbs./acre), the EEC (the amount of herbicide that the mule deer 

will be exposed to by eating the contaminated vegetation) is 33.7 milligrams per kilograms of body weight per day. 

Thus, the RQ is 33.7 mg./kg. divided by 170 mg./kg., or 0.198, which is a risk category of 0 (or no risk).

Tank Mixes - The BLM evaluated risks from mixing two herbicides together in a tank mix. The BLM assumed that 

products in a tank mix act in an additive manner. Therefore, to simulate a tank mix of two herbicides RQs for those 

two herbicides were combined (details provided in the individual Risk Assessments ). The application rates within 

86 An herbicide not included in this analysis.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

247 

the tank mix are not necessarily the same as those of each individual active ingredient applied alone. The percent 

of RQs exceeding LOCs for each of the 10 BLM herbicide active ingredients was compared to the percent of RQs 

exceeding LOCs for tank mixes, to determine whether additional risks were predicted for tank mixes.

BLM Human Health Risk Assessments (2007 and 2016)

The BLM Human Health Risk Assessments used the Aggregated Risk Index (ARI) and defined risk categories as 

follows: 

0 No Risk Majority of ARIs > 1 

L Low Risk Majority of ARIs < 1 but > 0.1 

M Moderate Risk Majority of ARIs < 0.1 but > 0.01 

H High Risk Majority of ARIs < 0.01 

The ARI is a formula for combining LOCs for all exposure avenues (oral, dermal, inhalation), each with different 

uncertainty factors, and comparing them with the exposure levels that would occur in the scenarios in the Risk 

Assessments. ARIs less than 1 indicate a concern from at least one of the exposure avenues (USEPA 2001b:51-55).

Forest Service Risk Assessments

The Forest Service Risk Assessments are very similar to the BLM’s Ecological Risk Assessments. The Forest Service 

Risk Assessments established a Hazard Quotient (HQ) for every herbicide and established risk categories as follows:

0 No Risk HQ < LOC for the species 

L Low Risk HQ = 1 to 10 times the LOC87 for the species 

M Moderate Risk HQ = 10 to 100 times the LOC for the species 

H High Risk HQ > 100 times the LOC for the species 

Figure C-1. Basis for Risk Assessments

Hazard 

Identification

Risk 

Characterization

Exposure 

Assessment

Dose-Response

Assessment

The HQ is calculated using the Reference Dose (RfD) and 

the Toxicity Index (TI). The RfD is the dose that an organism 

would be exposed to under the test scenario; the TI is the 

toxicity of the herbicide and the HQ is the RfD divided by 

the TI. An uncertainty factor can be brought in if it is 

thought that a species (or a particular individual within the 

species) is particularly susceptible to herbicide use, or that 

the single dose does not represent long-term exposure.

Figure C-1 shows the basis for Risk Assessments, which

consists of the following parts:

• Hazard Identification: what are the dangers

inherent with the herbicide? (e.g., endocrine

disruption, cancer causing, etc.)

• Exposure Assessment: who could come into

contact and how much? (specific exposure

scenarios)

87 As noted in the previous discussion, LOCs are generally set at 1/10th of the LOAEL. Thus, an HQ of 1 to 10 times LOC is 

equivalent to an HQ of 0.1 to 1 in the 2005 Forest Service Invasive Plant EIS (USDA 2005:4-73). The Forest Service EIS goes on to 

explain “The threshold is intended to help reviewers distinguish moderate risks (HQ=2 to 10 [HQ = 20-100 in this EIS]), which 

could in most cases be mitigated through exposure-reducing project design criteria from significant health risks (HQ>10 

[HQ>100 in this EIS]) that could be difficult to mitigate if Worst-Case situations occur at the project level. For specific situations 

where a HQ>10 [HQ>100 in this EIS] is identified, the specific physiologic effect and the relationship between the NOAEL and 

the LOAEL may be evaluated to more precisely determine whether a toxic effect is actually likely to occur (Durkin, personal 

communication).” (USDA 2005:4-73) 
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

248

• Dose Response Assessment: how much is too much? At what dose are observable effects observed?

• Risk Characterization: indicates whether or not there is a plausible basis for concern (HQ or RQ).

Stated another way, the lower range for the L, or low, risk category is theoretically the level at which an effect 

began to be discernable in testing or modeling (theoretically, because uncertainty factors have the effect of

reducing the dose identified as having the adverse effect). The minimum identified effect may have been skin or 

eye irritation, leaf damage, and so forth. Uncertainty factors are added to address hypersensitive individuals, or 

accommodate uncertainties in the measurements, such as inferring effects to one species based on actual tests on 

other species. Uncertainty factors are typically multiples of 10, so the assumed Lowest Observable Effects (LOAEL) 

dose could have been inflated 10, 100, or even 1,000 times for uncertainties. Thus, exposure of the average 

individual to the dose identified as having an effect, probably would not have an effect. Nevertheless, the L or low 

rating indicates risks start at that point. Moderate risk categories indicate risk starts at doses one-tenth those of 

the low ratings; high is one-hundredth of the testing scenario dose. Testing scenarios are severe – e.g., soaking the 

test animal – so Standard Operating Procedures and PEIS Mitigation Measures such as buffers, wind speed limits, 

and so forth, as well as required safety equipment, limit exposure to substantially less than tested doses. For 

herbicides with moderate and high risk categories for a particular receptor, special cautions are implemented. For 

example, buffers for Special Status plant species are as large as 1,500 feet for some herbicides (see Conservation 

Measures in Appendix A). The low, moderate, or high human health risk categories shown on Tables C-3 through C8 are more conservative than the EPA ratings used to apply the Caution, Warning, or Danger/Poison signal words 

to herbicide labels.

The Risk Assessments are summarized on tables showing herbicide risk categories at BLM maximum and typical 

application rates to vegetation, wildlife, and humans, in a variety of application scenarios. Tables C-3 and C-6 show 

herbicide risks to vegetation, from BLM and Forest Service Risk Assessments respectively. Tables C-4 and C-7 show 

herbicide risks to wildlife, fish, and aquatic invertebrates and Tables C-5 and C-8 show the risks to human health. 

Further information about the Human Health Risk Assessments can be found in the Human Health and Safety 

section of Chapter 4 of the Oregon FEIS.

Uncertainty in the Risk Assessment Process

The Risk Assessments conducted by the BLM and Forest Service incorporate various conservative assumptions to 

compensate for uncertainties in the Risk Assessment process. Within any of the steps of the human health risk 

evaluation process, assumptions were made due to a lack of absolute scientific knowledge. Some of the 

assumptions are supported by considerable scientific evidence, while others have less support. Every assumption 

introduces some degree of uncertainty into the risk evaluation process. Regulatory risk evaluation methodology 

requires that conservative assumptions be made throughout the Risk Assessment process to ensure that public 

health is protected. This conservatism, both in estimating exposures and in setting toxicity levels likely led to an 

exaggeration of the real risks of the vegetation management program to err on the side of protecting human 

health and other species.

Cumulative effects of long-term use of herbicides may have different outcomes than Risk Assessments can 

anticipate. Although identification of adverse effects from chronic exposures is one of the parameters examined in 

the Risk Assessment process, it is possible there are long-term sub-lethal effects on reproductive or migratory 

behavior from low concentrations of herbicides or additives that are not documented in the Risk Assessments.

See additional information about uncertainty near the end of Appendix 13 of the Oregon FEIS.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

249

Table C-3. BLM-Evaluated Herbicide Risk Categories1 for Vegetation

Application Scenario Chlorsulfuron Imazapic Overdrive ©3 Sulfometuron Aminopyralid Fluroxypyr Rimsulfuron

Typ.2 Max2 Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max

Direct Spray 

Terrestrial plants H1 H L M M H 0 L H H H H H H

[1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1]

Special Status terrestrial plants H H L M H H H H H H H H H H

[1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1] [1:1]

Aquatic plants, pond M M L L M M H H 0 0 0 L H M

[1:2] [2:2] [1:2] [2:2] [1:2] [1:2] [2:2] [2:2] [2:2] [4:4] [2:2] [2:4] [1:2] [2:4]

Aquatic plants, stream M M L M M H H H 0 0 0 0 H H

[2:2] [2:2] [2:2] [2:2] [1:2] [1:2] [2:2] [2:2] [2:2] [2:2] [2:2] [2:2] [1:2] [1:2]

Accidental Spill to a Pond

Aquatic plants, pond NE

H

NE

H

NE

M

NE

H 0 0 0 L H M

[1:2] [2:2] [1:1] [2:2] [2:2] [4:4] [2:2] [2:4] [1:2] [2:4]

Off-Site Drift

Terrestrial plants M M 0 0 0 0 0 0 L L L L L L

[5:12] [8:12] [18:18] [13:18] [5:6] [4:6] [12:12] [12:12] [10:18] [10:18] [11:18] [11:18] [9:18] [9:18]

Special Status terrestrial plants M M 0 0 L L H H L L L L L L

[7:12] [7:12] [17:18] [13:18] [3:6] [4:6] [5:12] [8:12] [10:18] [10:18] [13:18] [11:18] [9:18] [8:18]

Aquatic plants, pond 0 0 0 0 0 0 L L 0 0 0 0 0 0

[24:24] [24:24] [36:36] [34:36] [12:12] [12:12] [13:24] [12:24] [36:36] [36:36] [36:36] [36:36] [24:36] [23:36]

Aquatic plants, stream 0 0 0 0 0 0 L L 0 0 0 0 0 0

[24:24] [22:24] [36:36] [33:36] [8:12] [6:12] [14:24] [10:24] [36:36] [36:36] [36:36] [36:36] [24:36] [23:36]

Surface Runoff

Terrestrial plants 0 0 0 0 0 0 0 0 0 0 0 0 0 0

[42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42]

Special Status terrestrial plants 0 0 0 0 0 0 0 0 0 0 0 0 0 0

[42:42] [42:42] [42:42] [42:42] [34:42] [33:42] [32:42] [28:42] [42:42] [42:42] [42:42] [42:42] [42:42] [42:42]

Aquatic plants, pond 0 0 0 0 0 0 L L 0 0 0 0 0 0

[64:84] [53:84] [80:84] [62:84] [70:84] [67:84] [42:84] [38:84] [84:84] [84:84] [84:84] [84:84] [55:84] [54:84]

Aquatic plants, stream 0 0 0 0 0 0 0 0 0 0 0 0 0 0

[80:84] [77:84] [84:84] [83:84] [84:84] [84:84] [69:84] [60:84] [84:84] [84:84] [84:84] [84:84] [84:84] [84:84]

Wind Erosion

Terrestrial plants 0 0 0 0 0 0 0 0 0 0 0 0 0 0

[9:9] [9:9] [9:9] [9:9] [9:9] [9:9] [9:9] [9:9] [9:9] [8:9] [9:9] [8:9] [8:9] [8:9]

Special Status terrestrial plants 0 0 0 0 0 0 0 0 0 0 0 0 0 0

[9:9] [9:9] [9:9] [9:9] [9:9] [9:9] [9:9] [9:9] [8:9] [8:9] [8:9] [7:9] [8:9] [8:9]

Aquatic plants, pond NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Aquatic plants, stream NE NE NE NE NE NE NE NE NE NE NE NE NE NE

1. Risk categories: 0 = No risk (majority of RQs < most conservative LOC for non-Special Status species); L = Low risk (majority of RQs 1-10x most conservative LOC for non-Special Status species); M = Moderate risk 

(majority of RQs 10-100x most conservative LOC for non-Special Status species); H = High risk (majority of RQs >100 most conservative LOC for non-Special Status species); and NE = Not evaluated. The Risk Category is 

based on the risk level of the majority of risk quotients observed in any of the scenarios for a given exposure group and receptor type. See more information at the risk tables in Chapter 4 of the Ecological Risk Assessments 

(ENSR 2005c,d,g-j, l), AECOM 2014a, b, 2015) to determine the specific scenarios that result in the displayed level of risk for a given receptor group. The number in brackets represents the number of RQs in the indicated 

risk category: number of scenarios evaluated.

