## Aquatic Pesticide Application Plan
for the San Francisco Estuary Invasive Spartina Project

This plan addresses herbicide application activitie s undertaken by ISP Partner agencies in the effort to eradicate non-native, invasive Spartina from the San Francisco Estuary.

Annual update prepared by

Drew Kerr 2612-A 8 th Street Berkeley, CA 94710 dwkerr@spartina.org

for the State Coastal Conservancy 1330 Broadway, 13th floor Oakland, Ca 94612-2530

August 2008TABLE OF CONTENTS

1. BACKGROUND ........................................................................................................... 1

2. STATEMENT OF PURPOSE AND NEED ........................................................... 1

3. DESCRIPTION OF THE WATER BODY SYSTEM ........................................... 2 Ecology ................................................................................................................................... 2 Natural Processes Affecting Water Quality ............................................................................ 3 Water Quality .......................................................................................................................... 4 Sediment Quality .................................................................................................................... 7

4. DESCRIPTION OF TARGET SPECIES ............................................................... 9 Native Pacific Cordgrass ( Spartina foliosa ) ........................................................................... 9 Atlantic Smooth Cordgrass ( Spartina alterniflora ) and its Hybrids ..................................... 10 English Cordgrass ( Spartina anglica ) ................................................................................... 13 Chilean Cordgrass ( Spartina densiflora ) .............................................................................. 13 Salt-Meadow Cordgrass ( Spartina patens ) ........................................................................... 14

5. CONTROL TOLERANCES .................................................................................. 14

6. DESCRIPTION OF HERBICIDE ........................................................................ 15

Environmental Fate of Herbicides ........................................................................................ 21 Potential Biological and Ecological Effects ......................................................................... 25 Non-Target Aquatic Plants and Algae .............................................................................. 27 Aquatic and Benthic Invertebrates ................................................................................... 28

Fish

............................................................................................................................... .... 29

Birds

............................................................................................................................... .. 31

Mammals .......................................................................................................................... 31

7. DESCRIPTION OF ALTERNA TE, NON-CHEMICAL CONTROL METHODS ............................................................................................................. 32

ISP-selected Non-chemical Control Methods ....................................................................... 32 Hand-pulling and manual excavation ............................................................................... 32 Mechanical excavation and dredging ............................................................................... 33 Covering/blanketing ......................................................................................................... 34
Other Non-chemical Methods Evaluated .............................................................................. 35 Mowing, burning, pruning, and flaming .......................................................................... 35 Crushing and mechanical smothering .............................................................................. 35 Flooding and draining ...................................................................................................... 36

8. HERBICIDE APPLICATION AREAS FOR 2007 .............................................. 37 Site 01 – Alameda Flood Control Channel, Alameda County .............................................. 37 Site 02 – Bair & Greco Island Complex, San Mateo County ............................................... 37 Site 03 – Blackie’s Pasture, Marin County ........................................................................... 39Site 04 – Corte Madera Creek Complex, Marin County ....................................................... 39 Site 05 – Coyote Creek & Mowry Slough Area, Santa Clara County .................................. 40 Site 06 – Emeryville Crescent, Alameda County ................................................................. 40 Site 07 – Oro Loma Marsh, Alameda County ...................................................................... 41 Site 08 – Palo Alto Baylands, Santa Clara County ............................................................... 41 Site 09 – Pickleweed Park, Marin County ............................................................................ 42 Site 10 – Point Pinole Regional Shoreline, Contra Costa County ........................................ 42 Site 11 – Southampton Marsh, Solano County ..................................................................... 43 Site 12 – Southeast San Francisco, San Francisco County ................................................... 43 Site 13 – Whale’s Tail / Old Alameda Creek Complex, Alameda County ........................... 44 Site 15 – South San Francisco Bay Marshes, Santa Clara County ....................................... 45 Site 16 – Cooley Landing, San Mateo County ..................................................................... 45 Site 17 – Alameda Island / San Leandro Bay Complex, Alameda County ........................... 46
Site 18 – Colma Creek / San Bruno Marsh Complex, San Mateo County ........................... 46 Site 19 – West San Francisco Bay, San Mateo County ........................................................ 47 Site 20 – San Leandro / Hayward Shoreline Complex, Alameda County ............................ 48 Site 21 – Ideal Marsh, Alameda County ............................................................................... 48 Site 22 – Two Points Complex, Alameda County ................................................................ 49 Site 23 – Marin Outliers, Marin County ............................................................................... 49 Site 24 – Petaluma River, Sonoma County ........................................................................... 50 Site 26 – North San Pablo Bay, Solano County .................................................................... 50 9. WATER QUALITY MONITORING PLAN ....................................................... 51 Objective

............................................................................................................................... 51
Site Selection ........................................................................................................................ 51 Site Descriptions ............................................................................................................... 52 Sampling Frequency and Sampling Design .......................................................................... 56 Sampling Procedures ........................................................................................................ 56 Sample Analysis ............................................................................................................... 57 Data Analysis ................................................................................................................... 57 10. APPLICABLE WATER QUALITY BMPS ....................................................... 57 Applicator Calibration Training ............................................................................................ 58

11. REFERENCES ...................................................................................................... 60

Appendices

1. Chemical properties, degradation rates, environmental fate, and toxicity of imazapyr, glyphosate, and aquatic surfactants evaluated for Spartina control

2. 2008 Spartina Control Program Site Maps

3. General Site Safety & Materials Handling Guidelines and Procedures for Spartina Control Projects in the San Francisco EstuaryList of Figures Figure 1: Locations and mean discharges for municipal wastewater treatment plants in South San Francisco Bay.....................................................................4 Figure 2: Conceptual Model of Possibl e Exposure of Biological Organisms to Herbicide Mixture Used by the Spartina Control Program.............................26 Figure 3: Baywide map of 2008 Spartina Control Program treatment sites ...................38

List of Tables

Table 1: Dissolved concentrations of trace metals in water samples...............................7

Table 2: Total concentrations of trace metals in water samples ......................................7 Table 3: Ranges of trace pollutants in San Francisco Bay sediments..............................8 Table 4a: Imazapyr herbicide mixture co mponent concentrati ons and application rates for treatment of non-native Spartina in San Francisco Estuary ..............20 Table 4b: Glyphosate herbicide mixture co mponent concentrations and application rates for treatment of non-native Spartina in San Francisco Estuary ..............20 Table 5: Summary of water quality monitoring sites for the 2008 season.....................521. BACKGROUND The San Francisco Bay Estuary (San Francisco Estuary or Estuary) supports the largest and most ecologically important expanses of tidal mudflats and salt marshes in the contiguous western United States. This environment naturally supports a diverse array of native plants and animals. Over the years, ma ny non-native species of plants and animals have been introduced to the Estuary, and some now threaten to cause fundamental changes in the structure, f unction, and value of the Estu ary's tidal lands. Among these threatening invaders are several spec ies of salt marsh cordgrass (genus Spartina ). In recent decades, populations of non-native cordgrasses were introduced to the Estuary and began to spread rapidly. Though valuable in their native settin gs, these introduced cordgrasses are highly aggressi ve in this new environment, and frequently become the dominant plant species in areas they invade. One of the non-native cordgrass spec ies, Atlantic smooth cordgrass ( Spartina alterniflora ), is rapidly spreading throughout the Estuary, particularly in the South San Francisco Bay (South Bay). Atlantic smooth co rdgrass and its hybrids (formed when this species crosses with the native Pacific cordgrass, S. foliosa ) are now threatening the ecological balance of the Estuary. Based on a centu ry of international st udies of comparable cordgrass invasions, these hybrid s are likely to eventually cause the extinction of native Pacific cordgrass, choke tidal creeks, dominate newly restored tidal marshes, and displace thousands of acres of existing shorebird habita t. Once established in this estuary, invasive cordgrasses could rapidly spread to other estuaries along the Calif ornia coast through seed dispersal on the tides. Non-native invasi ve cordgrasses curren tly dominate approximately 1,200-1,500 acres of the San Francisco Estuary in seven counties — on State, Federal, municipal, and private lands— and are spreading at an alarming rate. The California State Coastal Conservancy (C onservancy) initiated the ISP in 2000 to stave off the invasion of non-nati ve cordgrass and its potential impacts. The ISP is a regionally coordinated effort of Federal, State, and local ag encies, private landowners, and other interested parties, with the ultimate goal of arresting and re versing the spread of non-native cordgrasses in the San Francisc o Estuary. When fully implemented, the ISP will provide opportunities to maximize resour ces, effectively disseminate information, facilitate regional monitoring, and reduce the occurrence of cordgra ss re-infestation. The geographic focus of the ISP includes the nearly 40,000 acres of tidal marsh and 29,000 acres of tidal flats that compri se the shoreline areas of the nine Bay Area counties, including Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Solano, and Sonoma Counties, and Sacramento County.

2. STATEMENT OF PURPOSE AND NEED The purpose of the Spartina control program is to arrest and reverse the spread of invasive non-native cordgrass species in the San Fr ancisco Estuary to preserve and restore the ecological integrity of the Estuary's intertidal habitats and estuarine ecosystem.

The Spartina control program is needed to prevent further degradation and loss of the natural ecological structure a nd function of the San Francisc o Estuary. In the absence of any coordinated and wide-ranging control program, within decades one-quarter to oneSan Francisco Estuary Invasive Spartina Project 1. 2008 Aquatic Pesticide Application Planhalf (up to 10,000 acres) of the existing inter tidal flats are likely to be replaced with dense, invasive cordgrass marsh, and much of the native diverse salt-marsh vegetation replaced with nearly homogeneous stands ofnon-native cordgrass. This ecological conversion is likely to alter the structure and f unction of the Estuary, a ffecting fisheries, migratory shorebirds and waterfowl, marine mammals, endangered fish, wildlife, and plants, tidal sediment transport, and the rate, pattern, and magnitude of tidal flows. In addition, invasive cordgrasses may impede or preclude plans to restore up to 20,000 acres of diked baylands to native tidal marsh. Arresting and reversi ng the invasion of nonnative cordgrasses may not be feasible once these species have spread and become established, due to the expansive scale of the i nvasion and the effects of hybridization. To avoid these consequences, the ISP is implem enting a regionally coordinated, long-term management program.

3. DESCRIPTION OF THE WATER BODY SYSTEM EcologyLike most Pacific estuaries, the majority of the intertidal zone of the San Francisco Estuary naturally consists of unvege tated tidal flats, or mudflats. Native California tidal marsh vegetation is limited to the upper intertidal zo nes, above mean sea level in San Francisco and San Pablo Bays. Below mean sea level, waves erode and redeposit the upper layers of bay mud with each tidal cycl e. Rich deposits of fine silt and clay from the SacramentoSan Joaquin Delta have accumulated in the Estuary to form highly productive mudflats, with abundant benthic invertebra tes. The mudflats provide a cr itical source of nutritionand energy for migratory shorebirds and waterfowl, with more than one million shorebirds using the Estuary's mudflats and salt ponds during migration, and over half of the west-coast migratory divi ng ducks making this estuar y their winter home. At elevations above the intertidal zone (in areas that have not b een diked and removed from tidal action), are the Estuary's tidal sa lt and brackish marshes. Pacific salt marsh vegetation is more diverse in plant species than its Atlantic counterparts. Until recent decades, the native Pacific cordgrass exclusivel y occupied the lower reaches of the Estuary's tidal salt marshes. At slightly higher el evations, a relatively fl at tidal marsh plain (reaching near the average level of the higher daily tides), is domi nated by low-growing, mostly perennial plants such as pickleweed, saltgrass, and other salt-tolerant herbs. The tidal marsh plain is punctuated by salty shal low ponds (pans), and dissected by irregular tidal creeks. Above the tidal marsh plain, at the uppermost edges of the marsh, are an even greater number of plant species. Many endemic (unique to the area) plant and animal species, includ ing many rare or endangered species, survive only in the Estuary's remaining tidal marshes. They remain at risk of extinction because of the severe dec line over the past century in the abundance, distribution, and quality of tidal marshes. Most of the Estuary's rare species have narrow or specific habitat requirements , and the health of their popula tions usually is sensitive to structural changes in their ha bitats - particularly the condi tion of the marsh vegetation. Strong dominance of the vegetation by one or mo re plant species nece ssarily results in lower overall species diversity, and can push rarer species to local extinction.

San Francisco Estuary Invasive Spartina Project 2. 2008 Aquatic Pesticide Application PlanNatural Processes Affecting Water Quality Water quality within the San Francisco Estuar y is connected to and affected by complex regional and local natural processes. Hydrol ogic relationships between the Pacific Ocean, the Estuary, and the many freshwater tributar ies (including the Sacramento-San Joaquin River system) govern salinity levels in differe nt portions of the Estuary and along the Bay margins. Variable natural factors such as tid al cycles, local winds, basin bathymetry, and salinity gradients interact with river flows a nd affect the circulati on of Estuary waters through channels, Estuary margins, and bays, distributing nutrients, salt concentrations, and pollutants. Major processes affecti ng water quality are described below. Tidal Cycles . The Estuary has two low tides and two high tides every 24.8 hours. During each tidal cycle, an average of about 1.3 milli on acre-feet of water, or 24 percent of the Bay and Delta’s volume, moves in and out of the Golden Gate. On the flood (incoming) tide, ocean water moves through the Golden Ga te and into the Estuary’s southern and northern reaches, raising the water level at the end of the South Bay by more than eight feet, and raising the height of the Sacramento River at the upstream edge of the Estuary by about three feet. It takes about two hours for the flood tide to reach the end of the South Bay and eight hours to reach Sacramento. Subregional Conditions . Suisun and North Bay subregi ons receive the majority of freshwater input from the Sacramento and San Joaquin River system. In the open bays, density-driven currents show ebb dominance of the surface water and flood dominance of the bottom water. Waters in these embayments are well oxygenated, with low- to moderate-salinity and high-suspende d solids concentrations. Water residence time affects the abundance and distribution of many estuarine organisms, the amount of primary production by phytoplankton, and some of the chemical and physical processes that influence the distribution and fate of pollutants. During low flow periods of the year (late summer), the residence time of freshwater moving from the Delta to the ocean can be relatively long (on the order of months) compared to pe riods when outflow is very high (winter), when freshwater can move from the Delta to the ocean in days. The Central Bay subregion is influenced by o cean waters that are cold, saline, and lower in total suspended sediment. Water quality para meters fluctuate less than in other sectorsof the Bay due to the predominance of ocean water. Net exchanges of ocean and Bay waters depend on freshwater flow in the Ba y, tidal amplitude, and longshore coastal currents. The southern part of San Francisco Bay r eceives less than 10 percent of the natural freshwater flow into the Bay, but the majority (>75 percent) of wa stewater discharges. The largest flow is from San Jose, where approximately 120 million gallons per day (MGD) of treated wastewater are released into Artesian Slough, a tributary to Coyote Creek (Figure 1). This fresh water flow creates a local zone of brac kish water in the otherwise saline tip if the South Bay. The rest of the South Bay, becau se it has so little freshwater input, is essentia lly a tidal lagoon with a relativ ely constant salinity (approximately the same as ocean water, 32 parts pe r thousand, ppt). South Bay waters are influenced by Delta outflow only during the winter months, when low-salinity water moves southward into the southern reach displacing the saline, denser wa ter northward. In the summer months, however, South Bay currents are largely influenced by wind stress on

San Francisco Estuary Invasive Spartina Project 3. 2008 Aquatic Pesticide Application Planthe surface; northwest winds transport waterin the direction of the wind, and the displaced water causes subsurface currents to flow in the opposite direction.

Currents and Circulation. Circulation patterns within the Bay are influenced by Delta inflows, gravitational currents, and tide- and wind-induced horizontal circulation. The cumulative effects of the latter three factors on net circulation within embayments tend todominate over that of freshwater inflows except during short period s after large storm events (Smith 1987). Exchanges between embayments are influenced both by mixingpatterns within embayments and by the magnitude of freshwater inflows (Smith 1987). Currents created by tides, freshwater inflows, and winds cause erosion and transport of sediments. Tidal currents are usually the dominant form of observed currents in theBay. Tidal currents are stronger in the channels and weaker in the shallows (Cheng andGartner 1984). These processes enhance exchange between shallows and channels during the tidal cycle, and cont ribute significantly to landw ard mixing of ocean water and seaward mixing of river water. Also, the S outh Bay begins flooding while San Pablo Bay is still ebbing, making it possi ble for the South Bay to recei ve water from the northern reach (Smith 1987). Figure 1. Locations and mean discharges for municipal wastewater treatment plants in South San Francisco Bay. Adapted from Schemel et al. 1999, based on Davis et al. 1991.

Tides have a significant influence on sedime nt resuspension during the more energetic spring tide when sediment con centrations naturally increase , and particularly during the ebbs preceding lower low water when the current speeds are highest. Powell et al. (1989), however, observed no correlation between tidal cycle and suspended sediment loads or distribution in the South Bay. Their conclusi on was that winds are the most important factor in resuspending sediments in the S outh Bay, and that sour ces of sediments are more important than transport of sedimentresuspended from other parts of the Bay (Reilly et al. 1992). Wind-induced currents have a significant effect on sediment transport by resuspending sediments in shallow waters (Krone 1979; Cloern et al. 1989). An estimated 100 to 286 million cubic yards of sediments are resuspe nded annually from shallow areas of the Bay by wind-generated waves (Krone 1974; SFEP 1992b). Water Quality Water quality in the San Francisco Estuary has improved significantly since the enactment of the California Water Quality Contro l Act (Porter-Cologne) in 1969 and the Clean Water Act in 1972. Nevertheless, the Estuary waters still carry significant loads of pollutants from human sources. Unde r Section 303(d) of the Clean Water Act, states were reSan Francisco Estuary Invasive Spartina Project 4. 2008 Aquatic Pesticide Application Planquired to develop a list of water bodies that do not meet water quality standards; this list is referred to as the “303(d) list.” This list de fines low, medium, and high priority pollutants that require immediate attention by State and Fe deral agencies. Portions of the Estuary have high-priority 303(d) listings for a number of pollutants, including dioxin compounds, furan compounds, PCBs, mercury, copper, nickel, a nd exotic (plant and animal) species. The most comprehensive information describi ng water quality in the Estuary comes from the Regional Monitoring Program managed by th e San Francisco Estuary Institute (SFEI) and ongoing studies by the Interagency Ecol ogical Program (IEP). In addition, numerous short-term studies that focus on specific site s, resources, or pollutants are conducted on a regular basis by researchers a nd entities conducting permit-sp ecified monitoring of waste discharges. The primary water quality paramete rs discussed below ar e: temperature, salinity, dissolved oxygen (DO), pH, total suspende d solids (TSS), turbidity, and pollutants. Temperature. Water temperatures in the Estu ary range from approximately 10  ̊ C to 22  ̊ C (50  ̊ F to 71.6  ̊ F). Temperatures are influenced by s easonal solar cycles and variable inputs of river and coastal ocean waters. Temperat ures are typically at the higher end of this range along the Estuary margin during daylighthours as the influen ce of solar energy warms the water. Salinity . The salinity of the Estuary varies sp atially and temporall y. Along the northern reach the salinity increases fr om the Delta to the Central Ba y. At the mouth of the Sacramento River, for example, the mean annual sa linity averages slightly less than 2 ppt; in Suisun Bay it averages about 7 ppt; and at the Presidio in Central Bay it averages about 30 ppt. In the South Bay, salinities remain at near-ocean concen trations (32 ppt) during much of the year, except in the vicinity of the San Jose wastewater outfall at Artesian Slough, where salinities are less concentrated. During summer months in dry years, high evaporation rates may cause salinity in South Bay to exceed that of ocean water. Seasonal changes in the salinity distribution wi thin the Estuary are controlled mainly by the exchange of ocean and Estuary water, and by river inflow. River inflow has the greater influence on salinity distribution throughout most of the Estuary because inflow varies widely, while variations in ocean inputs are relatively small. In winter, high flows of freshwater from the Delta lower the sali nity throughout the Estuar y’s northern reach. High Delta flows also intrude into South Ba y, lowering salinity th ere for extended periods. In contrast, during the summer, when freshw ater inflow is low, saline water from the Bay intrudes into the Delta. The inland limit of salinity intrusion varies greatly from year to year. In addition, channel dredging can in crease gravitational ci rculation and enhance salinity intrusion (Nichols and Pamatmat 1988). Dissolved Oxygen . Oxygen concentrations in estuarin e waters are increased by the mixing action of wind, waves, and tides; photosynthesis of phyt oplankton and other aquatic plants; and high DO in freshwater inflow . DO concentrations are lowere d by plant and animal respiration, chemical oxidati on, and bacterial decompos ition of organic matter. The Estuary’s waters are generally well oxygenated, except during summer in the extreme southern end of the South Bay where c oncentrations are redu ced by poor tidal mixing and high water temperature. Typical con centrations of DO range from 9 to 10 milligrams per liter (mg/l) throughout the Estuary during periods of high river flow, 7 to 9 mg/l during moderate river flow, and 6 to 9 mg/l during the late summer months when flows are the lowest. Unlike th e 1950s and 1960s, when inade quately treated sewage and

San Francisco Estuary Invasive Spartina Project 5. 2008 Aquatic Pesticide Application Planprocessing plant wastes depleted oxygen in parts of the Bay and Delta, today there are few reports of places in the Estuary where low oxygen concentrations adversely affect beneficial uses. Today, the lowest concentratio ns in the Estuary are typically observed in the extreme South Bay but, in some instances, DO levels in semi-enclosed embayments such as Richardson Bay can be much lowe r than in the main water body (SFEI 1994). pH . The pH of the water in San Francisco Bay is relatively constant and typically ranges from 7.8 to 8.2 1

. Total Suspended Solids (TSS) and Turbidity . Turbidity and TSS are generally used as measures of the quantity of suspended partic les. The distinction between the two terms lies mainly in the method of measurement. In general, higher TSS results in more turbid
water. Regions of maximum suspended solids occu r in the North Bay in the null zone 2 (generally 50 to 200 mg/l, but as high as 600 mg/l TSS). The speci fic location of the null zone changes depending upon freshwater discharge from the Delta. TSS levels in the Estuary vary greatly depending on the season, ranging from 200 mg/l in the winter to 50 mg/l in the summer (Nichols and Pamatmat 1988; Bu chanan and Schoellhamer 1995). TSS also varies with tidal stage and depth (Bucha nan and Schoellhamer 1995). Shallow areas and channels adjacent to shallow areas have the highest suspended sediment concentrations. The Central Bay generally has the lowest TSS concentrations; however, wind-driven wave action and tidal currents, as well as dr edged material disposaland sand mining operations cause elevations in suspended solids concentrations through out the water column.

Pollutants. Pollutant loading to San Francisco Bay has long been recogn ized as one of many factors that has historically stressed a quatic resources. Pollutants enter the aquatic system through atmospheric deposition, runoff from agricultural and urbanized land, and direct discharge of waste to se wers and from industrial activity. The Bay’s sediment can be both a source and a sink for pollutants in the overlying water column. The overall influx of pollutants fr om the surrounding land and waste discharges can cause increases in sediment pollutant le vels. Natural resuspension processes, biological processes, other mechanical disturbances , dredging, and sedimentdisposal can remobilize particulate-bound pollutants.

Metals

. Ten trace metals in the aquatic system and in waste discharged to the Bay are monitored on a regular basis. Total and dissolv ed fractions are sampled three times a year at Regional Monitoring Progra m (RMP) stations th roughout the Es tuary. Tables 1 and 2 present dissolved and total trace metal concentrat ion ranges in Bay waters during 1998 (SFEI 1998). Organic Pollutants. Three general types of trace organi c contaminants, polycylic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), and pesticides, are measured in San Francisco Bay water on a regular basis.

1 Water or solutions that are acidic have a pH of less than 7.0, and basic or alkaline water have a pH greater than 7.0. A pH o f 7.0 is considered neutral.

2 The null zone is area or region of an estuary where the bottom, high-density and surface, low-density currents have equal and opposite

effects. It is defined as the zone where the mean near-bottom speed is zero. The actual location of the null zone migrates in r esponse to changes in river discharge. It is important because it is typica lly characterized by high concentrations of suspended particula te matter and rapid sediment accumulation.

San Francisco Estuary Invasive Spartina Project 6. 2008 Aquatic Pesticide Application PlanWater column concentrations of dissolved and total PAHs in 1998 ranged from 2.1 to 46 parts per trillion (pptr) and from 20 to 300 pptr, respectively (SFEI 1998). Total PCB concentrations in Bay waters during 1998 ranged from 70 to 7,000 parts per quadrillion (ppq), and were below the U.S. Environmen tal Protection Agency (U.S. EPA) 4-day (chronic toxicity) water quali ty criteria (30 pptr ) (SFEI 1998). Dissolved PCB concentrations ranged from 12 to 930 ppq. Bay waters also contained measurable concentrations of chlorinated pesticides, including chlordanes and DDTs. Total chlordane concentrations ranged from 21 to 5,700 ppq, while total DDT concentrations ranged from 190 to 9,900 ppq (SFEI 1998).

