1792 (ORC000)

Coos Bay District Invasive Plant Management EA

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

Scoping Document

Dear Public Land User:

The Coos Bay District of the Bureau of Land Management (BLM) is beginning a planning process to expand 

and update its existing District-wide integrated noxious weed management program. The purpose of this 

letter is to give you an opportunity to share any information or concerns you may have about the proposal.

The District currently controls noxious weeds following existing BLM policy and a District-wide 1997 

Integrated Weed Management Plan and Environmental Assessment (EA) and Decision Record, using a range 

of methods including manual (e.g., hand-pulling) and mechanical treatments, using biological control agents,

proactive use of seeding and planting, and using herbicides (primarily 2,4-D and glyphosate, but also limited

amounts of dicamba and picloram). The District proposes to update and expand this program by—

• Increasing the kinds of non-native plants controlled from noxious weeds1 to all non-native invasive 

plants2; 

• Using additional non-herbicide methods like solarization, propane torches, and targeted grazing with 

sheep and goats; and

• Making additional herbicides available for use.

The additional herbicides, and their use on all invasive plants, were addressed in the 2010 Final 

Environmental Impact Statement and Record of Decision for Vegetation Treatments Using Herbicides on 

BLM Lands in Oregon (Oregon FEIS), the 2007 Final Programmatic Environmental Impact Statement and 

Record of Decision for Vegetation Treatments Using Herbicides in 17 Western States, and the 2016 Final 

Programmatic Environmental Impact Statement and Record of Decision for Vegetation Treatments Using 

Aminopyralid, Fluroxypyr, and Rimsulfuron. A 1984/87 court injunction had limited the BLM to using only 

four herbicides and restricting their use to noxious weeds only. This injunction was amended following 

completion of the Oregon FEIS and Record of Decision, to permit the use of additional herbicides and 

targeting additional species following completion of site-specific analysis and decision-making. This process 

will result in that site-specific analysis for invasive (non-native) plants on the Coos Bay District.

 

1 “Noxious weed” is a legal designation for invasive plants that are listed by the county, State, or Federal Government as injurious 

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

2 Invasive plants are non-native aggressive plants with the potential to cause significant damage to native ecosystems or cause 

significant economic losses, but are not currently listed on Federal, State, or County noxious weed lists... or are not currently 

recognized by Federal, State, or County governments as a “noxious weed.”

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
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Purpose and Need for Action

Despite the efforts of the BLM’s existing noxious weed program, there are 239 invasive species documented 

within the District boundary. There is a high likelihood that other invasive plants are present. Currently, 

many effective control methods are not available for use under the existing planning documents. 

Adverse effects caused by invasive plants include the displacement of native vegetation; reduced habitat and 

forage for wildlife; degraded habitat for endangered, threatened, or other Bureau listed Special Status plant 

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

recreation values; and reduced access to roads or recreation sites.

More selective herbicides are now available by the BLM to treat a wider variety of invasive plants. These 

herbicides can be used in lower quantities, and pose less environmental and human health safety risk than the 

four herbicides currently in use. The purpose for action is to

• 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-BLMadministered lands;

• Reduce the risk of unacceptable adverse effects to applicators and the public to desirable flora and 

fauna, and to soil, air, and water; and 

• Improve treatment effectiveness.

What Action is BLM Proposing? 

The Proposed Action is similar to the current invasive plant management program (the ‘No Action 

Alternative’) except it is expanded to allow herbicide use on all non-native invasive plants (not just those 

legally designated as noxious weeds), and it is expanded to include the use of additional herbicides on

District-managed lands. In addition to herbicide treatments, other inhibiting/removing/suppressing methods 

would include manual methods such as pulling and grubbing, seeding and planting; mechanical methods 

such as the use of chainsaws and mowers; burning methods such as prescribed fire, the use of biological 

control agents (generally insects), and targeted grazing (see Attachment 1: Invasive Plant Treatment 

Methods). 