2. Typ = Typical application rate; and Max = Maximum application rate. 3. Overdrive is a formulation of diflufenzopyr + dicamba.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

250

Table C-4. BLM-Evaluated Herbicide Risk Categories1 for Wildlife, Fish, and Aquatic Species

Application Scenario

Chlorsulfuron Imazapic Overdrive ©3 Sulfometuron Aminopyralid Fluroxypyr Rimsulfuron

Typ.2 Max2 Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max

Direct Spray

Non Special Status Species

Small mammal – 100% absorption 01 0 0 0 0 0 0 0 0 0 0 0 0 0

Pollinating insect – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Small mammal – 1st order dermal absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Fish pond 0 0 0 0 0 0 0 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

Fish stream 0 0 0 0 0 0 0 0 0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

Aquatic invertebrates stream 0 0 0 0 0 0 0 0 0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

Special Status Species

Small mammal – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Pollinating insect – 100% absorption 0 0 0 0 0 0 0 0 0 0 L L 0 0

Small mammal – 1st order dermal absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Fish pond 0 0 0 0 0 0 0 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[2:4]

0

[2:2]

0

[4:4]

Fish stream 0 0 0 0 0 0 0 0 0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

Aquatic invertebrates pond 0 0 0 0 0 0 0 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[3:4]

0

[2:2]

0

[4:4]

Aquatic invertebrates stream 0 0 0 0 0 0 0 0 0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

0

[2:2]

Indirect Contact with Foliage After Direct Spray

Non Special Status Species

Small mammal – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Pollinating insect – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Small mammal – 1st order dermal absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Special Status Species

Small mammal – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Pollinating insect – 100% absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Small mammal – 1st order dermal absorption 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Ingestion of Food Items Contaminated by Direct Spray

Non Special Status Species

Small mammalian herbivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Small mammalian herbivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large mammalian herbivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

251

Application Scenario

Chlorsulfuron Imazapic Overdrive ©3 Sulfometuron Aminopyralid Fluroxypyr Rimsulfuron

Typ.2 Max2 Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max

Large mammalian herbivore – chronic 0 0 0 0 L M 0 0 0 0 0 0 0 0

Small avian insectivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Small avian insectivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large avian herbivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large avian herbivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large mammalian carnivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large mammalian carnivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Special Status Species

Small mammalian herbivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Small mammalian herbivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large mammalian herbivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large mammalian herbivore – chronic 0 0 0 0 L M 0 0 0 0 0 0 0 0

Small avian insectivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Small avian insectivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large avian herbivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large avian herbivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large mammalian carnivore – acute 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Large mammalian carnivore – chronic 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Accidental Spill to Pond

Non Special Status Species

Fish pond NE 0 NE 0 NE 0 NE 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

Aquatic invertebrates, pond NE 0 NE 0 NE 0 NE 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

0

[2:2]

0

[4:4]

Special Status Species

Fish pond NE 0 NE 0 NE 0 NE 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[2:4]

0

[2:2]

0

[4:4]

Aquatic invertebrates, pond NE 0 NE 0 NE 0 NE 0 0

[2:2]

0

[4:4]

0

[2:2]

0

[3:4]

0

[2:2]

0

[4:4]

Off-Site Drift

Non Special Status Species

Fish, pond 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

Fish, stream 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

Aquatic invertebrates, pond 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

Aquatic invertebrates, stream 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

252

Application Scenario

Chlorsulfuron Imazapic Overdrive ©3 Sulfometuron Aminopyralid Fluroxypyr Rimsulfuron

Typ.2 Max2 Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max

Special Status Species

Fish, pond 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

Fish, stream 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

Aquatic invertebrates, pond 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

Aquatic invertebrates, stream 0 0 0 0 0 0 0 0 0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

0

[36:36]

Surface Runoff

Non Special Status Species

Fish, pond 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

Fish, stream 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

Aquatic invertebrates, pond 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

Aquatic invertebrates, stream 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

Special Status Species

Fish, pond 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

Fish, stream 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

Aquatic invertebrates, pond 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

Aquatic invertebrates, stream 0 0 0 0 0 0 0 0 0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

0

[84:84]

1. Risk categories: 0 = No risk (majority of RQs < most conservative LOC for non-Special Status species); L = Low risk (majority of RQs 1-10x most conservative LOC for non-Special Status species); M = Moderate risk 

(majority of RQs 10-100x most conservative LOC for non-Special Status species); H = High risk (majority of RQs >100 most conservative LOC for non-Special Status species); and NE = Not evaluated. The risk category is based 

on the risk level of the majority of risk quotients observed in any of the scenarios for a given exposure group and receptor type. See the risk tables in Chapter 4 of the Ecological Risk Assessments (ENSR 2005b-k, AECOM 

2014a, b, 2015) to determine the specific scenarios that result in the displayed level of risk for a given receptor group. The number in brackets represents the number of RQs in the indicated risk category: number of 

scenarios evaluated.

2. Typ = Typical application rate; and Max = Maximum application rate.

3. Overdrive is a formulation of diflufenzopyr + dicamba.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

253

Table C-5. BLM-Evaluated Herbicide Risk Categories1 for Human Health

Receptor Diflufenzopyr Imazapic Sulfometuron Aminopyralid Fluroxypyr Rimsulfuron3

Typ2 Max2 Accid Typ Max Accid Typ Max Accid Typ Max Accid Typ Max Accid Typ Max Accid

Hiker/hunter (adult) 01 0 0 NC NC NE NC NC NE NC NC NE NC NC NE 0 0 0

Berry picker (child) 0 0 0 NC NC NE NC NC NE NC NC NE NC NC NE 0 0 0

Berry picker (adult) 0 0 0 NC NC NE NC NC NE NC NC NE NC NC NE 0 0 0

Angler (adult) 0 0 0 NC NC NE NC NC NE NC NC NE NC NC NE 0 0 0

Residential – contaminated water 

(child) 0 0 0 NC NC NE NC NC NE NC NC NE NC NC NE 0 0 0

Residential – contaminated water 

(adult) 0 0 0 NC NC NE NC NC NE NC NC NE NC NC NE 0 0 0

Native American (child) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Native American (adult) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Swimmer (child) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NE NE NE

Swimmer (adult) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NE NE NE

Human/backpack -

applicator/mixer/loader 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

Human/horseback - applicator 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

Human/horseback - mixer/loader 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

Human/horseback -

applicator/mixer/loader 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

ATV – applicator4 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

ATV - mixer/loader 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

ATV - applicator/mixer/loader 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

Truck - applicator4 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

Truck - mixer/loader 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

Truck - applicator/mixer/loader 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 NE 0 0 L - M

Boat - applicator NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Boat - mixer/loader NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Boat - applicator/mixer/loader NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

1. Risk categories: 0 = No risk (majority of ARIs > 1); L = Low risk (majority of ARIs >1 but < 0.1); M = Moderate risk (majority of ARIs > 0.1 but < 0.01); H = High risk (majority of ARIs < 0.01); NE = Not evaluated; and NC = Not 

Calculated (based on toxicity assessment, no dose response values are available due to low toxicity. The reported risk category represents the typical/most common risk level for estimated risks from various time periods. 

See the Vegetation Treatments Programmatic EISs Human Health Risk Assessments Final Reports (ENSR 2005l, AECOM 2014c) and for the range of risk levels for each scenario.

2. Typ = Typical application rate; Max = Maximum application rate; and Accid = Accidental rate. Typical and maximum application rate categories include short-, intermediate-, and long-term exposures. Accidental scenario 

category includes accidents with herbicide mixed at both the typical and maximum application rates and with a concentrated herbicide.

3. For all worker receptors accidentally exposed to rimsulfuron, there is low risk from exposure to solutions mixed with the typical application rate, moderate risk from exposure to solutions mixed with the maximum 

application rate.

4. ATV and Truck categories include spot and boom/broadcast application scenarios.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

254

Table C-6. Forest Service-Evaluated Herbicide Risk Categories1 for Vegetation

2,4-D2, 4 Clopyralid Dicamba Glyphosate3, 4 Hexazinone Imazapyr3 Metsulfuron

methyl Picloram3 Triclopyr3,4 Fluazifop-Pbutyl6

Typ.5 Max5 Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max 0.16 0.3756

Terrestrial Plants

Direct spray, susceptible plants H1 H H H H H H H H H H H H H H H H H M M

Direct spray, tolerant plants L L 0 L 0 0 L M M M L L L M L M 0 L 0 0

Off-site drift, low boom, 

susceptible plants

L L L M L H M M L M M H L M H H L M 0 0

[3:6] [3:6] [4:6] [3:6] [3:6] [3:6] [3:6] [4:6] [4:6] [3:6] [3:6] [3:6] [4:6] [4:6] [3:6] [4:6] [3:6] [3:6] [6:6] [5:6]

Off-site drift, low boom, tolerant 

plants

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

[6:6] [6:6] [6:6] [6:6] [6:6] [6:6] [6:6] [6:6] [5:6] [4:6] [6:6] [6:6] [6:6] [6:6] [6:6] [6:6] [6:6] [6:6] [6:6] [6:6]

Off-site drift, backpack directed 

foliar, susceptible plants

0

[5:6]

0

[4:6] NE NE NE NE L[3:6]

M

[3:6]

L

[3:6]

L

[4:6]

M

[3:6]

M

[4:6] NE NE M[3:6]

M

[4:6]

0

[4:6]

0

[4:6]

0

[6:6]

0

[6:6]

Off-site drift, backpack directed 

foliar, tolerant plants

0

[6:6]

0

[6:6] NE NE NE NE 0[6:6]

0

[6:6]

0

[6:6]

0

[6:6]

0

[6:6]

0

[6:6] NE NE 0[6:6]

0

[6:6]

0

[6:6]

0

[6:6]

0

[6:6]

0

[6:6]

Surface runoff, susceptible plants 0 0 0 0 0 0 0 0 0 0 H H 0

[21:30]

0

[18:30] H H L M 0 0 [22:30] [21:30] [23:30] [22:30] [22:30] [22:30] [18:30] [17:30]

Surface runoff, tolerant plants 0 0 0 0 0 0 0 0 0 0 L M

0 0 0 0 0 0 0 0 [30:30] [29:30] [30:30] [28:30] [30:30] [30:30] [22:30] [22:30] [25:30] [22:30]

Aquatic Plants

Accidental spill, susceptible 

macrophytes H H H H NE NE H H NE NE H H H H NE NE H H NE NE

Accidental spill, susceptible algae H H L L H H H H H H L L M H H H H H H H

Accidental spill, tolerant algae L M 0 0 0 L M M H H 0 0 L M 0 0 M H L L

Acute exposure, susceptible 

macrophytes M M 0 0 NE NE L L NE NE M H L L NE NE 0 L NE NE

Acute exposure, susceptible

algae L L 0 0 0 L L L H H 0 0 0 0 L L M H M M

Acute exposure, tolerant algae 0 0 0 0 0 0 0 0 L M 0 0 0 0 0 0 0 0 0 0

Chronic exposure, susceptible 

macrophytes 0 L 0 0 NE NE 0 0 NE NE M M 0 0 NE NE H H NE NE

Chronic exposure, susceptible 

algae 0 0 0 0 0 0 0 0 M M 0 0 0 0 0 0 0 0 L M

Chronic exposure, tolerant algae 0 0 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 0

Shading denotes herbicides that are limited by Mitigation Measures to typical application rates where feasible.

1. Risk categories: 0 = No risk (HQ < LOC); L = Low risk (HQ = 1 to 10 x LOC); M = Moderate Risk (HQ = 10 to 100 x LOC); H = High risk (HQ > 100 LOC); and NE = Not evaluated. Risk categories are based on upper estimates of 

hazard quotients and the LOC of 1.0. If more than one scenario is involved in an exposure pathway (i.e., off-site drift and surface runoff), then the number of scenarios with the given risk category (out of the total number 

of evaluated scenarios) is displayed in parentheses. The reported risk category is that of the majority of the HQs for all the scenarios. As a result, risk may be higher than the reported risk category for some scenarios within 

each category. For more information, see the individual Forest Service Risk Assessments.

2. In the 2010 FEIS, 2,4-D maximum risk ratings were calculated at 4 lbs./acre, although the FEIS stated that the BLM maximum rate was 1.9 lbs./acre. The risk ratings in this table reflect a maximum rate of 1.9 lbs./acre.

3. Glyphosate, imazapyr, picloram, and triclopyr Risk Assessments were updated in 2011. The risk ratings in this table reflect these 2011 Risk Assessments and may differ from the risk ratings shown in the 2010 FEIS.

4. Risk categories for the more toxic formulations are presented here. 5. Typ = Typical application rate; and Max = Maximum application rate.

6. Taken from scoping/screening level Risk Assessment Final Report (SERA 2014).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

255

Table C-7. Forest Service-Evaluated Herbicide Risk Categories1 for Wildlife, Fish, and Aquatic Species

2,4-D2,4 Clopyralid Dicamba Glyphosate3,4 Hexazinone Imazapyr3 Metsulfuron 

methyl Picloram3 Triclopyr3,4 Fluazifop-Pbutyl6

Typ5 Max5 Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max 0.16 0.3756

Mammals

Acute/Accidental Exposures

Direct spray, small mammal, 1st order absorption 01 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Direct spray, small animal, 100% absorption L L L L 0 0 0 L L L 0 0 0 L 0 0 0 L 0 0

Consumption of contaminated fruit, small mammal L L 0 0 0 L 0 L 0 0 0 0 0 0 0 0 0 L 0 0

Consumption of contaminated grass, large mammal L L L L L M L L L L 0 0 0 L 0 0 M H 0 0

Consumption of contaminated water, small mammal, 

spill 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Consumption of contaminated water, small mammal, 

stream

NE NE 0 0 0 0 NE NE 0 0 NE NE 0 0 NE NE NE NE 0 0

Consumption of contaminated insects, small mammal L L L L L M L L L L 0 0 0 L 0 0 0 L 0 0

Consumption of contaminated small mammal, 

predatory mammal L L 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L 0 0

Chronic Exposures

Consumption of contaminated vegetation, small 

mammal, on- site M M 0 0 0 0 L L 0 0 0 0 0 0 L M L M L M

Consumption of contaminated vegetation, small 

mammal, off- site NE NE 0 0 0 0 NE NE 0 0 NE NE 0 0 NE NE NE NE NE NE

Consumption of contaminated vegetation, large 

mammal, on- site L L 0 L 0 0 0 0 L M 0 0 0 0 0 L M H L L

Consumption of contaminated vegetation, large 

mammal, off -site NE NE 0 0 0 0 NE NE 0 0 NE NE 0 0 NE NE NE NE NE NE

Consumption of contaminated water, small mammal 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Birds

Acute/Accidental Exposures

Consumption of contaminated grass, large bird 0 0 0 L L M 0 L L L 0 0 0 0 0 0 L M 0 0

Consumption of contaminated insects, small bird 0 L 0 L L M 0 L L L 0 0 0 0 0 0 L M 0 0

Consumption of contaminated small mammal, 

predatory bird 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 0 0 0

Consumption of contaminated fish, predatory bird, 

spill 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 0 0 0 0 0

Chronic Exposures

Consumption of contaminated vegetation, large bird, 

on-site 0 0 0 L 0 0 L L 0 0 0 0 0 0 0 L L M L M

Consumption of contaminated vegetation, large bird, 

off-site NE NE 0 0 0 0 NE NE 0 0 NE NE 0 0 NE NE NE NE NE NE

Consumption of contaminated fish, predatory bird 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