A recent review of historical data from several sources found severa l previously unidentified organic contaminants in the San Francisco Estu ary (SFEI 2002). In this study, p-nonylphenol, a common constituent in detergents and other ho usehold products, agricultural surfactants, and many industrial produc ts, was identified in Sacramentoand San Joaquin River water (at 19 ng/L and 5 ng/L, respecti vely), but it was not detected in Estuary water. Sediment Quality Sediment quality in the Estuar y varies greatly according to th e physical characteristics of the sediment, proximity to hist orical waste discharges, the physical and chemical condition of the sediment, and sediment dynamics that change with lo cation and season. Generally, the level of sediment contamination at a given location will vary depending on the rate of sediment deposition, which va ries with seasons and tides (Luoma et al. 1990). Chemical contaminant dynamics in an estuary ar e closely associated w ith the behavior of suspended and deposited sediments. The physic al and chemical characteristics of sediTable 1. Dissolved Concentrations of Trace Metals in Water Samples (SFEI 1998)

Ag μg/L As μg/L Cd μg/L Cr μg/L Cu μg/L Hg μg/L Ni μg/L Pb μg/L Se μg/L Zn μg/L

Minimum 0.0002 0.83 0.003 0.09 0.37 0.0003 0.56 0.002 ND 0.07

Maximum 0.006 4.8 0.09 3.8 3.5 0.015 7.2 0.40 6.1 22.5

WQ Criteria 1-hour 1.9 69 42 1100 5 74 210 90

WQ Criteria 4-day 36 9.3 50 3.1 8.2 8.1 81

ND – Not detectable at laboratory limits

Table 2. Total Concentrations of Trace Metals in Water Samples (SFEI 1998)

Ag μg/L As μg/L Cd μg/L Cr μg/L Cu μg/L Hg μg/L Ni μg/L Pb μg/L Se μg/L Zn μg/L

Minimum 0.002 ND 0.009 0.29 0.42 0.0006 0.63 0.05 ND 0.77

Maximum 0.20 9.4 0.36 101 20 0.73 49.0 15.8 6.8 98.6

WQ Criteria 1-hour 2.3 69 43 1100 2.1 140 58

WQ Criteria 4-day 36 9.3 50 0.025 7.1 5.6

N D

– No t de t ec t ab l e a t l abo r a t o ry limit s

San Francisco Estuary Invasive Spartina Project 7. 2008 Aquatic Pesticide Application Planments, and the bioavailability and toxicity of sediment-asso ciated chemicals to aquaticorganisms, are particularly important in determining their potential impact on environmental quality. While pollutant loading to the Estuary from point and non-point sources has declined dramatically over the past two decades, and surface sediment contamination may be declining from historical highs, Bay sediments are still an important source and sink of pollutants. Much of the data documenting concentr ations of trace metals and organics in Bay sediments are found in the historical summ ary of Long and Markel (1992) and in the more recent monitoring efforts by the State’ s Bay Protection and Toxic Cleanup Program (BPTCP) (SFBRWQCB 1994) and Regional M onitoring Program (SFEI 1994 and 1998). Concentrations of Metals and Or ganic Pollutants in Sediments. Mean concentrations of trace metals and organics in sediments vary according to grain size, organic carbon content, and seasonal changes associated with riverine flow, flushing, sediment dynamics, and anthropogenic inputs. Anthropogenic inpu ts appear to have the greatest effect on sediment levels of copper, silver, cadmium, and zinc, as well as several chlorinated and petroleum hydrocarbons (SFBRWQCB 1994). Range s in sediment metals and trace organic concentrations during 1998 are listed in Table 3. The table also compares measured concentrations to effects range-low (ER-L) and effects range-median (ER-M) values, which are levels that are rarely associated with adverse effects to benthic organisms from exposures to sediment-associated contaminants and levels that are fr equently associated with adverse impacts, respectively (Long et al. , 1995). For most pollutants, ranges in measured concentrations exceed the respect ive ER-L values but are below the correTable 3. Ranges of Trace Pollutants in San Francisco Bay Sediments (SFEI 1998)

S EDIMENT S AMPLES ( MG/ KG ) E FFECTS L EVELS ( MG / KG )

Minimum Maximum ER-L ER-M

Arsenic 3.1 19 8.2 70

Cadmium 0.1 2.1 1.2 9.6

Chromium 63 216 81 370
Copper 8.5 76 34 270

Lead 5.4 65 46.7 218
Mercury 0.03 0.82 0.15 0.71

Nickel 68 228 20.9 51.6

Selenium 0.06 0.52

Silver ND 2.0 1.0 3.7

Zinc 64 256 150 410

T OTAL PAH S 0.033 6.30 4.022 44.792

Total PCBs ND 0.26 0.0227 0.18

Total DDTs No Data 0.00158 0.0461

Total Chlordanes ND 0.0099 0.0005 0.006 Key: Concentrations bolded exceed the Lo west Observable Effects Level (ER-L) Concentrations bolded and underlined exceed th e Median Observable Effects Level (ER-M) ND

– Not detectable at laboratory limits

San Francisco Estuary Invasive Spartina Project 8. 2008 Aquatic Pesticide Application Plansponding ER-M values. The exceptions are mercury, nickel, total PCBs, and total chlordanes, which exceed the ER-M values at one or more locations in the Bay. Some sites within San Francisco Bay, such as Lauritzen Canal, the Port of Oakland near San Leandro Bay, and Richmond Harbor, which have be en greatly affected by historical contamination, contain sediment pollutant levels which are considerably higher than those measured by the Regional Monitoring Program.

4. DESCRIPTION OF TARGET SPECIES

There are one native and four non-native species of cordgrass in the San Francisco Estuary. The native species is Pacific cordgrass ( S. foliosa ), which is not a target of the ISP’s control efforts, and is actually the recipient of conservati on by controlling the invasive species). The non-native species are Atlantic sm ooth cordgrass ( S. alterniflora) , English cordgrass ( S. anglica) , Chilean cordgrass ( S. densiflora) , and salt-meadow cordgrass ( S. patens). The non-native Atlantic smooth cordgra ss hybridizes with the native Pacific cordgrass, and their offspring (referred to in this APAP as "Atlantic smooth cordgrass hybrids" or "hybrids") are highly invasive and considered no n-native. Key aspects of the cordgrass species found in the Estuary are co ntrasted below. The biological contrasts among these species and their ro les in their native habitats help to demonstrate how nonnative cordgrasses are likely to alter the Estu ary's salt marsh ecosystem. First described is the native Pacific cordgrass, fo llowed by the non-native species.

Native Pacific Cordgrass ( Spartina foliosa ) The historic range of Pacific cordgrass was confined to estuaries from Point Reyes to Baja California, with large gaps in between; fo r example, it is histor ically absent in Monterey Bay and Morro Bay. Most of the Pacifi c cordgrass population exists in San Francisco and San Pablo Bays. Its northern limit is now Bodega Bay, a small and recent natural population. It even more recently established in To males Bay, where its population surged following major flood and depositional ev ents of the mid-1990s. Pacific cordgrass is a perennial, salt-tolerant marsh grass, wh ich spreads both sexuall y, by seed dispersal, and asexually, by long, creeping rhizomes (unde rground stems, or runners) that propagate small clusters of leafy shoots. Clonal (asexua l) growth of rhizomes allows individual plants to form extensive colonies without being pollinated by another plant. A colony thus formed is referred to as a "clone." The slender leafy shoots with seed-heads seldom exceed five feet in height, and most shoots ra nge from about one to three feet tall. The height of the cordgrass plant is related to how well it tolerates submersion in tidewaters, and thus how low in the intertidal zone it ca n grow. The relatively short stature of Pacific cordgrass corresponds with its limited occupation of lower elevations within the intertidal

zone. Pacific cordgrass is genetically very similar to Atlantic smooth cordgrass, but the two species also have significan t differences. In size, growth rate, production, and ecological tolerances, Pacific cordgrass is much less r obust than Atlantic smooth cordgrass (Smart and Barko 1978, Callaway 1990, Boyer, Callaway and Zedler 2000). Pacific cordgrass grows more luxuriantly in clayey mud than sand, but it naturally grows in substrates ranging from sand and mud to peat. Its leaves an d stems wither in fall and are shed in winter, as the clones die back to young shoots and buds near the mud surface. The sparse remains of Pacific cordgrass stands in winter are relatively ineffectiv e in trapping sediment.

San Francisco Estuary Invasive Spartina Project 9. 2008 Aquatic Pesticide Application PlanPacific cordgrass is generally restricted to a narrow portion of the intertidal zone, between an elevation just above mean sea level and an elevati on near the leve l of the average higher daily tide (mean higher high water, "M HHW"). It tends to fail in competition with plants like pickleweed on the marsh plai n, which, in California es tuaries, approaches the elevation of the MHHW. Th is modest range in tidal elevation restricts Pacific cordgrass to the sloping banks of tidal creeks, and the gent ly sloping upper edges of mudflats where sediment accumulates. This leaves the vast acreages of Pacific tidal flats below mean sea level entirely free of emergent vegetation in natural hi storic conditions. The vegetated marsh plain (middle to high mars h zone) supports either sparse Pacific cordgrass in lower areas , or none at all. Early experiments with Pacific cordgrass dem onstrated that its slender, widely spaced leafy shoots and rhizomes are not as effective at stabilizing sedimentcompared with Atlantic smooth cordgrass, esp ecially under exposed conditions at the bay's edge (Newcombe et al. 1979). Seedlings of Pacific co rdgrass are seldom found in established marshes, and appear only intermitte ntly in sheltered upper mudflats. Pacific cordgrass is particularly valued as habitat for the endangered California clapper rail, which spends most of its time foraging for food within, or close to, the protective canopy of cordgrass. Rails can move within Pa cific cordgrass stands, and spend most of their time under cover of the cordgrass foliar ca nopy, usually selecting prey items such as invertebrates inhabiting the cord grass stands and their edges. In contrast to the clapper rail of southern California tidal marshes, Sa n Francisco Bay clapper rails generally do not construct "floating nests" in Pacific cordgrass; instead, they tend to build nests in gumplants or pickleweed in the higher marsh. Atlantic Smooth Cordgrass ( Spartina alterniflora ) and its Hybrids Smooth cordgrass is the closely related sibling to Pacific cordgrass. In the United States, it occurs along both the Atla ntic and Gulf Coasts (Gl eason and Cronquist 1991). It is unique among the world's cordgr ass species in terms of its growth potential and ecological breadth, and it is the parentspecies of the other most i nvasive cordgrass species of hybrid origin, English cordgrass ( S. anglica ; Adam 1990). The San Francisco Estuary population of Atlantic smooth cordgrass was founded by seed from Maryland in the mid1970s, introduced experimentally for one of th e first tidal marsh re storation projects on the west coast. We refer to the San Franci sco Bay population of sm ooth cordgrass as Atlantic smooth cordgrass. Atlantic smooth cordgrass is a co arse perennial grass that, like its Pacific relative, spreads both by seed dispersal and by cr eeping rhizomes that form extensive clonal colonies. In parts of the San Francisco Estuary, the rate oflateral spread by rhizomes averages between 3.3 and 6.6 feet per year, in contrast with native Paci fic cordgrass, which spreads only 0.6 to 2.4 feet per year in the same marshes (Josselyn et al. 1993). Similar rates of lateral spread of this species and its hybr ids have been recorded more recently in Cogswell Marsh on the Hayward Shoreline (K. Zaremba, M. Taylor, pers. comm.) The size range of Atlantic smooth cordgrass is wide and highly variable, depending on its local genetics and environment. In nutrient -rich, well-drained marsh sediment, such as along tidal creek banks and on ne wly colonized tidal flats, ex tensive dense stands can exceed 10 feet in height. On poorly drained mars h flats, its vegetation is typically sparse and short, but its dense root and rhizome ne twork maintains pure stands and effectively

San Francisco Estuary Invasive Spartina Project 10. 2008 Aquatic Pesticide Application Planbinds marsh sediments. The "tall form" and "short form" of this species were so strikingly different that they were long assumed to be dist inct varieties, rather than variations based on local environmental conditions. Modern res earch indicates that factors related to marsh drainage, such as wate rlogged soil chemistry (especia lly accumulation of toxic soil sulfides), excessive salinity, a nd nutrient deficiency interactto cause the dramatic differences in growth-forms of Atlantic smooth cordgrass (Bradley and Dunn 1989, Mendelssohn and Seneca 1980, Valiela et al. 1978, Smart and Barko 1978). Genetic variations in height forms of Atlantic smooth cordgrass al so has been defined in San Francisco Bay (Daehler et al. 1999) In the salt marshes of the Atlantic coastal plain, Atlantic smooth cordgrass is dominant over most of the intertidal zone. Depending on local tidal range, it can grow to and below mean low water (McKee and Patrick 1988), a nd it can occupy, and even dominate, the marsh plain and the low marsh. Vast, homogene ous stands of Atlant ic smooth cordgrass are the characteristic signat ure of the Atlantic region's tidal marshes (Dame et al. 2000, Adam 1990, Chapman 1964, 1977). In contrast with Pacific cordgrass, Atlantic smooth cordgrass freely establishes in relatively exposed shorelines with significant wave action, including estuarine sand beaches. It is planted in its native range to stabili ze shorelines and to trap and accumulate sediments, and the high density of its tall stems is highly effective at reducing estuarine wave energy (Gleason et al. 1979, Knutson and Woodhouse 1988, Knutson et al. 1990)

In other environmental toleran ces, Atlantic smooth cordgrass is also highly resilient. It can survive in salinity over 45 parts per t housand (well above ocean salinity), and grow luxuriantly in dilute brackish water. If buried, it can regenera te from up to about one foot of burial by deposited sediment. Atlantic smoot h cordgrass, like other low marsh species, can supply air to its roots in oxygen-poor waterlogged mud, using porous air-filled chambers linking its foliage to root s and rhizomes. Atlantic smooth cordgrass can also tolerate the severe waterlogging and hypersalinity that de velops in poorly dr ained depressions in the salt marsh, including salt marsh pans. Salt marsh pans are frequent and welldeveloped features of historic San Francisc o Estuary marshes, and important habitat for migratory waterbirds (Goals Project 1999). Along the Haywar d shoreline of San Francisco Bay, Atlantic smooth co rdgrass has colonized many pre-existing pans, converting them to solid cordgrass marsh. In the San Francisco Estuary, Atlantic smoot h cordgrass has displayed many of the ecological traits typical of its performance in its native saltmarsh habitat, and some highly novel phenomena as well. Most colonies in the San Francisco Estuary are young, often forming nearly circular, discre te, expanding colonies, which me rge into irregular patterns, resembling mold colonies in a petri dish. The edges of the colonies are tall and robust, while the centers often exhibit early symptoms of dieback or "short form" growth habits. The "donut" shape of colonies, in fact, is one of the species' signatures for identification in aerial photographs of San Francisco Bay. This trait is not typical of mature Atlantic salt marshes. In the mild Pacific winters, A tlantic smooth cordgrass shoots tend to retain green leaves and persistent dead leaves through much of the winter. This is an important contrast with native Pacific cor dgrass: combined withthe invader's much greater stem size and shoot density, year-round dense foliage gi ves Atlantic smooth cordgrass exceptionally high potential to accumulate and trap estuarin e sediment during winter storms or floods.

San Francisco Estuary Invasive Spartina Project 11. 2008 Aquatic Pesticide Application PlanThe San Francisco population of Atlantic sm ooth cordgrass has generated some unusual growth forms with strikingly atypical appearance. The dwarf form develops a profusion of short lateral shoots instead of a tall main stem, formi ng pure stands with complete ground cover of dense, low turf-like ankl e-high vegetation on the marsh plain. The growth rate of the dwarf form is, however, vi gorous. The dwarf form is genetic, not environmentally, induced; it occurs in the same lo cal environments that support luxuriant, tall stands of Atlantic smooth cordgrass, often c ontiguous with the dwarf patches. It has established at multiple locations in San Fran cisco Bay (Daehler et al. 1999). A comparable dwarf form of its hybrid daughter species, En glish cordgrass, inde pendently evolved in Britain and New Zealand (Bascand 1970). Hybridization of Atlantic smooth cor dgrass with native Pacific cordgrass. Perhaps the most novel and significant phenomenon of th e San Francisco population of Atlantic smooth cordgrass is the rapid evolution of an aggressively expanding hybrid swarm formed by cross pollination with the native Pacific cordgrass (Daeh ler and Strong 1997). The hybrid swarm includes first-generation cr osses between Atlantic smooth cordgrass and Pacific cordgrass with both species acti ng as pollen-parents a nd seed parents. Because the two species' pollination periods overlap little, first-generation crosses are infrequent. Hybrids, however, have a wide range of flowering times, and act as an effective reproductive bridge between the species. The hybrids produce polle n in much greater abundance (21 times greater) and with higher fe rtility than the native Pacific cordgrass. Superior hybrid pollen production and fertil ity so overwhelm popul ations of Pacific cordgrass ("pollen swamping") that native st ands of cordgrass produce mostly hybrid back-cross seeds in the presence of flower ing hybrid colonies, a nd fail to reproduce the species sexually (Ayres et al. 1999, Antilla et al. 2000). This process alone, called hybrid assimilation, can result in the extinction ofthe invaded species (Levin et al. 1996, Rhymer and Simberloff 1996). Genetic analysis has revealed that numerous large populatio ns of presumed Atlantic smooth cordgrass in the Estuary are predom inantly hybrids and back -crosses (introgressants). The ecologically invasive , dominant traits of Atlantic smooth cordgrass appear to be prevalent in the hybrid swarm. "Pure" At lantic smooth cordgrass is now a minority in most of the rapidly evolving hybrid swarms, and trends suggest that hybrids will eventually replace both parent speci es, as the hybrid-origin specie s English cordgrass did in Britain (see English Cordgrass, below). This recently discovered threat of genetic extinction to a native cordgrass from an alien cordgr ass invasion is unique to the San Francisco Estuary. No native cordgrasses existed wher e Atlantic smooth cordgrass invaded Washington and Oregon estuaries, and the cordgrasses native to Eur ope are genetically isolated from their hybrids. Atlantic smooth cordgrass, a nd its hybrids with similar a ppearance and behavior, are now widely distributed in the Cent ral and South Bay, but they have not yet been detected in the North Bay or Suisun, despite intensive se arches. The northern limit of its distribution in 2005 on the east bay is the bay on the wester n shore of Point Pinole (Giant Marsh), and on the west bay is a clone nor th of Miller Creek mouth (north of China Camp). The abundance of Atlantic smooth cordgrass and hybri ds remains greatest near the point of its original introduction circa 1977 (Pond 3, Hayward Shoreline, Alameda County), and sites of early transplanting (Colma Creek, San Ma teo County), early pione er colonies (Oakland, San Leandro Bay, Hayward Shoreline), and areas of subsequent transplanting

San Francisco Estuary Invasive Spartina Project 12. 2008 Aquatic Pesticide Application Plan(Cogswell Marsh, Hayward). It now is nearly the exclusive marsh plant species of recently formed or restored tidal marshes al ong the San Leandro-Hayw ard shoreline, and this trend is expected to increase. Even as the Bay edge salt marshes and levees are eroding landward through wave action, Atlantic sm ooth cordgrass marsh is spreading in the opposite direction below the wave-cut marsh cli ff. Its distribution becomes patchier south of the Dumbarton Bridge, decrea sing in size and frequency to Alviso, where it is still relatively rare. It is well established as scat tered, large but discrete colonies in the Dumbarton-Mowry Marsh, Newark, mostly in sloughs and disturbed marsh, or recently colonized mudflats. It is a common or dominantfeature in marshes from San Bruno, the San Francisco Airport, south to Foster City, and is scattered in variab le frequency along the Redwood City shoreline. The Napa-Sonoma a nd Petaluma Marshes are currently free from the Atlantic smooth cordgrass invasion, but young colonies have recently been detected in Bolinas Lagoon and Drakes Estero on the Point Reyes peninsula (K. Zaremba, pers. comm. 2005). English Cordgrass ( Spartina anglica ) English cordgrass is an aggre ssive invader of mudflats a nd salt marshes in Britain, New Zealand, Australia, and the Pacific Northwest, and thrives in cool temperate climates. It originated in Britain as a fertile hybrid derived from introduced Atlantic smooth cordgrass and common cordgrass ( S. maritima ), a small, slow-growing creeping cordgrass native to European coasts, now greatly reduced in abundance. Within a century after its origin, English cordgrass became the dominant salt marsh grass in Britain (Lee and Partridge 1983, Gray et al . 1990). It is shorter than Atlantic smooth cordgrass and more grayish in appearance, but partly shares other traits of its pare nt, such as vigorously spreading rhizomes, ability to transform mudflats into vast stands of low marsh vegetation, and ability to dominate and displace associated plant species. It was introduced to the San Francisco Estuary at Creekside Pa rk, Corte Madera, Marin County, along with Chilean cordgrass, in 1976. Un like Atlantic smooth cordgrass and Chilean cordgrass, this species failed (so far) to disperse from its point of introduction. It may be at or near its southern climatic limit on the Pacific Coast in San Francisco Estuary. Chilean Cordgrass ( Spartina densiflora ) Chilean cordgrass (also called dense-flowered cordgrass) is a distinctive cordgrass species native to South America. It has a bunchgrass growth hab it, forming tight clumps or tussocks with short creeping rhizomes, and narro w, firm, in-rolled leaves (Spicher 1984), resembling European beachgrass ( Ammophila arenaria ). It is generally restricted to the middle marsh plain and high marsh zones wher e pickleweed, saltgrass, jaumea, and other low-growing herbs otherwise prev ail. It does not spread into the low marsh where Pacific cordgrass and mudflats na turally dominate the Estu ary (Kittleson and Boyd 1997 ). Chilean cordgrass lacks well-developed tissues spec ialized for transporting air from foliage to roots (Spicher 1984), a feature common to co rdgrasses adapted to low marsh environments. Chilean cordgrass, along with other South American coas tal species, was probably accidentally introduced to Humboldt Bay, Califor nia by ship ballast containing seeds from South American ports that traded lumb er (Spicher 1984). For most of the 20 th Century, Chilean cordgrass was erroneously treated as an "ecotype," or minor geographic variation, of the native Pacific cordgrass, despite the lack of diagnostic traits matching this

San Francisco Estuary Invasive Spartina Project 13. 2008 Aquatic Pesticide Application Planspecies. In the late 1970s, the presumed nativ e "Humboldt Bay form" of Pacific cordgrass was deliberately transplanted to salt marsh re storation and landscaping sites at Creekside Park, Corte Madera, Marin County. Within the salt marshes fringing Corte Madera Creek, it has since become a locally domina nt component of the middle and high salt marsh vegetation, displacing even robust pickleweed. A second population of Chilean cordgrass spon taneously established across the Bay from Creekside Park in the ancient marsh plain atPoint Pinole (Whittell Marsh), Contra Costa County. The Point Pinole population was disc overed in the mid-1990s, and has been largely controlled. A single, large, individual clump of Chilean cordgr ass established in a very young restored tidal marsh (breached 1995) at the former Salt Pond 2A, Napa Marsh. That pioneer plant was also eradicated. Salt-Meadow Cordgrass ( Spartina patens ) Salt-meadow cordgrass is another rhizome-fo rming creeping cordgras s of Atlantic salt marshes, but unlike Atlantic smooth cordgrass, it has fine stems with narrow, soft, inrolled leaves, and is intolera nt of waterlogged mud. It is naturally confined to the welldrained high salt marsh and relatively moist sandy depressions at or a bove tidal influence. Two distinctive geographic and ecological types have been recognized, and in the past have been treated as distinct taxonomic variet ies. In peaty high salt marshes of the northeastern Atlantic coast, a relatively low form with lax, slender stems forming dense matted turfs with "cowlicks" was once treated as S. patens var. monogyna . These dense salt marsh turfs are often nearly pure stands of salt-meadow co rdgrass crowding out most potentially associated species that occupy gaps in the cover caused by winter ice or drifted wracks. In sandy marshes associated with large barrier beaches and wash-over fans from Cape Cod through the Atlantic coastal plain, a coarser, erect type, fo rmerly recognized as S. patens var. juncea , is prevalent. Interm ediate forms are common. Between the 1959 publication of A California Flora (Munz and Keck 1959) and its 1970 supplement, salt-meadow cordgrass was repor ted in Southampton Bay, Benicia, Solano County. The time and mode of in troduction is unclear. Salt -meadow cordgrass at Southampton occupies large, discrete patches in pure and exceptionally thick stands compared with its native marshes. The patches are dist ributed close to tidal sloughs, a pattern suggesting local transport by currents. One large stand is spreading into a high marsh site (pickleweed-saltgrass vegetation) that s upports a population of an endangered annual plant, soft bird's-beak ( Cordylanthus mollis ssp. mollis ). The Southampton Bay cordgrass population appears to match the t ype description of "variety monogyna ," the fine-stem type of northeastern Atlantic marshes.

5. CONTROL TOLERANCES As previously mentioned, the non-native Spartina invasion of the San Francisco Estuary is especially threatening to native marsh sy stems because of hybrid ization of Atlantic smooth cordgrass and the native Pacific cordgras s. This ability to hybridize, and the current expansion rates of the population of hybr id forms throughout the Estuary, defines the need for a zero tolerance threshold on invasive Spartina in San Francisco Bay. The Invasive Spartina Project is a regionally coordinated erad ication effort that will ultimately be successful only if all infestations are effec tively controlled and mon itored to eradication.

