United States Department of the Interior

BUREAU OF LAND MANAGEMENT

Coos Bay District Office

1300 Airport Lane, North Bend, OR 97459

Web Address: http://www.blm.gov/or/districts/coosbay

E-mail: BLM_OR_CB_Mail@blm.gov

1792/9015 (ORC000) 

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

FINDING OF NO SIGNIFICANT IMPACT

for the

Integrated Invasive Plant Management for the Coos Bay District

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

I. Introduction

The Bureau of Land Management (BLM), Coos Bay District, is proposing to expand and update its existing 

integrated noxious weed management program. The Coos Bay District currently controls noxious weeds 

under a District-wide 1997 Integrated Noxious Weed Program on the Coos Bay District Environmental 

Assessment (EA) that analyzes treatments 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 expand this program by selecting the selected alternative

in the EA, which would: 

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

• Increase the herbicide active ingredients available for use; and,

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

treatments.

Use of the additional herbicides was previously analyzed in the 2007 Vegetation Treatments Using 

Herbicides on BLM Lands in 17 Western States Final Programmatic Environmental Impact Statement (2007 

PEIS), the 2010 Vegetation Treatments Using Herbicides on BLM Lands in Oregon Final Environmental 

Impact Statement (2010 FEIS), and the 2016 Vegetation Treatments Using Aminopyralid, Fluroxypyr, and 

Rimsulfuron Final Programmatic Environmental Impact Statement (2016 PEIS). This 2018 EA tiers to the 

2007 PEIS, 2010 FEIS, and 2016 PEIS, and analyzes herbicide and non-herbicide invasive plant treatment 

methods applied in an integrated management approach. It examines the environmental effects of the 

proposal at a site-specific scale within the Coos Bay District. The Decision Record that follows this EA will 

replace the one currently in place. 

Consistent with the EA and the analysis summarized below, the selected alternative would not constitute a 

major Federal action that would have significant adverse impacts on the quality of the human environment. 

Therefore, preparation of an EIS is not required.

II. Determination of Significance

The Council on Environmental Quality’s (CEQ) regulations provide that the significance of impacts must be 

determined in terms of both context and intensity (40 CFR §1508.27). An analysis of the context and 

intensity of the effects of the selected alternative follows.
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A. Context: In accordance with CEQ regulations found at 40 CFR §1508.27(a), the significance of an action 

must be analyzed in several contexts such as society as a whole (human, national), the affected region, 

the affected interests, and the locality. Significance varies with the setting of the selected alternative. For 

instance, in the case of a site-specific action, significance would usually depend upon the effects in the 

locale rather than in the world as a whole. Both short and long-term effects are relevant.

The alternatives describe site-specific actions directly affecting approximately 1,000 gross acres on the Coos 

Bay District annually. Currently there are over 18,000 acres of mapped infestations and an unknown amount 

of unmapped infestations on the 311,942 total acres within the Coos Bay District boundary. There are also

interspersed private or other public lands within the District (EA:11). The treatments by BLM would occur 

entirely on BLM-administered lands within the Coos Bay District. The treatments would be dispersed (most 

sites are less than 1⁄2 acre in size)(EA:31) and 95 percent of herbicide applications would be spot treatments

(EA:51). The BLM has not and would not use aerial methods to apply herbicides (EA:41). The Selected 

alternative does not have international, national, region-wide, or state-wide importance.

B. Intensity: The following analyzes the intensity of the selected alternative using the ten significance 

criteria described in CEQ regulations found at 40 CFR §1508.27(b):

1. Impacts that may be both beneficial and adverse.

The potential for herbicides to harm wildlife, fish, people, non-target plants, and other elements of the 

environment has been examined in detail in existing Risk Assessments (see Appendix C of the attached EA 

for a summary). Where the Risk Assessments identified a potential for an adverse effect, and existing 

Standard Operating Procedures did not eliminate that potential, Mitigation Measures from the 2010 FEIS and 

the 2007 and 2016 PEISs and Project Design Features adopted as part of this analysis were incorporated into 

the selected alternative to eliminate the potential for significant adverse effects. Standard Operating 

Procedures and Project Design Features also address potential adverse effects of prescribed fire, mechanical, 

manual, and biological methods. The Risk Assessments, Standard Operating Procedures, and Mitigation 

Measures served as a primary information source for much of the analysis of effects (EA:47, 78).

