United States Department of Agriculture

Invasive Plant Control Project

Final Supplemental Environmental Impact 

Statement

Forest Service Carson and Santa Fe National Forests May 2018

MB-R3-10-26
For More Information Contact:

Sandra Imler-Jacquez, Forest NEPA Coordinator

11 Forest Lane, Santa Fe, NM 87508

(505) 438-5443

sandraimlerjacquez@fs.fed.us

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Cover photo: Bull thistle (Cirsium vulgare). Photo courtesy of Forest & Kim Starr, Starr Environmental, Bugwood.org
Final Supplemental Environmental Impact Statement

for the Invasive Plant Control Project Carson and Santa Fe National Forests

Colfax, Los Alamos, Mora, Rio Arriba, San Miguel, 

Santa Fe, Sandoval, and Taos Counties, New Mexico

Lead Agency: USDA Forest Service

Responsible Officials: James Duran, Carson National Forest Supervisor

208 Cruz Alta Road, Taos, NM 87571

James E. Melonas, Santa Fe National Forest Supervisor

11 Forest Lane, Santa Fe, NM 87508

Abstract: This final supplemental environmental impact statement updates and corrects some analyses in the 

Forest Service’s Final Environmental Impact Statement (FEIS) for the Invasive Plant Control Project for the 

Carson and Santa Fe National Forests published in September 2005. It keeps the same purpose and need, 

proposed action, alternatives, adaptive strategy, and design features (also referred to as mitigation measures) 

as the final environmental impact statement. The following substantive updates are contained in this 

supplement:

• The addition of aminopyralid as an herbicide proposed for use;

• The acres and species of weeds in the forests;

• The analysis of effects in chapter 3; and

• The analysis of effects of the proposed amendment to the Santa Fe National Forest Plan.

The pages in this supplement are intended to replace portions of the final environmental impact statement as 

noted in each section. If something is not addressed in this supplement, it means it was not updated.

This final supplemental environmental impact statement and the draft record of decision are subject to 

objection pursuant to 36 CFR 218.8, Subparts A and B. For more information on how to comment/file 

objections see the project website at: http://www.fs.usda.gov/project/?project=27249 or contact Sandra ImlerJacquez, project team leader, at 505-438-5443.

i

Contents

Summary of the Final Supplemental Environmental Impact Statement for the Invasive Plant Control Project .1

Introduction .....................................................................................................................................................1

Purpose and Need for Action...........................................................................................................................1

Public Involvement and Issues........................................................................................................................2

Proposed Action ..............................................................................................................................................4

Alternatives Considered in Detail....................................................................................................................4

Forest Plan Amendment ..................................................................................................................................7

Environmental Consequences and Comparison of Alternatives......................................................................8

Preface ...............................................................................................................................................................12

Notes on This Document ...............................................................................................................................12

Chapter 1. Purpose of and Need for Action.......................................................................................................13

Introduction and Setting ................................................................................................................................13

Definition of Invasive Plant...........................................................................................................................13

Purpose and Need for Action.........................................................................................................................13

Background: Existing Condition ...................................................................................................................15

Management Direction – Desired Condition.................................................................................................21

Other Direction..............................................................................................................................................21

Proposed Action ............................................................................................................................................22

Decision-making Framework ........................................................................................................................24

Public Involvement........................................................................................................................................24

Issues .............................................................................................................................................................26

Chapter 2. Alternatives, Including the Proposed Action....................................................................................27

Introduction ...................................................................................................................................................27

Alternatives Considered but Eliminated from Detailed Study ......................................................................27

Alternatives Considered in Detail..................................................................................................................27

Forest Plan Amendment ................................................................................................................................38

Permits and Authorizations Required............................................................................................................39

Comparison of Alternatives...........................................................................................................................40

Chapter 3. Affected Environment and Environmental Consequences..............................................................43

Introduction ...................................................................................................................................................43

Cumulative Actions for Cumulative Effects Analysis...................................................................................43