San Francisco Estuary Invasive Spartina Project 14. 2008 Aquatic Pesticide Application PlanA single small, expanding clone of hybrid Spartina within an otherwise native S. foliosa matrix has the capability of ‘swamping’ S. foliosa flowers with hybrid pollen, effectively converting the native stand into a hybrid-p roducing population. Within a couple of growing seasons, the majority of new seedlings es tablishing in the area will be of hybrid origin, resulting in the eventual extirpation of the native S. foliosa from the stand. Repeated throughout the Estuary on various scales, this progression threatens the population stability of native pacifi c cordgrass stands. Therefore, where hybrid forms of Spartina are identified, efforts must be directed at removing all of the plants in the area. There is no ac ceptable level of hybrid presence in anotherwise native marsh, as the inevitable result of even a small amount of hybrid presence will be the relatively rapid conversion of the marsh to a non-nati ve stand capable of infesting adjacent marshlands. Spartina densiflora has also been shown to ha ve very rapid expansion rates in the Estuary. In addition, this plant i nvaded Humboldt Bay, CA to su ch a degree that approximately 80% of the mudflats and marsh lands have been dominated by it. We are fortunate in the San Francisco Estuary to have only isol ated populations of S. densiflora at this point because of the efforts of the ISP and its partners, so as in the case with the more prevalent S. alterniflora hybrid s, there is a need for zero to lerance and an excellent opportunity for the eradication of this sp ecies before it becomes widespread.

For the other two invasive Spartina species in the Estuary, S. anglica and S. patens , each only inhabits a single infestation site and in a relatively small overall area. However, S. anglica is know to be the mo st invasive species of Spartina in the world, itself a fertile hybrid that has dominated introduction sites on several continents. With these types of threats, the fertile environment of the Estuar y, and the current size of the infestations, a zero tolerance policy is appropr iate. In addition, with a coupl e effective seasons of treatment, each of these species will be eradicated from the Estuary.

6. DESCRIPTION OF HERBICIDE Herbicides have proven highly effective in controlling populations of cordgrasses ( Spartina spp.). The aquatic formulation of imazapyr (Habitat ® ) was registered for use in the State of California on August 30, 2005. Previously, the Spartina Control Program used aquatic glyphosate-base d herbicides (Aquamaster ® , Rodeo ® ), which were the onlyherbicide formulations that could be used in sensitive estuarine systems and were designed to work on grasses/monocots. All ISP partners have since switched to imazapyr, although glyphosate will also be used at a singl e sub-site with special circumstances, and may be combined with imazapyr (according to the product labels) as a “brown-down indicator” to allow for more rapid detection of missed or skipped areas. Since imazapyr is such a slow-acting herbicide, it is difficult to know if the entire infestation at a site has been effectively treated until the following spring. Glyphosate treatment results in more noticeable yellowing/browning of the treated pl ants within a couple weeks. The use of a brown-down indicator would make any green, untreated plants stand out, and a follow-up spot treatment could be applied to these pl ants without losing a year of control. Imazapyr will also be used at a single site in 2008 to “chemically mow” Spartina areas to stop seed production but maintain above-gr ound biomass for endangered California clapper rail protection in sites wh ere phased treatment is require d. In this technique, a subSan Francisco Estuary Invasive Spartina Project 15. 2008 Aquatic Pesticide Application Planlethal dose is applied to the plants, stopping their growth a nd seed production for a single season, but allowing them to return the following spring at or near th eir previous level on the site. There are a number of quali ties that make imazapyr the I SP’s preferred choice over the previous alternative, glyphosate. Glyphosate te nds to be strongly adsorbed to sediment and salt particles accumulated on the Spartina , rendering the herbicide inactive. It is common for the tides to deposit abundant sedi ment from the turbid San Francisco Bay onto the invasive Spartina in the adjacent salt marshes. Glyphosate also requires significantly longer dry times to fully penetrate the cuticle of the plant and begin translocation. Imazapyr does not have these issues that can reduce its efficacy. In addition, imazapyr is applied at lower concentrations and the applicat or does not need to “spray to wet” as with glyphosate. This greatly reduces the amount of herbicide that will enter the environment as a result of the Spartina Control Program’s efforts, and allows for low volume applications such as aerial helicopter work. This herbicide delivery system is essential to the ISP’s initial efforts becaus e of the vast acreage of Spartina infesting hazardous and difficult to access marshes.Aquatic herbicide formulations such as those used by ISP must be combined with a suitable surfactant to f acilitate uptake and translocation ofthe herbicide down into the rhizomes. A harmless, inert marker dye or colorant is often added to th e tank mix to assistthe applicator at achieving full coverage while not over-applying to any areas. The following discussion addresses imazapyr, glyphosat e, breakdown products, and typical surfactants and colorants. Detailed descriptions of the chemical propertie s, degradation rates, environmental fate, and toxicity of imazapyr , glyphosate, and all ofthe aquatic surfactants evaluated for the Spartina Control Program are provided in Appendix 1. Imazapyr. Habitat ® or Polaris AQ TM are solutions of 28.7% isopropylamine salt of imazapyr in water, equivalent to 22.6% imazapyr aci d equivalents (a.e.) or 2 lbs. acid per gallon, and contain a small amount of an acidifier. Because Habitat ® is purportedly the same formulation as Arsenal ® and this product contains acetic acid, the acidifier in Habitat ® is likely also acetic acid (Leson & Associates 2005.) No information has been found in the published literature on manufacturing impuritie s associated with imazapyr. Because virtually no chemical synthesis yields a totally pure product, technical grade imazapyr most likely contains some impurities. However, to some extent, concern for impurities in technical grade imazapyr is reduced by the fact that most existing t oxicity studies on imazapyr were conducted with the technical grade product and en compass the toxic potential of the impurities (SERA 2004). A generic versio n of this aquatic imazapyr formulation is now available from NuFarm under the product name Polaris AQ TM

. Imazapyr inhibits an enzyme in the biosynthe sis of the three branched-chain aliphatic amino acids valine, leucine, and isoleucine. Because animals do not synthesize branchedchained aliphatic amino acids but obtain them from eating plants and other animals, the engineered mechanism for plant toxicity, i.e. the interruption of prot ein synthesis due to a deficiency of the amino acids valine, leucine, and isoleucine, is not generally relevant to birds, mammals, fish or invertebrates. Any toxicity to these rece ptors occurs through different mechanisms (Entrix 2003). Imazapyr is relatively slow acting taking several weeks for the plants to show lethal effects. Howe ver, plants cease grow th within 24 hours of a successful applica tion (J. Smith, pers. comm. 2006). On Spartina , it takes 2-4 weeks after

San Francisco Estuary Invasive Spartina Project 16. 2008 Aquatic Pesticide Application Plantreatment to see visible effects such as yello wing of the leaves, and complete plant death can take several months. In the San Francisc o Estuary, with the rela tively late season applications on invasive Spartina (mainly because of endangered species issues that effectaccess to the marshes), the treated plants may not reveal much of a response before natural senescence, but will simply not emerge in the spring of the following year if fully impacted. Glyphosate. Aquamaster ® and Rodeo ® are aqueous solutions containing 53.8% glyphosate in its isopropylamine sa lt form or 4 lbs. acid per gallon, and contain no inert ingredients other than water. The primary decomposition product of glyphosate is aminomethylphosphonic acid (AMPA), and the co mmercial product contains an impurity, 2,4-nitrosoglyphosate (NNG). Th e potential effects of AM PA and NNG are encompassed by the available toxicity da ta on glyphosate and glyphosate formulations (SERA 1996). Glyphosate inhibits an enzyme needed to synt hesize an intermediate product in the biosynthesis of the aromatic amino acids, esse ntial for protein synthesis and to produce many secondary plant products such as growth promoters, growth inhibitors, phenolics, and lignin. Animals do not synthesize these aromatic amino acids and glyphosate therefore has low toxicity to these receptors. (Schuette 1998.) In gene ral, glyphosate herbicides are somewhat faster acti ng than imazapyr herbicides. On Spartina , complete brown-down occurs within 7 to 21 days. (K. Patten, pers. comm. 2004). Surfactants . For most foliar applications of aqua tic herbicide formul ations, adjuvants must be added to spray solutions to improve the performance and minimize variation of herbicide efficacy. Surfactants are desi gned to improve the spreading, dispersing/emulsifying, sticking, abso rbing, and/or pest-penetrating properties of the spray mixture (Tu et al. 2001). The pure herbicide formulation mixed with water will stand as a droplet on the waxy leaf surface and the small ar ea of contact therefore provides little potential for uptake of the active ingredient into the foliage. Water droplets containing a surfactant will spread in a th in layer over a waxy leaf surface and improve herbicide uptake by maximizing herbicide distribution and forcing the fluid into the plant. As mentioned above, both Habitat ® and Polaris AQ TM , as well as the glyphosate herbicides Aquamaster ® and Rodeo ® , require the addition of surfact ants for post-emergent applications such as the control of invasive Spartina

. Imazapyr . The Habitat ® specimen label recommends a variety of different spray adjuvants for use on post-emergent vegetati on. For non-ionic surfactants the label recommends a rate of 0.25% v/v or higher, pref erably of a surfactan t with a hydrophilic to lipophilic ratio between 12 and 17 and with at least 70% su rfactant in the formulated product (BASF 2003). Alternately, the label reco mmends the use of methylated seed oils or vegetable oil concentrates at the rate of 1.5 to 2 pints per acre. For spray volumes greater than 30 gallons per acre , the surfactant should be mixed at a rate of 1%. The label further indicates that these oils may aid in imazapyr deposition and uptake by the plants under moisture or temperature stress. Silic one-based surfactants, which may reduce the surface tension of the spray droplet, allowing greater spreading on th e leaf surface as compared to conventional non-ionic surfact ants, are also recommended. However, the manufacturer points out that some silicone -based surfactants ma y dry too quickly, limiting herbicide uptake (BASF 2004).

San Francisco Estuary Invasive Spartina Project 17. 2008 Aquatic Pesticide Application PlanOne study from Washington State concluded that the esterified seed oil surfactant tested, Competitor ® , performed better than the other surfactants tested, i.e. Agri-Dex ® , a crop oil-based surfactant, and R-11 ® , a non-ionic surfactant. This finding is also supported by Patten (2002) in which the aut hor recommended using a methyl ated seed oil surfactant for aerial applications and for unfavorable conditions such as less than 6 hours of drying time or moist leaves. The experience of the ISP from 2005-2007 has shown that a lecithin product, Liberate ® , has also been highly effective with imazapyr. In addition, this product acts as a drift retardant which may help in helicopter treatments as well as other broadcast applications to ensure full coverage on the target Spartina and minimize drift onto nontarget marsh plants. Glyphosate. The Aquamaster ® and Rodeo ® specimen labels recommend the use of a non-ionic surfactant containing at least 50% active ingredient at a rate of 2 or more quarts per 100 gallons of tank mix (0.5% v/v). With glyphosate it is also important to balance the pH of the tank water to ensure eff ectiveness, and some adjuvants are designed with this purpose in mind, namely LI-700 ®

. Not all surfactants provide the same effectiv eness and surfactant costs vary widely. In general, non-ionic surfac tants and crop oil concentrates ar e the least expensive of the surfactant classes, followed by esterified seed oils and organo-silicates. (Miller & Westra 2004.) The ISP identified a number of potentia l surfactants for use with imazapyr and glyphosate. They include the non-ionic surfac tants Liberate ® and LI-700 ® , the crop-oil concentrate Agri-Dex ® , the esterified seed oil Competitor ® , and the organo-silicones Dyne-Amic ® and Kinetic ® . Based on the efficacy experienced by the ISP from 2004- 2007, and their superior relative toxicities, the ISP expects to continue to exclusively use Competitor ® and Liberate ® in the 2008 Spartina Control Program. LI-700 ® may be used to balance the pH of the tank if /when glyphosate is employed. Cygnet Plus ® was evaluated and originally included in the ISP list of surfactant choices for 2005, but it was shown to be ineffective with imazapyr and has been removed from the list available to the ISP partners. Competitor (Wilbur-Ellis Company) is a modified vegetable oil containing a non-ionic emulsifier system. The ingredients include et hyl oleate, sorbitan al kyl polyethoxylate ester, and dialkyl polyoxy-ethylene glycol. Toxici ty studies classified this surfactant as a toxicity category of 3-4 (CAUTION).

Liberate (Loveland Industries, Inc.) is a non-ionic, low foam penetrati ng adjuvant. Its active ingredients are lecithin (phosphatidylcholin e, which is a naturally occurring lipid derived from soybeans that biodegrades readily), methyl esters of fatty acids, and alcohol ethoxylate. In a 1% solution, the pH is an al most neutral 6.8. Toxicity studies classified this surfactant as a toxicity category of 3-4 (CAUTION). It improves deposition and retards drift by producing a more uniform spray pattern. Dyne-Amic (Helena Chemical Company) is a pr oprietary blend of non-ionic organosilicone surfactants and a methylated vegetable oil. Toxicity studies classified this surfactant as a toxicity category of 3-4 (CAUTION).

Kinetic (Helena Chemical Company) is a non-ion ic wetting agent that allows for the rapid spreading and absorption of herbicide sprays into the target vegetation, and is especially effective with water-based herbicide formulations. Its active ingredients include

San Francisco Estuary Invasive Spartina Project 18. 2008 Aquatic Pesticide Application PlanSan Francisco Estuary Invasive Spartina Project 19. 2008 Aquatic Pesticide Application Plan organosilicone and polyoxypropylene-polyoxyethylen e copolymer. Toxicity studies classified this surfactant as a toxi city category of 3-4 (CAUTION). Agri-Dex (Helena Chemical Company) is a non-i onic surfactant consisting of a paraffin base petroleum oil, polyol fatty acid esters, and polyethoxyla ted derivatives of the fatty acid esters. Toxicity studies classified this surfactant as a toxicity category of 3-4 (CAUTION). 3 . Biodegradation of this adjuvant is presumed to be rapid.

LI-700 (Loveland Industries, Inc.) contains phosph atidylcholine (lecithin), which is a naturally occurring lipid that biodegrades readily. It also contains methylacetic acid and alkyl polyoxyethylene ether. Toxicity studies classified this surfactant as a toxicity category of 1 (DANGER) because of corrosive properties to the skin a nd/or eyes. Biodegradation of this adjuvant is presumed to be rapid becaus e of the natural lecithin ingredients.

Colorant . There are several colorants suitable for use in the marsh environment, all of which are similar in composition and performance. Blazon Spray Pattern Indicator(Milliken Chemical), a typical colorant, is a wa ter-soluble polymeric product. As with most colorant products, the active ingredients in Bl azon are proprietary; the Material Safety Data Sheet (MSDS) indicates that it is non-hazardous a nd non-toxic. The product information sheet reports that the product is non-stai ning to the skin or clothing. A literature survey on the toxicity of colo r indicators done for the U.S. Department of Agriculture reports “most commercial indicators are blue ... and most often a form of Acid Blue 9...” (McClintock 1997 and Zullig 1997 cited in SERA 1997b). Acid Blue 9 is a disodium salt classed chemically as a triphenelmethane color (SERA 1997b). The Cosmetic, Toiletry, and Fragrance Association (CTFA) name for certified batches of Ac id Blue 9 is FD&C blue No. 1. Herbicide application . Impacts to water quality from herbicide application depend on environmental fate, degradation rates of ac tive agents and decomposition products of the herbicides. The primary route by which herbicide solution ma y contact water is by overspray directly onto the water surface or onto areas that will be covered by water on the next tide. Herbicide may also be washed o ff plants by tidal inunda tion or precipitation. Imazapyr and glyphosate solutions wi ll be applied as sprays to Spartina foliage for control of this invasive plant. Spray mixtures may be dispersed from manually transported tanks (backpack sprayers) or spray equipm ent mounted on trucks, amphibious tracked vehicles, boats, or helicopters. Application ra tes will be consistent with the product labels (Table 4). Applications from backpack sprayers or c onventional spray truck entails workers walking through the marsh and applying herb icide directly to target pl ants, with limited overspray to surrounding plants or water surfaces. Spot application from amphibious tracked vehicles or boats would entail vehicles moving through the marsh or adjacent waterway applying herbicide with hand-held equipment to target vegetation with limited overspray. Aerial ap-plication is conducted by helicop ter (the imazapyr label does not allow for fixed-wing air-craft to be used ) with either a boom sprayer (a horizontal pipe with spray nozzles along its length, mounted to the bottom of the helicopter) or a spray ball (a hollow ball with nozzles suspended from the botto m of the helicopter). Broadcast aerial

3 Toxicity categories are determined by the U.S. EPA for human health affects. See http://www.epa.gov/oppfead1/labeling/lrm/chap-08.htm for more information on pesticide label requirements.San Francisco Estuary InvasiveSpartinaProject20.2008 Aquatic Pesticide Application PlanTable 4a: Imazapyr herbicide mixture component concentrations and application rates for treatment of non-nativeSpartinain San Francisco Estuary (Leson & Associates 2005.)Application MethodSpray VolumeFormulationActive Ingredient1Surfactant2ColorantHigh volume handheld sprayer100 gal/acre0.52-0.75% solution4-6 pints/100 gal1-1.5 lb a.e./acre0.25% v/v NIS with≥70% a.i.;~1% v/v MSO, ESO, or VOC;SBS according to label3 qt/100 galLow-volume directedsprayer20 gal/acre0.75-1.5% solution1.2-2.4 pints/20 gal0.3-0.6 lb a.e./acre0.25% v/v NIS with≥70% a.i.;~1% v/v MSO, ESO, or VOC;SBS according to label3 qt/100 galBroadcast sprayer/Aerial application10-30 gal/acre2.5-7.5% solution6 pints/10-30 gal0.5-1.5 lb a.e./acre0.25% v/v NIS with≥70% a.i.;~1% v/v MSO, ESO, or VOC;SBS according to label0.5-1.5 qt/acre1Active ingredient in Habitat®is imazapyr isopropylamine salt; values expressed as imazapyr acid equivalent2NIS = non-ionic surfactant; MSO = methylated seed oil; ESO = esterified seed oil; VOC = vegetable oil concentrate, SBS = silicone-based surfactant, %v/v = percentage based onvolume by volumeTable 4b: Glyphosate herbicide mixture component concentrations and application rates for treatment of non-nativeSpartinain San Francisco Estuary (Leson & Associates 2005.)Application MethodSpray VolumeFormulationActive Ingredient1Surfactant2*ColorantHigh volume handheld sprayer100 gal/acre1-2% solution1-2 gal/100 gal4-8 lb a.e./acre≥0.5% v/v NIS with≥50% a.i.3 qt/100 galLow-volume directed sprayer25-200 gal/acre1-8% solution1-8 gal/100 gal1.35-10.8 lbs a.e./acre≥0.5% v/v NIS with≥50% a.i.3 qt/100 galBroadcast sprayer/Aerial application7-40 gal/acre/7-20 gal/acre4.5-7.5 pints/acre2.25-3.75 lb a.e./acre≥0.5% v/v NIS with≥50% a.i.0.5-1.5 qt/acre1The active ingredient in Rodeo®and Aquamaster®is glyphosate isopropylamine salt; valuesare expressed as glyphosate acid equivalent2NIS = non-ionic surfactant, %v/v = percentage based on volume by volumeapplication involving a boom sprayer would re sult in a wider dispersion of herbicides, with greater potential for overspray onto non- target areas or the water surface. However, for aerial treatment on smaller patches of i nvasive Spartina, the boom may be shortened up and the apparatus turned on only when over the target vegetation. Aerial application will be used primarily at large areas of dense cordgrass infestations, particularly in locations where little native cordgrass an d other non-target plants are nearby. Applications from backpack sprayers or c onventional spray truck entails workers walking through the marsh and applying herb icide directly to target plants, with limited overspray to surrounding plants or water surfaces. Spot application from amphibious tracked vehicles or boats would entail vehicles moving through the marsh or adjacent waterway applying herbicide with hand-held equipm ent to target vegetation with limited overspray. Aerial application is conducted by helicopter (the imazapyr label does not allow for fixed-wing aircraft to be used) with either a boom sprayer (a horizontal pipe with spray nozzles along its length, mounted to the bottom of the helicopter) or a spray ball (a hollow ball with nozzles suspended from the bottom of the helicopte r). Broadcast aerial application involving a boom sprayer would result in a wider dispersion of herbicides, with greater potential for overspray onto non-target areas or the wate r surface. However, for aerial treatment on smaller patches of invasive Spartina , the boom may be shortened up and the apparatus turned on only when over the targ et vegetation. Aerial applicat ion will be used primarily at large areas of dense cordgrass infestations, pa rticularly in locations where little native cordgrass and other non-targ et plants are nearby.

Environmental Fate of Herbicides Herbicide mixtures may be indirectly discharg ed to surface waters by tidal action or rainfall that rinses the herbicide solution from th e plants. Rainfall is unlikely to occur during the planned application season (summer in th e San Francisco Bay region), and herbicide applications would be postponed if rainfall were predicted, but tid al inundation is inevitable on a regular cycle. A pplications to invasive Spartina along slough or creek banks or at the Bayfront on fringe marshes and mudflats will result in a small percentage of the herbicide directly entering the water column. Food-web exposures become significant only with chemicals that have a tendency to bioaccumulate or biomagnify. The adverse effect s associated with bioaccumulative chemicals relate to their propensity to transfer through the food web and accumulate preferentially in adipose or organ tissue. Basic rout es for organism exposure to bioaccumulative compounds are the transport of dissolved contaminants in water across biological membranes, and ingestion of contaminated food orsediment particles with subsequent transport across the gut. For upper-trophi c-level species, ingestion of contaminated prey is the predominant route of exposure, especially for hydrophobic chemicals.

U.S. EPA’s Hazardous Waste Identification Rule (USEPA 1999) identifies compounds that are recognized as having a low, medium or high potential for bioaccumulation. For bioaccumulation in aquatic systems, rankings were determined using bioaccumulation factors in fish, which are indicated in laborat ory tests as having low octanol-water partitioning coefficient (or log K ow) ) values for organic compounds. Bioaccumulation potential is defined as follows:

San Francisco Estuary Invasive Spartina Project 21. 2008 Aquatic Pesticide Application PlanBioaccumulation potential Bioaccumulation Factor (BAF) log K ow High BAF >= 10,000 log K ow>= 4.0

Medium 10,000 > BAF >= 100 4.0 > log K ow >= 2.0

Low BAF < 100 log K ow < 2.0 Imazapyr. Under typical environmental conditions of pH 5-9, imazapyr is ionized and is therefore highly soluble in water. Because ofits high solubility, imazapyr has an inherently low sorption potential with a low soil organic ca rbon sorption coefficient (K oc ) of 8.81 (log K oc ), suggesting very high mobility in so il and little adsorption to suspended solids and sediment. Its octanol /water partition coefficient (K ow ) has been reported at 0.22 (log K ow ), reflecting its high solubility in water and low solubility in lipids, and hence low propensity to bioconcentrate. A low bioc oncentration factor (BCF) of 3 was calculated for imazapyr, which suggests a low poten tial for bioconcentra tion in aquatic organisms (Leson & Associates 2005). Imazapyr is relatively mobile in soils because it only weakly adsorbs to soils and sediments. Adsorption increases with decreasing pH. Above a pH of 5, imazapyr is ionized and does not adsorb to soil. Aerobic degradati on in soils occurs primarily by very slow microbial metabolism with quinoline as the main metabolite (Entrix 2003). Conditions in sediments differ substantially fromthose in soils, both in terms of the regular exchange of waters within the sediment pore water and over it, and in the degree of oxygenation in sediments that affect microbial metabolism. Because the pH of sediment surfaces and sediment pore water in intertidal mudflats is above neutral (pH >7), imazapyr will be entirely in its ionized form. T hus, adsorption to sediments is expected to be minimal. (Entrix 2003.) Microbia l metabolism in sediments has been determined to be insignificant. One study determined the half-lif e of imazapyr in the pore water of aerobic sediment at 17 months. The degradation of imazapyr when applied dire ctly to water largely mimics the pathway by which the herbicide would be mobili zed at high tide after application to Spartina during low tide. Residual imazapyr on the plants that have not completely dried or did notget absorbed by the plants will be inundated by the incoming tide and presumably solubilized. Aquatic degradation studies under laboratory conditions demonstrated rapid initial photolysis of imazapyr with reported half-liv es ranging from 3 to 5 days (SERA 2004). The two primary photodegradation products were rapidly degraded w ith half-lives less than or equal to 3 days and eventual mi neralization to carbon dioxide (Entrix 2003). Degradation rates in turbid and sediment-l aden waters, common to estuarine environments, are expected to be lower than those determined under laboratory conditions. In controlled field dissipation st udies in two freshwater pond sy stems with application of1.5 lb imazapyr a.e./acre, imazapyr rapidly dissipated from the water with first-order halflives of 1.9 days and 12.8 days. No detectable residues of imazapyr were found in the water and sediment after 14 and 59 days, resp ectively. (Entrix 2003.) The ISP’s NPDES water quality monitoring at treatment sites over the past several years has found a standard reduction in imazapyr in the adjacent surface water of more than 95% one-week posttreatment over the amount present immediately after the application.