256

2,4-D2,4 Clopyralid Dicamba Glyphosate3,4 Hexazinone Imazapyr3 Metsulfuron 

methyl Picloram3 Triclopyr3,4 Fluazifop-Pbutyl6

Typ5 Max5 Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max Typ. Max 0.16 0.3756

Aquatic Species

Acute/Accidental Exposures

Fish (susceptible species7) – accidental spill H H L L 0 L H H L L 0 L 0 L M M H H M M

Fish (tolerant species) – accidental spill L L 0 0 0 0 M H 0 L NE NE 0 0 0 L M H M M

Fish (susceptible species) – acute exposure, peak EEC L L 0 0 0 0 L M 0 0 0 0 0 0 0 0 0 L 0 0

Fish (tolerant species) – acute exposure, peak EEC 0 0 0 0 0 0 0 L 0 0 NE NE 0 0 0 0 0 0 0 0

Aquatic invertebrates – accidental spill 0 0 L M L M M M L L 0 0 0 0 0 0 L M L L

Aquatic invertebrates – acute exposure, peak EEC 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Chronic Exposures

Fish – chronic exposure 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NE NE

Aquatic invertebrates – chronic exposure 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Insects

Acute Exposures

Direct spray, bee, 100% absorption NE NE 0 L NE NE NE NE L L NE NE 0 0 NE NE NE NE NE NE

Consumption of fruit by a herbivorous insect NE NE NE NE NE NE 0 0 NE NE 0 0 NE NE 0 0 0 0 0 0

Consumption of broadleaf/small Insects by a 

herbivorous Insect

NE NE NE NE NE NE L L NE NE 0 0 NE NE 0 0 0 L 0 0

Consumption of short grass by a herbivorous insect NE NE NE NE NE NE L L NE NE 0 0 NE NE 0 0 0 L 0 0

Consumption of tall grass by a herbivorous insect NE NE NE NE NE NE L L NE NE 0 0 NE NE 0 0 0 L 0 0

Shading denotes herbicides that are limited by Mitigation Measures to typical application rates where feasible.

1. Risk categories: 0 = No risk (HQ < LOC); L = Low risk (HQ = 1 to 10 x LOC); M = Moderate risk (HQ = 10 to 100 x LOC); H = High risk (HQ > 100 LOC); and NE = Not evaluated. Risk categories are based on upper estimates of 

hazard quotients and the BLM LOCs of 0.1 for acute scenarios and 1.0 for chronic scenarios. The reader should consult the text of this section of the individual Forest Service Risk Assessments to evaluate risks at central 

estimates of hazard quotients.

2. In the 2010 FEIS, 2,4-D maximum risk ratings were calculated at 4 lbs./acre, although the FEIS stated that the BLM maximum rate was 1.9 lbs./acre. The risk ratings in this table reflect a maximum rate of 1.9 lbs./acre.

3. Glyphosate, imazapyr, picloram, and triclopyr Risk Assessments were updated in 2011. The risk ratings in this table reflect these 2011 Risk Assessments and may differ from the risk ratings shown in the 2010 FEIS.

4. Risk levels for the more toxic formulations are presented here.

5. Typ = typical application rate; and Max = maximum application rate.

6. Taken from scoping/screening level Risk Assessment Final Report (SERA 2014).

7. Fish susceptible species include coldwater fish, such as trout, salmon, and federally listed species. Fish tolerant species include warm water fish, such as fathead minnows.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix C – Herbicide Risk Assessment Summaries

257

Table C-8. Forest Service-Evaluated Herbicide Risk Categories1 for Human Health

2,4-D2,4 Chlorsulfuron Clopyralid Dicamba Glyphosate3,4 Hexazinone Imazapyr3 Metsulfuron 

methyl Picloram3 Triclopyr3,4 Fluazifop-Pbutyl6

Typ5 Max5 Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max Typ Max 0.16 0.3756

Workers

General Exposures

Directed foliar and spot treatments (backpack) L1 L 0 0 0 0 0 0 0 0 0 L 0 0 0 0 0 0 0 L 0 0

Broadcast ground spray (boom spray) L L 0 L 0 0 0 L 0 0 0 L 0 0 0 0 0 0 0 L 0 0

Aquatic applications L L NE NE NE NE NE NE 0 0 0 NE 0 0 NE NE NE NE NE NE NE NE

Accidental/Incidental Exposures

Immersion of hands 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Wearing contaminated gloves M M 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L 0 0

Spill on hands 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Spill on lower legs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Public

Acute/Accidental Exposures

Direct spray - child, entire body 0 L 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Direct spray - woman, lower legs 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L 0 0

Dermal - contaminated vegetation, woman 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L 0 0

Consumption of contaminated fruit 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L 0 0

Consumption of contaminated water - pond, spill NE NE 0 0 0 L 0 L NE NE 0 0 NE NE 0 0 NE NE NE NE NE NE

Consumption of contaminated water - stream, 

ambient NE NE 0 0 0 0 0 0 NE NE 0 0 NE NE 0 0 NE NE NE NE NE NE

Consumption of contaminated water - child 0 0 NE NE NE NE NE NE 0 L NE NE 0 0 NE NE 0 0 0 L 0 0

Consumption of contaminated fish - general public 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Consumption of contaminated fish - subsistence 

populations 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L

Chronic/Longer-term Exposures

Consumption of contaminated fruit 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 L 0 0

Consumption of contaminated water 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Consumption of contaminated fish - general public 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Consumption of contaminated fish - subsistence 

populations 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Shading denotes herbicides that are limited by Mitigation Measures to typical application rates where feasible.

1. Risk categories: 0 = No risk (majority of HQs < 1); L = Low risk (majority of HQs >1 but < 10); M = Moderate risk (majority of HQs > 10 but < 100); H = High risk (majority of HQs > 100); and NE = Not evaluated. Risk 

categories are based on central HQ estimates. To determine risk for lower or upper HQ estimates, see the individual herbicide Risk Assessments. Risk categories are based on comparison to the HQ of 1 for typical and 

maximum application rates.

2. In the 2010 FEIS, 2,4-D maximum risk ratings were calculated at 4 lbs./acre, although the FEIS stated that the BLM maximum rate was 1.9 lbs./acre. The risk ratings in this table reflect a maximum rate of 1.9 lbs./acre.

3. Glyphosate, imazapyr, picloram, and triclopyr Risk Assessments were updated in 2011. The risk ratings in this table reflect these 2011 Risk Assessments and may differ from the risk ratings shown in the 2010 FEIS.

4. Where different formulations exist, risks reported are the most conservative.

5. Typ = Typical application rate; and Max = Maximum application rate. 6. Taken from scoping/screening level Risk Assessment Final Report (SERA 2014).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

258 

Appendix D - Invasive Plant Infestations

Table D-1. Invasive Plants Mapped in NISIMS by Infestation Size. NISIMS (described in the Inventory section in 

Chapter 2) includes 18,100 gross acres of documented invasive plant sites on the Coos Bay District. These are 

summarized on Table 2-2, and are displayed in Map 2-1 (maps are located at the end of this EA).

Table D-2. Further Information about Invasive Plant Species. Includes low priority species (Category IV) as well as 

family, type (woody, grass, or herbaceous), and life cycle information for species on (or potentially on) the District.

Table D-3. Estimated Total Treatment Acres, 20-Year Analysis Period, Including Tank Mixes and Application Rates

Table D-4. Estimated Total Treatment Acres, 20-Year Analysis Period (Not Including Tank Mixes or Application 

Rates)

Invasive Plant Treatments Example

The following example is provided to illustrate how adaptive management and effectiveness monitoring would be 

implemented within the context of invasive plant treatments. Integrated invasive plant management includes a 

process to determine when and where to take action. The Integrated Vegetation Management Manual (USDI 

2008a:59) describes an adaptive management approach based on clearly identified outcomes, monitoring to 

determine if management actions are meeting, and if not, facilitating management changes that will best ensure 

that outcomes are met or re-evaluated. 

The Planning sub-section of the Integrated Invasive Plant Management section in Chapter 2 describes that the 

district manages invasive plants to minimize adverse effects to ecological function and that setting treatment 

priorities is primarily driven by the resources that would be adversely affected by the invasive plants such as 

habitats for Special Status species. Because of this, the Annual Treatment Plan (Table 2-9) shows that Canada 

thistle would be treated in the Hunter Creek ACEC as habitat enhancement for the Mardon skipper, a rare 

butterfly. Canada thistle is in the sunflower family in the Treatment Key (Table 2-10), which shows potential 

treatment options for this infestation. As described in Invasive Plant Issue 1, mowing Canada thistle is effective 

when it is repeated every 3 to 4 weeks over several growing seasons (DiTomaso et al. 2013), but this frequency of 

mowing is not practical (estimated at 3 to 6 times a year) and woody debris precludes the use of mowing in many 

areas. Canada thistle can be effectively controlled with dicamba or picloram, but these herbicides are not 

registered for use in the wetland and riparian areas, like Hunter Creek. Under the Proposed Action, aminopyralid 

and clopyralid would both be effective treatment methods for Canada thistle. In the first year, clopyralid could be 

used on Canada thistle, applied at the rosette stage. The Effectiveness Monitoring section (Chapter 2) describes 

that sites are revisited following treatments to assess how the infestation and associated plant community have 

changed over time. This would be done several months after treatments; clopyralid takes two weeks after contact 

to kill target weeds but can take several weeks for complete control. Staff conducting the monitoring would look at 

factors such as the size and density of the Canada thistle infestation; the amount of colonization by nearby invasive 

annual grasses; the amount of damage or mortality in neighboring native species in the figwort family as well as 

their growth, vigor, and population density; and the need for follow-up treatments. If the native figwort family 

species were unharmed by this treatment and were able to colonize the site (instead of the invasive annual 

grasses) and the population of Canada thistle was reduced, but not eliminated, another follow-up treatment would 

occur the following spring. However, spring rain accelerates seed growth, and in the spring, the Canada thistle 

seedbank may have begun to produce additional plants. Hence, aminopyralid would be used during the second 

year, as it has longer soil residual than clopyralid. If the original treatment eliminates the Canada thistle but the 

site is reinfested with invasive annual grasses, the annual grass treatment group in the Treatment Key (Table 2-10) 

indicates that imazapic would be an appropriate treatment method during the second year.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

259

Table D-1. Invasive Plants Mapped in NISIMS by Infestation Size

Common Name Scientific Name NISIMS 

Code

< 0.1 Acres 0.1 to < 0.5 0.5 to <1 1 to < 5 5 to <20 20 to < 100 > 100

Acres Sites Acres Sites Acres Sites Acres Sites Acres Sites Acres Sites Acres Sites

Silver wattle Acacia dealbata ACDE3 0.12 2

Biddy-biddy Acaena novae-zealandiae ACNO4 0.56 9 1.95 5 4.19 1 11.62 1 34.62 1

European beachgrass Ammophila arenaria AMAR4 0.12 2 1.28 4 2.74 4 1.24 1 53.32 2

False brome Brachypodium sylvaticum BRSY 0.50 5 2.02 6 15.56 6 38.93 3 218.17 6

Butterfly bush Buddleja davidii BUDA2 1.53 2 1.45 1 34.62 1

Meadow knapweed Centaurea x moncktonii CEDET 1.74 55 9.35 31 22.47 29 59.24 32 62.42 8

Meadow knapweed Centaurea x moncktonii CEMO6 9.15 92 8.88 22 1.67 3 34.62 1

Canada thistle Cirsium arvense CIAR4 40.60 439 18.16 68 10.01 14 75.83 33 43.00 5

Bull thistle Cirsium vulgare CIVU 187.41 1,982 128.14 411 150.80 206 428.81 219 102.19 14

Old man's beard Clematis vitalba CLVI6 1.20 13 2.35 1 6.08 1

Field bindweed Convolvulus arvensis COAR4 0.20 2

Jubata grass Cortaderia jubata COJU2 0.41 8 0.18 1

One seed hawthorn Crataegus monogyna CRMO3 1.57 2

Scotch broom Cytisus scoparius CYSC4 278.45 3,562 1,102.14 3,681 1,272.67 1,765 3,756.12 1,983 943.91 114 788.57 22 2,286.29 2

Teasel/Fuller's teasel Dipsacus fullonum DIPSA 1.54 16 5.08 14 11.53 6 12.73 2

Fennel Foeniculum vulgare FOVU 0.10 1

French broom Genista monspessulana GEMO2 29.46 360 47.82 148 10.14 15 247.77 126 153.30 14 201.95 5 105.19 1

Herb Robert Geranium robertianaum GERO 11.96 124 16.36 54 6.18 8 33.59 20 25.55 2 25.98 1

English/Atlantic ivy Hedera helix HEHE 1.69 21 0.43 1 10.40 5 12.11 1

St. Johnswort Hypericum perforatum HYPE 0.93 12 3.77 11 4.23 6 2.43 2

English holly Ilex aquifolium ILAQ80 0.76 1

Yellow flag iris Iris psuedacorus IRPS 0.00 1

Perennial peavine Lathyrus latifolia LALA4 3.14 33 0.73 3 1.96 3 2.94 2

Oxeye daisy Leucanthemum vulgare LEVU 0.96 2 2.39 2

Birdsfoot trefoil

Lotus corniculatus/

L. angustissimus/

L. pedunculatus

LOCO6 0.10 1 0.46 1 0.84 1 1.17 1

Purple loosestrife Lythrum salicaria LYSA2 0.11 7 4.45 17 12.40 5

White/yellow sweetclover Melilotus albus /M. 