Assumptions Common to the Analysis of Effects.........................................................................................51

Vegetation......................................................................................................................................................52

Wildlife Resource..........................................................................................................................................66

Fish and Aquatic Resources ..........................................................................................................................97

Water Resources..........................................................................................................................................104

Soil...............................................................................................................................................................115

Air Quality...................................................................................................................................................123

Heritage Resources......................................................................................................................................130

Recreation and Wilderness..........................................................................................................................132

Visual Resources.........................................................................................................................................143

Livestock Grazing........................................................................................................................................146

Social-Economic Resources........................................................................................................................153

Consistency with Forest Plan, Laws, and Policies ......................................................................................171

Other Required Disclosures.........................................................................................................................171

Preparers and Contributors ..............................................................................................................................173

Distribution of the Supplemental Environmental Impact Statement ...............................................................174

References........................................................................................................................................................175

Appendix 1. Past, Present, and Future Weed Control Activities.....................................................................185

Appendix 2. Weed Species Ecology and Impacts............................................................................................185
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Appendix 3. Herbicides: Characteristics, Effects, and Risk Assessments ......................................................189

Program Description ...................................................................................................................................190

Application Methods...................................................................................................................................190

Overall Conclusions....................................................................................................................................190

Human Health Risk Assessment .................................................................................................................190

Factors Affecting Hazard of Herbicides......................................................................................................190

Wildlife Risk Assessment ...........................................................................................................................192

Aquatic Risk Assessments..........................................................................................................................195

Specific Herbicide Characteristics and Environmental Effects ..................................................................195

Appendix 4. Effects of Non-Herbicide Weed Control Methods.....................................................................197

Appendix 5. Herbicide Model for Watershed Analysis...................................................................................197

Appendix 6. Chemical Spill Prevention and Cleanup Plan .............................................................................197

Appendix 7. Weed Populations and Treatments .............................................................................................197

Appendix 8. Implementation and Monitoring .................................................................................................203

Appendix 9. Response to Comments on the Draft Environmental Impact Statement.....................................203

Appendix 10. Response to Comments on the Draft Supplemental Environmental Impact Statement............203

NEPA ..........................................................................................................................................................203

Law, Regulation, Policy..............................................................................................................................206

Best Available Science................................................................................................................................207

Public Involvement .....................................................................................................................................209

Proposed Action..........................................................................................................................................210

Alternatives.................................................................................................................................................215

Effect Analysis............................................................................................................................................217

Wildlife .......................................................................................................................................................221

Water Resources .........................................................................................................................................229

Health and Safety........................................................................................................................................232

Index................................................................................................................................................................239

List of Tables

Table S-1. Weed distribution by species.............................................................................................................2

Table S-2. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76; bold text is new language).8

Table S-3. Comparison of alternatives by issues and objectives (purpose and need) .......................................10

Table S-4. Weed species locations and impacts (shows the changes from the final environmental impact 

statement only) ..........................................................................................................................................16

Table S-5. Weeds by landform type as of August 1, 2013................................................................................18

Table S-6. Weed species and their abundance in the project area as of August 1, 2013...................................20

Table S-7. Summary of treatments proposed for alternative B.........................................................................29

Table S-8. Summary of treatments proposed for alternative C.........................................................................30

Table S-9. Summary of treatments proposed for alternative D.........................................................................31

Table S-10. Additional treatment criteria and limitations.................................................................................31

Table S-11. Design features and monitoring requirements for all alternatives.................................................33

Table S-12. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76) .......................................39

Table S-13. Comparison of alternatives by issues and objectives (purpose and need) .....................................41

Table S-14. Past and present actions (1987-2013) contributing towards the cumulative effects baseline........44

Table S-15. Reasonably foreseeable future actions (2015-2025)......................................................................47

Table S-16. Summary of cumulative actions by key resource ..........................................................................49

Table S-17. Weed infestations by vegetation type as of August 1, 2013 ..........................................................53