Under both the No Action and Proposed Action Alternatives, all treatments would be conducted following

Standard Operating Procedures and prescribed project design features to prevent adverse effects. Treatments 

analyzed in these alternatives would be planned and conducted in an integrated weed management context 

that prioritizes prevention (education or regulations that prevent weed introduction or spread), followed by 

inventory, treatment (using the appropriate control method), monitoring, and re-establishment of siteappropriate native species through seeding or planting.

The District will prioritize invasive plant treatments based primarily on the risk and consequence of invasive 

plant introduction, establishment, and spread. Treatment priorities would include preventing the introduction 

of invasive plants into uninfested areas; detecting and controlling new infestations of new invasive plants on 

treated sites before they spread; containing established infestations; and, reducing the size and abundance of 

established infestations.
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What Actions are Not Being Proposed In this Analysis?

The Proposed Action will not analyze the use of herbicides to control native plants, for timber or livestock 

forage production, or the aerial application of herbicides.

How to Be Involved:

We would like to hear from you regarding any issues or concerns you feel should be analyzed to help ensure 

the completeness of the EA. The input you provide will help an interdisciplinary team of BLM natural 

resource professionals to assess the potential environmental effects of the proposed treatment methods. 

Comments helpful to the analysis process are those that identify new scientific or technical information and 

determine the scope of issues to be addressed. The BLM will refine the draft proposed action and/or develop 

alternatives for inclusion in the EA, based on the relevant issues raised during the public scoping period. 

Please submit your comments by May 10, 2017. 

Before including your address, phone number, email address, or other personal identifying information in 

your comment letter, you should be aware that your entire comment, including your personal identifying 

information, may be made publicly available. While you can ask to have your personal identifying 

information withheld from public review, we cannot guarantee that we will be able to do so.

Ways to Submit Scoping Comments:

• ePlanning: http://bit.ly/2nPTihx

• Email: blm_or_invasive_plant_ea_comments@blm.gov Subject: Coos Bay Invasive

Plant Management EA

• FAX: (541) 751-4303 Attn: Coos Bay Invasive Plant Management EA 

• Mail: Coos Bay District BLM, Attn: Coos Bay District Invasive Plant Management 

• EA, 1300 Airport Lane, North Bend, OR 97459

Once an EA has been prepared, the public will be notified of the opportunity to review and comment on the 

proposed action and analysis. If you do not have comments at this time but would like to be kept informed as 

planning progresses, please us send your name and email or address and your name will be maintained on the 

mailing list for this project. 

Questions about the project may be directed to Jeanne Standley, Project Lead, jstandle@blm.gov, (541)751-

4283.

/s/ Kathy Westenskow April 10, 2017

Kathy Westenskow Date

District Manager

Attachment : Invasive Plant Treatment Methods
Overview of Invasive Plant Treatment Methods Potentially Available Under the Proposed Action

Department of the Interior policy states, “[b]ureaus will accomplish pest management through cost-effective means that pose the least risk to humans, natural and cultural 

resources, and environment.”

Non-Herbicide Treatment Methods

Method and Examples Pros Cons Example Restrictions on Use

Manual 

Hand pull, dig, grub, lop

• Suitable for small infestations

• Target specific 

•Minimize damage to non-target plants

• Labor and time intensive, cost per acre high

• Must be conducted repeatedly to be effective

• Take care to avoid damage to desirable plants. 

•Botanist will oversee treatments in rare plant 

(SSS) habitat.

Mechanical

Hand held Equipment

String trimmers, mowers, 

propane burners, saws

• Appropriate for small infestations 

• More target specific than some other methods

•Suitable for public use areas 

• Used in conjunction with other treatments

• Potential for damage to non-target vegetation

• Must be conducted repeatedly to be effective

• Labor and time intensive, cost per acre high

• Take care to avoid damage to desirable plants. 