officianalis MEAL2 5.45 56 3.52 8 1.45 2 2.81 2 7.27 1

Reed canarygrass Phalaris arundinacea PHAR3 0.36 1

Japanese knotweed Polygonum cuspidatum POCU6 1.91 81 0.70 3 2.89 4 5.55 1

Giant knotweed Polygonum sachalinensis POSA4 0.77 8 0.33 2

Himalayan blackberry Rubus armeniacus RUAR9 159.60 1,716 379.24 1,158 401.13 557 1,409.20 697 782.40 94 714.08 17 2,550.15 3

Evergreen/cutleaf blackberry Rubus laciniatus RULA 25.70 259 11.11 39 4.92 7 21.79 13

Tansy ragwort Senecio jacobaea SEJA 3.84 47 11.41 37 8.08 11 21.87 13

Gorse Ulex europaeus ULEU 7.53 113 10.20 33 7.83 10 11.13 4

Bigleaf/common periwinkle Vinca major/V. minor VIMI2 0.10 1

Calla lily Zantedeschia aethiopica ZAAE 0.00 1
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

260

Table D-2. Further Information about Invasive Plant Species on the District

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Alfalfa Medicago sativa 10 Fabaceae Annual, perennial Herbaceous Pea Family

x Alsike clover Trifolium hybridum 1 Fabaceae Annual, perennial Herbaceous Pea Family

x American/European-sea rocket Cakile edentula/maritima 232 Brassicaceae Annual, biennial, 

perennial Herbaceous Mustard Family

x Annual bluegrass Poa annua 1 Poaceae Annual Grass Annual Grasses

x Annual honesty Lunaria annua 1 Brassicaceae Annual Herbaceous Mustard Family

x Annual rabbitsfoot grass Polypogon monspeliensis 1 Poaceae Annual Grass Annual Grasses

x Annual ryegrass Lolium multiflorum 10 Poaceae Annual Grass Annual Grasses

x Annual yellow sweetclover Melilotus indicus 0 Fabaceae Annual Herbaceous Pea Family

x Bachelor buttons Centaurea cyanus 5 Asteraceae Annual Herbaceous Sunflower Family

x Barestem teesdalia Teesdalia nudicaulis 1 Brassicaceae Annual Herbaceous Mustard Family

x Barnyard grass Echinochloa crus-galli 1 Poaceae Annual Grass Annual Grasses

x Bermuda grass Cynodon dactylon 10 Poaceae Perennial Grass Perennial Grasses

x Biddy-biddy Acaena novae-zealandiae 20 Roseaceae Perennial Herbaceous Misc. Herbaceous

x Big quakinggrass Briza maxima 30 Poaceae Annual Grass Annual Grasses

x Bigleaf/common periwinkle Vinca major/V. minor 5 Apocynaceae Perennial Herbaceous Misc. Herbaceous

x Bindweed Solanum dulcamara 0 Solanaceae Perennial Herbaceous Misc. Herbaceous

x Birdsfoot trefoil Lotus corniculatus /L. 

angustissimus/L. pedunculatus 20 Fabaceae Perennial Herbaceous Pea Family

x Bitter dock Rumex obtusifolius 10 Polygonaceae Perennial Herbaceous Knotweed Family

x Black locust Robinia pseudoacacia 0 Fabaceae Perennial Woody Woody Species

x Black medick Medicago lupulina 10 Fabaceae Annual, perennial Herbaceous Pea Family

x Black mustard Brassica nigra 1 Brassicaceae Annual Herbaceous Mustard Family

x Blessed milkthistle Silybum marianum 1 Asteraceae Biennial Herbaceous Sunflower Family

x Blue field madder Sherardia arvensis 1 Rubiaceae Annual Herbaceous Misc. Annual Herbaceous

x Blue flax Linum bienne 1 Linaceae Perennial Herbaceous Misc. Herbaceous

x Bouncingbet Saponaria officinalis 5 Caryophylllaceae Perennial Herbaceous Carnation Family

x Brassbuttons Cotula australis 1 Asteraceae Annual Herbaceous Sunflower Family

x Bristleleaf bulrush Isolepis setacea 1 Cyperaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Bristly dogtail grass Cynosurus echinatus 10 Poaceae Annual Grass Annual Grasses

x Brome fescue Vulpia bromoides 15 Poaceae Annual Grass Annual Grasses

x Broomcorn millet Panicum miliaceum 5 Poaceae Annual Grass Annual Grasses

x Brown fruited rush Juncus pelocarpus 1 Juncaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Buckhorn plantain Plantago coronopus 10 Plantaginaceae Perennial Herbaceous Misc. Herbaceous

x Buffalobur nightshade Solanum rostratum 0 Solanaceae Annual Herbaceous Misc. Annual Herbaceous

x Bull thistle Cirsium vulgare 500 Asteraceae Biennial Herbaceous Sunflower Family
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

261

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Burdock Arctium minus 10 Asteraceae Biennial Herbaceous Sunflower Family

x Butterfly bush Buddleja davidii 5 Scrophulariaceae Perennial Woody Woody Species

x Calla lily Zantedeschia aethiopica 1 Araceae Perennial Herbaceous Lilies, Iris, Sedges, Rushes

x Canada bluegrass Poa compressa 1 Poaceae Perennial Grass Perennial Grasses

x Canada rush Juncus canadensis 1 Juncaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Canada thistle Cirsium arvense 800 Asteraceae Perennial Herbaceous Sunflower Family

x Cape ivy Delairea odorata 1 Asteraceae Perennial Herbaceous, 

woody Woody Species

x Catchfly Silene gallica 5 Caryophyllaceae Annual, biennial Herbaceous Carnation Family

x Changing forget-me-not Myosotis discolor (M. bicolor) 1 Boraginaceae Annual, perennial Herbaceous Borage Family

x Cheatgrass Bromus tectorum 1 Poaceae Annual Grass Annual Grasses

x Cheeseweed Malva neglecta 5 Malvaceae Biennial Herbaceous Misc. Herbaceous

x Chicory Cichorium intybus 5 Asteraceae Biennial, perennial Herbaceous Sunflower Family

x Clasping pepperweed Lepidium perfoliatum 1 Brassicaceae Annual, biennial Herbaceous Mustard Family

x Clustered dock Rumex conglomeratus 10 Polygonaceae Perennial Herbaceous Knotweed Family

x Coastal burnweed Erechtites (Syn. Senecio) minimus 20 Asteraceae Annual, perennial Herbaceous Sunflower Family

x Colonial bent grass Agrostis capillaris 5 Poaceae Annual Grass Annual Grasses

x Comfrey Symphytum x uplandicum 1 Boraginaceae Perennial Herbaceous Borage Family

x Common chickweed Stellaria media 5 Caryophyllaceae Annual Herbaceous Carnation Family

x Common milkwort Polygala vulgaris 0 Polygalaceae Perennial Herbaceous none

x Common mullein Verbascum thapsus 5 Scrophulariaceae Biennial Herbaceous Snapdragon Family

x Common mustard Brassica rapa 1 Brassicaceae Annual, biennial Herbaceous Mustard Family

x Common plantain Plantago major 5 Plantaginaceae Perennial Herbaceous Misc. Herbaceous

x Common ragweed Ambrosia artemisiifolia 1 Asteraceae Annual Herbaceous Sunflower Family

x Common reed Phragmites australis 0 Poaceae Perennial Grass Perennial Grasses

x Common sow thistle Sonchus oleraceus 40 Asteraceae Annual Herbaceous Sunflower Family

x Comon brassbuttons Cotula coronipifolia 1 Asteraceae Perennial Herbaceous Sunflower Family

x Corn speedwell Veronica arvensis 10 Plantaginaceae Annual Herbaceous Misc. Annual Herbaceous

x Corn spurry/sandspurry Spergula arvensis/Spergularia 

maritima/S. rubra 1 Caryophyllaceae Annual Herbaceous Carnation Family

x Cotoneaster Cotoneaster franchetii/C. lacteus 20 Roseaceae Perennial Woody Woody Species

x Cranesbill Geranium molle 10 Geraniaceae Annual, biennial, 

perennial Herbaceous Geranium Family

x Creeping bent grass Agrostis stolonifera 5 Poaceae Perennial Grass Perennial Grasses

x Creeping buttercup Ranunculus repens 50 Ranunculaceae Perennial Herbaceous Misc. Herbaceous

x Creeping sedge Carex chordorrhiza 2 Cyperaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Creeping wood sorrel Oxalis corniculata 10 Oxalidaceae Annual, perennial Herbaceous Misc. Herbaceous
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

262

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Creeping yellow cress Rorippa sylvestris 1 Brassicaceae Perennial Herbaceous Mustard Family

x Crested dogtail grass Cynosurus cristatus 1 Poaceae Annual Grass Annual Grasses

x Curly dock Rumex crispus 10 Polygonaceae Perennial Herbaceous Knotweed Family

x Cut leaf teasel Dipsacus laciniatus 0 Dipsacaceae Biennial Herbaceous Teasels

x Cutleaf burnweed Erechtities glomeratus 10 Asteraceae Annual, perennial Herbaceous Sunflower Family

x Cutleaf geranium Geranium dissectum 10 Geraniaceae Annual, biennial Herbaceous Geranium Family

x Daggerleaf cottonrose Logfia gallica 1 Asteraceae Annual Herbaceous Sunflower Family

x Dallisgrass Paspalum dilatatum 1 Poaceae Perennial Grass Perennial Grasses

x Dalmatian toadflax Linaria dalmatica 0 Scrophulariaceae Perennial Herbaceous Snapdragon Family

x Dandelion Taraxacum officinale 5 Asteraceae Perennial Herbaceous Sunflower Family

x Darwin’s barberry Berberis darwinii 5 Berberidaceae Perennial Woody Woody Species

x Deptford pink Dianthus armeria 1 Caryophyllaceae Annual, biennial Herbaceous Carnation Family

x Diffuse knapweed Centaurea diffusa 1 Asteraceae Annual, biennial, 

perennial Herbaceous Sunflower family

x Dog rose Rosa canina 1 Roseaceae Perennial Woody Woody Species

x Dogfennel Anthemis cotula 1 Asteraceae Annual Herbaceous Sunflower Family

x Earth loosestrife Lysimachia terrestris 0 Primulaceae Perennial Herbaceous Loosestrifes

x English daisy Bellis perennis 2 Asteraceae Perennial Herbaceous Sunflower Family

x English holly Ilex aquifolium 10 Aquifoliaceae Perennial Woody Woody Species

x English/Atlantic ivy Hedera helix 100 Arailiaceae Perennial Woody Woody Species

x European beachgrass Ammophila arenaria 240 Poaceae Perennial Grass Perennial Grasses

x European centaury Centarium erythraea 1 Gentianaceae Annual, biennial Herbaceous Misc. Annual Herbaceous

x European crabapple Malus sylvestris 0 Roseaceae Perennial Woody Woody Species

x Evergreen/cutleaf blackberry Rubus laciniatus 100 Roseaceae Perennial Woody Woody Species

x Fall panicgrass Panicum dichotomiflorum 1 Poaceae Annual Grass Annual Grasses

x False brome Brachypodium sylvaticum 200 Poaceae Perennial Grass Perennial Grasses

x False dandelion Hypochaeris radicata/H. glabra 25 Asteraceae Perennial Herbaceous Sunflower Family

x Fennel Foeniculum vulgare 10 Apiaceae Perennial Herbaceous Perennial Parsley Family

x Field bindweed Convolvulus arvensis 10 Convolvulaceae Perennial Herbaceous,

woody Misc. Herbaceous

x Field burrweed Soliva sessilis 1 Asteraceae Annual Herbaceous Sunflower Family

x Field chickweed Cerastium arvense 1 Caryophyllaceae Perennial Herbaceous Carnation Family

x Field pennycress Thlaspi arvense 1 Brassicaceae Annual Herbaceous Mustard Family

x Fourleaf manyseed Polycarpon tetraphyllum 1 Caryophyllaceae Annual, biennial, 

perennial Herbaceous Carnation Family

x French broom Genista monspessulana 500 Fabaceae Perennial Woody Woody Species

x Garden vetch Vicia sativa 10 Fabaceae Annual Herbaceous Pea Family
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

263

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Garden yellow loosestrife Lysimachia vulgaris 0 Primulaceae Perennial Herbaceous Loosestrifes

x Garlic mustard Alliaria petiolata 0 Brassicaceae Annual, biennial Herbaceous Mustard Family

x German knotgrass Scleranthus annuus 5 Caryophyllaceae Annual Herbaceous Carnation Family

x Giant hogweed Heracleum mantegazzianum 0 Apiaceae Annual Herbaceous Misc. Annual Herbaceous

x Giant knotweed Polygonum sachalinensis 100 Polygonaceae Perennial Herbaceous Knotweed Family

x Gorse Ulex europaeus 40 Fabaceae Perennial Woody Woody Species

x Green bristlegrass Setaria viridis 1 Poaceae Perennial Grass Perennial Grasses

x Green stem filaree Erodium moschatum 5 Geraniaceae Annual, biennial Herbaceous Geranium Family

x Ground ivy Glechoma hederacea 0 Lamiaceae Perennial Herbaceous Perennial Mints

x Hairy crabgrass Digitaria sanguinalis 10 Poaceae Annual, biennial Grass Annual Grasses

x Hairy vetch Vicia hirsuta 1 Fabaceae Annual Herbaceous Pea Family

x Hardy fuschia Fuschia magellanica 1 Onagraceae Perennial Woody Woody Species

x Hawkbit Leontodon saxatalis 1 Asteraceae Annual, biennial, 

perennial Herbaceous Sunflower Family

x Hedgemustard Sisymbrium officinale 1 Brassicaceae Annual Herbaceous Mustard Family

x Herb Robert Geranium robertianaum 25 Geraniaceae Annual, biennial Herbaceous Geranium Family

x Himalayan blackberry Rubus armeniacus 5,000 Roseaceae Perennial Woody Woody Species

x Himalayan knotweed Polygonum polystachyum 0 Polygonaceae Perennial Herbaceous Knotweed Family

x Hop clover Trifolium campestre 10 Fabaceae Annual, biennial Herbaceous Pea Family

x Horehound Marrubium vulgare 5 Lamiaceae Perennial Herbaceous Perennial Mints

x Hyssop loosestrife Lythrum hyssopifolia 5 Lythraceae Perennial Herbaceous Loosestrifes

x Iceplant Carpobrotus chilensis 1 Aizoaceae Perennial Herbaceous Misc. Herbaceous

x Italian/slenderflower thistle Carduus pycnocephalus/C. 