San Francisco Estuary Invasive Spartina Project 22. 2008 Aquatic Pesticide Application PlanIn estuarine systems, dilution of imazapyr in the incoming tide will contribute to its rapid dissipation and removal from the area where it has been applied. Studi es in estuaries in Washington State examined the fate of imazapyrapplied at a standard rate of 1.5 lb imazapyr a.e./acre directly to sediment. The study design was conservative because imazapyr was applied to bare mudflats with no algal or emergent vegetation intercepting the herbicide. The study measured immediate maximum c oncentrations of imazapyr in intertidal waters and sediment less than 3 hours after ap plication and short-termconcentrations between 24 and 72 hours after application. Sedime nt samples collected 3 hours after application were retrieved immediately after the fi rst tidal wash over the area. Maximum concentrations in water and sediment were de tected at 3.4 mg/L and 5.4 mg/kg, respectively. Measurable concentrations ofimazapyr declined exponentially in both water and sediment, approaching the zero-asymptote at 40 and 400 hours with half- lives of <0.5 and 1.6 days, respectively. Water collected 20 and 200 feet outside the spray zone with the first incoming tide was 99% lower than the maximum water concentration atthe edge of the spray zone (Leson & Associates 2005). Applicat ion of the same amount of herbicide to a stand of 5.5-foot tall Spartina resulted in a 75% reduction in concentrations in sediment through interception by the canopy (Patten 2003). In sum, this research suggests that imazapyr quickly dissipates in es tuarine environments. In addi tion, the same researcher observed that other vegetation rapidly colonize s the plots treated with imazapyr after the Spartina plants have died, which supports the co nclusion of very low persistence of imazapyr in estuarine environments. The ISP ha s observed this phenomenon of rapid native plant colonization of treated areas at ma ny sites around San Francisco Bay since 2005, usually involving either annual pickleweed ( Salicornia europaea ), perennial pickleweed ( Sarcocornia pacifica ), or Jaumea carnosa

. Glyphosate. Under typical environmental conditions of pH 5-9, glyphosate is ionized. Glyphosate and its salts are r eadily soluble in water with a solubility of about 12,000 mg/L. Its interactions with soil and sediment are primarily ionic, rather than hydrophobic and pH dependent. Laboratory and field studi es indicate that glyphos ate is strongly and reversibly adsorbed by soil, sediment, and suspended sediment. Glyphosate is inactivated through soil adsorption. Because glyphosate ad heres strongly to particles, it does not readily leach to waters (Sprankle et al. , 1977 cited in Alberts on, 1998), and potential movement of glyphosate to groundwater is unlik ely. Due to its negligible vapor pressure (7.5×10 -8 mmHg) and its ionic state in water, glyphosate is not expected to volatilize from water or soil. Glyphosate’s K ow has been reported at 0.00033, indicating its high solubility in water, low solubility in lipi ds, and thus low potentia l to bioconcentrate. All reported bioaccumulation factor values fo r glyphosate in aquatic organisms are well below 100 (Ebasco 1993; Heyden 1991; Wang et al. 1994). The highest bioaccumulation factor of 65.5 was reported for tilapia (a species of fish) in fresh water (Wang et al. 1994). Other studies report much lower bioa ccumulation factors in the range of 0.03 to 1.6 for fish (Ebasco 1993). Most studies repo rt rapid elimination and depuration from aquatic organisms after exposure stops (Eba sco 1993). Therefore, bioaccumulation of glyphosate is considered to be low and food-we b transfer is not considered to be a significant exposure route.

Soil studies have determined glyphosate half-lives ranging from 3 to 130 days. The soil field dissipation half-life aver aged 44 to 60 days. (Leson & Associates 2005.) In the soil environment, glyphosate is resistant to chemical degradation, is stable to sunlight, is relaSan Francisco Estuary Invasive Spartina Project 23. 2008 Aquatic Pesticide Application Plantively non-leachable, and has a low tendency to runoff (except as adsorbed to colloidal matter). It is relatively immobile in most so il environments as a result of its strong adsorption to soil particles. Glyphosate is rapidl y and strongly adsorbed to sediment, which appears to be the major sink for glyphosate in aquatic systems. Like in soils, the herbicide is inactivated and biodegraded by microorganisms. Several studies indicate that glyphosate is stab le in water at pH ranging from 3 to 6. The photolytic half-life of glyphos ate in deionized water expos ed outdoors to sunlight was approximately 5 weeks at 100 ppm and 3 weeks at 2000 ppm. Glyphosate shows little propensity toward hydrolytic decomposition. Its hydrolysis half-life is greater than 35 days. It is also stable to phot odegradation under visible light but photolyzes when exposed to UV radiation. Glyphosate’s loss from wa ter occurs mainly through sediment adsorption and microbial degrada tion. The rate of microbial de gradation in water is generally slower because there are fewer microorgani sms in water than in most soils. Studies conducted in a forest ecosystem found that glyphosate dissipated rapidly from surface water ponds high in suspended sediment, with first order half-lives ranging from 1.5 to 11.2 days. In streams, residues were undetectable within 3 to 14 days. Other studies using water from natural sources determined glyphos ate’s half-life ranging from 35 to 63 days. (Leson & Associates 2005.) For all aquatic sy stems, sediment appears to be the major sink for glyphosate residue. A review of the literature on glyphosate dissipation applied under estuarine conditions s uggests that 24 to 48 hours af ter applications, glyphosate concentrations in water were reduced by more than 60-fold. Energetic tidal cycles and tidal currents e ffectively disperse bound (adsorbed) glyphosate and surfactants and dilute them in microbially active suspended sediment. Studies of the fate of glyphosate and surfactants applied in tidal marshes and mudflats ha ve reported that concentrations of both substances dr opped below detection levels as soon as two tidal cycles (one day) to seven days (Kroll 1991, Paveglio et al. 1996) after application. The initial tidal submergence of sprayed surfaces disperses a large fraction of applied glyphosate and surfactant. Research conducted for the California Department of Food and Agriculture (Trumbo 2002) studied the environmental fate and aquati c toxicity of Rodeo and R-11 in three locations, including a Sacramento-San Joaquin Delta slough, a riverine area, and a nooutlet pond. This study measured glyphosate, aminomethylphosphonic acid (AMPA; glyphosate’s primary metabolite), nonylphenol etho xylate, and nonylphenol at treated sites one hour, two days, and eight days after applic ation. The study also tested for toxicity using 96-hour toxicity tests with the fish species fathead minnow Pimephales promelas

. The study found that concentratio ns of the tested constituen ts at slough and river sites(with moving water) was below detectible levels for all tests, and that there was no significant mortality of test fishes. The pond site , however, showed detectable residues of glyphosate, nonylphenol ethoxylate, and nonylphenol at one hour and two days after treatment, but all constituents were below detection limits by day eight. The one-hour pond samples experienced 30% mortality of test fishes, which, because of the relatively low concentrations of glyphosate (which is kn own to be non-toxic at the detected level), was attributed to effects caused by nonylphe nol ethoxylate and nonylphenol. The two- and eight-day tests showed no signifi cant mortality to test fishes. Patten (2002) compiled data on the fate of gl yphosate in water and sediment following applications in estuarine environments. Dataare presented as geometric means for immeSan Francisco Estuary Invasive Spartina Project 24. 2008 Aquatic Pesticide Application Plandiate maximum concentration (<3hrs after appl ication) and short-term concentration (between 24 hrs and 48 hrs after application). For use rates between 8 and 16 kg/ha (7-15 lbs/acre), the immediate maximum geometri c mean glyphosate concentrations were 0.174 mg/L (174 μ g/L) in water and 2 mg/kg in sediment. The short-term geometric mean glyphosate concentrations were 0.003 mg/L (3 μ g/L) in water and 1.9 mg/kg in sediment. These independent lines of research in the fate of imazapyr or glyphosate combined with a surfactant in tidal (a nd other) habitats suggest that pot ential impacts to water quality and beneficial uses of waters of the State caused by spraying these herbicide mixtures in intertidal environments are likely be small and temporary. Therefore, controlled applications (i.e., following label instructions) of regi stered herbicides are not expected to degrade water quality, except for limited temporal and spatial extent.In summary, the use of imazapyr or glyphosate combined with a surfactant to treat infestations of non-native cordgrass would resultin less than significant impacts on water quality due to the rapid degradation rate and controlled application of herbicides only on target plants. Since application of herbicid es would take place during low tide and low wind conditions, the herbicide would likely be absorbed by plants for a minimum of several hours (up to several weeks in high mars h) following application resulting in less than significant quantities of imazapyr, glyphosate or surfactants entering the water. Potential Biological a nd Ecological Effects The known properties of the herbicides, poten tial methods of app lication, and the ecological characteristics of the Estuary were ev aluated to develop a conceptual model (Figure 2) and identify likely receptors and exposure pathways. This model includes identification of primary and secondary herbicide s ources, release mechanisms, exposure media, exposure routes, and potential ecological receptors. For effects to occur, a receptor and a comple te exposure pathway must be present. An exposure pathway is only considered complete when all four of the following elements are present: project- related source of a chemical, a mechanism of release of the chemical from the source to the environment, a mechanis m of transport of the chemical to the ecological receptor, and a rout e by which the receptor is exposed to the chemical. The exposure routes associated with the comp lete pathways include direct contact with the herbicide mixture during and immediatel y after application, ingestion of contaminated surface water and sediments, direct contact with contaminated surface water and sediments, and food-web exposure. The conceptu al model (Figure 2) illustrates the links between sources, release and transport mechanis ms, affected media, exposure routes, and potentially exposed ecological receptors. Alt hough several complete exposure pathways may exist, not all pathways are comparable in magnitude or si gnificance. The significance of a pathway as a mode of exposure depends on the identity and nature of thechemicals involved and the magnitude of the likely exposure dose. For birds and mammals, ingestion is generally the most signifi cant exposure pathway. Dermal contact is expected to be insignificant and unquantifiable due to the nature of the site and frequent movement, ranging habits, and furry or feathe ry outer skin of most wildlife species. Because Project applications of herbicides would occur only once or (at most) twice a year, and compounds in the herbicide mixture are not expectedto persist in significant concentrations for more than several hours, chronic exposure is not likely. In addition, since imazapyr is a newly registered herbic ide in California as of 2005, there are few

San Francisco Estuary Invasive Spartina Project 25. 2008 Aquatic Pesticide Application PlanPRIMARY SOURCE

RELEASE MECHANISM

SECONDARY

SOURCE

RELEASE MECHANISM

EXPOSURE MEDIUMUptake/ Direct ContactaIngestionFood-Web ExposureInhalationUptake/ Direct ContactaIngestionFood-Web ExposureUptake/ Direct ContactaIngestionFood-Web Exposure

EXPOSURE ROUTE

C IC IC IC C IC IC C IC IC

IC IC IC IC C C M C C M

IC IC IC IC M C M C C M

MCM N M C M M M M

MCM N M M M M M M

M M IC M M IC IC M IC IC

Legend: C Potentially complete pathway (evaluated in a quantitative way) N Not quantified because insufficient data available M Minor or insignificant pathway IC Incomplete pathway

aDirect contact refers to dermal exposure. Herbicide Mixture in Tanks and Equipment

Partioning into Water/ Adsorbing to Sediment Accidental Spills

Herbicide Mixture before adsorption/dilution occurs) Application

Non-Target Aquatic Plants and Algae Aquatic and Benthic Invertebrates

Fish

Humans (Applicators)Potential Ecological Receptors Herbicide Mixture (before adsorption/dilution occurs)

Mixing and Dispersion Sediment Surface Water

Surface Water Sediment

Mammals Birds

other sources for its introduction to the environm ent to add to those of the ISP. Therefore, this evaluation focuses on acu te toxicity, which would occur when the compounds are present at relatively high c oncentrations during and immediately following application. Figure 3.3-2. Conceptual Model of Possible Exposure of Biological Organisms to Herbicide Mixture Used by the Spartina Control Program Figure 2. Conceptual Model of Possible Exposure of Biological Organisms to Herbicide Mixture Used by the Spartina Control Program

Herbicide solutions have the potential to aff ect organisms that live in the water column, including algae, non-target plants, fish and a quatic invertebrates. While some other recepSan Francisco Estuary Invasive Spartina Project 26. 2008 Aquatic Pesticide Application Plantors such as mammals and birds may spend a c onsiderable portion of th eir time in the water, they are generally more likely to be a ffected by other exposure routes, primarily dermal contact during application and incidental ingestion of contaminated sediment during foraging. Non-Target Aquatic Plants and Algae Due to their engineered mechanisms of action, imazapyr and glyphosate are toxic to a wide variety of plants. Native salt marsh plants, aquatic macrophytes, and algae in the Estuary waters where the herbicides would be applied could be negatively affected. However, both imazapyr and glyphosate are in effective for treati ng submerged aquatic vegetation. Imazapyr . The species most sensitive to technical grade imazapyr and an herbicide/surfactant mixture appear to be aquatic macrophytes with reported EC 25 values for duckweed ( Lemna gibba ) of 0.013 mg/L for growth and for common water milfoil ( Myriophyllum sibiricum ) of 0.013 mg/L for shoot growth and 0.0079 mg/L for root growth. (Hughes 1987; Roshon et al. 1999; both in SERA 2004.) Aquatic algae appear to be substantially less sensitive. The most sensitive species of algae tested was a unicellular green algae ( Chlorella emersonii ) with an EC 50 of about 0.2 mg/L for growth. Some algal species appear to be stimulated rather than inhibited by imazapyr concentrations of up to 100 mg/L. (Hughes 1987 in SERA 2004.) Some species of plants, including aquatic plants, may develop resistance to imazapyr. Bioassays conducted on Chlorella emersonii indicated that resistant strains may be le ss sensitive by a factor of 10. (Landstein et al. 1993 in SERA 2004.) Due to the infrequent application of imazapyr for control of Spartina

, i.e. once per year, development of re sistance to imazapyr is unlikely. Recent studies conducted in Washington Stat e also document the potential for imazapyr to impact non-target vegetation. Effects of imazapyr application on non-native Japanese eelgrass were compared to glyphosate appli cation. For both herbicides, the eelgrass canopy was killed if herbicide was applied on dr y eelgrass at low tide with imazapyr being more toxic. Application onto an eelgrass bed with a thin overlying film of water did not result in toxic effects. Within 12 months, a ll treated eelgrass beds had recovered. Persistence was not recorded in the sediment unde rlying these eelgrass beds. (Patten 2003.) Glyphosate. In laboratory growth inhibition studies with submerged aquatic plants no adverse effects on the growth of elodea ( Elodea canadensis ), water milfoil ( Myriophyllum spicatum ), and wild celery ( Valisneria americana ) were found with glyphosate concentrations of up to 1 mg/L. (Forney & Da vid 1981 in WS FEIS 1993.) These results are consistent with the findings of other invest igators who report that submerged plants are either resistant or affected only by very high glyphosate concentrations. (Evans 1978; Peverly & Crawford 1975; both in WS FEIS 1993.) A large number of studies with a variety of green algae, blue-gr een algae, diatoms, and periphy ton indicate that glyphosate is slightly toxic to practically non- toxic to most algae. Most alg ae tolerate concentrations of glyphosate greater than 1 mg/L. (WS FEIS 1993.) Species of algae vary in their sensitivity to glyphosate in terms of population growth (EXTOXN ET, Giesy 2000). Field studies indicate the least t oxicity to phytoplankton (microscopic floating algae), possibly because of dilution and adsorption in open water and flooded marshes.

Few data are available on effects to marine al gae, as most toxicity tests have been performed on freshwater species. Giesy et al. (2000) reviewed the da ta available on glySan Francisco Estuary Invasive Spartina Project 27. 2008 Aquatic Pesticide Application Planphosate toxicity to micro-organisms, and found that acute toxicity EC 50 values ranged from 2.1 to 189 mg/L. NOECs ranged from 0.73 to 33.6 mg/L. Giesy et al. (2000) also reviewed the data available on glyphosate toxicity to aqua tic macrophytes, and found that acute toxicity EC50 values ranged from 3.9 to 15.1 mg/L.

It should be noted that th ese studies included tests on the (non-aquatic) Roundup formulation as well as other forms of glyphos ate. The formulated product known as Roundup, which includes the terrestrial surfactant pol yethoxylated tallowamine (POEA) is known to be more toxic than the technical grade glyphosate found in aquatic formulations such as Aquamaster. For studies conducted on micr oorganisms using glyphosate tested as isopropylamine salt, EC 50 values ranged from 72.9 to 412 mg/L, and NOEC values ranged from 7.9 to 26.5 mg/L (Giesy et al. 2000). The lowest of these NOEC values (0.73 mg/L) is well above the maximum concentrati on of 0.026 mg/L reported by Paveglio et al. (1996) and the immediate maximum geometri c mean glyphosate conc entration of 0.174 mg/L reported by Patten (2002). Therefore, these data indicate that impacts to non-target submerged aquatic plants or algae are not likely. Impacts in estuarine conditions with high concentrations of suspended sediment , which interfere with glyphosate activity, would be even less likely. Aquatic and Benthic Invertebrates Imazapyr

. Imazapyr has been found to have low toxi city to aquatic invertebrates. A study where Daphnia was exposed to an imazapyr form ulation (~50%) produced a 48-hour EC 50 concentration of 373 mg imazapyr a.e./L (Cyanamid 1997 in Entrix 2003.). Another study with Arsenal ® (identical to Habitat ® ) with an unspecified surfactant determined a 48-hour LC 50 of 350 mg Arsenal/L (79.1 mg imazapyr a.e./L) and a NOEC of 180 mg Arsenal/L (40.7 mg imazapyr a.e. /L) for the freshwater flea ( Daphnia magna ), highlighting the potential effects of su rfactants on aquatic toxicity. Other studies also reported 24 and 48-hour LC 50 concentrations of greater than 100 mg/L, the highest dose tested (“HDT”), in static tests c onducted with newly-hatched Daphnia. (Kintner & Forbis 1983 in SERA 2004.) Chronic studies reported no adverse effects on survival, reproduction or growth of 1 st generation Daphnia after 7, 14 and 21-days of e xposure at concentrations up to 97.1 mg/L, the HDT. (Manning 1989 in SERA 2004.). Testing with other invertebrate species that exhibit alternative life cycles has been limited to survival of pink shrimp ( Penaeus duorarum ) and growth studies with the Eastern oyster ( Crassostrea virginica ). Acute toxicity to pink shrimp was determined at LC 50 >132 mg imazapyr a.e. /L, the HDT, which was also the NOEC. The EC 50 for growth inhibition of the Eastern oyster was established at a concentration greater than 132 mg imazapyr a.e./L, with the NOEC set at this concentration, the HDT. (Mangels & Ritter 2000 in SERA 2004.) A recent microcosm study analyzing benthic macroinvertebrates in a logged pond confirmed the low toxicity of imazapyr to bent hic freshwater macroinvertebrates. The study analyzed macroinvertebrate community composition, chironomid deformity rate, and chironomid biomass and concluded that imazapyr did not affect the macroinvertebrate community at the concentrations tested. Th e NOEC was determined to be greater than 18.4 mg/L (Fowlkes et al. 2003.) Glyphosate

. Glyphosate is only slightly toxic to pr actically non-toxic to marine and freshwater aquatic invertebrates. Acute toxici ty for freshwater inve rtebrates varies from 545 to 780 mg/L for water flea ( Daphnia magna ), to 673 mg/L for mosquito 4 th instar ( Anopheles quadrimaculatus ), to 1,157 mg/L for a leech ( Nephaelopsis obscura ). Acute

San Francisco Estuary Invasive Spartina Project 28. 2008 Aquatic Pesticide Application Plantoxicity for marine invertebra tes was reported as greater than 10 mg/L for Atlantic oyster larvae ( Crassostrea virginica ), 281 mg/L for grass shrimp ( Palaemonetes vulgaris ), and 934 mg/L for fiddler crab ( Uca pugilator ). (ExToxNet 2005; Henry 1992, Heydens 1991; both in SERA 2004.) The wide variation in th e aquatic toxicity of glyphosate has been attributed to the dilution wa ter, temperature, formulation, and the amount of suspended sediment in the water. Toxicity appears to in crease with temperature, and decrease with elevated pH and suspended sediment. (Schuette 1998). Giesy et al. (2000) reviewed the data available on glyphosate toxicity to aquatic invertebrates. Few data were availabl e for marine species, and those studies that did use marine species were conducted w ith glyphosate acid, not salt. Acute toxicity EC 50 values for five marine species ranged from 281 mg/L to greater than 1000 mg/L, and NOEC values ranged from 10 to 1000 mg/L. Data compiled by Ebasco (1993) include mortality tests on two marine species, for which EC 50 values were found to be 281 mg/L and greater than 1,000 mg/L.

Grue et al. (2002) conducted laboratory studies to evaluate reproductive effects of exposure to Rodeo mixed with four different surfactants, including R-11, LI 700, and Agridex, on Pacific oysters. The EC 50 for glyphosate alone was 68.1 mg/L, the EC 50 for the tank mix including Rodeo and R-11 surfactant was 29.9 mg/L, and the EC 50 for the R-11 surfactant alone was 1.0 mg/L.

The lowest of these NOEC and LC 50 values (10 mg/L) for glyphosate or glyphosate/surfactant mixtures is well above the maximum glyphosate concentration of 0.026 mg/L reported by Paveglio et al. (1996) and the immediate maximum geometric mean glyphosate concentration of 0.174 mg/L reported by Patten (2002). Therefore, these data indicate that impacts to aquatic invert ebrates due to post-application water concentrations of glyphosate are unlikely in experime ntal conditions. Impacts in estuarine conditions with high concentrations of suspende d sediment, which interfere with glyphosate activity, would be even less likely.

Kubena et al. (1997) conducted sediment and water toxicity studies on marine invertebrates (oysters and amphipods). The LC 50 values for Rodeo and surfactant in water ranged from 200 to 400 mg/L, and the LC 50 values in sediment ranged from 1000 to 6000 mg/kg. These LC 50 values are well above the highest measured geometric mean sediment concentrations of 2.3 mg /L reported by Kilbride et al. (2001) and Patten (2002). Field studies of glyphosate/surf actant applications to tidal mudflat invertebrate communities in Willapa Bay, Washington, agree with labo ratory tests, which indicate low potential for adverse impacts to benthic invertebrates. Sampling of benthic invertebrates in mudflats up to 199 days after glyphosate/surfactan t (X-77) applications revealed no shortterm or long-term effects. Short-term la boratory tests of amphipods exposed to glyphosate and surfactants did not affect survival even at hi gh concentrations relative to post-spray field condi tions (Kubena 1996).

Fish Imazapyr

. As detailed in both the 2003 Entrix an d 2004 SERA reports, a number of standard bioassays submitted to the U.S. EPA in support of the registration of imazapyr indicate very low toxicity to fish with 96-hr LC 50 values greater than 100 mg/L in most studies. According to U.S. EPA’s ecotoxicity classification for aquatic organisms (see Table A-6), these values classify imazapyr as prac tically non-toxic, the lowest category for adSan Francisco Estuary Invasive Spartina Project 29. 2008 Aquatic Pesticide Application Plandressing acute risk to aquatic organisms fr om use of chemicals. (U.S. EPA 2005.) A recent study suggests that both Habitat ® and Rodeo ® have relatively low toxicity to juvenile rainbow trout. The LC 50 determined for Arsenal ® (a terrestrial formulation identical to Habitat ® that did not contain any surfactants ) was determined at 22,305 mg imazapyr a.e./L. (King et al. 2004.) One study reported much lower 96-hr LC 50 values of 4.7 mg/L for Nile tilapia ( Tilapia nilotica ) and 2.7 mg/L for silver barb ( Barbus genionotus ). (Supamataya et al. 1981 in SERA 2004.) Although the herbicide used was not specified, it is lik ely that a formulation was used rather than the technical grad e active ingredient. Historically imazapyr herbicides contained surfactants and a formulation that removed the surfactant was only developed in 1992. The use of an herbicide cont aining surfactants might explain the considerably lower LC 50 values. The 2004 SERA report used the lowest LC 50 value from this study, 2.7 mg/L, for their risk assessment desp ite some reservations about the study due to the fact that they only had access to its abstract and because th e species studied were not native to the U.S. Nevertheless, the 2004 SERA report assumed that, even though the study was not well documented, the response of these apparently sensitive species may well encompass the response of other sensi tive species native to the U.S. (SERA 2004, p. 4-22.) This conclusion is supported by a st udy that examined the comparative sensitivity of eight ESA-listed fish species to standa rd test organisms exposed to five different pesticides or metals in order to validate the use of surr ogate species as a predictive tool in toxicological assessments . Based on their findi ngs, the authors concluded that a safety factor of two would prov ide a conservative estimate in risk assessments for listed cold-water, warm-water and euryha line fish species. (Sappington et al. 2000 in Entrix 2003, p. 49.) Glyphosate . Acute toxicity studies with warm and cold water fish indicate that technical glyphosate is slightly to pr actically non-toxic. (U.S. EPA 1993.) Acute toxicity LC 50 values were reported at 86 mg/L in rainbow trout, 120 mg/L in bluegill sunfish, and 168 mg/L in harlequin. (ExToxNet 2005.) Chronic to xicity studies with a terrestrial formulation of glyphosate, Roundup ® , found no significant advers e effects on growth, carcinogenicity, feeding, and agonistic behavior in rainbow trout finger lings. The authors concluded that sublethal levels of the formula tion are relatively non-toxic. (Morgan & Kiceniuk 1992 in WS FEIS 1993.) A recent st udy with the aquatic formulation Rodeo ® determined the LC 50 for juvenile rainbow trout at 782 mg glyphosate a.e./L. Giesy et al. (2000) reviewed the data available on glyphosate toxicity to fish. Although some data were available for anadromous sp ecies, it appears that a ll tests were conducted using freshwater test methods. Acute toxicity LC 50 values for glyphosate tested as isopropylamine salt ranged from 97 to greater than 1,000 mg/L and NOEC values ranged from <97 to 1,000 mg/L. Data compiled by Ebas co (1993) on one-day acute toxicity tests indicate EC 50 values ranging from 12.8 mg/L to 240 mg/L.

The lowest of these NOEC and LC 50 values (12.8 mg/L) for glyphosate or glyphosate/surfactant mixtures is well above the maximum glyphosate concentration of 0.026 mg/L reported by Paveglio et al. (1996) and the immediate maximum geometric mean glyphosate concentration of 0.174 mg/L reported by Patten (2002). Therefore, these data indicate that impacts to fish due to maximum post-application water concentrations of glyphosate are unlikely in experimental conditions. Impacts in estuarine conditions

San Francisco Estuary Invasive Spartina Project 30. 2008 Aquatic Pesticide Application Planwith high concentrations of suspended sedime nt, which interfere with glyphosate activity, would be even less likely.