Mechanical

Ride-on and Heavy Equip

Tractors, Bulldozers, 

mowers, discs, plow, baler

•Used in conjunction with other treatments, such 

as fire, mowing, and herbicide

• Efficient for larger areas and rhizomatous plants

•Cost per acre typically high 

•Non-selective, all vegetation in treatment area

affected

•Suitable for areas with slope under 20%

• Use equipment that minimizes soil compaction

• Conduct treatments when the ground is 

sufficiently dry to support heavy equipment

Biological 

Traditional Control Agents

Insects, mites, pathogens

• Reduces vigor and abundance of noxious weeds

• Host-specific, regulated to avoid harm to crops 

and non-target species

• Available from ODA without cost for agent(s)

•Will not eradicate an infestation

• Requires a large infestation size to be effective

•Only available for some noxious weeds

•Permit and Release Reports required

• Use only APHIS and ODA approved agents 

•Use only ODA permitted agents

Biological 

Targeted Livestock Use

Cattle, sheep, and goats

• Effective at reducing palatable plants

•Use gives a competitive advantage to nontarget plants

•Will not eradicate infestation(s)

•Requires skilled herder or suitable fencing

•Efficacy depends on timing, other plants present

•Requires regular monitoring

• Select weeds that are palatable and non-toxic to 

the animals

• Manage the intensity and duration to minimize 

overutilization of desirable plant species

Cultural

Prescribed burning

• Effective just before flower or seed set 

•Effective at removing rank growth in pastures

• Only useful on larger infestations

•Requires burn and smoke management plan

•Requires oversight to keep in treatment area

•Requires smoke and traffic management

• Manage smoke to prevent air quality violations 

and minimize impacts to smoke-sensitive areas.

• Burn under favorable moisture conditions

Cultural

Seeding or planting

• Restores native plants following treatments

•Provides competition reduce or prevent invasive 

plant establishment

• Used with other treatments to restore function

• Labor and time intensive, cost per acre high

• Preplanning required to have native seed or 

plants available when needed

• Use locally adapted native species

Cultural 

Weed Barrier Mats

• Suitable for small infestations

• Prevents sunlight from reaching target plants

•Typically lasts for years

• Labor and time intensive to install

•Plastic and woven materials are not resistant to 

wind or hooves if used for more than a few 

months.

•Do not use plastic that is not wind and (elk) hoof 

resistant.
Herbicides

Herbicide Active Ingredient

Example trade names Target Vegetation and Examples Herbicide Characteristics Example Restrictions on Use

2, 4-D

Amine, Hardball, Unison, 

Saber, Salvo, Aqua-Kleen, 

and Platoon

Broadleaf plants

blackberry, brooms, buttercups, fennel, Field 

bindweed, foxglove, gorse, knapweed, Poison 

hemlock, Policeman’s helmet, Spanish heath, 

sowthistle, thistles, toadflax, Velvetleaf, Yellow 

glandweed

Selective, post emergent, foliar application

Effective on a wide range of broadleaf invasive 

plants while not affecting most grasses. Used to 

help inhibit seed production, enhance herbicide 

effectiveness and reduce herbicide resistance.

Add a small amount to other herbicides to 

improve effectiveness of the other herbicides and 

reduce the likelihood of herbicide resistance. 

Registered for aquatic/riparian use. Group 4

• Only use approved formulations for riparian, 

wetland and streamside applications.

• 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.

Aminopyralid

Milestone

Broadleaf plants

Starthistles, thistles, knapweeds, Oxeye daisy; 

Japanese, Giant, Himalayan and Bohemian 

knotweeds, Poison hemlock

Selective, post emergent, foliar application, 

Some soil residual activity to control germination. 

Can be an alternative to picloram, clopyralid, 2,4-

D, and dicamba, often at lower application rates. 