tenuiflorus 20 Asteraceae Biennial Herbaceous Sunflower Family

x Japanese (Field)brome Bromis japonicus (B. arvensis) 1 Poaceae Annual Grass Annual Grasses

x Japanese knotweed Polygonum cuspidatum 100 Polygonaceae Perennial Herbaceous Knotweed Family

x Jimsonweed Datura stramonium 0 Solanaceae Annual Herbaceous Misc. Annual Herbaceous

x Jubata grass Cortaderia jubata 10 Poaceae Perennial Grass Perennial Grasses

x Kentucky bluegrass Poa pratensis L. ssp. pratensis 1 Poaceae Perennial Grass Perennial Grasses

x Lance-leaved plantain Plantago lanceolata 10 Plantaginaceae Perennial Herbaceous Misc. Herbaceous

x Least lettuce Lactuca saligna 5 Asteraceae Annual, biennial Herbaceous Sunflower Family

x Lemon balm Melissa officinalis 1 Lamiaceae Perennial Herbaceous Perennial Mints

x Lesser swinecress Coronopus (Syn. Lepidium) 

didymus 0 Brassicaceae Annual, biennial Herbaceous Mustard Family

x Little quaking grass Briza minor 10 Poaceae Annual Grass Annual Grasses

x Longstalk geranium Geranium columbianum 1 Geraniaceae Annual Herbaceous Geranium Family

x Maiden pink Dianthus deltoides 1 Caryophyllaceae Perennial Herbaceous Carnation Family
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

264

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Maltese starthistle Centaurea melitensis 0 Asteraceae Annual, biennial Herbaceous Sunflower Family

x Marestail/horseweed Conyza bonariensis 50 Asteraceae Annual Herbaceous Sunflower Family

x Matgrass Nardus stricta 0 Poaceae Perennial Grass Perennial Grasses

x Meadow foxtail Alopecurus pratensis 5 Poaceae Perennial Grass Perennial Grasses

x Meadow knapweed Centaurea x moncktonii 500 Asteraceae Perennial Herbaceous Sunflower Family

x Mediterranean medick Medicago praecox 1 Fabaceae Perennial Herbaceous Pea Family

x Mediterranean rabbitsfoot grass Polypogon maritimus 0 Poaceae Annual Grass Annual Grasses

x Mexican-tea Dysphania ambrosioides 1 Amaranthaceae Annual Herbaceous Misc. Annual Herbaceous

x Montbretia Crocosmia X crocosmiflora 5 Iridaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Morning-glory Ipomoea purpurea 0 Convolvulaceae Annual Herbaceous, 

woody Misc. Herbaceous

x Moth mullein Verbascum blattaria 1 Scrophulariaceae Biennial Herbaceous Snapdragon Family

x Mouseear cress Arabidopsis thaliana 1 Brassicaceae Annual Herbaceous Mustard Family

x Musk thistle Carduus nutans 0 Asteraceae Biennial Herbaceous Sunflower Family

x Narrow-leaf clover Trifolium angustifolium 10 Fabaceae Annual Herbaceous Pea Family

x Narrowpanicle rush Juncus brevicaudatus 1 Juncaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x New Zealand geranium Geranium core-core 0 Geraniaceae Perennial Herbaceous Geranium Family

x Nipplewort Lapsana communis 5 Asteraceae Annual Herbaceous Sunflower Family

x Nit grass Gastridium (Syn. Pheoides) 

ventricosum 1 Poaceae Annual Grass Annual Grasses

x Northern St. Johnswort Hypericum mutilum 1 Hypericaceae Perennial Herbaceous Misc. Herbaceous

x Old man's beard Clematis vitalba 10 Ranunculaceae Perennial Woody Woody Species

x Old-man-in -the-spring Senecio vulgaris 50 Asteraceae Annual, biennial Herbaceous Sunflower Family

x One seed hawthorn Crataegus monogyna 1 Roseaceae Perennial Woody Woody Species

x Orchard grass Dactylis glomerata 10 Poaceae Perennial Grass Perennial Grasses

x Oxeye daisy Leucanthemum vulgare 50 Asteraceae Perennial Herbaceous Sunflower Family

x Pampas grass Cortaderia selloana 10 Poaceae Perennial Grass Perennial Grasses

x Panic veldt grass Ehrharta erecta 1 Poaceae Perennial Grass Perennial Grasses

x Pasture rush Juncus effusus spp. effusus 10 Juncaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Pennyroyal Mentha pulegium 20 Lamiaceae Perennial Herbaceous Perennial Mints

x Perennial peavine Lathyrus latifolia 100 Fabaceae Perennial Herbaceous Pea Family

x Perennial ryegrass Lolium perenne 10 Poaceae Perennial Grass Perennial Grasses

x Petty spurge Euphorbia peplus 10 Euphorbiaceae Annual Herbaceous Misc. Annual Herbaceous

x Pine echium Echium pininana 0 Boraginaceae Biennial Herbaceous Borage Family

x Pineapple weed Matricaria discoidea 5 Asteraceae Annual Herbaceous Sunflower Family

x Poison hemlock Conium maculatum 10 Apiaceae Perennial Herbaceous Perennial Parsley Family

x Policemen’s helmet Impatiens glandulifera 0 Balasaminaceae Annual Herbaceous Misc. Herbaceous
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

265

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Portuguese broom Cytisus striatus 0 Fabaceae Perennial Woody Woody Species

x Poverty brome Bromus sterilis 1 Poaceae Annual Grass Annual Grasses

x Prickly lettuce Lactuca serriola 10 Asteraceae Annual, biennial Herbaceous Sunflower Family

x Procumbent pearlwort Sagina procumbens 1 Caryophyllaceae Perennial Herbaceous Carnation Family

x Proliferous pink Petrorhagia nanteuilii 1 Caryophyllaceae Annual Herbaceous Carnation Family

x Prostrate knotweed Polygonum aviculare 5 Polygonaceae Perennial Herbaceous Knotweed Family

x Puncturevine Tribulus terrestris 0 Zygophyllaceae Annual Herbaceous Misc. Annual Herbaceous

x Purple deadnettle Lamium purpureum 20 Lamiaceae Annual Herbaceous Misc. Annual Herbaceous

x Purple foxglove Digitalis purpurea 20 Scrophulariaceae Biennial Herbaceous Snapdragon Family

x Purple loosestrife Lythrum salicaria 25 Lythraceae Perennial Herbaceous Loosestrifes

x Quackgrass Elymus repens 1 Poaceae Perennial Grass Perennial Grasses

x Queen Anne's lace Daucus carota 5 Apiaceae Perennial Herbaceous Perennial Parsley Family

x Rabbitfoot clover Trifolium arvense 10 Fabaceae Annual Herbaceous Pea Family

x Rat-tail fescue Vulpia myuros 10 Poaceae Annual Grass Annual Grasses

x Red clover Trifolium pratense 10 Fabaceae Biennial, perennial Herbaceous Pea Family

x Red escallonia Escallonia rubra 10 Escalloniaceae Perennial Woody Woody Species

x Red sepaled evening-primrose Oenothera glazioviana 5 Onagraceae Biennial Herbaceous Misc. Herbaceous

x Red valerian Centranthus ruber 0 Valarianaceae Perennial Herbaceous Misc. Herbaceous

x Redstem storks bill Erodium cicutarium 5 Geraniaceae Biennial Herbaceous Geranium Family

x Reed canarygrass Phalaris arundinacea 1,200 Poaceae Perennial Grass Perennial Grasses

x Rescue grass Bromus catharticus 0 Poaceae Annual, perennial Grass Perennial Grasses

x Ribbongrass Phalaris arundinacea var picta 0 Poaceae Perennial Grass Perennial Grasses

x Ripgut brome Bromus diandrus 30 Poaceae Annual Grass Annual Grasses

x Rose campion Lychnis coronaria 50 Caryophyllaceae Perennial Herbaceous Carnation Family

x Rose clover Trifolium hirtum 5 Fabaceae Annual Herbaceous Pea Family

x Saltmeadow rush Juncus gerardi ssp. gerardi 1 Juncaceae Perennial Grass Perennial Grasses

x Scarlet pimpernel Anagallis arvensis 0 Primulaceae Annual, biennial Herbaceous none

x Scotch broom Cytisus scoparius 2,000 Fabaceae Perennial Woody Woody Species

x Scotch thistle Onopordum acanthium 0 Asteraceae Biennial Herbaceous Sunflower Family

x Self heal Prunella vulgaris var vulgaris 0 Lamiaceae Perennial Herbaceous Perennial Mints

x Sharpleaf cancerwort Kickxia elatine 1 Scrophulariaceae Annual Herbaceous Snapdragon Family

x Sheep sorrel Rumex acetosella 40 Polygonaceae Perennial Herbaceous Knotweed Family

x Shepherd’s cress Teesdalia coronopifolia 1 Brassicaceae Annual Herbaceous Mustard Family

x Shepherd’s-purse Capsella bursa-pastoris 1 Brassicaceae Annual Herbaceous Mustard Family

x Shepherd’s needle Scandix pecten-veneris 1 Apiaceae Annual Herbaceous Misc. Annual Herbaceous

x Shiny leaf geranium Geranium lucidum 25 Geraniaceae Annual, biennial Herbaceous Geranium Family
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

266

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Sickelgrass Parapholis incurva 1 Poaceae Annual Grass Annual Grasses

x Silver wattle Acacia dealbata 1 Fabaceae Perennial Woody Woody Species

x Silver/little hairgrass Aira caryophylla/praecox 10 Poaceae Annual Grass Annual Grasses

x Slender oat Avena barbata 1 Poaceae Annual Grass Annual Grasses

x Small burnet Sanguisorba (Poterium) minor 0 Roseaceae Perennial Herbaceous Misc. Herbaceous

x Small flower buttercup Ranunculus parviflorus 5 Ranunculaceae Annual Herbaceous Misc. Herbaceous

x Smooth brome Bromus inermis spp inermis 1 Poaceae Perennial Grass Perennial Grasses

x Smooth hawksbeard Crepis capillaris 1 Asteraceae Annual, biennial Herbaceous Sunflower Family

x Soft chess Bromus hordeaceus 10 Poaceae Annual Grass Annual Grasses

x Spanish broom Spartium junceum 0 Fabaceae Perennial Woody Woody Species

x Spanish heath Erica lusitanica 0 Ericaceae Perennial Woody Woody Species

x Spiny sow thistle Sonchus asper 20 Asteraceae Annual Herbaceous Sunflower Family

x Spotted knapweed Centaurea stoebe 10 Asteraceae Biennial, perennial Herbaceous, 

woody Sunflower Family

x Spotted ladysthumb Polygonum persicaria 1 Polygonaceae Perennial Herbaceous Knotweed Family

x Spotted medick Medicago arabica 20 Fabaceae Annual Herbaceous Pea Family

x Spreading hedgeparsley Torilis arvensis 1 Apiaceae Annual Herbaceous Misc. Annual Herbaceous

x Spurge laurel Daphne laureola 0 Thymelaeaceae Perennial Woody Woody Species

x St. Johnswort Hypericum perforatum 20 Hypericaceae Perennial Herbaceous Misc. Herbaceous

x Sticky chickweed Cerastium glomeratum 1 Caryophyllaceae Annual Herbaceous Carnation Family

x Stinging nettle Urtica dioica ssp dioica 1 Urticaceae Perennial Herbaceous Misc. Herbaceous

x Subterranean clover Trifolium subterraneum 20 Fabaceae Annual Herbaceous Pea Family

x Suckling clover Trifolium dubium 10 Fabaceae Annual Herbaceous Pea Family

x Sulfur cinquefoil Potentilla recta 0 Roseaceae Perennial Herbaceous Misc. Herbaceous

x Sweet vernal grass Anthoxanthum odoratum 25 Poaceae Perennial Grass Perennial Grasses

x Sweet violet Viola odorata 10 Violaceae Perennial Herbaceous none

x Sweetbriar rose Rosa rubiginosa 0 Roseaceae Perennial Woody Woody Species

x Tall fescue Schedonorus arundinaceus 10 Poaceae Perennial Grass Perennial Grasses

x Tall wheatgrass Thinopyrum pontica 1 Poaceae Perennial Grass Perennial Grasses

x Tansy ragwort Senecio jacobaea 50 Asteraceae Biennial Herbaceous Sunflower Family

x Teasel/Fuller's teasel Dipsacus fullonum 50 Dipsacaceae Biennial Herbaceous Teasels

x Three-sided leek Allium triquetrum 1 Liliaceae Perennial Herbaceous Lilies, Iris, Sedges, Rushes

x Timothy Phleum pratense 1 Poaceae Perennial Grass Perennial Grasses

x Tree-of-heaven Ailanthus altissima 1 Simaroubaceae Perennial Woody Woody Species

x Velvetgrass Holcus lanatus 20 Poaceae Perennial Grass Perennial Grasses

x Velvetleaf Abutilon theophrasti 5 Malvaceae Annual Herbaceous Misc. Herbaceous
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