Birds Imazapyr

. Only few toxicity studies exist for bird s. No adverse effects were noted at imazapyr concentrations of up to 5,000 ppm in the diet. Based on the highest doses tested and the U.S. EPA ecotoxicity categories ( see attached Table A-5), these results suggest that imazapyr is moderately or less toxic ora lly to birds. No data exist for the potential toxicity of imazapyr to shorebirds. (Fletc her 1983a,b,c,d in SERA 2004.) No studies exist on toxicity to raptors or on preening or inhalation exposure potentials. Glyphosate

. Effects of glyphosate on birds have been tested on mallard ducks (dabbling ducks which ingest wetland sediment along with seeds, insects, and vegetation) and bobwhite quail. Glyphosate is no more than slightly toxic to birds. Seve ral single-dose acute oral studies indicate that glyphosate is practically non-t oxic to upland birds and onlyslightly toxic to waterfowl. (U.S. EPA 1993.) As with mammals, very high dietary concentrations of glyphosate (a 4,640 mg/kg dietar y concentration) resulted in no adverse reactions such as weight loss or mortalit y (Ebasco 1993). Chronic exposure studies with glyphosate determined a no-observed-effect c oncentration (NOEC) of 1,000 ppm in the diet. (Heydens 1991 in WS FEIS 1993.) Little or no data are available on toxicity of surfactants to birds.

Mammals Imazapyr

. Based on U.S. EPA ecotoxicity criteria, imazapyr is considered practically non-toxic to mammals via oral or dermal administration ba sed on acute and chronic studies conducted with a variety of mammalian sp ecies. For example, the reported acute oral LD 50 for technical imazapyr in rats is greater th an 5,000 mg/kg body weight (b.w.) Rats were observed to rapidly excrete imazapyr in urine and feces with no residues detected in their liver, kidney, muscle, fat, or blood. No observable effect was noted for any formulation of imazapyr administered dermally. Very few inhalatory studies were performed and none tested concentrations high enough to dete rmine acute toxicity. Inhalatory effects at sublethal concentrations (<5 mg/L aerosol ) were found with technical grade imazapyr resulting in slight nasal di scharge and congested lungs. T echnical grade imazapyr and imazapyr isopropylamine salt were both found to be moderately irrita ting to rabbit eyes with complete recovery within 7 days. Technical grade imazapyr is reported as mildly irritating to rabbit skin. Commercial formulati ons of imazapyr appear to be less toxic via dermal exposure. (Entrix 2003, p. 42-44.) Chroni c and subchronic toxicity studies with imazapyr with dogs, mice, and rats did not s uggest any systemic toxic or carcinogenic effects. (SERA 2004.) Glyphosate

. Glyphosate has been determined to be practically non-toxi c to mammals by ingestion with an acute oral LD 50 of 5,600 mg/kg b.w. in rats. The no-observed-effect level (NOEL) for chronic toxicity to rats has been determined at 362 mg/kg b.w./day (8,000 ppm) and LOEL at 940 mg/kg b.w./da y (20,000 ppm). (USDA 1981; Monsanto 1983; both in WS FEIS 2003.) The reported acute LD 50 values for dermal effects range from >5,000 to 7,940 mg/kg for rabbits. Subchr onic oral toxicity studies of glyphosate with rats and dogs indicate that oral does of up to 2,000 pp m do not significantly affect behavior, survival, or body we ight. Laboratory studies of the chronic effects of glyphosate show that it is slightly to practically non-irritating to rabbits ’ eyes. No significant

San Francisco Estuary Invasive Spartina Project 31. 2008 Aquatic Pesticide Application Planreproductive, teratogenic, muta genic, or carcinogenic effect s from exposure to concentrations of up to 300 ppm were reported in 20-ye ar laboratory studies with rats, dogs, rabbits, and mice. Little is known about potential interactiv e effects between applied imazapyr or glyphosate/surfactant solutions and cumulative load s of herbicides, insecticides, detergents, perfume agents, and many other organic contamin ants in the San Francisco Estuary. It is reasonable to assume that cumulative, interac tive effects occur in organisms of the Estuary, but the complexity of multiple interac tions in uncontrolled field conditions makes definitive research difficult. In practice, total dosages of imazapyr or glyphosate/surfactan t solutions applied in field conditions (amount of solution applied, a nd concentration, and the number of reapplications to eradicate survivors) depe nds on many factors whic h are independent of the physiology of imazapyr, glyphosate or the surfactants themselves. The physiological activity and health of the plant, interference wi th spray coverage by persistent dead leaves or sediment films, all can affect the percent kill of vegetation, and th e ability of regenerative buds to survive and re-establish the popul ation. Regeneration re quires re-application of herbicide or other eradication methods.

7. DESCRIPTION OF ALTERNATE, NON-CHEMICAL CONTROL METHODS

The Spartina Control Program implements a number of non-chemical control methods in situations where environmental impacts can be reduced, sites are appropriate for volunteer efforts and educational opportunities, or where public demand dictates. These methods are especially appropriate for small, newly establishing infestations and/or for some of the final cleanup of sites after control efforts have reduced the infestation down to small remaining patches. Non-chemical control methods are also a great way to engage the community around a site because they foster vol unteer stewardship efforts and public outreach. During the development of the Site-Specific Plans for control of invasive Spartina around the Bay, the Spartina Control Program evaluated ev ery possible known control method that could be used. A number of criteria were used in the evaluation including efficacy at controlling the Spartina , human health and safety, damage to the marsh habitat and/or other aspects of the environment, impacts on water quality, feasibility of applying the method in the salt marsh, cost, etc. Several non-chemical methods (hand-pulling and manual excavation, covering/blanketing, and mechan ical excavation or dredging) have been incorporated into the Site-Specific Plans fo r 2008-2010. The remainder of the methods that were evaluated were found to have significant limitations , and are not part of the Spartina Control Program’s current plans. However, so me of these methods may be used in conjunction with our selected control methods at a later date. The entire set of possible control methods that were evaluated are discussed belo w, starting with the me thods that were selected and incorporated into the plans.

ISP-selected Non-chemical Control Methods Hand-pulling and manual excavation Manual removal methods are the simplest tec hnology for removal of cordgrass. Manual removal includes pulling cordgrass plants out of marsh sediments or using hand tools such as spades, mattocks, or similar tools to cut away as much cordgrass as possible within reach. Manual removal methods are e ffective primarily at removing aboveground

San Francisco Estuary Invasive Spartina Project 32. 2008 Aquatic Pesticide Application Planplant parts, but are less effective at rem oving belowground rhizomes (the horizontal underground stem that sends out roots and shoot s from buds) that rapidly regenerate shoots. Unless digging removes the entire marsh soil profile containing viable rhizomes and buds, its effect is equivalent to pruning (see Mowing, burning, pruning, and flaming, below). The vigor with which remaining rhizomes resprout and regrow is often proportional with the severity of the disturbance. Freque nt re-digging and maintenance is needed to exhaust rhizome reserves of energy and nutr ition, and the population of buds capable of resprouting.

Manual removal is most effective on isolat ed seedlings, or very young discrete clones (asexually reproduced colonies of cordgrass) or clumps, wh ere they are infrequent. Manual excavation in tidal marshes is extremely labor-intensive. Most cordgrass colonies occur in soft mud, where footing needed for digging is impossible or hazardous, even for workers on platforms, mats, or snowshoe-lik e boots adapted for walking on mudflats. Dug plants with roots left in contact with moist soil may retain viability and regenerate in place or disperse on high tides to establish new populations.

As the invasive Spartina populations are reduced around Sa n Francisco Bay, the ISP has increased its use of manual removal methods as part of an Integrated Pest Management strategy and a way to reduce the need for he rbicide where appropriate. Manual removal is particularly useful on Spartina densiflora , the secondary invasive cordgrass species in the Estuary which is a discretely-rooted bunchgra ss as opposed to the d eeply-rooted rhizomatous clones of the main problem species, hybrid Spartina alterniflora . The infestations of S. densiflora occur mainly in Marin County withthe exception of a few outlier populations in Contra Costa and San Mateo Counties. Many tons of S. densiflora will be removed manually in 2008. Disposal of manually removed material, especi ally root/rhizome systems, is problematic. On-site disposal in marshes may cause additional marsh disturbance and may result in spread of invasive cordgrass by regeneration of viable roots. Where manual removal occurs next to levees, salt ponds, or other non-tidal environments, local disposal may be feasible. Disposal of manually removed mate rials may also be accomplished with specialized low-ground-pressure equipment (amphi bious vehicles), but the number of passes needed to transport materials also increases marsh disturbance. Mechanical excavation and dredging Mechanical removal in marshes uses equipm ent specially designed for working in semiterrestrial, semi-aquatic wetland environm ents. Excavation and dredging are accomplished using (1) amphibious dredges fitted with excavators, clamshells, or "cutterhead" dredges, or (2) excavators working from ma ts (large wood pile supports placed flat on geotextile fabric placed over the marsh su rface). Some locations allow use of conventional shallow-draft, barge-mounted dredging equipment working within reach of marsh from the margins of navigable channels, part icularly at high tide. Where cordgrass colonies lie within the limited r each of track-mounted excavators working from levees, mechanical removal also can be performed without entry of equi pment to aquatic or wetland environments. Another mechanical technique is maceration or pulverization of so il and plant remains on site using modified agricultural equipment, "c hewing" them into particles too small to be viable or regenerate. Floating maceration eq uipment has been used in inland waterways

San Francisco Estuary Invasive Spartina Project 33. 2008 Aquatic Pesticide Application Planto control submerged aquatic vegetation. The Control Program may s upport research and development of this method for use in the ba ylands environment, a nd would utilize this method if it were shown to be effectiv e and reliable with mitigable impacts. Mechanical excavation working to the full dept h of the rhizome system (up to 1 foot) in tidal marshes has the potential to be signifi cantly more effective than manual excavation. Similarly, maceration techniques that almost completely destroy both aboveground and belowground living mass of cordgrass have high potential effectiveness. Both techniques also have significant limitations in the Sa n Francisco Estuary, however. Excavators working from levees have an inherent limitati on of short reach or access distance, usually a working distance of less than 20 feet for the size equipment th at typical levees could bear. Floating barges with clamshell or cutterhead dr edges, in contrast, would need to work at high tides within about 70 feet of the lead ing edge of cordgrass vegetation. Excavators have sufficient reach to dispose of excavat ed marsh soil and biomass in non-wetland areas, on levees, or in aquatic habitats such as salt ponds, which lack vegetation. Heavy equipment often is used within the Es tuary's tidal marshes for purposes other than eradication of cordgrass, including removal oflarge debris hazards and contaminated materials, and construction or main tenance of ditches or canals. Most of this work is done on mats, to distribute the weight of equipmen t and protect underlying vegetation. These actions are usually aimed at operations that are highly localized (points or narrow alignments) in the marsh, and usually on the relatively firm marsh plain. Even there, equipment may become mired in soft spots, and removal of mired equipment can damage the marsh. In contrast, to maintenance-type work, removal ofinvasive cordgrass involves a mosaic pattern for operations, and occurs most often in the low marsh and mudflats, which do not easily support mats and geotextile fabrics. Thus, control methods based on excavators working on mats would be most applicable to localize d, large patches of invasive cordgrass on the marsh plain. Some tidal flats invaded by co rdgrass occur on sandy deltas with intertidal sand bars (e.g., San Leandro, San Lorenzo Cr eek) where equipment could be staged, but this situation is unusual. Th e feasibility of using mechanical excavation or dredging methods at a particular location would be determined based on site-specific conditions. Covering/blanketing This is another technique that is aimed at ex hausting the reserves of energy and nutrition in cordgrass roots and rhizomes and increasing environmental an d disease stress. Covering typically involves securing opaque geotextile fa bric completely over a patch of cordgrass. This excludes light essential to photosynthesis (transformation of solar energy to food energy), and "bakes" the covered grass in a tent of high temperature and humidity. This technique may be used for discrete col onies (clones) where th e geotextile fabric can be fastened to the marsh surface securely with stakes for a sufficiently long period of time. High tides, high winds, and tide-transpor ted debris common in tidal marshes often make this difficult or impossible in some situ ations. Care must be taken to cover the entire clone to a distance suffici ent to cover all rhizomes. If rhizomes spread beyond the reach of the blanketing cover, rhizome conn ections to exposed, healthy stems can translocate (pipe) foods to the stressed, starving connected portions of the clone under the fabric, and increase overall survival. Staking geot extile tents on soft mudflats is very difficult, and may make this method infeasible in many situations.

San Francisco Estuary Invasive Spartina Project 34. 2008 Aquatic Pesticide Application PlanWrack (piles or lines of drifted debris and de tritus from tidal sources) also is capable of smothering cordgrass and other salt marsh pl ants. Wrack can be created artificially by placing temporary debris piles on the marsh surf ace, but cannot be stabilized for long (usually no longer than the highest December-J anuary or June tides or winter storm surges). Their duration at any position in th e marsh depends on the frequency and height of tides. The lower in the intertidal zone, the less stable the position of a wrack pile is likely to be. This technique would be used only for small colonies, and would depend on locally available accumulations of organic tidal debris.

Other Non-chemical Methods Evaluated Mowing, burning, pruning, and flaming Cordgrasses are well adapted to disturbances that "crop" or ot herwise remove aboveground biomass. A single event that removes living or dead above ground cordgrass biomass generally stimulates cordgrass growth, a nd as soon as a cordgras s stand refoliates, it begins to "recharge" its root s and rhizomes with new food re serves. If vegetation is removed with frequency, roots and rhizomes ar e prevented from rege nerating reserves of energy and nutrition and cordgras s begins to die back as it s organs of regeneration and storage become exhausted. If the cordgrass is mown close to the mud surface, it also severs the connections between leaves and roots th at transport gases to roots growing in extremely anoxic (oxygen-deprived) waterlogged se diment and further stress the plant. Repeated close mowing may be used to in crease physiological stress to a point that cordgrass cannot regenerate; frequent burning would have similar effects. The use of pruning, burning, and mowing for cordgrass erad ication in open mudflats and marshes would require very frequent treatment of all aboveground growth until the cordgrass rhizome/root systems become exhausted. For robus t stands of Atlantic smooth cordgrass, this may require weekly treatment for more than one growth season. Controlled burning may be used in some situ ations to remove vege tation prior to other treatments, or to prevent polle n and seed dispersal in founder colonies invading new sites. Burning would be used only in suitable lo cations, and only during periods of low-wind conditions (especially early morning), when fi re hazards in succulent vegetation of tidal pickleweed marshes would be manageable . Ignition, however, may be difficult in cordgrass stands on mudflats. Selective pruning (partial mowi ng with "weed-whackers" or flaming with hand torches) may be used to remove flowerheads and seedhead s of discrete colonies to prevent flow of pollen from contaminating seed production of native cordgrass, and to prevent seed production within founding colonies. However, pruni ng would have little or no effect on the clone's growth rate and must be followed up with other methods to control spread. Mown vegetation without viable seeds or pr opagules may be left in place or removed from the site. Vegetation containing viable seeds or propagules would require removal from the treatment site and disposal in a suit able area not conducive to cordgrass growth. Crushing and mechanical smothering This method uses amphibious track vehicles to trample new plant shoots and stems, and cover them with a layer of sediment. The obj ective is to smother the plant by preventing the use of stems to transport oxygen to its roots and rhizomes. The method would typically be used in the fall, and ideally a period of time after mowing, when young shoots

San Francisco Estuary Invasive Spartina Project 35. 2008 Aquatic Pesticide Application Planand stems have developed. This method has been used with some success in Washington State, but has not yet been used in the San Francisco Estuary. Flooding and draining Flooding and draining techniques entail construc ting temporary dikes or other structures to impound standing water or remove water to kill emergent vegetation. Cordgrasses are intolerant of permanently flooded or stable, dry conditions, and are generally absent inthe diked nontidal salt marshes of the Estuary. Salt evaporation ponds, managed waterfowl ponds, and completely diked pickleweed marsh exclude cordgrasses, native and non-native alike. Atlantic smooth cordgrass and English cordgrass are capable of invading tidal marsh pools (salt pans) subject to irregular tidal influence (Campbell et al. 1990, P. Baye, pers. observ.), but they are not lik ely to survive in typical diked wetlands.

When tidal marshes are diked and drained ra ther than flooded, they undergo rapid physical and chemical changes. Organic matter deco mposes when microbes are exposed to air; clays shrink when dewatered; and sulfides formed in oxygen-free mud transform to sulfates forming strong acids (Portnoy, 1999). Th erefore, diking and draining, although conceivably effective for killing cordgrass, would ad versely impact marsh soils and restoration, and the longer salt marsh soils are diked and drained the more difficult these adverse soil changes are to reverse. For these reasons , diking and draining only would be used in critical situations where no other method is feasible, and only after careful evaluation and planned mitigation. Diked salt marsh soils thatremain permanently flooded undergo relatively slower and less significant changes. Diked flooded salt marshes would eliminate existing standing vegetation, but are readily re -colonized by youthful salt marsh vegetation if the diking is brief. Isolating the treatment area for flooding or draining may be accomplished by constructing temporary dikes or by closing openings in ex isting dikes. Temporary constructed dikes need not be large to accomplish treatment. Low earthen berms (about one foot above marsh plain elevation), constructed using low-ground pressure amphibious excavators, could be built around large colonies of cordgr ass within open marsh plains. Alternatively, water-filled geotextile tubes ("inflatable dams"), analogous with inflatable cofferdams used in aquatic construction/dewatering ope rations, may be used. Upon completion of treatment, berms would be graded down to marsh surface elevation, and inflatable dams removed. Temporary dike structures may be di fficult to construct in tidal mudflats. Mudflat sediments are usually too soft to "stack" into berms, and firmer material placed on fluid or plastic muds simply subsides into th e flats. Similarly, inflatable dams may not be feasible for softer tidal flats. Many populations of non-native cordgrasses have invaded marshes restored by breaching dikes within former diked bayl ands, where most of the orig inal dikes remain. In these situations, a dike-enclosed tidal marsh could be temporarily re-closed ("choked") by placing a sheetpile barrier in the existing breach, thus creating a tempor ary lagoon and effecting mass cordgrass eradication. Water control structures (adjustable tidegates) may be installed to enable marsh managers to maintain water depths lethal to cordgrass, suitable diving duck habitat, and adequa te water quality. Marsh recol onization is expected to proceed rapidly following restoration of tidal flows.
An alternative form of treatment, intermed iate between flooding and draining, would be to combine impoundment of water with delibe rate solar evaporation, creating hypersaline

San Francisco Estuary Invasive Spartina Project 36. 2008 Aquatic Pesticide Application Planlagoons. Hypersaline conditions would make the habitat transformation even more rapidly lethal for invasive cordgrass. Restori ng tidal flows to temporary salt ponds, however, may require dilution of brines, which could increase cost.

8. HERBICIDE APPLICATION AREAS FOR 2008-2010 Twenty-five sites, comprising 166 sub-areas and approximately 300 acres of non-native Spartina , are slated for control during the 2008 Spartina Treatment Season (Figure 3), and 150 of these infestation sites will potentially be treated with herbicide for at least a portion of their control work. Most of these sites are being re-treated for the second or third year, hence the significant reduction in treatment area from 2,000 acres in 2006. Aquatic herbicide was determined to be the most efficaciou s, feasible, and least impactful method for Spartina control following a thorough evaluatio n of the available control methods described above. Each site has been evaluated taking into account many factors including site access, endangered species issues, habitat sens itivity, the infestation’s susceptibility to nonchemical control methods, partner involvement, public comment, and other factors. A brief description of each site follows including the herbicide delivery systems(s) to be used and an identification of the ISP Partner involved in treatment work on the site. Detailed maps of the each site can be fo und in Appendix 2. Site 01 – Alameda Flood Control Channel, Alameda County The Alameda County Flood Control Channel (A CFCC) is a large, unlined, trapezoidal channel that runs from east to west th rough Hayward, Alameda County, draining a nearly 800 square mile watershed into the San Fran cisco Bay. The levees on both sides of the ACFCC are topped with multi-use public trails that are part of the San Francisco Bay Trail and Coyote Hills Regional Park. Do wnstream from Ardenwood Blvd., beyond the levees to the north, are both active and in active commercial salt ponds, with an industrial facility and parking lot along the furthest ups tream levee. To the south are active salt ponds, seasonal wetlands, and Coyote Hills Re gional Park. There are currently no housing units, schools or other similar faci lities within this lower reach.

The combined infestation of the six sub- areas of the Alameda Flood Control Channel comprised one of the largest S partina alterniflora hybrid infestations in San Francisco Bay. The ISP's 2004 mapping effort estimated a total of roughly 200 c ontiguous acres of S. alterniflora / hybrids on this site spread over approximately 470 acr es (43%) of salt marsh and tidal mudflats. The treatments fr om 2005 -2007 have reduced the infestation by at least 85%. The primary treatment method at this site is aquatic herbicide, which will be applied by helicopter, conventional spray truck, and tracked amphibious vehicle. Partners on this site include th e Alameda County Flood Control District and the California Wildlife Foundation. Note that this is a comp lex site composed of multiple sub-areas. Please refer to the Site Specific Plan for detail ed descriptions of th e sub-areas and the associated treatment methods. Site 02 – Bair & Greco Island Complex, San Mateo County The Bair & Greco Island complex encompassed by this plan is loca ted in the southwest portion of the San Francisco Bay Estuary. The northern edge of the complex is at Belmont Slough on the border of Foster City a nd Redwood City, including the marshes of Brewer Island just south of the San Mateo Br idge. The southern border of the complex is the Union Pacific railroad line just south of the Dumbarton Bridge. The site includes

San Francisco Estuary Invasive Spartina Project 37. 2008 Aquatic Pesticide Application PlanFigure 3. Location of 2008-2010 Spartina Treatment Sites within the San Francisco Estuary and adjacent Outer Coast marshes. Each treatment site is comprised of one to 23 sub sites, which are identified by letters (a through z) in project plans and documents

marsh islands, active and inactive commerc ial salt ponds, six large sloughs with numerous smaller channels, and other bay front mars h that is part of the San Francisco Don Edwards National Wildlife Refuge (DENWR). The Bair & Greco Island complex contains many different marsh systems, all of which are impacted to varying degrees by Spartina alterniflora hybrids. Of the roughly 3,060 acres of Baylands within the complex, there were approximately 216 acres (7%) infested with non-native Spartina in 2005. Three years of effective herbicide treatments in this complex leave less than 50 acres to treat/ret reat in 2008. Three sub- areas were added to this complex for the 2008-2010 Site-Specific Plans, one along Redwood Creek and the

San Francisco Estuary Invasive Spartina Project 38. 2008 Aquatic Pesticide Application PlanDeepwater Slough with a few acres of hybrid Spartina , and two areas thatare soon to be opened to tidal inundation but are not yet infe sted. The primary treatment method at this site is aquatic herbicide, wh ich will be applied by helicopter, conventional spray truck, backpack sprayer, tracked amphibious vehicle, and boat. Partners on this site include the U.S. Fish and Wildlife Service, Don Edwa rds National Wildlife Refuge and the San Mateo County Mosquito Abatement District. Note that this is a complex site composed of multiple sub-areas. Please refer to the Site Sp ecific Plan for detailed descriptions of the sub-areas and the associated treatment methods. Site 03 – Blackie’s Pasture, Marin County

Blackie’s Pasture is a small Ci ty of Tiburon park located al ong the shoreline of Richardson Bay, adjacent to Tiburon Boulevard. With the ample parking provided at the park, it is heavily used by the public for passive recreation. The park is comprised of a 0.7-acre pasture, a small creek channel (“Blackie’s Creek”) along the eas tern edge of the pasture, and a shoreline area that includes the channe l mouth, a small open mudflat (fed by sediment delivered by the creek), a nd landscaped pathways and picnic areas. The total area of non-native Spartina at the Blackie’s Pasture site was around 0.8 acre in 2005, divided between two sub-areas. This has been reduced to several hundred square feet that will betreated in 2008. The upper portion of this site is represented by the Blackie’s Creek Channel (Sub-Area 3a), wherein Spartina alterniflora hybrids dominated what was previously an open channel. Spartina densiflora and Spartina alterniflora hybrids dominated the mouth of Blackie’s Creek (Sub-Area 3b) , readily hybridizing with the native Spartina foliosa stand there. Some excavation of the uppe r channel occurred in 2005 as part of a restoration project, but only the invasive Spartina in the center of the creek was actually removed; the remainder was treated in 2006. The primary treatment method at this site is aquatic herbicide, which will be applied by backpack sprayer. Removal of young S. densiflora plants will be done manually with the plants taken off site for disposal. Partners on this site include the City of Tiburon Public Works and the Tiburon Audubon Society. Site 04 – Corte Madera Creek Complex, Marin County The Corte Madera Creek complex is located on the west side of the North San Francisco Bay in Marin County, south of the San Quentin peninsula and San Ra fael Bay. The complex consists of a wide corridor stretching up stream from the mouth of Corte Madera Creek to the uppermost point of non-native Spartina growth in this watershed at about 2.2 miles from the mouth. The entire Corte Madera Creek corridor is heavily developed with upscale residential and commercial facilities. The Cort e Madera Creek complex is comprised of 11 distinct sub-areas that occur on both public and pr ivate lands, each of which will require different treatment and p ublic outreach approaches. The infestation at the Corte Madera Creek comp lex was still in a relatively early stage of establishment, with approximately 12 acres s cattered over 318 acres, or 4% of the total marsh area. The infestation at this complex contains some unique features, including the only infestation of Spartina anglica in the Bay, as well as the first documented case of Spartina densiflora hybridizing with the native Spartina foliosa . Most of the sub-areas have small S. densiflora infestations (less than 0.5 acre), enabling manual control to be used in conjunction with spot herbicide treatments. One sub-area also has Spartina alterniflora hybrids, bringing the overall site total to three of th e four invasive cordgrass species currently found in the Bay.