In addition to the foregoing, the EA demonstrates that the selected alternative would slow the spread of

invasive plants. Under the selected alternative, the 18,100 acres of mapped infestations would spread to 

12,600 fewer acres after 20 years of treatments than would be expected on the District under the No Action 

Alternative (EA:84). Additionally, the selected alternative provides treatment options to control species of 

noxious weeds like Canada thistle and perennial grasses that currently cannot be effectively controlled with 

the four herbicides and treatment methods available to the Coos Bay District. In addition, 41 other invasive 

plants species cannot currently be treated because they are not designated as noxious (EA:27-31, 49), but 

could be treated under the selected alternative. Therefore, the selected alternative would facilitate protection 

and rehabilitation of plant communities overrun or threatened by these invasive plants in the long-term

(EA:95-97). Given the adverse effects of invasive plants on District resources identified within the EA, the

selected alternative is expected to result in a net beneficial effect.

2. The degree to which the selected alternative will affect public health or safety.

The EA demonstrates that the selected alternative would have no potential for significant negative effect on 

public health or safety, as described in the Human Health Issues in Chapter 3. Appropriate training and work 

practices dictated by Federal and State Occupational Safety and Health Administration rules, together with 

Standard Operating Procedures and Mitigation Measures, address worker and public safety associated with 

invasive plant treatments. The herbicides included in the selected alternative have been examined by the 

BLM and Forest Service through Risk Assessments and have been analyzed in the national and state 
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programmatic EISs to which the attached EA is tiered. Human health risk ratings are discussed in the Human 

Health Issues in Chapter 3 of the attached EA. The Risk Assessment-modeled scenarios, including direct 

exposure as well as subsistence-level ingestion of contaminated fruit and water, were deemed no risk for 

most of the herbicides under most scenarios. “No risk” means exposure modeling scenarios resulted in 

dosages less than one-tenth of the lowest observable effect level identified during testing or simulations 

based on existing research.1 Where the Risk Assessments found risks above the lowest observable effect 

level, Mitigation Measures identified in the 2010 FEIS or 2007 and 2016 PEISs were incorporated into the 

selected alternative to ensure that human exposures remain below the modeled scenarios where effects would 

not be expected. Mitigation Measures include using lower herbicide application rates where feasible, 

prohibiting broadcast spraying in some situations, and posting warning signs in large application areas and 

high public use areas (EA:121-128). With application of the Mitigation Measures adopted by the EISs to 

which this EA tiers, the EA analysis shows that none of the potential risks to human health are significant.

Public concern has been expressed regarding labeling of glyphosate as “probably carcinogenic” based on 

confusing terminology from different committees within the World Health Organization that described the 

“risk” and the “hazard” of exposure. Multiple studies, court cases and scientific literature reviews have been 

conducted since then and all have come to similar conclusions that there is insufficient information that 

glyphosate causes cancer. The Oregon FEIS to which this EA tiers 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 (USDI 2010a:344). This remains 

true for the analysis in this EA.

Project Design Features addressed in the EA to prevent risk of harm to Tribal members also include meeting 

with interested local Tribes in advance of treatments to review treatment plans (potentially adjusting actions 

after consultation with Tribes) and posting signs in appropriate treatment areas (EA:152). In addition, 

Standard Operating Procedures and Mitigation Measures (see Appendix A of the attached EA; EA:183-226) 

will be followed to prevent water (including groundwater), soil, and vegetation contamination.

The EA demonstrates that there would be no disproportionate negative health or safety effect to low income 

or minority populations (see Environmental Justice Issue; EA:153-154)

3. The anticipated severity of the impacts to unique characteristics of the geographic area such as prime and 

unique farm lands, Wild and Scenic Rivers, Designated Wilderness, or Areas of Critical Environmental 

Concern (ACECs).

There are no prime and unique farmlands, Wild and Scenic Rivers, or Designated Wilderness on BLMadministered lands within the Coos Bay District. 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. As described in the Native Vegetation 

Issue 1, control of invasive plants must be done in a manner that protects the resources and values for which 

special areas are designated, and therefore adverse effects to Special Status plants and the ACECs would be 

negligible. Selective treatments that target individual plants or patches, such as hand-pulling, digging, and 

grubbing, would have short-term, minor effects affecting individual Special Status plants, but not entire 

populations. Long-term effects would benefit Special Status plants and their habitat. The BLM would use 

spot treatments on 95 percent of herbicide treatments, so the overall effects to Special Status plants from drift 

would be negligible. In the long term, effects would be beneficial to special area values because of the return 

of native vegetation. The result of an invasive plant management program with more effective herbicides and 

 1 The lowest observable effect may have been eye irritation, rash, or any other adverse effect. Risk Assessments note that most of these effects 

are reversible when the exposure is eliminated.
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additional non-herbicide methods under the selected alternative (80 percent effective compared to 60 percent 

effective under the No Action Alternative) would allow the District to selectively treat invasive plants with 

fewer retreatments and fewer adverse effects to non-target species (EA:95-97). 