In mixtures with other herbicides, can control

hard-to-control species. Group 4

• 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

Telar

Broadleaf plants

Field mustard, foxglove, mullein, Queen Anne’s 

lace, teasel, thistles, toadflax, Yellow glandweed

Selective, pre-emergent and early post-emergent

Effective at very low dosages (half ounce to a few 

ounces per acre). Has similar targets as 

metsulfuron methyl. Can be used in combination 

with 2,4-D when the plant has developed 

resistance to other herbicide. Group 2

• Do not apply more than 1.33 oz/acre per year in 

pasture, range, and CRP 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

Transline, Stinger, and Spur

Broadleaf plants

of Sunflower, Pea and Knotweed families

brooms, Buffalo burr, burdock, knapweeds, 

kudzu, nightshade, Marestail, Oxeye daisy,

Perennial peavine, teasel, thistles, Spotted cat’s 

ear

Selective, post emergent

Targets same plants as picloram, but is more 

selective. Particularly effective on knapweeds and 

Canada thistle, while minimizing risk to 

surrounding desirable brush, grass, and trees.

Often mixed with other herbicides. Group 4

• 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.

Dicamba

Vanquish, Banvel, Diablo, 

Vision, and Clarity

Broadleaf plants

Biddy biddy, chickory, cocklebur, gorse, 

foxglove, knapweeds, plantain, Poison hemlock, 

mustards, Tansy ragwort, teasel, thistles, 

toadflax, White bryonia

Selective, post emergent

Effective on thistles and in combination with 2,4-

D on perennial mustards and knapweeds. 

Chlorsulfuron and metsulfuron methyl could be 

used in place of dicamba for the majority of 

mustard treatments. However, dicamba provides 

control right up to seed set, which extends the 

treatment window. Group 4

• Do not apply under conditions which favor 

runoff.

• Do not apply to impervious substrates such as 

paved or highly compacted surfaces in areas with 

high potential for ground water contamination.

Diflufenzopyr + dicamba

Distinct and Overdrive

Broadleaf plants

Field bindweed, Meadow knapweed, Oxeye 

daisy, teasel, thistles, starthistles

Selective, Post-emergent

Used for same species as dicamba. Can be used in 

a mixture with picloram, triclopyr, and clopyralid, 

allowing for a reduced rate of those herbicides. 

Important for herbicide resistance. Group 19 + 4

• Do not load, mix, or apply within 50 feet of 

wells.

• Do not apply directly to water, where surface 

water is present.

• Do not apply to impervious substrates or under 

conditions which favor runoff.

• Do not apply to soils which classify as sand. 
Herbicides

Herbicide Active Ingredient

Example trade names Target Vegetation and Examples Herbicide Characteristics Example Restrictions on Use

Fluroxypyr

Comet, Vista

Broadleaf plants

mustards, blackberry

Selective, Post-emergent, Growth regulator

Effective on annual and biennial broadleafs

particularly when mixed with 2,4-D, dicamba, 

metsulfuron methyl, or triclopyr. Useful for weeds 

that herbicide resistant plants with different 

modes of action. Use on administrative sites and 

rights-of-way. Group 4

• Do not apply directly to water, to areas where 

surface water is present.

• Do not apply where drift may be a problem due 

to proximity to susceptible crops or other nontarget broadleaf plants.

Glyphosate 

Many, including Rodeo, 

Mirage, Roundup Pro, and 

Honcho

Broadleaf, woody and grass plants

Blackberry, brooms, butterfly bush, Common 

reed, cordgrasses, False brome, ivy, Garlic 

mustard, geraniums, Giant hogweed, gorse, 

Jubata grass, knotweeds, matgrass, Purple 

loosestrife, yellow flag iris

Non-selective, Post emergent

Controls most plants. Careful application 

necessary to minimize damage to non-target 

plants. Useful for riparian species.

Registered for aquatic/riparian use. Group 9

• Only use approved aquatic formulations for 

applications in riparian and wetland vegetation.

Hexazinone

Velpar

Broadleaf, woody and grass plants

Canada thistle, geraniums, Spotted cat’s ear, 

Ripgut brome, Rattlesnake brome, Sweet vernal 

grass, Velvet grass,

Broad spectrum, Pre and Post emergent

Foliar or soil applied. Primarily for use on road 

rights-of-way. Group 5

• Do not apply directly to water, or to areas 

where surface water is present. 

• Use care where soils are permeable to avoid 

groundwater contamination.