San Francisco Estuary Invasive Spartina Project 39. 2008 Aquatic Pesticide Application PlanThe Marin Conservation Corps conducted a gr eat deal of manual removal throughout the winters from of 2005-2008, and this method was highly effective. A few of the sites that were controlled by herbicide in 2007 will be re visited this season to manually pull/dig the few plants that have resp routed or emerged from the seedbank, while any healthy Spartina densiflora plants will be treated with imazapyr . Partners on this site include the Friends of the Corte Madera Creek Watershe d, California Department of Fish and Game, California State Lands Commission, College of Marin, City of Larkspur, Golden Gate Bridge Highway and Transpor tation District, Marin Count y Parks and Open Space District, and the Marin County Flood Control and Water Conservation Distri ct. Note that this is a complex site composed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descriptions of the sub-ar eas and the associated treatment methods. Site 05 – Coyote Creek & Mowry Sl ough Area, Santa Clara County The area encompassed by this Site-Specific Plan includes approximately 3,652 acres of marshland within the San Francisco Don Edwa rds National Wildlife Refuge that lie between Coyote Creek to the south and the Dumbar ton Bridge to the north. The site is surrounded entirely by marsh and salt ponds, and th ere is very little public access, except for a portion of the Bay Trail along part of Newa rk Slough (Sub-Area 5c). Within this area, the sub-areas include recently restored tid al marshes, freshwater ponds and upland islands, highly complex and diverse historic marsh habitats that include channels, high marsh, mudflats and pans, thin strip marshes, open mudflats, creek channels and mouths, and sandy beach areas. The pioneering infestation of Spartina alterniflora hybrids in the Coyote Creek and Mowry Slough complex is still very limited in its dist ribution. However, though the acreage is still relatively small, the clones are distributed thro ughout the habitat types described above. In sum, these infestations covered approximately 15.3 acres in 2005 scatte red over this very large marshland complex, which is equal to just 0.4% of th e area. Much of this area was treated for the first time in 2006 using a directed herbicide application tool (spray ball) that the ISP developed with PJ Helicopters of Red Bluff, CA. The results from 2007 treatmentwere less efficacious and several of these areas need to be treated by broadcast aerial application in 2008. The primary treatme nt method at this site is aqua tic herbicide, which will be applied by broadcast from helicopter, conven tional spray truck, backpack sprayer and tracked amphibious vehicle. The partner on this site is the U.S. Fish and Wildlife Service, Don Edwards National Wildlife Re fuge. Note that this is a co mplex site composed of multiple sub-areas. Please refer to the Site Spec ific Plan for detailed de scriptions of the subareas and the associated treatment methods. Site 06 – Emeryville Crescent, Alameda County The Emeryville Crescent marsh is a 1 03.5-acre, fringing mixed pickleweed ( Salicornia virginica ) marsh shoreline between Powell Street in Emeryville and the eastern landfall of the Oakland Bay Bridge. Two sub-areas, Emeryville Crescent East (6a) and Emeryville Crescent West (6b), have been delineate d due to the historical ownership and maintenance of the site. The site abuts an extremel y heavily developed area on the east side of the Bay, with Interstate 80/580 directly adjacen t to the east, and the approach to the San Francisco Bay Bridge adjacent to the south. Lo cal anglers, dog-walkers, and other recreational groups frequently use the marshlands includ ed in this site. Illegal activities such as dumping and littering, unauthorized camping, a nd public inebriation also occur along the edges of, and sometimes within, th e marshlands of this site.

San Francisco Estuary Invasive Spartina Project 40. 2008 Aquatic Pesticide Application PlanThe non-native Spartina infestations at Emeryville Crescen t were in the early stages of establishment on the site. The individual locatio ns of these plants were scattered across both of the sub-areas, but th eir overall acreage was small in 2005, at less than 2.6 acres or 2.5% of the combined marsh acreage. The in festation is located mainly along the bay edge of the marsh, adjacent to the open mudfla ts on the outer edge of the site, with a few scattered clones establishing on the interior portio ns of the marsh within Sub-Area 6b. Treatment in 2008 will be needed on less than 1000 square feet after three years of successful applications. The primary treatment met hod at this site is aquatic herbicide, which will be applied by conventional spray truck, backpack sprayer, and tracked amphibious vehicle. Partners on this site include the California Departme nt of Parks and Recreation and the East Bay Regional Parks District. Site 07 – Oro Loma Marsh, Alameda County Oro Loma Marsh is a large, 324-acre, recentl y restored salt pond located on the eastern shore of the San Francisco Bay Estuary adj acent to the town of San Lorenzo, about 1.5 miles south of the Metropolitan Oakland International Airport. The marsh is surrounded by levees, with Bockmann Channel and Sulfur Creek bordering the marsh to the north and south respectively. The San Francisco Bay Trail, a multi-use public recreational pathway, utilizes the levee to the west of Oro Loma, and the Southern Pacific Railroad borders the marsh to the east. The surroundi ng area includes various industrial and commercial developments to the north and south including a sewage treatment plant, electrical substation, and capped landfill. Beyond the railroad to the east ar e residential developments, the Skywest Golf Course, and Ha yward Municipal Airport, with I-880 approximately 0.5 mile from the marsh edge. The entirety of the Oro Loma Marsh site was infested with Spartina alterniflora hybrids across both Sub-Areas prior to the very succ essful helicopter treatment in 2005, totaling approximately 100 acres (31% of the marsh). Th is was one of the larg est infestations of S. alterniflora hybrids in the eastern Central Bay, a nd was adjacent to several other large infestations including sites along the San L eandro/ Hayward shoreline. Successful helicopter treatments occurred in 2006 & 2007, but there are still scattered clusters of Spartina throughout that will be treated in 2008. The primary treatment method at this site is aquatic herbicide, which will be appl ied by helicopter on the remaining stands. The partner on this site is the Ea st Bay Regional Parks District. Site 08 – Palo Alto Baylands, Santa Clara County The Palo Alto Baylands is a 1,030-acre natu re preserve and park complex owned by the City of Palo Alto and locate d on the bayfront south of th e Dumbarton Bridge. The site includes those areas to the north and south of Charleston Slough, and may extend to the northernmost tip of marshland on the southeas t portion of the outlet of Charleston Slough – that land within the city limits of Palo Alto. The site is partof a large expanse of intact native Spartina foliosa and pickleweed ( Salicornia virginica )/gumplant ( Grindelia sp.) marsh habitat. The park has high visitation on the established pathways through the marsh, and serves as an educational center for birdwatchers, naturalists, local schools, and the public. Other recreational users of the preserve include hikers, kayakers, anglers, bikers, joggers and many others. The pioneering infestation of S. alterniflora hybrids on this site covered approximately one acre in 2005, scattered along th e bayfront, mostly south of the Baylands Nature InSan Francisco Estuary Invasive Spartina Project 41. 2008 Aquatic Pesticide Application Planterpretive Center. Treatment from 2005-2007 has reduced this infestation by approximately 90%. There are several main areas of in festation: the southeas t side of the "YachtClub Bay" near Mayfield Slough, clones near Hooks Point and Hooks Island, and scattered plants along the bayfront from Mayf ield Slough to Charleston Slough. The primary treatment method at this site is aquatic herbicide, which will be applied by conventional spray truck, backpack sprayer, a nd boat. Partners on this site in clude the City of Palo Alto and Palo Alto High School. Site 09 – Pickleweed Park, Marin County

Pickleweed Park is an 18-acre City of San Rafael Park locat ed on the edge of San Rafael Bay in the northwestern San Francisco Bay Estuary. It is bounded to the north by San Rafael Creek and to the south by East Canal St reet. Bordering the park on the east side is the 10-acre Tiscornia Marsh, a thin band of high marsh pi ckleweed/gumplant habitat, which grades abruptly from a 2 to 3 foot-hi gh escarpment to an ex tensive mudflat extending bayward. This band of marshland tapers as it extends southward along the park boundary, and becomes very thin as it curves eastward along the riprap of a levee surrounding an area filled for development. Ther e is an east/west w ooden service walkway through the marsh that provides access to the Pacific Gas and Electric (PG&E) power line tower adjacent to the site. There is an establishing population of Spartina densiflora within the fringing marshlands of the park. These plants are at their greates t density in the marsh near the outlet of San Rafael Creek. The plants form a dense st and on the Bay edge surrounding the escarpment, near an electrical tower. Scattered plants extend southward from this main area along the Bay edge, and then east and southeas t to Shoreline Park. The total infestation size of S. densiflora on the site was approximately 0.05 acres (2200 ft 2 ). In spring 2005, a pioneering infestation of S. alterniflora / hybrid was also discovered just south of the PG&E walkway. Treatment from 2005-2007 has b een highly effective and just a handful of plants will need to be treated in 2008. The primary treatment method at this site is manual removal of all S. densiflora , with very limited aquati c herbicide application by backpack sprayer to an established patch of hybrid S. alterniflora in one of the channels. Partners on this site include the Tiscorni a Estate Company and City of San Rafael. Site 10 – Point Pinole Regional Shoreline, Contra Costa County Point Pinole Regional Shoreline is a 2,315-acr e park owned by the East Bay Regional Parks District. It is located to the west of the city of Ri chmond, in Contra Costa County. Point Pinole opened to the public in 1973 afte r the property was acquired from Bethlehem Steel. Bethlehem had acquired the land in the early 1960s from Atlas Powder Co., one of several firms that had manufactured gunpowder and dynamite there for almost 100 years. The park occupies a short peninsula composed of a main upland core with open, grassy parklands interspersed with predominantly eucalyptus woodlands. Along the northern portion of the park, a wide border of high marsh picklew eed characterizes Whittell Marsh, Sub-Area 10a. The southern porti on of the park, Sub-Area 10b is a narrow band of tidal marsh grading quickly over a 10-20 meter span from high marsh pickleweed to sandy mudflat. A new Sub-Area 10c was adde d this year with EBRPD’s acquisition of Giant Marsh.

The non-native Spartina infestations at Point Pinole were in the early stages of establishment. The individual locations of these pl ants are scattered within the Sub-Areas, but

San Francisco Estuary Invasive Spartina Project 42. 2008 Aquatic Pesticide Application Plantheir overall acreage is small. The addition of Giant Marsh added infestation areas that have not yet been treated until 2008. The primary treatment method at this site is aquatic herbicide, which will be applied by backpack sp rayer. The partner on th is site is the East Bay Regional Parks District. Site 11 – Southampton Marsh, Solano County Southampton Marsh is the largest extant mars h within the Carquine z Strait. Its roughly 175 acres are located within the 720-acre Be nicia State Recreati on Area, Solano County. Highway 780 borders the park on the north a nd east, Southampton Bay on the south, and on the west stands the residential developmen t of Vallejo. Cyclists , runners, walkers and roller skaters use the park’s 2.5 miles of road and bike paths, which circle the perimeter of the park. The Marsh lies in the central portion of the par k, and consists mostly of high marsh pickleweed/gumplant habitat, with a d eep main channel and several smaller channels throughout. Cordylanthus mollis ssp . mollis (soft bird’s-beak), an endangered plant species, can be found in some of the high mars h areas of the site. Access to the marsh is restricted to park personnel and researchers to protect the C. m. mollis populations from potential damage caused by trampling. Southampton Marsh contains the only known population of Spartina patens in the San Francisco Estuary. Several large clones are s cattered throughout the southern and western portions of the marsh, and multiple smaller clones are peppered throughout the area. A number of S. patens clones are adjacent to the main channel draining the marsh. There was a total of roughly 0.5 acre of S. patens at this site in 2005, which has reduced by herbicide applications in the area s that are not contiguous with Cordylanthus .. Some of the areas occupied by S. patens are directly adjacent to, or in terspersed with individuals or patches of Cordylanthus. These areas are highly sensitive, and any S. patens eradication effort here will require diligent protection efforts for the C. m. mollis . For 2008, treatment will occur on only a few hundred square feet, mostly composed of S. patens seedlings. The primary treatment method at this site is aquatic herbicide, which will be applied by backpack sprayer. The partner on this site is the California Department of Parks and Recreation.

Site 12 – Southeast San Fran cisco, San Francisco County The Southeast San Francisco complex include s a scattered group of remnant marshlands totaling 56.7 acres within a h eavily industrialized landscape on the western shores of the San Francisco Bay Estuary. The complex is bounded by the Islais Creek Channel and Pier 94 on the north, and the San Francisco Co unty and City boundaries to the south. The Southeast San Francisco complex is adjacent to an inactive naval shipyard, shipping container facilities, and 3Com Park stadium (for merly Candlestick Park), as well as the Bayview residential neighborhood of San Francisco. Within this area there are a number of marshland habitats including intertidal mudflats, native Spartina foliosa stands, riprap shoreline, marshland fill, and pickleweed-dominated tidal marsh plain.

The six sub-areas of the Southeast San Fr ancisco complex contained approximately 8.2 acres of Spartina alterniflora hybrids in 2005. This represents 14.5% of the area of these fragmented remnant marshlands. The rapid hybridization of this population, and conversion of these last pieces of remnant marsh in the area, lends a sense of urgency to the control efforts outlined in this plan. The individual patches of non-native Spartina within this area represent localized ‘stepping stones’ in th e available marsh habitat of the area to the

San Francisco Estuary Invasive Spartina Project 43. 2008 Aquatic Pesticide Application Planopen waters of the North Bay, and the outer coast. Two sub-areas were added to this complex following the discovery of these small infestations. Treatment occurred at mostof these sites in 2006 & 2007, reducing the area to approximately 3 acres needing treatment in 2008. The treatment methods at this site include a combination of manual digging, covering with geotextile fabric, and application of aquatic herbicide by conventional spray truck or backpack. Partners on this site include the California Department of Parks and Recreation, Literacy for Environmenta l Justice (LEJ), Port of San Francisco, Golden Gate Audubon, City of San Francisco Recreation & Parks, and the U. S. Navy. Note that this is a complex site composed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descriptions of the sub-areas and the associated treatment methods.

Site 13 – Whale’s Tail / Old Alam eda Creek Complex, Alameda County

The Whale’s Tail and Old Alameda Creek Co mplex is a 564-acre site on the eastern shores of the San Francisco Bay Estuary, sout h of the San Mateo Bridge and bordered to the east by Union City. This ar ea includes remnant marshland patches that predate alterations to the site for salt production, channeli zed flood control struct ures, restored salt pond marshland, small sinuous channels, high marsh flats, mudflats, eroding scarp, sand/shell beach, small depositional deltas, a nd other habitats. The areas included within this complex are entirely restricted from public access and are either managed by California Department of Fish and Game (C DFG) as wildlife habitat (Sub-Areas 13d, 13e, 13f), or by Alameda County Fl ood Control District for flood control purposes (Sub-Areas 13a, 13b, 13c, 13g). On the northern side of the main channel, formerly diked salt ponds are undergoing restoration activities to convert them to tid ally influenced marshlands. To the south of the main channel, Cargill Cor poration maintains active salt-producing evaporator ponds.

The invasive Spartina at the Whale’s Tail and Old Alameda Creek Complex is one of the oldest infestations of non-na tive cordgrass in the San Fran cisco Estuary. The marshlands of this site contained a total of 82 acres of Spartina alterniflora hybrids representing 14.5% of the area. Applications from 2005 - 2007 were very effective, reducing the area to be treated in 2008 to less than 10 scattered acres, mostly in channels and other low elevation areas. The infestations ar e establishing in a wide variet y of marsh habitats including high marsh pickleweed ( Sarcocornia virginica )/saltgrass ( Distichlis spicata ), lower marsh Spartina foliosa /mudflat areas, channel banks, e dges of salt pans, and bayfront scarps and mudflats. Since the Cargill Mitigation Marsh was a fo rmer salt evaporator pond, it was largely unvegetated with native salt marsh species when tidal action wa s partially restored in 1995. Without any biotic resistance to invasion, the marsh has become infested with large, coalescing clones of invasive Spartina . On the eastern portion of the site, these clones have coalesced into meadows. The Cargill Mitigat ion Marsh sub-area contained approximately 19.0 acres of S. alterniflora hybrids, representing 38.8% of this restoration site in 2005. Treatment over the past three years has reduced the infestation substantially, with only a couple acres near the breach left to tr eat in 2008 because of low efficacy from 2007. The primary treatment method at this site is aquatic herbicide, which will be applied by helicopter, with some follow up with tracked amphibious vehicle if necessary. Partners on this site include the Alameda County Flood Control District, California Department of Fish and Game, and the California Wildlife Fo undation. Note that this is a complex site

San Francisco Estuary Invasive Spartina Project 44. 2008 Aquatic Pesticide Application Plancomposed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descriptions of the sub-areas and th e associated treatment methods. Site 15 – South San Francisco Bay Marshes, Santa Clara County The South Bay Marshes are located at the extr eme southern tip of the San Francisco Bay, with both San Mateo and Alameda Counties bo rdering to the north west and northeast, respectively. The area include s over 100 miles of shoreline, and encompasses some 1,750 acres of marshland. This highly diverse area includes extensive current and former salt ponds, restoration marshes, creek channels and sloughs, bay fill, large intact salt marshes, brackish marsh areas, slough edge marshes, pa ns, islands, mudflats , sand/shell beaches and other marsh habitats. Included within this area are Guadalupe Slough, Coyote Creek,Alviso Slough, Mountain View Slough and San Francisquito Creek. There is a high degree of complexity in the South Bay Marshes that will be enhanced significantly by the work of the South Bay Salt Ponds Restora tion Project, which will convert sizable portions of former salt-making ponds to various types of marsh habitat. The infestation was approximately 8 acres in 2005, but it had expa nded rapidly over the past several years desp ite the effectiveness of imazapyr, largely due to the cryptic hybrids and post-September 1 treatment. The majority of the infestation occurs in the area of Knapp Tract, on Alviso and Guadalupe Sloughs, and along the bayfront adjacent to the DENWR newly acquired ‘salt ponds’ A1 and A2 W. Both Pond A1 and A2W marshes are composed of large expanses of intact native Spartina foliosa (California cordgrass) and pickleweed ( Sarcocornia virginica ), interspersed with gumplant ( Grindelia stricta ) and tule ( Scirpus sp.) Both marshes lie adjacent to comp acted earthen levee roads, which are gated, locked, and require DENWR permission to access. The other sites are patchy and scattered throughout the South Bay extending fr om San Francisquito Creek in the northwest to the Coyote Slough tidel ands in the northeast. The primary treatment method at this site is aquatic herbicide, which will be applied by helicopter broadcast in the case of the newly discovered areas, or by conventiona l spray truck and bac kpack sprayer. Partners on this site include the Santa Clara Valley Water District and the U.S. Fish and Wildlife Service, Don Edwards National Wildlife Refuge. Site 16 – Cooley Landing, San Mateo County Cooley Landing is a 165-acre salt marsh restora tion site located at th e northwestern point of the South San Francisco Bay Estuary, south of the Dumbarton Bridge and adjacent to the point where the Hetch-Hetchy Aqueduct makes landfall on the western shore at Menlo Park. The site is a fo rmer salt production evaporator pond that is undergoing restoration to tidal marsh. Initial restoration activ ities were completed between September and December of 2000, and included the excavation of two breaches through the east levee at locations of historic tidal channels. Re-veget ation of the former salt pond is expected to occur through natural colonizat ion. Performance criteria for the restoration of Cooley Landing requires 70 percent cover of salt marsh vegetation and less than five percent cover of non-native vegetation by the tenth ye ar following restoration. Cooley Landing is part of the Ravenswood Open Space Preserve. Prior to opening Cooley Landing to tidal acti on in 2000, just five adult clones of invasive Spartina covering a total of 0.1 acre were present along the lev ees outboard of the restoration area. However, since S. alterniflora hybrids are known to occur on the adjacent properties north and south of the restoration area, and restored salt ponds lack the biotic

San Francisco Estuary Invasive Spartina Project 45. 2008 Aquatic Pesticide Application Planresistance in the form of an established native plant community, the infestation spread rapidly and already covered 20.0 acres of the rest oration site or 13 % of this large area by 2005. Treatment in 2006 & 2007 over a portion of th e site has reduced the infestation by 50%, but a significant amount of hybrid Spartina will be treated in 2008. The primary treatment method at this site is aquatic he rbicide, which will be applied by helicopter with some follow-up with backpacks, Argos, or conventional spray truck. Partners on this site include S.S. Papadopoulos Associates and the Midpeninsula Regional Open Space District, as well as San Mateo County Mosquito Abatement District.

Site 17 – Alameda Island / San Le andro Bay Complex, Alameda County The area encompassed by this Site-Specific Pl an includes all marshl ands of the Alameda and San Leandro Bay Area extending from th e western tip of Bayfarm Island and San Leandro Channel in the west, to east of In terstate 880 and the Oakland Coliseum in the east. The northern boundary of the site is the Port of Oakl and shipping terminals, and the southern edge is 98th Ave on San Leandro Cr eek. This area supports many diverse habitat types despite the fact that it is directly adjacent to some of the most highly developed land on the west coast. Within this area there are recently restored tidal marshes, freshwater ponds and upland islands, highly complex and diverse historic marsh habitats that include channels, high marsh, mudflats and pans , thin strip marshes along rip-rapped shoreline, public parks and trails, open mudflats, creek channels and mouths, sandy beach areas, marinas, private residences, commercial areas, industrial manuf acturing facilities, shipping, and many other land use types.

The Spartina infestations within this site are di stributed throughout th e habitat types described above. Most notably, Arrowhead Ma rsh, Fan Marsh and the Elsie Roemer Bird Sanctuary support the larg est infestations of Spartina in the Alameda and San Leandro Bay Complex. In sum, the shoreline of this site contained 88.5 acres of non-native Spartina in 2005 targeted for control. This infe station was rapidly expanding into new areas, including the restored ma rshlands of the Martin Luth er King Jr. Wetlands Project. Treatment from 2005 -2007 has reduced this in festation to approximately 35 acres. The primary treatment method at this site complex is aquatic herbicide, which will be applied by conventional spray truck, backpack spraye r, amphibious tracked vehicle, boat, and helicopter. EBRPD will conduct some “chemical mowing” at Arrowhead, using a low, sub-lethal rate of imazapyr applied by helicop ter to stop the plants from setting seed but preserve them as refugia for the large Califor nia clapper rail population at this site. Partners on this site include th e Alameda County Flood Control District, East Bay Regional Parks District, City of Alameda, City of Oakland, Port of Oakland, U.S. Coast Guard, Save the Bay, and Golden Gate Audubon. Note th at this is a comple x site composed of multiple sub-areas. Please refer to the Site Sp ecific Plan for detailed descriptions of the sub-areas and the associated treatment methods. Site 18 – Colma Creek / San Bruno Marsh Complex, San Mateo County The area encompassed within this Site-Specific plan includes all of the marshlands north of the San Francisco International Airport, up to the northern tip of the outlet of San Bruno Canal or Colma Creek. Within this ar ea there are broad marshlands fringing the industrial fill of South San Francisco, cha nnel bank marshland hab itat, open mudflats, pickleweed and gumplant marshes, upland ma rsh edges, brackish creek channels and other tidal marsh systems. Much of this areais highly developed with light industrial, commercial, and business facili ties, and a portion of the Bay Trail runs through the northSan Francisco Estuary Invasive Spartina Project 46. 2008 Aquatic Pesticide Application Planern portion of the site. For the purposes of th is plan, there were an estimated 100.3 acres of marshland within this site in 2005.

The Spartina infestations within this site are di stributed throughout th e habitat types described above. In sum, the marshes of this site contain 60.0 acres of non-native Spartina targeted for control, repres enting 60% of the surrounding marsh. This infestation has rapidly expanded onto the open mudflats on the we stern portion of this site, as well as constricting the channels on the norther n and southern portions. Non-native Spartina has dominated most of the available marshland ha bitat, with only scattered populations of native tidal marsh plant species remaining in the area. Because of the unusually large and high density population of clappe r rail in this site complex, treatment has been phased over several years, with only the upper cha nnels receiving applica tions in 2006. The entire site was treated in 2007, with approximately 60% just “chemically mowed” with a low, sub-lethal concentration of imazapyr to stop seed production while maintaining the above-ground biomass for rail ref ugia. In 2008, all remaining hybrid Spartina will be treated with the full concentr ation of imazapyr, which will be applied by conventional spray truck, backpack sprayer, amphibious tr acked vehicle, and helicopter. Partners on this site include the San Mateo County Mo squito Abatement District, San Mateo Flood Control District, City of South San Francisc o, and the San Mateo County Transit District (Sam Trans). Note that this is a complex site composed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descri ptions of the sub-areas and the associated treatment methods. Site 19 – West San Francisco Bay, San Mateo County The area encompassed by this Site Specific Pl an includes all marshlands of San Mateo County extending south from the San Francisco/ San Mateo County line in the north to the San Mateo-Hayward Bridge in the South. A se parate Site-Specific Plan for the Colma Creek/San Bruno Marsh Complex (TSN:ISP-2005-18) has been developed to specifically address the Spartina treatment approaches for that area, and is therefore not included in this plan. Many of the Sub-Areas for this site are small marshes or mudflat areas bordered by light or heavy industrial development, ri prap shoreline, Highway 101, the San Francisco International Airport, or other intensive uses. Seve ral are partially restored marshes. Few of these Sub-Areas support diverse, int act native marsh conditions, and non-native Spartina has come to dominate each one.