The largest concentrations of invasive species threatening Special Status plants are found in the coastal sand 

dune communities of the New River and North Spit ACECs (of 262 acres of unique habitat threated by 

invasive plants, 238 acres are in these two ACECs). These ACECs are also critical habitat for the threatened 

western snowy plover and Special Status pink sand verbena habitat. In coastal dune communities, annual 

treatments of European beachgrass and seeding and planting prevent major adverse effects to pink sand 

verbena. Outside of the habitat restoration areas, spot treatments of imazapyr with or without glyphosate, 

imazapic, and sulfometuron methyl would be used to effectively treat invasive grasses and plantain in open 

sand dune habitats. In addition, as described in Native Vegetation Issue 1, the selected alternative provides 

effective control of the Canada thistle, which is currently threatening Special Status species and unique plant 

communities in several ACECs. For example, control of Canada thistle is necessary for Oregon bensoniella 

(in China Wall ACEC) to continue to persist on the District (EA:89-90, 95-97).

4. The degree to which the effects on the quality of the human environment are likely to be highly 

controversial.

Controversy is defined as disagreement within the scientific community about the nature of the effects (40 

CFR 1508.27(b)(4)). The Environmental Protection Agency (EPA) requires pre-market multiple toxicity, 

persistence, and environmental fate tests prior to registration of herbicide products. The toxicity tests include 

mammals, fish, plants, and other taxa. All of the herbicides proposed for use in this EA are registered with 

the EPA. In addition, this analysis relies on BLM or Forest Service-prepared Risk Assessments for each of 

these herbicides. Risk Assessments are analytical examinations of the potential for adverse effects given 

modeled and described exposures and doses, and include an up-to-date review of the best available scientific 

literature (EA:243-257). In addition, the herbicides in the selected alternative were also analyzed at the 

statewide level in the 2010 Vegetation Treatments Using Herbicides on BLM Lands in Oregon FEIS or 

nationally in the 2007 and 2016 Vegetation Treatments PEISs. Though there has been public disagreement or 

controversy about the potential for glyphosate to cause cancer, the scientific evidence has consistently 

determined that a causal relationship cannot be established, demonstrating a lack of scientific controversy. 

These herbicides are extensively studied and there is enough information available for the decision-maker to 

understand the potential for environmental effects. The science used to inform environmental effects 

described in this EA is long established and not highly controversial.

5. The degree to which the possible effects on the human environment are highly uncertain or involve unique 

or unknown risks.

The BLM concludes that there is very little uncertainty regarding the effects of the selected alternative, that 

there are no unique risks associated with the selected alternative, and that there is a very small chance that 

unknown risks will come to light beyond those already analyzed in the EISs to which the attached EA is 

tiered. The BLM bases this conclusion on the following:

(a) The herbicides in the selected alternative were analyzed at the statewide level in the 2010 

Vegetation Treatments Using Herbicides on BLM Lands in Oregon FEIS or nationally in the 2007 

and 2016 Vegetation Treatments PEISs;

(b) The herbicides have been analyzed as part of EPA registration and Forest Service / BLM Risk

Assessments, which examine wildland herbicide use and worker / public safety;

(c) Specialists familiar with District resources and past noxious weed treatments prepared the EA 

analysis;
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(d) Currently there are 18,100 acres of mapped infestations and an unknown amount of unmapped 

infestations on the 311,942 total acres within the Coos Bay District boundary. The treatments on 

1,000 gross acres annually would occur entirely on BLM-administered lands within the Coos Bay 

District. The treatments would be dispersed (most sites are less than 1⁄2 acre in size) and 95 percent

of herbicide applications would be spot treatments; and,

(e) The herbicides and treatment methods that are included in the selected alternative have been 

extensively researched and analyzed and are subject to hundreds of Protection Measures controlling 

how, when, and where treatments can be implemented in order to mitigate potential risks.