267

Category Common Name Scientific Name Treatment 

Acres Family Life Cycle Type Treatment Group I III IV

x Wall bedstraw Galium divaricatum 0 Rubiaceae Annual Herbaceous Misc. Annual Herbaceous

x Wall lettuce Mycelis murialis 5 Asteraceae Annual Herbaceous Sunflower Family

x Water speedwell Veronica anagallis-aquatica 1 Plantaginaceae Biennial Herbaceous Misc. Herbaceous

x Weedy brome Bromus stamineus 1 Poaceae Annual Grass Annual Grasses

x Western mannagrass Glycera x occidentalis 0 Poaceae Perennial Grass Perennial Grasses

x Wheat Triticum aestivum 1 Poaceae Annual Grass Annual Grasses

x White clover Trifolium repens 10 Fabaceae Perennial Herbaceous Pea Family

x White ramping fumitory Fumaria capreolata 0 Fumariaceae Perennial Herbaceous Misc. Herbaceous

x White/yellow sweetclover Melilotus albus/M officianalis 50 Fabaceae Annual, biennial, 

perennial Herbaceous Pea Family

x Wild oats Avena fatua 1 Poaceae Annual Grass Annual Grasses

x Wild radish Raphanus raphanistrum/R. sativas 232 Brassicaceae Annual, biennial Herbaceous Mustard Family

x Woodland tansy Senecio sylvaticus 100 Asteraceae Annual Herbaceous Sunflower Family

x Yarrow Achillea millefolium 5 Asteraceae Perennial Herbaceous Perennial Parsley Family

x Yellow archangel Lamiastrum galeobdolon 0 Lamiaceae Perennial Herbaceous Perennial Mints

x Yellow flag iris Iris psuedacorus 5 Iridaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Yellow foxtail Setaria pumila 1 Poaceae Annual Grass Annual Grasses

x Yellow glandweed Parentucellia viscosa 40 Scrophulariaceae Annual Herbaceous Snapdragon Family

x Yellow nutsedge Cyperus esculentus 0 Cyperaceae Perennial Grass Lilies, Iris, Sedges, Rushes

x Yellow salsify Tragopogon dubius 1 Asteraceae Annual, biennial Herbaceous Sunflower Family

x Yellow starthistle Centaurea solstitialis 1 Asteraceae Annual Herbaceous Sunflower Family

x Yellow toadflax Linaria vulgaris 0 Scrophulariaceae Perennial Herbaceous Snapdragon Family
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

268

Table D-3. Estimated Total Treatment Acres, 20-Year Analysis Period, Including Tank Mixes and Application Rates

Treatment Method Lbs./Acre1 No Action2 Proposed Action2 Alternative 3 

2,4-D 0.95 10.00 24.76 24.76

2,4-D 1.90 3.50 6.30 6.30

2,4-D 0.95 to 1.90 - 0.00 0.00

Aminopyralid 0.11 - 0.00 0.00

Aminopyralid 0.05 to 0.11 - 1,480.62 1,480.62

Aminopyralid + Metsulfuron methyl 0.08 to 0.11 + 0.12 to 0.15 - 170.69 170.69

Aminopyralid + Triclopyr 0.11 + 1.00 - 156.12 156.12

Chlorsulfuron 0.05 - 44.93 44.93

Chlorsulfuron 0.04 to 0.05 - 0.00 0.00

Chlorsulfuron 0.05 to 0.12 - 0.00 0.00

Chlorsulfuron + 2,4-D 0.05 + 0.95 - 23.23 23.23

Chlorsulfuron + 2,4-D 0.06 + 0.95 - 73.80 73.80

Chlorsulfuron + Clopyralid + 2,4-D 0.05 + 0.38 + 0.95 - 46.46 46.46

Clopyralid 0.09 to 0.19 - 2.25 2.25

Clopyralid 0.23 to 0.49 - 163.35 163.35

Clopyralid 0.25 to 0.38 - 1.30 1.30

Clopyralid + 2,4-D 0.16 to 0.38 + 1.00 to 1.90 - 1.00 1.00

Clopyralid + 2,4-D 0.38 + 0.95 - 116.15 116.15

Dicamba 1.00 - 6.70 6.70

Dicamba + 2,4-D 0.50 + 0.95 98.15 3.46 3.46

Dicamba + 2,4-D 0.50 to 1.00 + 0.95 6.00 15.30 15.30

Dicamba + 2,4-D 0.50 to 2.00 + 0.95 4.00 1.50 1.50

Dicamba + 2,4-D 0.75 + 0.25 1.25 2.80 2.80

Dicamba + 2,4-D 1.00 + 0.95 - 6.70 6.70

Dicamba + Diflufenzopyr 0.18 to 0.35 - 135.75 135.75

Fluazifop-P-butyl 0.38 - - 30.00

Fluroxypyr 0.49 - - 2.80

Fluroxypyr 0.13 to 0.49 - - 0.90

Glyphosate <3.00 7,683.61 1,494.42 1,490.72

Glyphosate + 2,4-D 0.50 + 0.70 6.00 16.10 16.10

Hexazinone 0.75 - - 2.80

Hexazinone 2.00 - - 87.15

Hexazinone 2.00 to 4.00 - - 0.00

Imazapic 0.06 to 0.12 - 161.84 92.94

Imazapic 0.13 to 0.19 - 77.62 77.62

Imazapic + Glyphosate 0.06 to 0.09 + 0.13 to 0.19 - 0.90 0.90

Imazapic + Glyphosate 0.06 to 0.19 + 0.13 to 0.38 - 69.72 69.72

Imazapyr 0.75 - 6.75 6.75

Imazapyr 0.38 to 0.75 - 8.40 8.40

Imazapyr 0.75 to 1.00 - 187.50 187.50

Imazapyr 0.75 to 1.50 - 177.65 160.22

Imazapyr 1.00 to 1.50 - 393.30 393.30

Imazapyr + Glyphosate 0.75 to 1.50 + 3.00 - 226.59 313.74

Metsulfuron methyl 0.01 to 0.02 - 12.10 12.10

Metsulfuron methyl 0.01 to 0.08 - 3.40 3.40

Metsulfuron methyl 0.02 to 0.04 - 273.27 273.27

Metsulfuron methyl 0.04 to 0.08 - 4.50 4.50

Metsulfuron methyl + 2,4-D 0.04 + 0.95 - 0.20 0.20

Picloram 1.00 - 0.00 0.00

Picloram 0.50 to 0.95 5.00 0.00 0.00

Picloram + 2,4-D 0.25 + 0.95 - 0.00 0.00

Picloram + 2,4-D 0.50 + 0.95 0.80 0.00 0.00

Picloram + 2,4-D 0.50 + 1.50 - 0.00 0.00

Picloram + 2,4-D + Dicamba 0.25 + 0.95 + 0.50 19.63 23.23 23.23

Rimsulfuron 0.03 to 0.06 - - 138.62

Sulfometuron methyl 0.19 - 0.60 0.60

Sulfometuron methyl 0.05 to 0.09 - 0.00 0.00
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix D – Invasive Plant Infestations

269

Treatment Method Lbs./Acre1 No Action2 Proposed Action2 Alternative 3 

Sulfometuron methyl + Chlorsulfuron 0.05 + 0.14 - 0.00 0.00

Triclopyr 1.00 - 1.50 1.50

Triclopyr 2.00 - 4,200.38 4,200.38

Triclopyr <6.00 - 390.30 390.30

Triclopyr 0.50 to 2.00 - 27.60 27.60

Triclopyr 0.75 to 5.00 - 4.20 4.20

Triclopyr 1.50 to 3.00 - 11.70 11.70

Triclopyr + 2 4-D 1.50 + 0.95 - 0.00 0.00

Triclopyr + 2 4-D 2.00 + 0.95 - 780.60 780.60

Biological control agents 901.55 546.95 546.95

Prescribed fire 0.00 2,000.00 2,000.00

Manual control 351.13 708.12 708.12

Mechanical control 467.53 686.77 460.18

Propane torch - 21.05 21.05

Weed barrier mats - 5.00 5.00

Targeted grazing (cattle) 200.00 200.00 200.00

Targeted grazing (goats) 5.00 5.00 5.00

Targeted grazing (sheep) - 0.25 0.25

Competitive seeding and planting 2,000.00 2,000.00 2,000.00

1. Lbs./acre in bold are at the typical application rate or above. Red indicates lbs./acre at the maximum application rate.

2. A dash indicates that the treatment method would not be used under that alternative. 0.00 indicates that the treatment would be used 

under the alternative, but on acres that round to 0.00 (e.g. 0.003 acres).

Table D-4. Estimated Total Treatment Acres, 20-Year Analysis Period (Not including tank mixes or application rates)

Treatment Method No Action

Acres1

Proposed Action Alternative 3

Acres1 % change from 

No Action Acres1 % change from No Action

% change from 

Proposed Action

2,4-D 149.33 360.99 142% 360.99 142% 0%

Aminopyralid - 1,807.43 NA 1,807.43 NA 0%

Chlorsulfuron - 188.42 NA 188.42 NA 0%

Clopyralid - 330.51 NA 330.51 NA 0%

Dicamba 129.03 59.69 -54% 59.69 -54% 0%

Dicamba + Diflufenzopyr - 135.75 NA 135.75 NA 0%

Fluazifop-P-butyl - - NA 30.00 NA NA

Fluroxypyr - - NA 3.70 NA NA

Glyphosate 7,689.61 1,807.73 -76% 1,891.18 -75% 5%

Hexazinone - - NA 89.95 NA NA

Imazapic - 310.08 NA 241.18 NA -22%

Imazapyr - 1,000.19 NA 1,069.91 NA 7%

Metsulfuron methyl - 464.16 NA 464.16 NA 0%

Picloram 25.43 23.23 -9% 23.23 -9% 0%

Rimsulfuron - - NA 138.62 NA NA

Sulfometuron methyl - 0.60 NA 0.60 NA 0%

Triclopyr - 5,572.40 NA 5,572.40 NA 0%

Biological control agents 901.55 546.95 -39% 546.95 -39% 0%

Prescribed fire 0.00 2,000.00 NA 2,000.00 NA 0%

Manual control 351.13 708.12 102% 708.12 102% 0%

Mechanical control 467.53 686.77 47% 460.18 -2% -33%

Propane torch - 21.05 NA 21.05 NA 0%

Weed barrier mats - 5.00 NA 5.00 NA 0%

Targeted grazing (cattle) 200.00 200.00 0% 200.00 0% 0%

Targeted grazing (goats or sheep) 5.00 6.25 25% 6.25 25% 0%

Competitive seeding and planting 2,000.00 2,000.00 0% 2,000.00 0% 0%

1. A dash indicates that the treatment method would not be used under that alternative.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

270

Appendix E - Prevention

Prevention, education, and awareness are the highest priority for the management of invasive plants. A list of 

prevention measures applicable to projects or vegetation treatment actions is included in Invasive Plant

Prevention Measures (below). The District maintains a District Weed Prevention Schedule (see section, below) 

that outlines prevention steps like cleaning vehicles and equipment before moving onto or from BLM-managed 

lands and helping with community invasive plant education events. Specific responsibilities are assigned for 

keeping administrative sites free of invasive plants, reestablishing desirable vegetation on disturbed sites, 

inspecting gravel and other materials sites, and including invasive plant prevention measures in all planning 

documents, contracts, and leases. Other activities include the continuing education of employees, contractors, and 

the public.

Additionally, BLM policy requires that planning for ground-disturbing projects, or projects that have the potential 

to alter plant communities, include an assessment of the risk of introducing or spreading noxious weeds (USDI 

1992b:9015.8).88 If there is a moderate or high risk of spread, actions to reduce the risk must be implemented and 

monitoring of the site. See the Noxious Weed Risk Assessment Factors and Rating section, below (taken from BLM 

Manual 9015, Integrated Weed Management, USDI 1992b).

Invasive Plant Prevention Measures

Invasive Plant Prevention Measures are designed to prevent the spread of invasive plants by minimizing the 

amount of existing non-target vegetation that is disturbed or destroyed during project or vegetation treatment 

actions (USDI 2007d:2-20). They are designed to work in conjunction with BLM’s policy requiring that planning for 

ground-disturbing projects in the Resource Area, or those that have the potential to alter plant communities, 

include an assessment of the risk of introducing noxious weeds, and if there is a moderate or high risk of spread, 

actions to reduce the risk must be implemented and monitoring of the site must be conducted to prevent 

establishment of new infestations.

Information included in this Invasive Plant Prevention Measures section is a compilation of information originally 

presented in:

• the Vegetation Treatments on BLM Lands in 17 Western States Programmatic Environmental Report (USDI 

2007d);

As stated in the BLM’s Partners Against Weeds - An Action Plan for the BLM (USDI 1996), prevention and public 

education are the highest priority weed management activities. Priorities are as follows:

• Priority 1: Take actions to prevent or minimize the need for vegetation control when and where feasible, 

considering the management objectives of the site.

• Priority 2: Use effective nonchemical methods of vegetation control when and where feasible.

• Priority 3: Use herbicides after considering the effectiveness of all potential methods or in combination 

with other methods or controls.