The infestations of non-native Spartina that constitute the West San Francisco Bay Complex are scattered along the shoreline in many types of habitats. Spartina can be found along the rip-rap of shoreline development, in remnant or newly formed pickleweed marsh, along channels emptying into the ba y, amongst sand/shell b eaches, within large established marsh, in wide lagoons, on shallo w mudflats, and in small coves and sheltered crannies all along the Bay edge. In all Sub-Areas, non-native Spartina was rapidly expanding into the existing available habitat. Out of an estimated 350 acres of marsh habitat covered by this Site-S pecific Plan, there were 85 net acres (24%) of non-native Spartina requiring control in 2005. Three years of successful treatment by SMCMAD has reduced this site complex to less than 10 wide ly scattered acres to be treated in 2008. The primary treatment method at this site is a quatic herbicide, which will be applied by conventional spray truck, backpack sprayer, am phibious tracked vehicl e, boat, and helicopter. Partners on this site in clude the San Mateo County Mosq uito Abatement District, San Francisco International Airport, Oyster Point Marina, City of Brisbane, City of BurlinSan Francisco Estuary Invasive Spartina Project 47. 2008 Aquatic Pesticide Application Plangame, City of San Mateo, County of San Mate o, City of Foster City, California State Lands Commission, City of South San Franci sco, U.S. Coast Guard Reservation, and a number of individual commercia l property owners. Note that this is a complex site composed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descriptions of the sub-areas and the a ssociated treatment methods. Site 20 – San Leandro / Hayward Shoreline Complex, Alameda County The area encompassed by this Site-Specific Plan includes the marshlands of the San Leandro and Hayward shoreline, Alameda County, extending sout h from the Metropolitan Golf Course and Oakland Internationa l Airport in the north to the San MateoHayward Bridge in the south. A separate Site-Specific Plan for Oro Loma Marsh (TSN:ISP-2004-07) has been develope d to specifically address the Spartina treatment approaches for that area, and is therefore not included in this Plan. The marshland areas in this site complex range from large, co mplex restored marsh systems to channel-bank fringe marsh areas. They line the east shor e of the Bay, providing a natural border between the highly urbanized and developed ar eas of the cities of San Leandro, San Lorenzo, and Hayward and the open waters of the Bay. Much of this area is regularly used for passive recreational activities along portions of the Bay trail, within EBRPD lands, and other trails throughout the area.

The infestations of non-native Spartina that constitute the San Leandro and Hayward Shoreline Complex are located along the shor eline in many types of habitats. Invasive Spartina can be found along the rip-rap of shorelin e fill and levees, in remnant or newly formed pickleweed marsh, along channels emptying into the bay, amongst sand/shell beaches, within large established marsh restor ation sites, on shallow Bay-edge mudflats, and in small coves and sheltered marsh areas along the Bay edge. In all sub-areas, nonnative Spartina was rapidly expanding into the existi ng available habitat. Out of an estimated 580 acres of marsh habitat covered by th e Site-Specific Plan, there were an estimated 204 net acres of non-native Spartina requiring control in 2005, representing 35.2% of the area. Treatment from 2005 -2007 has re duced this infestati on by 70-80%, leaving approximately 45 acres to treat in 2008. Ei ght new sub-areas were added for the 2008- 2010 Site-Specific Plans comprised of small newly-discovered infestations within the geographic boundaries of the overa ll site. The primary treatment method at this site isaquatic herbicide, which will be applied by helicopter, conventional spray truck, backpack sprayer, and amphibious tracked vehicle. Partners on this site include the Alameda County Flood Control District, Ea st Bay Regional Parks Distri ct, City of San Leandro, City of Oakland, and the Oro Loma Sanitary Di strict. Note that this is a complex sitecomposed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descriptions of the sub-areas and th e associated treatment methods. Site 21 – Ideal Marsh, Alameda County

Ideal Marsh is a 178.8-acre wetland restoration site located on the eastern shore of the San Francisco Bay Estuary that was allowed to naturally restore to unrestricted daily tidal exchange. The site is bordered to the nor th by the mouth of the Alameda Flood Control Channel (TSN:ISP-2004-1); the shoreline marshe s of this site run for approximately 2.5 miles south of the channel to a point about a mile north of the Dumbarton Bridge where a levee cuts back to the shoreline. Levees along th e eastern edge of this site separate it from current salt evaporator ponds, with the Coyot e Hills, and the Regiona l Park of the same name, located just over one mile to the east.

San Francisco Estuary Invasive Spartina Project 48. 2008 Aquatic Pesticide Application PlanThe two Sub-Areas of Ideal Marsh (North and South) were being ra pidly colonized with an expanding infestation of Spartina alterniflora hybrids, with a total of 98 acres of invasive Spartina or 54% of the marshlands at Ideal Ma rsh in 2006. These plants occupied all habitat types present in these marshes, in cluding open mudflats, sand/shell beaches, eroding marsh edge, pickleweed plain, levee edge and other areas. Helic opter treatment from 2005 -2007 reduced the infestation by 95% or more. The area to be treated in 2008 contains patches and individual hybrid S. alterniflora plants scattered across the marsh plain and in a few of the channels. The primary treat ment method at this site is aquatic herbicide, which will be applied by backpack or truck. The partner on this site is the U.S. Fish and Wildlife Service, Don Edwards National Wildlife Refuge. Site 22 – Two Points Complex, Alameda County The Two Points Complex is lo cated on the east side of northSan Francisco Bay and southeast San Pablo Bay in Contra Costa County, al ong the shoreline of the City of Richmond, and includes areas both north and south of the Point Richmond peni nsula and the Richmond-San Rafael Bridge. The shoreline adjacent to these sites is heavily developed with land use including commercial, industrial, reside ntial, and park or marina areas. The Bay Trail provides recreational access along the upl and edge of the southern marshes in the complex, but only provides distant viewing of th e north marshes because the trail is located further inland at this point. The marshes of th is area are wide fringing marshes with mixed pickleweed/Spartina vegetation assemblages. These marshes contain large and small channels, mudflats, wide mid-marsh plains and other areas. The infestations at the Two Points Complex are still in the early stages of establishment, with approximately 5 acres scat tered over the 598 acres of the five sub-areas, or less than 1% of the total marsh area. Th e establishing clonal patches w ithin this area are located mostly along the bay front amongst native Spartina stands or along the banks of small channels within the marshes, and are begi nning to coalesce. The channels and marsh plain of San Pablo Marsh was being rapidly invaded until treatment began in 2005 on the western portion and 2007 for the eastern. The easternmost portion of San Pablo Marsh will be treated for the first time in 2008 because the plants senesced early in both 2006 & 2007. The primary treatment method at this site is aquatic herbicide, applied by airboat, backpack sprayers, and conventi onal spray truck. Partners on this site include the State of California Lands Commission, Republic Serv ices, Chevron/Texaco, Richmond Rod and Gun Club Inc., and East Bay Re gional Parks District. Note that this is a complex sitecomposed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descriptions of the sub-areas and th e associated treatment methods. Site 23 – Marin Outliers, Marin County The area encompassed by this Site Specific Pl an includes selected marshlands of Marin County extending south from the Point San Pedro in the north to Saus alito in the South. Separate Site-Specific Plans for the Cort e Madera Creek Complex (TSN:ISP-2005-04), Blackie’s Pasture (TSN: I SP-2004-03) and Pickleweed Park (TSN:ISP-2004-09) have been developed to spec ifically address the Spartina treatment approaches for each of those areas. Many of the Sub Areas are small marshes or mudflat ar eas bordered by light or heavy industrial development, rip-rap shore line, or other uses. Se veral are partially restored marshes. In sum, these areas represen t an important patchwork of small marsh areas within Marin County.

San Francisco Estuary Invasive Spartina Project 49. 2008 Aquatic Pesticide Application PlanThe infestations of non-native Spartina that constitute the Marin Outliers complex are scattered along the shoreline in many types of habitats. Spartina can be found along the rip-rap of shoreline development, in remn ant or newly formed pickleweed marsh, along channels emptying into the ba y, within large established ma rsh, on shallow mudflats, and in small coves and sheltered crannies along the Bay edge. In all Sub-Areas, non-native Spartina was in the initial stages of expansion into the existing habitat. Out of an estimated 130 acres of marsh habitat covered by th is Site-Specific Plan, there were 2.6 net acres of non-native Spartina requiring control in 2005, re presenting 2% of the marsh area. Most of these sites are down to only se veral hundred square feet or less after effective treatments from 2005 -2007. The primary tr eatment method at a number of sites in this complex is manual removal after the reduc tions of the past seve ral control seasons. Other sites will still depend on aquatic herbic ide treatment, which will be applied by backpack sprayer & conventiona l spray truck. Partners on this site include Marin Audubon, County of Marin, CDFG, Loch Lomond Marina, Strawberry Recreation District, City of San Rafael, City of Mill Valley, City of Novato, California State Lands Commission, McNear Brick and Block, Pa radise Cay Yacht Club, City of Sausalito, and a number of smaller residential and commercial landowners . Note that this is a complex site composed of multiple sub-areas. Please refer to the Site Specific Plan for detailed descriptions of the sub-areas and the a ssociated treatment methods. Site 24 – Petaluma River, Sonoma County This area includes approximately 4,500 acres of marshland and riparian habitat within the Petaluma River Watershed stretching from the City of Petaluma, at the confluence of the Petaluma River and Lynch Creek in the north to San Pablo Bay in the south. This site consists of a complex mosaic of historic tid al marsh habitat, developed shoreline, brackish tidal riparian edge zones, maintained past ureland, restoration site s, light industrial facilities and urban development. The pioneering infestation of Spartina alterniflora hybrids in the Petaluma River complex was discovered in November 2006, and is still very limited in its distribution. The majority of the infestation is located along th e banks of the river adjacent to a dredging and barge dock facility just downstream of the Highway 101 crossing south of Petaluma, with scattered infestations located upstream and downstream this central core. In sum, these infestations cover approximately 0.2 acres scattered over this very large marshland complex, which is equal to less than 0.01% of th e area. The first treatment at this site occurred in 2007 and reduced th is pioneering infestation si gnificantly. The primary treatment method at this site is aquatic herbic ide, which will be applied by boat, backpack and/or conventional spray truck. The primary I SP partner on this site is the Friends of Petaluma River, a group that has existing rela tionships with the community of the watershed and the landowners along the river. Site 26 – North San Pablo Bay, Solano County There are two main portions of this sub area: the restoration site on the east side of the Napa River called White Slough, in Vallejo, and the marshes along the shorelines of the Northeastern San Pablo Bay. White Slough marsh is a roughly 135-acre restor ed tidal marsh that lies to the east of Highway 37 and west of Sonoma Boulevard in the City of Vallejo. The marsh is a sparsely vegetated tidal marsh in the initial stages of colonization. The majority of the

San Francisco Estuary Invasive Spartina Project 50. 2008 Aquatic Pesticide Application Planarea is open mudflat with tidally inundated lo w sections. The periphery of the marsh is composed of scattered pickleweed ( Sarcocornia pacifica ), non-native Spartina , and alkali bulrush ( Bolboschoenus maritimus ).

The other marsh areas included in this sub-ar ea is the massive mudflat and shoreline area of San Pablo Bay NWR west of Mare Island. This large area of restored and historic tidal marsh, developed shoreline, industrial and military facilities is only lightly infested with non-native Spartina, including both S. densiflora and hybrid S. alterniflora

. The infestation at White Slough east of Hwy. 37 is in the very early stages of colonization, and is located along the western, norther n and eastern edges ofthe marsh in scattered small patches. The clona l individuals have not coales ced to any real extent, and there is very little marsh vegetation in some portions of this marsh. Aquatic herbicide will be applied by backpack sprayer.

9. WATER QUALITY MO NITORING PLAN ObjectiveConduct water quality monitoring sufficient to achieve compliance with NPDES Statewide General Permit requirements. Monitoring Site Selection Approximately 150 sites (sub-areas) of invasive Spartina throughout the San Francisco Bay region are slated for treatment with a quatic herbicide during the 2008 control season. According to current NPDES permit requirement s, ten percent (10%), or 15 of the 150 sites, must be monitored for water quality. Thes e sites are to be select ed at representative locations, and are to include a ll of the herbicides being appl ied. To assist with sampling site selection, the ISP identified four different treatment site types, as follows:
I. Tidal Marsh, Microtidal Marsh, Form er Diked Bayland, Backbarrier Marsh
II. Fringing Tidal Marsh, Mudflats, and Estuarine Beaches
III. Major Tidal Slough, Creek or Flood Control Channel
IV. Urbanized Rock, Rip-Rap, Docks, Ramps, etc. The ISP has selected representative sites of each of these marsh site types to be sampled for water quality. Since Type IV infestation s ites are usually very sm all, sparse, and adjacent to large bodies of water wi th constant flushing that will serve to quickly dilute any herbicide incidentally entering the water colu mn; fewer sites within this type will bemonitored for 2008. Site Types I and II are considered to be the sites most likely to develop detectible levels of he rbicide in the water column, a lthough the results of ISP’s 2006 WQMP revealed that the highest one-week post- treatment samples actu ally came from two Type III sites. For 2008, the final sampling plan list includes six Type I sites, five Type II sites, three Type III sites, and one Type IV s ite chosen to represent the range of herbicidedelivery systems and marsh dynamics present in our work program. Imazapyr is the primary herbicide with glyphosate applied to ju st one of the 150 sub-areas; consequently just one glyphosate site will be monitored fo r water quality as a representative. Table 5 provides a summary of the sites.

San Francisco Estuary Invasive Spartina Project 51. 2008 Aquatic Pesticide Application PlanTable 5. Summary of Water Quality Monitoring Sites for the 2008 Season

Sites Site Number Marsh Type Treatment Date Application

Upper Corte Madera Creek 4h III 7/8/08 Imazapyr – Backpack, Truck

Loch Lomond Marina 23c IV 7/17/08 Imazapyr – Backpack
Imazapyr – Backpack, Truck 23b Beach Drive 7/17/08 II

7/18/08 Imazapyr – Backpack; Manual for seedlings 3b Blackie’s Pasture III

22b I 7/21/08 Imazapyr – Backpack, Airboat, Truck San Pablo Marsh

Creekside Park 4g I 7/31/08 Imazapyr – Backpack

Alameda Flood Control Channel Mouth 1a III 7/31/08 Imazapyr – Helicopter

Cargill Mitigation Marsh 13c I 7/31/08 Imazapyr – Helicopter

Inner Harbor 18d II 8/18/08 Imazapyr – Helicopter

Sam Trans Peninsula 18e II 8/18/08 Imazapyr – Helicopter

Elsie Roemer Bird Sanctuary 17a II 8/18/08 Imazapyr – MarshMog, Backpack

Fan Marsh 17j I 8/21/08 Imazapyr – Truck

Stevens Creek Tidal Marsh 15c I 9/2/08 Imazapyr – Truck

Southampton Marsh 11 I 9/3/08 Glyphosate – Backpack

Giant Marsh 10c II 9/4/08 Imazapyr - Backpack

Monitoring Site Descriptions Following are brief descriptions for each of th e monitoring sites. Additional site information was included previously in Section 8 of this plan.

Alameda Flood Control Channel. The Alameda County Flood Control Channel (ACFCC) is a large, unlined trapezoidal channel that runs from east to west through Hayward, Alameda County, draining a nearly 880 square mile watershed into the San Francisco Bay. The levees on both sides of the ACFCC are topped with multi-use public park trails that are part of the San Fran cisco Bay Trail and Coyot e Hills Regional Park. The flood control channel will be sampled rightupstream of its mouth to the San Francisco Bay, a Type I site. Efficacy from 2006 & 2007 imazapyr applications was high, and the site will be retreate d where necessary in 2008. Cargill Mitigation Marsh. This sub-area, a Type I site, is a 49-acre formersolar salt production evaporator pond that was restored by opening the site to muted tidal action in 1995, and full tidal action in 1998. It is bounded on the north by the levees of the Old Alameda Creek Channel, on the west by the S outhern Whale’s Tail Marsh Site, and to the east and south by inactive salt ponds. The enti rety of the site is surrounded by levees,

San Francisco Estuary Invasive Spartina Project 52. 2008 Aquatic Pesticide Application Planwith two breach points on the western levee that drain the site into the Whale’s Tail South Fluke. Efficacy from 2006 & 2007 imazapyr applications was high, and the site will be retreated where necessary in 2008. Corte Madera Creek Complex. Two sites in the Corte Madera Creek Complex will be monitored, the banks of Upper Corte Madera Creek and Creekside Park. Upper Corte Madera Creek . This Type III site repres ents the upper reach from the College of Marin downstream to the Bon Air Road bridge, and includes the short section of an unnamed tributary that drains marshes near Lot 13 (College of Marin parking). Much of this stretch ha s narrow strips of marsh vegetation below the rip-rap, mostly pickleweed and S. foliosa , and a mudflat component. Much of the upper reach has an open space character, with Creekside Park and the College of Marin Ecology Study Area along the north bank, a small marsh to the south downstream of the confluence with the Lo t 13 drainage, and the backyards of the houses on the south bank set back from th e creek on the other side of the Marin County Flood Control District’s gravel maintenance road above the rip-rap. Efficacy from 2006 & 2007 imazapyr applications controlled the infestation but has not succeeded in full mortality on many of the plants. Any green, healthy S. densiflora will be retreated with imazapyr in 2008, while plants not healthy enough to translocate the herbicide will be removed manually.

Creekside Park

. This Type I site is estimated to contain 20.6 acres of marshland habitat adjacent to the upper portion of Corte Madera Creek just upstream of Bon Air Road. The park was restored to marshland habitat in 1976, when a new channel system was excavated, upland areas were graded to intertidal elevations, and central islands were constructed from the ch annel dredge spoils as upland refugia. As part of this initial restoration effort, both Spartina densiflora and Spartina anglica were planted, as native marsh plants failed to establish within the first year of restoration. These plants were impor ted from Humboldt Bay and England respectively. Efficacy from 2006 & 2007 imazapyrapplications controlled the infestation but has not succeeded in full mortality on many of the plants. Any green, healthy S. densiflora will be retreated with imazapyr in 2008, while plants not healthy enough to translocate the herbicide will be removed manually. Colma Creek Complex. Two sites in the Colma Creek Complex will be monitored, the shoreline of Sam Trans Peninsula an d the entirety of Inner Harbor.

Sam Trans Peninsula. The Sam Trans Peninsula is a reclaimed peninsula constructed of fill to the north of the San Fr ancisco International Airport. This site contains the fringing marsh areas on the eas t side of the peninsula proper, from the North Access Road north, to just west of the tip of the peninsula. Within this area there is an estimated 14.1 acres of marshland habitat with an estimated 8 acres of non-native Spartina prior to treatment. The Spartina is growing on previously open mudflats in mostly uniform monocultural stands, and advancing eastward into the Bay. This Type II site wa s treated for the first time in 2007, with some areas receiving a sub-lethal dose as a chemical mow. In 2008 the entire subarea will be treated with the full concentr ation of imazapyr used by ISP partners.

Inner Harbor. The invasive Spartina has caused this marsh to establish through the accretion of sediment on the open mudflats west of the Sam Trans Peninsula.

San Francisco Estuary Invasive Spartina Project 53. 2008 Aquatic Pesticide Application PlanSan Bruno Creek feeds this area of the co mplex from its mouth in the southwest corner of Inner Harbor. This sub-area encompasses some 14.6 total acres of marshland, mudflat, and channel. The Spartina here consists of a coalesced meadow in the south and expanding indi vidual pioneer clones scattered through the northern area. In sum, the infestation at this site is estimated at 8.5 acres. This Type II site was treated for the first time in 2007, with some areas receiving a sub-lethal dose as a chemical mow. In 2008 the entire sub- area will be treated with the full concentration of imazapyr used by ISP partners. Alameda-San Leandro Bay

. Two sites in the Alameda-San Leandro Bay complex will be monitored, Elsie Roemer Bird Sanctuary and Fan Marsh. Elsie Roemer Bird Sanctuary. This Type II site incl udes an area along a stretch of southern Alameda Island, which runs fr om the jetty off Shoreline Dr. in the west to the Bayfarm Island Bridge in th e east. Within the estimated 17.3 acres of marsh at this site, there were approximately 7 acres of non-native Spartina alterniflora hybrids, including several large cl ones coalescing on the open mudflats south of the main infestation. Efficacy from the 2007 imazapyr application was much more significant than in 2005 or 2006, and the site will be retreated where necessary in 2008.

Fan Marsh. Fan Marsh is a roughly 11-acre marsh located along on the interior of Doolittle Drive at Earhart Road in Alameda. The property is owned by the Port of Oakland and consists of high marsh pickleweed/ Spartina interspersed with several small channels draining to the Bay to the east of Doolittle Pond. The Spartina infestation within Fan Marsh is fair ly uniform over the entirety of the marsh area. Prior to treatment, roughly 5 acres of Spartina were spread over 11 acres of channels and high marsh plain at th is site. This Type I site was treated for the first time in 2007, with very high effi cacy at the mid-marsh elevation but poor results in the channels at low elevation. The site will be retreated where necessary in 2008.

Marin Outliers

. Two sites in the Marin Outliers complex will be monitored, Loch Lomond Marina and Beach Drive.

Loch Lomond Marina. The Loch Lomond Marina is a Type IV site located off Point San Pedro Road in San Rafael, with Beach Drive immediately to the east. This site consists of a narrow fringe of marsh vegetation along the shoreline of a cove to the west of the marina, and the rip-rap along the inside of the protective marina levee on the western, southern and eastern edges. The site is lightly infested in scattered patches around the inne r marina levees, with a few areas persisting in the small cove to the west. The site will be retreated where necessary in 2008.

Beach Drive. This sub-area actually consists of two very different marsh systems on either side of Beach Drive, which is a small residential str eet to the south of Point San Pedro Road in eastern San Raf ael. To the west is a narrow, 100 m-wide cove which extends about 450 m to the northwest behind a row of residential properties on Beach Drive and Point San Pedro Road. This cove, a Type II site, has a significant and ex panding presence of native Spartina foliosa with the associated increase in the accretion of sediment in recent years. Across the road to the

San Francisco Estuary Invasive Spartina Project 54. 2008 Aquatic Pesticide Application Planeast is a 3-acre muted tidal ma rsh composed of pickleweed ( Sarcocornia pacifica ), gumplant ( Grindelia stricta ) and native Spartina in some of the small channels. Efficacy has been excellent in the muted marsh, but much more challenging in the mudflats of the cove even after several applications. The site will be retreated where necessary in 2008.

Blackie’s Pasture. Blackie’s Pasture is a small City of Tiburon park co-managed by the City of Tiburon and Tiburon Audubon. The pa rk is located along the shoreline of Richardson Bay, adjacent to Ti buron Boulevard. The park is heavily used by the public for passive recreation, and is comprised of a 0.7-acre pasture, a small creek channel (“Blackie’s Creek”) along the eastern edge ofthe pasture, and a shoreline area that includes the channel mouth, open mudflat (fed by sediment delivered by the creek), landscaped pathways and picnic areas, and rip-rap fill to the east along the Tiburon Peninsula. The Blackie’s Creek channel, a Type III site, was heavily infested with hybrid S. alterniflora , as was the small marsh component at the mouth. The mouth area downstream of the footbridge was also heavily infested with S. densiflora . After several years of manual and chemical control work, the infestation in the creek contains just minimal patches, and the marsh at the mouth has few mature plants remaining. Much of the treatment in 2008 will involve manual removal of seedlings of S. densiflora , and retreatment of hybrid S. alterniflora from backpack sprayers.

San Pablo Marsh. This Type I site is a 165-acre ma rsh at the mouth of San Pablo Creek on the City of Richmond shoreline in sout heastern San Pablo Bay. San Pablo Marsh is predominantly pickleweed with S. foliosa on the bayfront and in the channels. The marsh stretches east to an 11-acre pickleweed, S. foliosa and alkali bulrush ( Bolboschoenus maritimus ) cove bordered by levees on either si de, located behind the Richmond Rod and Gun Club rifle range. The western portion of this site has been tr eated since 2005, but the larger infestation in the eastern marsh and out onto the mudflats ha s evaded treatment due to early senescence. These e xpanding mudflat clones, as well as the infestation encroaching up the channels, will be treated by air boat and backpack in 2008, along with any necessary retreatment in the western areas. Southampton Marsh . Southampton Marsh is the largest extant marsh within the Carquinez Strait. Its roughly 175 acr es are located within the 720 -acre Benicia State Recreation Area, Solano County. The marsh lies in the central portion of the park, and consists mostly of high marsh pickleweed/gumplant hab itat, with a deep main channel and several smaller channels throughout. Cordylanthus mollis ssp . mollis (soft bird’s-b eak), an endangered plant species, can be found in some of the high marsh areas of the site. Access to the marsh is restricted to park personnel and research ers to protect the C. m. mollis populations from potential damage caused by trampling. Southampton Marsh contains the only known population of Spartina patens in the San Francisco Estuary. Several large clones were scattered throughout the southern and western portions of the marsh, and multiple smaller clones are peppere d throughout the area. A number of S. patens clones are adjacent to the main channel draining the marsh. This is a Type I site and will be the only site treated with glyphosate in 2008.