Table S-18. Acres of treatment method in in aspen ..........................................................................................57

Table S-19. Acres of treatment method in big sagebrush..................................................................................57

Table S-20. Acres of treatment method in blue grama......................................................................................57

Table S-21. Acres of treatment method in deciduous shrub mix ......................................................................57

Table S-22. Acres of treatment method in juniper ............................................................................................58
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Table S-23. Acres of treatment method in perennial grass mix.........................................................................58

Table S-24. Acres of treatment method in piñon-juniper ..................................................................................58

Table S-25. Acres of treatment method in ponderosa pine................................................................................58

Table S-26. Acres of treatment method in sparsely vegetated areas..................................................................59

Table S-27. Acres of treatment method in spruce-fir.........................................................................................59

Table S-28. Acres of treatment method in upper deciduous-evergreen forest...................................................59

Table S-29. Acres of treatment method in upper forb mix ................................................................................59

Table S-30. Threatened or endangered plant species.........................................................................................63

Table S-31. Forest Service Southwestern Region regional forester’s sensitive plant species, 2013, on the Santa 

Fe (SF) and Carson (C) National Forests...................................................................................................64

Table S-32. Wildlife management indicator species, habitat, and weed infestation..........................................71

Table S-33. Effects to management indicator species .......................................................................................75

Table S-34. Threatened or endangered wildlife species ....................................................................................79

Table S-35. Effects to, and determinations for, threatened or endangered species............................................82

Table S-36. Sensitive species, amphibians ........................................................................................................84

Table S-37. Sensitive species, birds...................................................................................................................84

Table S-38. Sensitive species, mammals...........................................................................................................85

Table S-39. Sensitive species, snail ...................................................................................................................86

Table S-40. Sensitive species: Effects to amphibians........................................................................................87

Table S-41. Sensitive species: Effects to birds..................................................................................................87

Table S-42. Sensitive species: Effects to mammals...........................................................................................89

Table S-43. Sensitive species: Effects to snail...................................................................................................91

Table S-44. Highest priority migratory birds and habitats used ........................................................................93

Table S-45. Effects to migratory birds and habitats...........................................................................................94

Table S-46. Sensitive aquatic species found on the Carson and Santa Fe National Forests and occupied or 

suitable habitats..........................................................................................................................................98

Table S-47. Environmental consequences and determinations for fish and aquatic species ...........................100

Table S-48. Watersheds on, or intersecting, the forests and the acreage of weeds on National Forest System 

lands.........................................................................................................................................................106

Table S-49. Characteristics of representative watersheds................................................................................108

Table S-50. Impaired waterbodies in representative watersheds 2012-2014...................................................109

Table S-51. Weed acres by erosion hazard class.............................................................................................116

Table S-52. Weed acres by revegetation potential class..................................................................................116

Table S-53. Characteristics of herbicides in soil..............................................................................................121

Table S-54. National ambient air quality standards for criteria pollutants of concern. (New Mexico standards 

are the same as the national standards)....................................................................................................124

Table S-55. Affected heritage resource sites ...................................................................................................131

Table S-56. Recreational visits to the Carson and Santa Fe National Forests.................................................134

Table S-57. Cumulative effects to recreation and wilderness resources..........................................................142

Table S-58. Cumulative effects of action alternatives to visual quality...........................................................146

Table S-59. Grazing allotments with known weed infestations on the Carson National Forest......................147

Table S-60. Grazing allotments with known weed infestations on the Santa Fe National Forest ...................148

Table S-61. Wild horse territories....................................................................................................................151

Table S-62. Ethnicity and race at the county scale (all figures are percentages).............................................154

Table S-63. Percent of population below the Federal poverty level by county (all figures are percentages)..155

Table S-64. Comparison of the toxicity of herbicides proposed for use..........................................................160

Table S-65. Cumulative effects to human health and safety............................................................................166

Table S-66. Present net value (rounded to nearest dollar) of the alternatives..................................................170