Prevention is best accomplished by ensuring the seeds and vegetatively reproductive plant parts of new weed 

species are not introduced into new areas. The BLM is required to develop a noxious weed risk assessment when it 

is determined that an action may introduce or spread noxious weeds or when known habitat exists (USDI 1992b). If 

the risk is moderate or high, the BLM may modify the project to reduce the likelihood of weeds infesting the site, 

and to identify control measures to be implemented if weeds do infest the site. To prevent the spread of weeds, 

 88 Current handbook direction requires this assessment only for noxious weeds (Integrated Weed Management Manual 9015; 

USDI 1992b).
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

271

the BLM takes actions to minimize the amount of existing non-target vegetation that is disturbed or destroyed 

during project or vegetation treatment actions. During project planning, the following steps are taken:

• Incorporate measures to prevent introduction or spread of weeds into project layout, design, alternative 

evaluation, and project decisions.

• During environmental analysis for projects and maintenance programs, assess weed risks, analyze 

potential treatment of high-risk sites for weed establishment and spread, and identify prevention 

practices.

• Determine prevention and maintenance needs, to include the use of herbicides if needed, at the onset of 

project planning.

• Avoid or remove sources of weed seed and propagules to prevent new weed infestations and the spread 

of existing weeds.

During project development, weed infestations are prioritized for treatment in project operating areas and along 

access routes. Weeds present on or near the site are identified, a risk assessment is completed, and weeds are 

controlled as necessary. Project staging areas are weed free, and travel through weed-infested areas is avoided or 

minimized. Examples of prevention actions to be followed during project activities include cleaning all equipment 

and clothing before entering the project site; avoiding soil disturbance and the creation of other soil conditions 

that promote weed germination and establishment; and using weed-free seed, hay, mulch, gravel, soil, and 

mineral materials on public lands where there is a state or county program in place.

Conditions that enhance invasive species abundance should be addressed when developing mitigation and 

prevention plans for activities on public lands. These conditions include excessive disturbance associated with road 

maintenance, poor grazing management, and high levels of recreational use. If livestock grazing is managed to 

maintain the vigor of native perennial plants, particularly grasses, the chance of weeds invading rangeland is much 

less. By carefully managing recreational use and educating the public on the potential impacts of recreational 

activities on vegetation, the amount of damage to native vegetation and soil can be minimized at high use areas, 

such as campgrounds and OHV trails. Early detection in recreation areas is focused on roads and trails, where 

much of the weed spread occurs.

The BLM participates in the National Early Warning and Rapid Response System for Invasive Plants. The goal of this 

System to minimize the establishment and spread of new invasive species through a coordinated framework of 

public and private processes by:

• Early detection and reporting of suspected new plant species to appropriate officials;

• Identification and vouchering of submitted specimens by designated specialists;

• Verification of suspected new state, regional, and national plant records;

• Archival of new records in designated regional and plant databases;

• Rapid assessment of confirmed new records; and

• Rapid response to verified new infestations that are determined to be invasive.

Project Planning Prevention Measures

• Incorporate prevention measures into project layout and design, alternative evaluation, and project 

decisions to prevent the introduction or spread of weeds.

• Determine prevention and maintenance needs, including the use of herbicides, at the onset of project 

planning.

• Before ground-disturbing activities begin, inventory weed infestations and prioritize areas for treatment 

in project operating areas and along access routes.

• Remove sources of weed seed and propagules to prevent the spread of existing weeds and new weed 

infestations.

• Pre-treat high-risk sites for weed establishment and spread before implementing projects.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

272

• Post weed awareness messages and prevention practices at strategic locations such as trailheads, roads, 

boat launches, and public land kiosks.

• Coordinate project activities with nearby herbicide applications to maximize the cost-effectiveness of 

weed treatments.

Project Development Prevention Measures

• Minimize soil disturbance to the extent practical, consistent with project objectives.

• Avoid creating soil conditions that promote weed germination and establishment.

• To prevent weed germination and establishment, retain native vegetation in and around project activity 

areas and keep soil disturbance to a minimum, consistent with project objectives.

• Locate and use weed-free project staging areas. Avoid or minimize all types of travel through weedinfested areas, or restrict travel to periods when the spread of seeds or propagules is least likely.

• Prevent the introduction and spread of weeds caused by moving weed-infested sand, gravel, borrow, and 

fill material.

• Inspect material sources on site, and ensure that they are weed-free before use and transport. Treat 

weed-infested sources to eradicate weed seed and plant parts, and strip and stockpile contaminated 

material before any use of pit material.

• Survey the area where material from treated weed-infested sources is used for at least 3 years after 

project completion to ensure that any weeds transported to the site are promptly detected and 

controlled.

• Prevent weed establishment by not driving through weed-infested areas.

• Inspect and document weed establishment at access roads, cleaning sites, and all disturbed areas; control 

infestations to prevent spread within the project area.

• Avoid acquiring water for dust abatement where access to the water is through weed-infested sites.

• Identify sites where equipment can be cleaned. Clean equipment before entering public lands.

• Clean all equipment before leaving the project site if operating in areas infested with weeds.

• Inspect and treat weeds that establish at equipment cleaning sites.

• Ensure that rental equipment is free of weed seed.

• Inspect, remove, and properly dispose of weed seed and plant parts found on workers’ clothing and 

equipment. Proper disposal entails bagging the seeds and plant parts and incinerating them.

Revegetation Prevention Measures

• Include weed prevention measures, including project inspection and documentation, in operation and 

reclamation plans.

• Retain bonds until reclamation requirements, including weed treatments, are completed, based on 

inspection and documentation.

• To prevent conditions favoring weed establishment, re-establish vegetation on bare ground caused by 

project disturbance as soon as possible using either natural recovery or artificial techniques.

• Maintain stockpiled, uninfested material in a weed-free condition.

• Revegetate disturbed soil (except travel ways on surfaced projects) in a manner that optimizes plant 

establishment for each specific project site. For each project, define what constitutes disturbed soil and 

objectives for plant cover revegetation. Revegetation may include topsoil replacement, planting, seeding, 

fertilization, liming, and weed-free mulching, as necessary.

• Where practical, stockpile weed-seed-free topsoil and replace it on disturbed areas (e.g., road 

embankments or landings).

• Inspect seed and straw mulch to be used for site rehabilitation (for wattles, straw bales, dams, etc.) and 

certify that they are free of weed seed and propagules.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

273

• Inspect and document all limited term ground-disturbing operations in noxious weed infested areas for at 

least 3 growing seasons following completion of the project.

• Use native material where appropriate and feasible. Use certified weed-free or weed-seed-free hay or 

straw where certified materials are required and/or are reasonably available.89

• Provide briefings that identify operational practices to reduce weed spread (for example, avoiding known 

weed infestation areas when locating fire lines).

• Evaluate options, including closure, to regulate the flow of traffic on sites where desired vegetation needs 

to be established. Sites could include road and trail ROW, and other areas of disturbed soils.

District Weed Prevention Schedule

General Prevention Activity Description

(Describe the activity and where it will take place)

When

(season) Who

GENERAL - All Field-going Employees

Check and clean vehicles- Check 

any vehicle that is used off of 

established roads or on 

overgrown roads and clean with 

best available method prior to 

moving into relatively weedfree areas.

Avoid driving through vegetation or parking in vegetation. 

When driving through or parking in vegetation is necessary, 

(especially known invasive plants) inspect vehicle for seeds 

or other plant materials. Check body, undercarriage, wheel 

wells, grill, inside bumpers, frame, bed, etc. for plant 

materials, soil, and mud and plant material and remove 

with best available method (sweep, pick off plant parts, 

power wash, etc.) prior to travelling into other areas.

All Year

All field-going 

employees that 

operate pick-ups, 

ATVs, boats, or 

other vehicles

Attend Weed Awareness 

Training – Learn employee 

responsibilities for weed 

prevention and control.

Attend training annually. Learn top 10-12 weeds and what 

to do when you see them. Spring All field-going employees

Report location of known or 

suspected weeds.

Collect location information such as Township-RangeSection, Rd. #, approximate mileage to nearest land mark 

or road junction or UTMs of suspected infestations and 

report to weed coordinator.

All Year All field-going 

employees

GENERAL - Planning Documents – All Resources

Ensure that all NEPA and 

planning documents include an 

invasive plant element for 

analysis.

Include Weed Risk Assessment and invasive plant inventory 

in planning document file. Where possible, minimize soil 

and vegetation disturbance.

All Year NEPA 

Coordinators

Assess weed potential/risk when 

developing project proposals.

On all soil or vegetation disturbing projects, conduct pre –

disturbance weed surveys and include results in project file. 

Complete a Weed Risk Assessment (BLM Manual 9015) that 

considers the likelihood and consequences of infestation 

and prescribe weed prevention measures commensurate 

with activity and risk.

All Year Botanist or Weed 

Coordinator

Prevent weed spread into weed 

free areas.

Incorporate appropriate Standard Operating Procedures 

(SOPs) from 2007 and 2010 Vegetation Treatments EISs and 

ER. These include Best Management Practices and 

mitigation measures to prevent the spread of weeds.

All Year

Botanist or Weed 

Coordinator, 

NEPA 

Coordinators

GENERAL - Facilities and Buildings

Ensure that the BLM facilities 

and compounds are kept free of 

priority invasive plants.

Control invasive plants on BLM compounds. Coordinate 

with weed coordinator for effective treatments and correct 

deficiencies identified monitoring.

Spring/Su

mmer

Recreation and 

Facilities 

Supervisors

Use native, weed-free seed and 

plants for revegetation and 

erosion prevention.

When planting or seeding use native plants or seed that is 

free of invasive plants. Use native plants unless a NEPA 

analysis has shown the need for other species.

Spring/Su

mmer/Fall Project Leads

 89 The Coos Bay District requires the use of weed-free hay or straw on District lands.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

274

General Prevention Activity Description

(Describe the activity and where it will take place)

When

(season) Who

Obtain gravel, mulch and fill 

from weed free sources.

Obtain or purchase weed-free mulch, gravel, fill or similar 

materials OR inspect and control weeds for a minimum of 3 

years following the use of materials that are not certified 

weed-free.

All Year Procurement, 

Engineering

Road Construction/Maintenance

Ensure that the BLM 

maintenance compounds are 

kept free of invasive plants

Control invasive plants on BLM compounds. Coordinate 

with weed coordinator for effective treatments and correct 

deficiencies identified monitoring.

Spring/Su

mmer

Maintenance 

Supervisor

Clean equipment Clean equipment regularly of mud, soil and plant parts to 

avoid moving weed seed. All Year Equipment Operators

Avoid spreading weeds when 

brushing or grading.

When possible grade or brush up to weed infestation 

rather than away from them, particularly when seeds are

present on plants. Work with weed coordinator to include 

problem areas in spray contracts.

All Year Equipment 

Operators

Obtain gravel, mulch and fill 

from weed free sources.

Inspect and control weeds in stockpiles and fill sources. 

Purchase weed-free gravel, mulch and fill OR inspect and 

control weeds for a minimum of 3 years following the use 

of materials that are not known to be weed-free.

All Year Maintenance 

Supervisor

Prevent weed establishment on 

bare soil from slides, etc.

Apply native grass seed to bare soil and soil piles following 

slide removal, or similar projects.

Fall or 

Spring

Road 

Maintenance 

staff

Address weeds during road 

maintenance planning. Prevent 

weed spread into weed-free 

areas.

For soil or vegetation disturbing projects, identify and 

implement ways to prevent weeds from being introduced 

or spreading into the proposed project area. Work with 

weed coordinator to include projects in annual weed 

contracts.

Annual 

Meeting 

in August

Maintenance 

Supervisors, 

Maintenance 

staff and District 

Weed 

Coordinator

Recreation

Ensure that the BLM facilities 

and compounds are kept free of 

priority invasive plants.

Control invasive plants on BLM compounds. Coordinate 

with weed coordinator for effective treatments and correct 

deficiencies identified monitoring.

Spring/Su

mmer Recreation

Promote and maintain weed 

free campgrounds, trails and 

recreation sites.

Install signs/posters to inform visitors of weed concerns 

and how to prevent weed spread into recreation areas, 

especially at high use times. Consider boot cleaning stations 

at trailheads. Consider weed pulling/cutting activities with 

volunteers or youth crews.

Year 

round

Recreation 

Specialist 

/Technician

Ensure all developed and semideveloped recreation sites have 

regular weed inventory and onsite weed control.

Work with weed coordinators to ensure weed inventory is 

up to date and included in District weed GIS layer. Conduct 

invasive plant removal as needed.

Spring/Su

mmer/Fall

Recreation 

Specialist 

/Recreation 

Technician

Use weed free seed and plant 

materials.

When planting or seeding disturbed areas use native plants 

or seed that is free of invasive plants. Use native plants 

unless a NEPA analysis has shown the need for other 

species.

Spring/Su

mmer/Fall

Recreation 

Specialist 

/Recreation 

Technician

Obtain gravel, mulch and fill 

from weed free sources.

Inspect and control weeds in stockpiles and fill sources. 

Purchase weed-free gravel, mulch and fill OR inspect and 

control weeds for a minimum of 3 years following the use 

of materials that are not known to be weed-free.

All Year Maintenance 

Supervisor

ACECs

Ensure that all ACECs have 

current weed inventory, 

monitoring and on- site weed 

control.

Work with botanists/weed coordinators to keep weed 

inventory on ACECs up to date and included in District 

weed GIS layer.

Spring, 

Summer, 

Fall

ACEC Lead
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

275

General Prevention Activity Description

(Describe the activity and where it will take place)

When

(season) Who

Actively control known 

infestations to prevent spread 

to un-infested areas.

When practical, control invasive plants before seed set to 

protect resources for which ACEC is designated. ACEC Lead

Re-vegetate bare soils and 

sparse vegetation with weedfree seed and mulch.