Stevens Creek Tidal Marsh. The City of Mountain View’s Shoreline Regional Wildlife and Recreation Area includes several tidal slough s, Bay-front tidal marsh habitat and restored tidal marsh areas. Two of the main ma rshes within this area are the Charleston Slough marsh and the Stevens Creek Marsh, bot h of which have infestations of nonSan Francisco Estuary Invasive Spartina Project 55. 2008 Aquatic Pesticide Application Plannative Spartina . Stevens Creek Marsh, a smaller marsh at roughly 30 acres, is also a restored formerly diked salt pond, but Stevens Creek is highly vegetated. The marsh is located on the eastern end of th e Recreation Area, at the Bayward end of the Stevens Creek Trail. The marsh has well-established populati ons of native tidal marsh plant species including broad meadows of native Spartina foliosa . Within this native matrix however, a sizeable population of non-native Spartina hybrids has been expandi ng over the last 3-5 years. This Type I site was treated for the first time in 2007, and retr eatment will be necessary on a portion of the marsh in 2008.

Giant Marsh. Giant Marsh is a 30-acre pickleweed marsh in the far southwestern corner of Point Pinole Regional Shoreline on San Pabl o Bay. This is a newly added sub-area that has not yet been treated. The in festation at Giant Marsh is co mposed of scattered clones of hybrid Spartina alterniflora along the bayfront edge of the marsh and out onto the mudflats. This infestation is in the very early stages of establishment, with less than 500 ft 2 of hybrid Spartina that has been identified. The inva sive cordgrass has not yet colonized the interior of the marsh or established along the channels. This Type II site will be treated with imazapyr by b ackpack sprayer in 2008. Sampling Frequency and Sampling Design The sampling events are designed to characte rize the potential risk involved with imazapyr and glyphosate applications relative to adjacent surface waters. Consistent with permit requirements, the monitoring program will include background/pre-treatment sampling up to 24 hours prior to the applica tion, application event monitoring immediately post-treatment, and one-week post-application event monitoring. During background sample collection, the point will be recorded using GPS and marked with a flagged PVC pipe to aid ISP staff in locati ng the point for future sampling events. The application event samples will be collected immediately adjacent to the treatment area after sufficient time has elapsed such that tr eated water will have entered the adjacent area. Since it is standard protoc ol for the ISP partners to treat Spartina on a low or receding tide when possible, application event samples will often be taken 2-5 hours posttreatment when the tide has again flooded th e site. Finally, the one-week post-treatment monitoring will be conducted when sufficient wa ter is present at the site on the seventh day after the application. The CDFG Wate r Pollution Control Laboratory recommendsthe submission of one duplicate for every 20 samples collected, so the ISP will be submitting three duplicates for the 45 total base sa mples taken to enhance quality assurance. These will be added to either the treatment event or one-week post-treatment event since the herbicide levels in the pre-treatment samples are usually 0. It is standard for the lab to include blanks itself as part of their quality control, so the ISP will only occasionally send additional blanks. Sampling Procedures

The Spartina Project will be conducting its own water quality monitoring program for 2008 following the procedures developed for the State Water Resources Control Board Aquatic Pesticide Monitoring Program (APMP) by the San Francisco Estuary Institute (SFEI). These procedures are outlined in the APMP Quality Assurance Program Plan (2004), available at www.sfei.org . Water samples will be colle cted using a sampling rod and pre-cleaned amber glass 1-liter bottles. Te mperature, electrical conductivity, salinity, and dissolved oxygen will be measured in the field with a portable YSI Model 85 (Yellow Springs Instruments Inc., Ohio , USA), while pH will be meas ured with an Oakton waterSan Francisco Estuary Invasive Spartina Project 56. 2008 Aquatic Pesticide Application Planproof pHTestr1 (Oakton Instrume nts, Illinois, USA). Turbidity will be measured by the lab from the water samples submitte d by ISP, as allowed for in the NPDES Statewide General Permit. Sample Analysis Following collection, water samples will be stor ed on ice packs and shipped for priority overnight delivery to the California Depart ment of Fish and Game’s Water Pollution Control Laboratory in Rancho Cordova, CA. The samples will be analyzed within the appropriate holding times for imazapyr or glypho sate concentrations. The analytical lab will adhere to all QA requirements outlined in the APMP QA plan. Data Analysis

The results of the conventiona l water quality parameters (turbidity, water temperature, dissolved oxygen, pH, conductivity, and salinity) will be tested for normality and then analyzed with paired t-tests to determine if the values of the parameters change significantly over the three sampling events at each site. This test is used for matched pairs when two responses form a pair of measurements coming from the same experimental subject, such as measurement of dissolved oxygen before and after herbicide treatment in the adjacent marsh. The t-test will be run th ree times on each parameter, first comparingthe pre-treatment value to the treatment value, then the pre-treatment to the posttreatment, and finally the treatment to post-treatment. Results will be submitted to theSan Francisco Bay Regional Water Quality Control Board and placed on the ISP’s website for public viewing.

10. APPLICABLE WATER QUALITY BMPS The following mitigations were identified in the Spartina Control Program’s Programmatic Environmental Impact Report/Statemen t (PEIR/S). These mitigations will be implemented at all herbicide treatment sites a nd verified by the Field Operations Staff. IMPACT WQ-1: Degradation of Water Quality Due to Herbicide Application MITIGATION WQ-1: Herbicides shall be applied directly to plants and at low or receding tide to minimize the potential application of herbicide directly on the water surface, as well as to ensure proper dry times before tidal inundation. Herbicides shall be applied by a certified applicator and in accordance with applica tion guidelines and the manufacturer label. The Control Program shall obtain coverage under the State NPDES Permit for the Use ofAquatic Herbicides and any necessary local permits. A monitoring program shall be implemented as part of the NPDES permit, and shall include appropria te toxicological studies to determine toxicity levels of the he rbicide solutions being used. The Control Program shall use adaptive management strategies to refine herbicide application methods to increase control effectiveness and reduce impacts. IMPACT WQ-2: Herbicide Spills MITIGATION WQ-2: Herbicides shall be applied by or under the direct supervision of trained, certified or licensed applicators. Storage of herbicid es and adjuvants/surfactantson-site shall be allowed only in accordance with an approved spill prevention and containment plan; on-site mixing and filling opera tions shall be confined to areas appropriSan Francisco Estuary Invasive Spartina Project 57. 2008 Aquatic Pesticide Application Planately bermed or otherwise protected to minimi ze spread or dispersion of spilled herbicide or surfactants into surface waters. When containers of herbicide larger than th e standard 2.5 gallon are used (such as the 15 gallon containers that are used by the helicopter contractors for aerial application), these containers must remain in the staging area(s ) on a levee or other appropriate upland site. These larger containers will not be allowed into the marsh, and a spill response plan must be in place in the event of an accidental disc harge, to ensure that herbicide does not reach the marsh or surface waters. IMPACT WQ-3: Fuel or Petroleum Spills MITIGATION WQ-3: Fueling operations or storage of petroleum products shall be maintained off-site, and a spill prevention a nd management plan shall be developed and implemented to contain and clean up spills. Transport vessels and vehicles, and other equipment (e.g., mowers, pumps, etc.) shall not be serviced or fueled in the field except under emergency conditions; hand-held gas-power ed equipment shall be fueled in the field using precautions to minimize or avoid fu el spills within the marsh. Other, specific best management practices shall be specifiedas appropriate in project-specific Waste Discharge Requirements. In addition to these water quality mitigation measures, each partner agency and its contractors are required to have an acceptable Site Safety and Materials Handling Plan (Appendix 3). Applicator Calibration Training During the first year of operation, ISP rec ognized that, even when partners exercised great care during herbicide application, there wa s still considerable variability in application rates. Because the rate of herbicide applic ation is critical for protecting water quality and staying within the proj ect budget, the ISP began provi ding annual “Applicator Calibration Training” for contra ctors and agency personnel in 2006. The training, which is authorized by California Department of Pe sticide Regulation Continuing Education, provides partners with a hands-on opportunity to practice and fine tune application techniques. At each training, ISP staff discusse s the importance of corr ect application, and a representative of the herbic ide manufacturer, BASF, presen ts the manufacturer’s recommendations of how to apply imazapyr (Habit at®) properly. The presentations are followed by field exercises where partners comp ete to be the most accurate applicator. A major motivation for these annual trainings came from a study in Cornish and Burgin (2005) showing that applicators applying herbic ide to a given plot size could vary by as much as ten times in the amount of product used and the time it took to spray the plot. In their first experiment, applicat ors treated a 20 X 0.5m strip (10m 2 ). Application times ranged from 24.3 to 112.7 seconds, equivalent to 2.7 – 12.6 hours for them to complete one acre. They used the equivalent of 34.2 – 160 gallons/acre of tank mix, or 0.34 – 1.6 gallons of product per acre. For our expe nsive imazapyr herbicide (about $275 per gallon) the range would be $92 – $432 per acre, and more than twice the maximum label rate of 0.75 gallons per acre. Their second experiment showed even more alarming results. Using a smaller 1m 2 test area for the applications, trea tment times ranged from 4.5 – 45 seconds, the equivalent of spending 5 – 50.6 hours on each acre. They used the equivalent of 21.4 – 684 galSan Francisco Estuary Invasive Spartina Project 58. 2008 Aquatic Pesticide Application Planlons/acre of tank mix, or 0.21 – 6.84 gallons of product per acre. If this were imazapyr, the cost range would be $57 - $1847 per acre for the herbicide alone (up to nine times the max label rate), and labor co sts would be extremely high fo r those on the upper end of the time spectrum. In addition to off-label applications, lack of FIFRA compliance, and higher costs, there are other problems with this variation between applicators. As the BASF representative noted, over-applications can actually reduce efficacy by washing the product off the plants, which emphasizes the importance of ge tting the application rates right. This may be especially true when usi ng surfactants made from oils. The hands-on portion of the ISP fi eld training is an attempt to directly address some of these obvious problems, achieve some cons istency across the many applicators working around the Estuary on this project, and reduce the amount of herbicid e entering the environment while still eliminating the Spartina threat efficiently. We established 340ft 2 plots in the marsh (equivalent to 1/128 of an acre) and had the attendees spray the plots (with just water, no herbicide) utilizing a variet y of equipment including backpack sprayers, conventional spray truck, and amphibious vehicl e. Applicators were timed and then were asked to spray into a bucket for the same lengt h of time at the same pressure as the application. The amount of water in the bucket wa s measured and recorded for each participant. Because the area of the plots was 1/128 of an acre, and there are 128 ounces in a gallon, the number of ounces sprayed into ea ch bucket was equivalent to the number of gallons per acre they would have applied. The beauty of this exercise is that once the plots are set up, it requires no math to achieve your calibration, just a timer and a bucket. BASF distributes these simple calibration kits for free to ISP partne rs. The training attendees were able to get direct feedback on th eir application rates a nd to see how easy and beneficial calibration can be, a nd left the training with a simp le kit and protocol to do so. And managers in attendance were able to see how the correct rates will affect the bottom line and help to manage the budget for Spartina control.

San Francisco Estuary Invasive Spartina Project 59. 2008 Aquatic Pesticide Application Plan11. REFERENCES
Adam, P. 1990. Saltmarsh Ecology. Cambridge University Press, Cambridge, UK.Anttila, C.K, R.A. King, C. Ferris, D.R. Ayres, and D.R. Strong. 2000. Reciprocal hybrid formation of Spartina in San Francisco Bay. Molecular Ecology 9: 765-770. Ayers, D.R., D. Garcia-Rossi, H.G. Davis, and D.R. Strong. 1999. Extent and degree of hybridization between exotic ( Spartina alterniflora ) and native ( S. foliosa ) cordgrass (Poaceae) in California, USA determined by random amplified polymorphic DNA (RAPDs). Molecular Ecology Volume 8, 1179-1186. Bascand, L.D. 1970. The roles of Spartina species in New Zealand. New Zealand Ecological Society Proceedings 17: 22-40. BASF Corporation . 2003. Habitat® Herbicide, Specimen, EPA Reg. No. 241-426, 2003. BASF Corporation . 2004. Habitat® Herbicide for Aquatic and Invasive Vegetation Control, 2004. Boyer, K.E., J.C. Callaway, and J.B. Zedler. 2000. Evaluating the progress of restored cordgrass ( Spartina foliosa ) marshes: belowground biomass and tissue nitrogen. Estuaries 23: 711- 721.Bradley, P.M. and E.L. Dunn. 1989. Effects of sulfide on the growth of three salt marsh halophytes of the southeastern United States. American Journal of Botany 76: 1707-1713. Callaway, J.C. 1990. The introduction of Spartina alterniflora in South San Francisco Bay. M.A. thesis, San Francisco State University. San Francisco, CA. 50 pages. Chapman, V.J. 1977. Coastal Vegetation. Chapman and Hall, London. Cornish, P.S. and S. Burgin. 2005. Residual effects of glyphosate herbicide in ecological restoration. Restoration Ecology 13:695-702. Daehler, C.C., and D.R. Strong. 1997. Hybridization between introduced smooth cordgrass ( Spartina alterniflora ; Poaceae) and native California cordgrass ( S. foliosa ) in San Francisco Bay. American Journal of Botany 84(5): 607-611. Daehler, C.C., C.K. Antilla, D.R. Ayres, D.R. Strong, J.P. Baily. 1999. Evolution of a new ecotype of Spartina alterniflora in San Francisco Bay. American Journal of Botany Volume 86, 543-544. Dame, R., M. Alber, D. Allen, M. Mallin, C. Mont ague, A. Lewitus, A. Chalmers, R. Gardner, C. Gilman, Bjorn Kjerfve, J. Pinckney, and N. Smith. 2000. Estuaries of the south Atlantic Coast of North America: their geographic signatures. Estuaries 23: 793-819. Dow AgroSciences LLC. 2001. Rodeo ® , Specimen Label, EPA Reg. No. 62719-324, revised April 17, 2001. Ebasco. 1993a. Element F. Chemical Methods Only: Human Health Effects of Glyphosate. Final Report. Prepared for Washington State Depart ment of Ecology by Ebasco Environmental. January 1993. Ebasco Environmental. 1993b. Prepared for Washington State Department of Ecology. Element I: Integrated weed management alternative for managing noxious emergent plants. Ebasco Environmental, a Division of Ebasco Services Incorporated. 40 pp. Ebasco. 1993c. _Final Report, Element C: Efficacy and Impacts. Prepared for Washington State Department of Ecology. Ebasco Environmenta l, a Division of Ebasco Services Incorporated.

San Francisco Estuary Invasive Spartina Project 60. 2008 Aquatic Pesticide Application PlanEntrix, Inc. 2003. Ecological Risk Assessment of the Proposed Use of the Herbicide Imazapyr to Control Invasive Cordgrass ( Spartina spp.) in Estuarine Habitat of Washington State, prepared for Washington State Department of Agriculture, October 30, 2003. ExToxNet: a cooperative effort of University of California-Davis, Oregon State University, Michigan State University, Cornell University, and the University of Idaho, Pesticide Information Profile for Glyphosate; http://extoxnet.orst.edu/ , accessed April 5, 2005. Fowlkes, M. D., Jerry L. Michael, Thomas L. Crisman, and Joseph P. Prenger. 2003. Effects of the Herbicide Imazapyr on Benthic Macroinvertebrates in a Logged Pond Cypress Dome, Environmental Toxicology and Chemistry, vol. 22, no. 4, pp. 900–907. Giesy, J.P., S. Dobson, and K.R. Solomon. 2000. Ecotoxicological Risk Assessment for Roundup Herbicide. In Review of Environmental Contamination and Toxicology . 167:35-120. Gleason, H.A. and A. Cronquist. 1991. Manual of vascular plants of Northeastern United States and adjacent Canada, Second Edition. New York Botanical Garden.Gleason, M.L., D.A. Elmer, and J.S. Fisher. 1979. Effects of stem density upon sediment retention by salt marsh cord grass, Spartina alterniflora Loisel. Estuaries 2: 271-273, Goals Project. 2000. Baylands Ecosystem Species and Community Profiles: Life histories andenvironmental requirements of key plants, fish and wildlife. Prepared by the San Francisco Bay Area Wetlands Ecosystem Goals Project. P.R. Olofson, editor. San Francisco Bay Regional Water Quality Contro l Board, Oakland, California. Gray, A.J. D.F. Marshall, and A.F. Raybould. 1991. A century of evolution in Spartina anglica

. Advances in Ecological Research Volume 21, 1-62. Kilbride, K.M., and F.L. Paveglio. 2001. Long-ter m fate of glyphosate associated with repeated rodeo applications to control smooth cordgrass ( Spartina alterniflora ) in Willapa Bay, Washington. In Archives of Environmental Contamination and Toxicology , 40. 179-183 (2001) Grue, C., B. Smith, N. Kohn, and J. Davis. 2002. Effects of Rodeo and R-11, LI 700, Agri-dex, and Hasten on Embryogenesis in Pacific Oysters. Presented at Spartina Conference 2002, Olympia Washington Heydens, W.F. 1991. Rodeo herbicide use to control Spartina . Impact of glyphosate on marine and terrestrial organisms. Monsanto Agri cultural Company, St. Louis, MO, USA. Kilbride, K.M., and F.L. Paveglio. 2001. Long-ter m fate of glyphosate associated with repeated rodeo applications to control smooth cordgrass ( Spartina alterniflora ) in Willapa Bay, Washington. In Archives of Environmental Contamination and Toxicology , 40. 179-183 (2001). King K., C. Curran, B. Smith, D. Boehm, K. Gra nge, S. McAvinchey, K. Sowle, K. Genther, R. Highley, A. Schaaf, C. Sykes, J. Grassley, and C. Grue. 2004. Toxicity of Rodeo ® and Arsenal ® Tank Mixes to Juvenile Rainbow Trout, Third International Conference on Invasive Spartina, San Francisco, California, November 8-10, 2004. Kittleson, P.M. and M.J. Boyd. 1997. Mechanisms of expansion for an introduced species of cordgrass, Spartina densiflora , in Humboldt Bay, California. Estuaries 20: 770-778. Knutson, P.L. and W.W. Woodhouse Jr. 1983. S hore stabilization with salt marsh vegetation. Special Report No. 9, U.S. Army Corps of E ngineers, Coastal Engineering Research Center, Fort Belvoir, Virginia. Knutson, P.L., H.H. Allen, and J.W. Webb. 1 990. Guidelines for vegetative erosion control on wave-impacted coastal dredged material sites. U.S. Army Corps of Engineers, Waterways

San Francisco Estuary Invasive Spartina Project 61. 2008 Aquatic Pesticide Application PlanExperimental Station, Dredging Operations Technical Support Program, Technical Report D-90-13. Department of the Army, Waterw ays Experimental Station,Vicksburg, MS. Kroll, R.B. 1991. Field investigations of the e nvironmental fate of Rodeo (glyphosate) in two tidal marshes. Technical Report 115. Maryla nd Department of the Environment, Baltimore, MD. Kubena, K.M., C.E. Grue, and T.H. DeWitt. 19 97. Rounding up the facts about Rodeo: development of concentration-response relationships for selected non-target species. In Proceedings of the Second International Spartina Conference, March 20-21. Lee, W.G. and T.R. Partridge. 1983. Rates of spread of Spartina anglica and sediment accretion in the New River Estuary, Invercargill, New Zealand. New Zealand Journal of Botany 21: 231-236. Leson & Associates. 2005. Use of Imazapyr Herbicide to Control Invasive Cordgrass ( Spartina spp.) in the San Francisco Estuary: Wate r Quality, Biological Resources, and Human Health and Safety, prepared for the San Francisco Estuary Invasive Spartina Project, May 4, 2005. Levin, D.A, J. Francisco-Ortega, and R.K. Jansen . 1996. Hybridization and the extinction of rare species. Conservation Biology Volume 10, 10-16. McKee, K.L. and W.H. Patrick. 1988. The relationship of smooth cordgrass ( Spartina alterniflora ) to tidal datums: a review. Estuaries 11: 143-151. Mendelssohn, I.A. and E.D. Seneca. 1980. The influence of soil drainage on the growth of salt marsh cordgrass, Spartina alterniflora , in North Carolina. Ecology 60: 574- 584Newcombe, C.L., J.H. Morris, P.L. Knutson, and C.S. Gorbics. 1979. Bank erosion control with vegetation, San Francisco Bay, California. Miscellaneous Report No. 79-2, U.S. Army Corps of Engineers, Coastal Engi neering Research Center, Belvoir, Virginia.

Miller P. and P. Westra. 2004. Herbicide Surfactan ts and Adjuvants, Colorado State University Cooperative Extension, Bulletin no. 0.559, August 23, 2004. Monsanto Company. 2000. Aquamaster ® , Complete Directions for U se in Aquatic and other Noncrop Sites, EPA Reg. No. 524-343, 2000. Munz, P.A., and D.D. Keck, 1968. A California Flora and Supplement. University of California Press.NCAP (National Coalition for Alternatives to Pesticides). 2002. Herbicide Factsheet, Glyphosate(Roundup). Journal of Pesticide Refo rm, Caroline Cox, editor. 18:3, Updated September 2002. Rhymer, J.M. and D.S. Simberloff. 1996. Extinct ion by hybridization a nd introgression. Annual Review of Ecology and Systematics 27: 83-109. Patten K. 2002. Smooth cordgrass (Spartina altern iflora) control with imazapyr, Weed Technology, vol. 16, pp. 826-832, 2002.

Patten K. 2003. Persistence and non-target impact of imazapyr associated with smooth cordgrass control in an estuary, Journal of Aqua tic Plant Management, vol. 41, pp. 1-6. Paveglio, F.L., K.M. Kilbride, C.E. Grue, C.A. Simenstad, and K.L. Fresh. 1996. Use of Rodeo® and X-77® spreader to control smooth cordgrass ( Spartina alterniflora ) in a southwestern Washington estuary. II. Environmental Fate. Environmental Toxicology and Chemistry 15.

Schuette J. 1998. California Environmental Prot ection Agency, Department of Pesticide Regulation, Environmental Fate of Glyphosate, revised November 1998.

San Francisco Estuary Invasive Spartina Project 62. 2008 Aquatic Pesticide Application PlanSERA (Syracuse Environmental Research Associates , Inc.). 1997. Effects of Surfactants on the Toxicity of Glyphosate, with Specific Refere nce to Rodeo. Prepared for USDA Animal and Plant Health Inspection Services. SERA, Fayetteville, NY. SERA (Syracuse Environmental Research Associates, Inc.). 2004. Imazapyr - Human Health andEcological Risk Assessment – Final Report, prepared for USDA, Forest Service, December 18, 2004.Smart, R.M. and J.W. Barko. 1978. Influence of sediment salinity and nutrients on the physiological ecology of selected salt marsh plants. Estuarine and Coastal Marine Science 7: 487-495. Spicher, D.P. 1984. The eco logy of a caespitose cordgrass ( Spartina spp.) introduced to San Francisco Bay. M.A. Thesis, San Francisco State University, San Francisco, California. Sprankle, P., W.F. Meggitt and D. Penner. 1975. Rapid inactivation of glyphosate in soil. Weed Sci. 23:224-228. Tu M, C. Hurd, & J.M. Randall. 2001. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Area, April 2001. U.S. Environmental Protection Agency, Technical Overview of Ecological Risk Assessment, Analysis Phase: Ecological Effects Character ization, Ecotoxicity Categories for Terrestrial and Aquatic Organisms; http://www.epa.gov/oppefed1/ecorisk_ders/toer a_analysis_eco.htm#Ecotox, accessed April 2, 2005.

U.S. Fish and Wildlife Service and State Coastal Conservancy. (2003) Final Programmatic Environmental Impact Statement/Environmental Impact Report, San Francisco Estuary Invasive Spartina Project: Spartina Control Program. Volume 1: Final Programmatic Environmental Impact Statement/Environmental Impact Report. State Clearinghouse #2001042058. USFWS, Sacramento, California/State Coastal Conservancy, Oakland, California. www.spartina.org/project_documents/eis_final.htm . September 2003.

U.S. Fish and Wildlife Service and State Coastal Conservancy. (2003) Final Programmatic Environmental Impact Statement/Environmental Impact Report, San Francisco Estuary Invasive Spartina Project: Spartina Control Program. Volume 2: Appendices. State Clearinghouse #2001042058. USFWS, Sacramento, California/State Coastal Conservancy, Oakland, California. www.spartina.org/project_documents/eis_final.htm . September 2003. San Francisco Estuary Invasive Spartina Project. 2004. 2004 Site-specific Spartina Control Plans, San Francisco Estuary Invasive Spartina Project: Spartina Control Program. Prepared by SFEISP, Berkeley, California. www.spartina.org/project_documents/ . June 2004. Valiela, I., J.M. Teal, W.G. Deuser. 1978. The na ture of growth forms in the salt marsh grass Spartina alterniflora

. American Naturalist Volume 112 (985) 461-470. Wang, Y.S., C.G. Jaw, and Y.L. Chen. 1994. Accumulation of 2,4-D and Glyphosate in Fish and Water Hyacinth. Water, Air and Soil Pollution . 74(3/4):397-403.

Personal Communications
John Smith, BASF, Salem, OR Mark Taylor, East Bay Regiona l Park District, Hayward, CA Katy Zaremba, Invasive Spartina Project, Stinson Beach, CA

San Francisco Estuary Invasive Spartina Project 63. 2008 Aquatic Pesticide Application Plan