Table S-67. Risk assessments..........................................................................................................................189

Table S-68. Herbicide use program description...............................................................................................190

Table S-69. Herbicides formulations, application rates, target plants .............................................................190

Table S-70. Herbicide risk assessment standard terminology .........................................................................190
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Table S-71. Herbicide characteristics..............................................................................................................190

Table S-72. Exposure risk of herbicides..........................................................................................................192

Table S-73. Relative risk of each herbicide.....................................................................................................193

Table S-74. Effects of each herbicide..............................................................................................................194

Table S-75. Level of Concern for Chemical Use Using the Risk Quotient Method .......................................195

Table S-76. Herbicide formulations, impurities, other ingredients.................................................................196

Table S-77. Summary of treatments for the action alternatives ......................................................................200

List of Figures

Figure S-1. An illustrative concept of the definition of an invasive plant, or “weed” ......................................13

Figure S-2. Weed distribution in the project area, August 1, 2013 ...................................................................19

Figure S-3. Dominant vegetation types on the Carson and Santa Fe National Forests.....................................55

Figure S-4. Locations of weeds in valley bottoms and riparian areas on the Carson and Santa Fe National 

Forests, August 1, 2013...........................................................................................................................105

Figure S-5. Areas of slight, moderate, and severe erosion hazard on the Carson and Santa Fe National Forests

.................................................................................................................................................................117

Figure S-6. Areas of revegetation potential (ranging from poor to high) on the Carson and Santa Fe National 

Forests .....................................................................................................................................................118

Figure S-7. PM10 24-hr maximum values in Taos and Santa Fe with 3-year moving average (micrograms per 

cubic meter).............................................................................................................................................125

Figure S-8. PM2.5 24-hr values for 98th percentile weather conditions in Taos and Santa Fe with 3-year 

moving average (micrograms per cubic meter).......................................................................................125

Figure S-9. PM2.5 annual mean values in Taos and Santa Fe with 3-year moving average (micrograms per 

cubic meter).............................................................................................................................................126

Figure S-10. Visibility conditions on worst 20 percent visibility days for San Pedro Parks Wilderness and 

glide path to 2064 goal ............................................................................................................................127

Figure S-11. Visibility conditions on worst 20 percent visibility days for Bandelier National Park and glide 

path to 2064 goal .....................................................................................................................................128

Figure S-12. Weeds located near recreation sites, August 1, 2013 .................................................................136

Figure S-13. Locations of weeds in wilderness areas, August 1, 2013 ...........................................................137
Final Supplemental Environmental Impact Statement

1

Summary of the Final Supplemental Environmental 

Impact Statement for the Invasive Plant Control Project

Introduction

In northern New Mexico’s Carson and Santa Fe National Forests, more than 13,260 acres of invasive 

nonnative plant populations (weeds) inhabit National Forest System lands. Although this amount represents 

about 0.5 percent of the 3 million acres managed by these two national forests, weed treatments are most 

effective when infested areas are still small and before weeds are well established. It is important to control 

weed infestations at an early stage, before costly large-scale treatments such as aerial herbicide spraying 

become necessary. 

This supplement summarizes the “Final Supplemental Environmental Impact Statement for the Invasive 

Weed Control Project.” It provides an overview of the purpose and need for the project, proposed action, the 

public involvement to date, issue and alternative development, and a summary of the expected effects of 

alternatives on the human environment.

The pages in this supplement replace portions of the final environmental impact statement as noted in each 

section. Editorial notes are provided in bracketed, bold text. If something is not addressed or written in this 

supplement, it means it was not updated and the text in the 2005 final environmental impact statement is still 

valid. This final supplemental environmental impact statement is best read in conjunction with the final 

environmental impact statement. The 2005 final environmental impact statement has been posted on the two 

national forests’ websites: the Carson National Forest website and Santa Fe National Forest website.