6. The degree to which the action may establish a precedent for future actions with significant effects or 

represents a decision in principle about a future consideration.

The BLM made a decision with the Northwestern and Coastal Oregon Resource Management Plan and the 

2010 FEIS as well and the 2007 and 2016 PEISs, to which the attached EA tiers, to control invasive plants 

using the suite of treatment methods. The selected alternative does not establish a precedent for actions with 

potentially significant adverse effects, nor does it represent a decision in principle about a future 

consideration. The selected alternative only applies to invasive plant management within the Coos Bay

District. Each of the other BLM districts in Oregon has conducted or will conduct an independent NEPA 

analysis to determine appropriate site-specific invasive plant management within that district. No national or 

other precedent would be created by implementing the selected alternative. Use of herbicides other than 

those analyzed in this EA would be subject to additional NEPA analysis and significance of effects of such 

action would be separately assessed.

7. Whether the action is related to other actions with individually insignificant but cumulatively significant 

impacts.

Based on the analysis contained within the various resource effects issues in Chapter 3 of the attached EA,

the selected alternative would not have significant cumulative effects and there are no adverse cumulative 

effects associated with the selected alternative. The analysis shows more effective control of invasive plant 

species due to more targeted treatments that are more consistent with treatments of other State, County, and 

Federal agencies and private industrial timber landowners. Under the selected alternative, invasive plants are 

less likely to spread from BLM to adjacent lands and vice versa.

For the following resources, the analysis shows negligible or no adverse effects resulting from invasive plant 

treatments: native vegetation, fish and aquatic organisms, wildlife, human health, soil, water, air quality, fire, 

archeological and cultural resources, traditional and cultural uses, socioeconomics, and recreation (see Issue 

sections in Chapter 3 of the attached EA; EA:79-161). This is largely due to the small amount of acres 

treated in a given year, the dispersed nature of the treatments, the targeted application of herbicides and 

several hundred Project Design Features and Standard Operating Procedures that would be applied for the 

selected alternative. These individually insignificant effects are not cumulatively significant, beyond the 

effects already analyzed in the EISs to which the attached EA is tiered.

8. The degree to which the action may adversely affect districts, sites, highways, structures, or other objects 

listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of 

significant scientific, cultural, or historical resources.

The selected alternative would be implemented within areas used historically by Native Americans, and 

which contain known and unknown Native American spiritual and sacred sites, and important ceremonial 

and subsistence plant collecting sites. The potential to affect these sites is discussed in Chapter 3 of the EA

(see Traditional and Cultural Uses (Native American Interests) Issue, EA:152-153). The analysis concludes 

that cultural site surveys, the incorporation of appropriate Project Design Features, Mitigation Measures, 
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monitoring, and annual review of treatment plans with interested Tribes will prevent the loss or destruction 

of significant cultural or historical resources.

Additionally, the action will not adversely affect districts, sites, highways, structures, or other objects listed 

in or that are eligible for listing in the National Register of Historic Places (see Archeological and Cultural 

Resources Issue; EA:150-152). The BLM will follow the 2015 State Protocol between the Oregon BLM and 

the Oregon State Historic Preservation Office (SHPO) regarding the manner in which the BLM 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). The BLM reviews each treatment 

application (project) on a case-by-case basis to determine the appropriate protection measures needed. 

Fieldwork may be required to establish the presence / absence of cultural resources and their significance

(EA:16).

9. The degree to which the action may adversely affect an endangered or threatened species or its habitat 

that has been determined to be critical under the Endangered Species Act of 1973.

The action would not have adverse effects on threatened or endangered species or their critical habitat 

beyond those already analyzed in the EISs (USDI 2007a:4-92 to 4-96 and 4-118 to 4-124; USDI 2010a:235-

240, 245-258; USDI 2016a:4-44 to 4-51 and 4-54 to 4-63) to which the attached EA is tiered. The Coos Bay 

District has seven federally listed species that are known to occur on the District that have the potential to be 

affected by invasive plant management.

There is one federally listed plant species documented on BLM-administered lands in the Coos Bay District 

– the endangered western lily. The western lily has been documented at one site on the Coos Bay District and 

there are no known invasive plant sites within a thousand feet of the western lily population. The western lily 

site is also located off-trail 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 (EA:90).