Imazapic

Plateau and Panoramic

Broadleaf and some grass plants

annual bromes, bugloss, Giant hogweed, 

Johnsongrass, knapweed, nutsedges, 

Rattlesnake grass, Sweet vernal grass, Velvet 

grass, teasel, Yellow flag iris,

Selective, Post-emergent

Used primarily for treatment of invasive annual 

grasses. Selective at low rates, leaving the 

perennial herbaceous species critical for 

restoration. Group 2

• Do not apply directly to water, or to areas 

where surface water is present.

• To reduce run-off, avoid applications when rain 

is forecast w/in 48 hours.

Imazapyr

Arsenal, Stalker, Habitat, 

and Polaris

Broadleaf, woody and grass plants

blackberry, brooms, butterfly bush, cordgrass, 

European beachgrass, flowering rush, Jubata 

grass, knotweeds, matgrass, purple loosestrife, 

quackgrass, spurge laurel, Yellow flag iris

Non-selective, Pre and Post emergent

Registered for aquatic/riparian use. May be used 

in and around standing and flowing water, as well 

as in riparian / wetland settings.

Registered for aquatic/riparian use. Group 2

• 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.

Metsulfuron methyl

Escort, Patriot, and 

PureStand

Broadleaf plants

Blackberry, bugloss, field bindweed, loosestrife, 

nightshades, Sulphur cinquefoil

Selective, Post-emergent

Does not affect most grasses. Has similar targets 

and effects as chlorsulfuron. Group 2

•Do not apply directly to water, or to areas where 

surface water is present

Picloram

Triumph, OutPost, and 

Tordon

Broadleaf and woody plants

Blackberry,brooms, gorse, knapweeds,

Patterson’s curse, Poison hemlock, 

puncturevine, nightshade, Spanish heath, Tansy 

ragwort, thistles, toadflax, velvetleaf

Selective, Post-emergent, Persistent

Highly water mobile, active through foliage and 

roots. Cannot be used on coarse textured soils, 

above fractured bedrock and within no-spray 

buffers surrounding waterbodies. 

Provides residual control. Group 4

• Do not apply directly to water, or to areas 

where surface water is present.

• Do not contaminate water or water sources 

when mixing, loading, or disposing of wash-water.

• Do not make application when circumstances 

favor movement from treatment site. 

• Requires license to purchase or apply 
Herbicides

Herbicide Active Ingredient

Example trade names Target Vegetation and Examples Herbicide Characteristics Example Restrictions on Use

Rimsulfuron

Matrix

Some broadleaf and grass plants

Bouncing bet, Bur buttercup, Johnsongrass, 

Reed canarygrass 

Selective, Pre and Post emergent

Effective on winter-annual grasses in the fall or 

spring. It provides a longer window of control 

than imazapic, although it must be used at the 

highest label rates for effective spring 

applications. Group 2

• Do not apply directly to water, or to areas 

where surface water is present. 

Sulfometuron methyl

Oust, Spyder

Broadleaf and Annual Grass Plants

annual grasses, Bristly dog tail, bur buttercup, 

field mustard, reed canarygrass

Broad-spectrum Pre and Post-emergent 

Like imazapic, it is effective on cheatgrass and 

medusahead rye and can be selective for annuals 

at low rates. Group 2

• Do not apply directly to water, or to areas 

where surface water is present. 

Triclopyr

Garlon, Renovate, and 

Element

Broadleaf perennials and Woody Plants

Acacia, Biddy biddy, blackberry, brooms, gorse, 

hawkweeds, holly, ivy, knapweeds, knotweeds, 

Old man’s beard, periwinkle, Policeman’s 

helmet, Purple loosestrife, Spanish heath, Tansy 

ragwort, teasel, Tree of heaven, thistles, White 

bryonia, Yellow archangel

Selective, Post-emergent, Growth regulator

Triclopyr BEE, the ester formulation, is more 

effective at smaller doses and often used as a cutstump treatment, in addition to foliar 

applications. TEA form is registered for 

aquatic/riparian use. Group 4

• Minimize overspray to open water (streams, 

lakes, etc.) when treating vegetation growing at 

water edge.