Purpose and Need for Action

The purpose of, and need for, controlling or eradicating weed infestations on the Carson and Santa Fe 

National Forests is to maintain or improve the diversity, function, and sustainability of desired native plant 

communities on the Carson and Santa Fe National Forests. Protecting the abundance and diversity of native 

plant communities will also help maintain or enhance other natural resources that can be impacted by weeds 

and the loss of desired plant communities. Weeds are aggressive, undesirable plants that are a serious threat to 

the forests. Weeds typically outcompete native plants for space, water, and nutrients because they have 

characteristics that give them a competitive advantage over native plant species. They demonstrate high 

reproductive capacity through prolific seed production and root sprouting. If left uncontrolled, they tend to 

dominate areas and reduce the diversity and sustainability of native plant populations. In some areas, weeds 

have increased so dramatically they create a monoculture by entirely taking over large areas.

Without effective control, weeds will increasingly impact natural resources on the Carson and Santa Fe 

National Forests in the following ways:

• Native plant communities will become more impacted as weeds gradually dominate these communities. 

Some weed species form monocultures or greatly simplified ecosystems. Ecosystem processes become 

degraded, with evidence of slower nutrient cycling and lower hydrological stability. They prove less 

sustainable when confronted with natural disturbances such as fire. Weeds also threaten the continued 

existence of certain endangered, sensitive, or rare plant species that occur on the two national forests. 

• Erosion is increased by many weed species. Knapweeds and other weeds have a single, deep taproot and 

outcompete native grasses that have better soil-holding root systems. Native riparian plants, including 

rushes, sedges, willows, and cottonwoods, maintain streambank stability better than the weed species 

currently spreading through the riparian zones on the Carson and Santa Fe National Forests. 
Invasive Plant Control Project

2

• Wildlife habitat quality decreases when weeds take over native plant communities. Palatable forage for 

game and nongame species of wildlife decreases as weeds like thistle, leafy spurge, and toadflax take 

over. Weeds such as black henbane, poison hemlock, and yellow starthistle can poison animals. Negative 

impacts to wildlife magnify in riparian areas because of the important role riparian vegetation plays for a 

large number of southwestern wildlife species. A large percentage of the known weed infestations occur 

in or near riparian areas. 

• Recreation opportunities are lessened when dense weed infestations limit access to streams and riparian 

areas. Some weeds cause allergies or skin irritations. Scenic values and wilderness characteristics also 

typically decline as weeds reduce the abundance and diversity of native plant communities. 

• Wildland fires are known to burn more intensely and severely in areas where weed species like saltcedar, 

Siberian elm, and Russian olive have taken over native riparian ecosystems. 

• The majority of known weed infestations (approximately 13,260 acres) occurs within 150 feet of roads or 

trails.

In terms of current weed species distribution, the most dominant weed species are the nonnative thistles, 

followed by the valley bottom species of saltcedar, Siberian elm, and Russian olive. Table S-1 shows the weed 

species distribution by percent of inventoried weed infestations.

Table S-1. Weed distribution by species

Species Acres Percent

Thistles 13,731 70.8

Trees 4,396 22.7

Knapweed 951 4.9

Toadflax 65 0.3

Grasses 131 0.7

Others 118 0.6

Public Involvement and Issues

Collaboration and Scoping

In 1996 and 1997, the Forest Service met informally with other Federal, State, and County agencies to discuss 

the threat of weeds and coordinate treatments. In 1998, the Forest Service began scoping for this project, 

starting with public meetings held in Taos and Espanola. In March 2000, a letter was sent to approximately 

450 individuals, agencies, Tribes, and organized groups to inform them about the Forest Service’s weed 

control treatment proposals. At that time, each national forest was independently working on separate 

environmental assessments for forestwide weed control projects. As a result of the March 2000 scoping, a 

decision was made to combine the efforts of the two national forests and document the analysis in an 

environmental impact statement. In December 2000, the Forest Service sent a new letter to the public about 

the proposed action. On December 15, 2000, the Forest Service published a notice of intent to prepare an 

environmental impact statement in the Federal Register. 