The selected alternative could potentially affect three federally listed anadromous fish, including the Coho 

Salmon (threatened, Oregon Coast and Southern Oregon / Northern California Coast Evolutionary 

Significant Units) and its designated critical habitats and essential fish habitat; the Green Sturgeon and its 

designated critical habitat (threatened, southern distinct population segment); and the Pacific Eulachon and 

its designated critical habitat (threatened, southern distinct population segment). No direct adverse effects are 

anticipated as a result of the selected alternative, as Protection Measures limit the potential for terrestrial 

applications of herbicides from entering the water directly. 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 selected alternative, ninety-five percent of herbicide treatments 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. None of the proposed 

treatments would target large overstory trees, so shade and sources of future coarse wood inputs would be 

maintained in treatment areas.

The effects from terrestrial invasive plant control actions on these species were analyzed in the Aquatic 

Restoration Biological Assessment II (ARBA II) and were provided Endangered Species Act coverage under 

the National Marine Fisheries Service’s Aquatic Restoration Biological Opinion (ARBO II, NMFS 2013). In 

ARBO II, a Likely to Adversely Affect determination was made for Coho Salmon and its critical habitat.

Project Design Criteria for invasive plant control outlined in National Marine Fisheries Service (NMFS)’s 
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ARBO II were fully incorporated as a Project Design Feature 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 6th field HUC [hydrologic unit code] 

watershed / year)(EA:219-223). 

The effects of management activities, including invasive plant management, on two wildlife listed species 

were assessed in a Fiscal Years 2014-2018 Programmatic Suite of Activities that May Affect [Northern] 

Spotted Owls, [Marbled] Murrelets and their designated Critical Habitats Proposed by The Coos Bay 

District BLM and the Coquille Indian Tribe Biological Assessment (USDI 2014a). BLM determined that 

noxious weed management and native plant reestablishment would not affect habitat and the disturbance 

may affect, but is 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 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 selected alternative as a Project Design 

Feature to minimize potential effects. 

The BLM has engaged in multiple consultations with the US Fish and Wildlife Service over time addressing 

habitat restoration activities for western snowy plover at North Spit and New River. The most recent 

consultations 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 2007f) 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 Fish and Wildlife Service 

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.

10. Whether the action threatens to violate Federal, State, or local law or requirements imposed for the 

protection of the environment.

The EA demonstrates that the selected alternative complies with all applicable Federal, State, and local 

environmental laws and other environmental requirements, including, without limitation, the Clean Water 

Act, Clean Air Act, and Endangered Species Act. Additionally, the Federal Land Policy and Management Act 

requires that any action that BLM implements must also conform to the current land use plan and other 

applicable plans and policies. The selected alternative conforms to the management direction contained in

the Northwestern and Coastal Oregon Resource Management Plan and Record of Decision (USDI 

2016d)(EA:19-20). It also conforms with Executive Orders and various U. S. Department of the Interior 

policies regarding the use of herbicides and the management of invasive plants (EA:18); and the constraints 

and requirements adopted in the Records of Decision for the 2010 FEIS and the 2007 and 2016 PEISs 

(EA:52). The BLM has consulted with the U.S. Fish and Wildlife Service and the National Marine Fisheries 

Service on threatened and endangered species and has incorporated all protection measures into the selected 

alternative (EA:202-226). 

III. Finding

The potential impacts associated with the use of herbicides to treat noxious weeds and other invasive plants 

were previously evaluated in the 2010 FEIS and the 2007 and 2016 PEISs to which the attached EA is tiered.

The impacts of herbicide use described for the selected alternative analyzed in the attached EA fall within the 
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range of those analyzed in these analyses and the types of actions and the amounts of treatments under the 

selected alternative would be consistent with the actions analyzed in the 2010 Oregon FEIS and the 2007 and 

2016 PEISs. In view of this, and on the basis of (1) the analysis contained in the attached EA addressing 

manual, mechanical, biological, prescribed fire, herbicide application, and competitive seeding or plantings, 

(2) the consideration of context and intensity factors described above, and (3) all other available information, 

my determination is that the selected alternative would not constitute a major Federal action which would 

have significant impacts on the quality of the human environment. Therefore, an EIS for the selected 

alternative is unnecessary and will not be prepared.

/s/ Kathy Westenskow-Davis October 29, 2018

________________________________ __________________ 

Kathy Westenskow-Davis Date

District Manager, Coos Bay District