Use locally adapted native seed to re-vegetate disturbed 

areas. Use certified weed free seed. Check with botanist for 

appropriate seed and requirements before purchasing. 

Make every reasonable effort to obtain weed free mulch.

All Year ACEC Lead

Forest Management

Include weed prevention in 

timber management activities.

On all proposed soil or vegetation disturbing projects 

include and implement weed prevention measures such as 

pre-disturbance weed inventory, risk assessment and weed 

treatments, followed by post disturbance monitoring and 

treatment for 3-5 years to avoid spreading weeds or 

allowing them to establish in weed-free areas.

All Year Forester/Project 

lead

Re-vegetate bare soils with 

weed-free seed and mulch.

Use locally adapted native seed to re-vegetate disturbed 

areas. All seed used will be certified weed free. Make every 

reasonable effort to obtain weed free mulch. Check with 

botanist for appropriate seed and requirements before 

purchasing.

All Year Forester/Project 

lead

Obtain standard stipulations for 

weed prevention and include in 

contracts.

See weed coordinator for standard contract stipulations 

and include in all contracts. Standard stipulations include 

equipment cleaning, use of certified weed free seed and 

mulch and reporting of suspect weeds.

All Year Contract writer

Enforce weed prevention 

measures in contracts or activity 

plans.

Become familiar with weed prevention stipulations in 

contracts or activity plans and enforce them by inspecting 

vehicles, seed, mulch or other materials, reporting known 

or suspected weeds.

All Year PI or COR

Monitor timber harvest areas 

for invasive plants and control 

them at earliest opportunity

Include weed survey and inventory in silvicultural activity 

planning. Include invasive plant control in contracts for 

release, pruning, etc. Report invasive plants and suspected 

weeds to weed coordinator.

All Year Silviculture

Use weed free materials

Use weed free mulch, gravel and other materials to prevent 

weed introduction and establishment. If this is not possible, 

then monitor and treat weeds for at least 3 years following 

disturbance.

All year Project lead

Hydro & Fisheries Management

Clean equipment to prevent the 

spread of aquatic weeds and 

other invasive species.

Clean equipment (including waders, boots, boats, etc.) and 

allow to dry thoroughly before moving from one water 

body to another.

All Year Hydrologists, Fish 

Biologists

Minimize risk of weed spread on 

hydrologic and fisheries 

projects.

Monitor and control weeds until vegetation is sufficiently 

grown to exclude weeds. All Year Hydrologists, Fish Biologists

On all proposed soil or 

vegetation disturbing projects 

prescribe and implement weed 

prevention measures.

Ensure that pre – disturbance weed surveys and weed 

control are done as appropriate. Following soil or 

vegetation disturbance monitor for invasive weeds and 

control weeds for 3-5 years to avoid weed spread or 

establishment into areas that were free from weeds prior 

to project.

Spring/Su

mmer Project Lead

Establish native plants that will 

compete with weed seedlings 

and prevent establishment.

Seed areas of bare soil and sparse vegetation with native 

weed free seed/plants to prevent weed establishment.

Spring and 

Fall Project Lead

Use weed free materials

Use weed free mulch, gravel and other materials to prevent 

weed introduction and establishment. If this is not possible, 

then monitor and treat weeds for at least 3 years following 

disturbance.

All year Project lead
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

276

General Prevention Activity Description

(Describe the activity and where it will take place)

When

(season) Who

Wildlife Management

Consider the risk of weed spread 

and effects when planning 

habitat improvements. Be 

proactive in preventing habitat 

degradation by weeds.

Determine appropriate weed prevention measures when 

developing wildlife habitat improvement projects. Identify 

and fund weed control activities to preserve or improve 

wildlife habitat

All Year Wildlife Biologists

On all proposed soil or 

vegetation disturbing projects 

prescribe and implement weed 

prevention measures.

Ensure that pre-disturbance weed surveys and weed 

control are done as appropriate. Following soil or 

vegetation disturbance monitor for invasive weeds and 

control weeds for 3-5 years to avoid weed spread or 

establishment into areas that were free from weeds prior 

to project.

Spring/Su

mmer Project Lead

Establish native plants that will 

compete with weed seedlings 

and prevent establishment.

Seed areas of bare soil and sparse vegetation with native 

weed free seed/plants to prevent weed establishment.

Spring and 

Fall Project Lead

Use weed free materials

Use weed free mulch, gravel and other materials to prevent 

weed introduction and establishment. If this is not possible, 

then monitor and treat weeds for at least 3 years following 

disturbance.

All year Project lead

Botany (Plant Conservation)

Document invasive plants during 

project surveys.

Survey for and report invasive plants during pre-project 

surveys. Submit reports for incorporation into District weed 

database. Include survey and risk assessment reports in 

project NEPA.

All Year Botanists

Identify unknown plants Identify plants brought in by employees and report 

suspected weeds to weed coordinator All Year Botanists

Establish native plants that will 

compete with weed seedlings 

and prevent establishment.

On habitat improvement projects, seed areas of bare soil 

and sparse vegetation with native weed free seed/plants to 

prevent weed establishment. Monitor for and control 

weeds.

Spring and 

Fall Project Lead

Use weed free materials

Use weed free mulch, gravel and other materials to prevent 

weed introduction and establishment. If this is not possible, 

then monitor and treat weeds for at least 3 years following 

disturbance.

All year Project lead

Fire and Fuels Management

Prevent weed spread on fires.

In planning and on–the-ground activities include weed 

prevention measures such as cleaning engines; preventing 

crews from walking through known infestations, seed bare 

soils with weed free native seed and mulch.

All Year Fire/Fuels 

Management

Prevent weed spread on 

prescribed burns.

Ensure that pre-burn weed surveys are done. Consider 

changes in weed infestation as a result of timing and 

intensity of burn. Time burn to favor desired native plants 

and reduce weed infestation.

All Year Project Lead

Post burn weed monitoring and 

control

Monitor burn for invasive weeds and control weeds until 

vegetation has recovered sufficiently to exclude weeds.

Spring/Su

mmer Project Lead

Establish native plants that will 

compete with weed seedlings 

and prevent establishment.

Seed areas of bare soil and sparse vegetation with native 

weed free seed/plants to prevent weed establishment.

Spring and 

Fall Project Lead

Use weed free materials

Use weed free mulch, gravel and other materials to prevent 

weed introduction and establishment. If this is not possible, 

then monitor and treat weeds for at least 3 years following 

disturbance.

All year Project lead
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

277

General Prevention Activity Description

(Describe the activity and where it will take place)

When

(season) Who

ROW, Lands & Realty

Include assessment for weed 

control in all land tenure 

adjustments.

As needed All Year Realty Specialists

Include weed prevention 

stipulations in all rights-of-way 

authorizations.

See weed coordinator for standard contract stipulations 

and include in all contracts. Standard stipulations include 

equipment cleaning, use of certified weed free seed and 

mulch and reporting of suspect weeds.

All Year Realty and Access 

Specialists

Include weed prevention 

stipulations in tail hold 

authorizations.

See weed coordinator for standard contract stipulations 

and include in tail hold authorization. Standard stipulations 

include equipment cleaning, use of certified weed free seed 

and mulch and reporting of suspect weeds.

All Year Realty and Access 

Specialists

Enforce weed prevention 

stipulations as appropriate.

Monitor authorizations for compliance with weed 

stipulations. Report known or suspected weeds to weed 

coordinator and permittee.

Engineering & Project Contract Administration

Obtain standard stipulations for 

weed prevention and include in 

contracts.

See weed coordinator for standard contract stipulations 

and include in all contracts. Standard stipulations include 

equipment cleaning, use of certified weed free seed and 

mulch and reporting of suspect weeds.

All Year Contract writer

Enforce weed prevention 

measures in contracts.

Become familiar with weed prevention stipulations in 

contracts or activity plans and enforce them by inspecting 

vehicles, seed, mulch or other materials, reporting known 

or suspected weeds.

PIs, CORs

Re-vegetate bare soils with 

weed-free seed and mulch.

Use locally adapted native seed to re-vegetate areas of 

disturbed soil or vegetation. Use only certified weed free 

seed. Check with botanist for appropriate seed and 

requirements before purchasing.

All Year Project lead

On all proposed soil or 

vegetation disturbing projects 

prescribe and implement weed 

prevention measures.

Ensure that pre – disturbance weed surveys and weed 

control are done as appropriate. Following soil or 

vegetation disturbance monitor for invasive weeds and 

control weeds for 3-5 years to avoid weed spread or 

establishment into areas that were free from weeds prior 

to project.

Spring/Su

m mer Project Lead

Use weed free materials

Use weed free mulch, gravel and other materials to prevent 

weed introduction and establishment. If this is not possible, 

then monitor and treat weeds for at least 3 years following 

disturbance.

All year Project lead

General- Weed Management

Conduct weed awareness 

training for field-going 

employees and managers.

Present the “Dirty Dozen”, how to identify a potential new 

invader and how to report suspected weed infestations. Spring District Weed Coordinator

Review documents involving 

vegetation or ground 

disturbance for appropriate 

weed prevention measures.

Provide standard stipulation to prevent weed introduction 

and spread for contracts, ROW agreements, EAs, CXs, 

DNAs. When needed, review documents for appropriate 

weed prevention measures. Prescribe additional measures 

as needed.

All year Weed 

Coordinator

Survey the District lands to 

detect new invaders and 

expansions of established 

invasive plants.

Systematically inventory the District to detect new invaders 

and expansions of established invasive plants. Document 

using current data standards and enter into Oregon SDE 

and NISIMS.

Spring/Su

m mer/fall

District & 

Resource Area 

Weed 

Coordinators, and 

GIS Specialists

Alert employees to new 

invaders

Send out weed alerts when new weeds are found or likely 

to be found on the District Spring-Fall Weed Coordinator
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

278

General Prevention Activity Description

(Describe the activity and where it will take place)

When

(season) Who

Monitor treatments sites for 

implementation and 

effectiveness.

Review Pesticide Applicator Reports and monitor on the 

ground treatments for compliance with SOPs, Mitigation 

Measures and effectiveness of treatments.

Summer/F

all

Weed 

Coordinators

Coordinate with partners and

the public to prevent weed 

spread, particularly into weed 

free areas.

Participate in county weed boards. Coordinate weed 

prevention materials and activities with watershed 

councils.

All Year District Weed 

Coordinator

Distribute information and 

brochures to the public

Display weed brochures for the public in the front lobby. 

Distribute weed identification and control information to 

partners and the public at county fair and other events.

Year 

round

Front desk 

District Weed 

Coordinator

Establish and maintain 

partnerships to prevent the 

spread and control existing 

weeds.

Work closely with Oregon Dept. of Agriculture, County 

Weed Boards, Watershed Councils and Soil and Water 

Conservation Districts to develop and maintain mutually 

beneficial weed management efforts. Work with partners 

to develop and distribute educational and outreach 

brochures, articles and presentations.

All Year District Weed 

Coordinator

Work with adjacent landowners 

on weed awareness and control 

strategies.

Engage adjacent landowners to address mutually beneficial 

weed control strategies and activities. Attend annual ROW 

and Road Maintenance meetings.

All Year

District and 

Resource Area 

Weed 

Coordinators

Noxious Weed Risk Assessment Factors and Rating

Risk Assessment Factors

Factor 1: Likelihood of Noxious Weed Species Spreading to Project Area:

None: Noxious weed species not located within or adjacent to the project area. Project activity is not likely 

to result in the establishment of noxious weed species in the project area.

Low: Noxious weed species present in areas adjacent to but not within the project area. Project activities 

can be implemented and prevent the spread of noxious weeds into the project area.

Moderate: Noxious weed species located immediately adjacent to or within the project area. Project activities 

are likely to result in some area becoming infested with noxious weed species even when 

preventative management actions are followed. Control measures are essential to prevent the spread 

of noxious weeds within the project area.

High: Heavy infestations of noxious weeds are located within or immediately adjacent to the project area. 

Project activities, even with preventative management actions, are likely to results in the 

establishment and spread of noxious weeds on disturbed sites throughout much of the project area.

Factor 2: Consequence of Noxious Weed Establishment in Project Area:

Low to Nonexistent (1): None. No cumulative effects expected.

Moderate (5): Possible adverse effects on site and possible expansion of infestation within project 

area. Cumulative effects on native plant community are likely, but limited.

High (10): Obvious adverse effects within the project area and probable expansion of noxious 

weed infestations to area outside the project area. Adverse cumulative effects on 

native plant community are probable.
Integrated Invasive Plant Management for the Coos Bay District

Environmental Assessment

Appendix E – Prevention

279

Risk Rating

Step 1 – Identify level of likelihood and consequence of adverse effects and assign values according to the 

following:

None 0

Low 1

Moderate 5

High 10

Step 2 – Multiply level of likelihood times consequences.

Step 3 – Use the value resulting in Step 2 to determine Risk Rating and Action as follows:

Value Risk Rating Action

0 None Proceed as planned.

1-10 Low Proceed as planned. Initiate control treatment on noxious weed populations that get established in 

the area.

25 Moderate

Develop preventative management measures for the proposed project to reduce the risk of 

introduction or spread of noxious weeds into the area. Preventative management measures should 

include modifying the project to include seeding the area to occupy disturbed sites with desirable 

species. Monitor area for at least 3 consecutive years and provide for control of newly established 

populations of noxious weeds and follow-up treatment for previously treated infestations.

50-

100 High

Project must be modified to reduce risk level through preventative management measures, including 

seeding with desirable species to occupy disturbed sites and controlling existing infestations of noxious 

weed prior to project activity. Project must provide at least 5 consecutive years of monitoring. Projects 

must also provide for control of newly established populations of noxious weeds and follow-up 

treatment for previously treated infestations.