The Forest Service first contacted Tribal governments about treating weeds in 1999. The Carson and Santa Fe 

National Forests included the Tribal governments in their March and December 2000 scoping efforts. In 

December 2003, the Forest Service sent another letter to all potentially affected Tribal governments to initiate 

consultation and solicit their comments about the proposed project. 

Issues were identified from the comments received during scoping. The treatment that appeared to be of 

greatest concern to those who commented was the use of herbicides. Most opposition was based on concerns 
Final Supplemental Environmental Impact Statement

3

that herbicides could adversely impact human health, non-target plants, and wildlife. Concerns over the 

impact to water quality and fish were also mentioned. On the other hand, others were concerned that nonherbicidal methods would be less effective and weeds would spread faster than they could be controlled.

Public Comment on the Draft Environmental Impact Statement

On July 16, 2004, the Forest Service published a notice of availability of the draft environmental impact 

statement in the Federal Register. The legal notices announcing the start of the 45-day comment period were 

published in the newspapers of record on July 22, 2004. The Forest Service received 106 letters on the draft 

environmental impact statement; of these, 7 were received after the end of the comment period, which was 

August 30, 2004.

The Forest Service’s interdisciplinary team identified approximately 750 individual comments contained in 

the letters. As with scoping, the use of herbicides continued to be a main concern among members of the 

public. In response, the final environmental impact statement clarified and expanded its discussion of the risks 

associated with the use of herbicides (see appendix 3 of the final environmental impact statement). Appendix 

9 of the final environmental impact statement responds to comments received on the draft environmental 

impact statement. Other relevant comments were incorporated into the final environmental impact statement.

Appeal of the Record of Decision

On September 12, 2005, the Carson and Santa Fe National Forest Supervisors signed a record of decision 

selecting alternative B. The Forests published a notice of availability of the final environmental impact 

statement and record of decision in the Federal Register on November 18, 2005. The legal notices announcing 

the start of the 45-day appeal period were published in the newspapers of record on November 23, 2005. 

Eight appeals of the record of decision were submitted. The Forest Service met with the appellants but was 

unable to resolve the issues stated. The Deputy Regional Forester reversed the decision on February 23, 2006.

Draft Supplemental Environmental Impact Statement 

The Forest Service prepared a draft supplemental environmental impact statement to correct the deficiencies 

identified by the Deputy Regional Forester and to update the analysis and facts where needed pursuant to 40 

CFR 1502.9(c)(1). In accordance with the Council of Environmental Quality (CEQ) regulations at 

§1502.9(c)(4), the draft SEIS was “prepare(d), circulate(d), and file(d) ... in the same fashion (exclusive of 

scoping) as a draft and final statement.” The project was not re-scoped, but the public had the opportunity to 

comment before a final decision was made.

In February 2012, the Forest Service sent postcards to 274 people and organizations anticipating the draft 

supplemental environmental impact statement would be published that spring, and asking them how they 

would like to be notified. Seventeen responses were received.

On March 21, 2014, the Forest Service published a notice of availability of the draft supplemental 

environmental impact statement in the Federal Register. The legal notices announcing the start of the 45-day 

comment period were published in the newspapers of record on March 24, 2014. The Forest Service received 

33 letters on the draft supplemental environmental impact statement.

The Forest Service’s interdisciplinary team identified approximately 75 individual comments contained in the 

letters. The use of herbicides continued to be a main concern among members of the public. Appendix 10 of 

the final supplemental environmental impact statement responds to comments received on the draft 

supplemental environmental impact statement. The Forest Service has published regulations that institute an 

objection process in lieu of the appeal process. This project and its decision fall under the objection process 

(36 CFR 218).
Invasive Plant Control Project

4

Proposed Action

The proposed action is an integrated set of management actions considered necessary to control weeds on the 

Carson and Santa Fe National Forests with the goal of completely eliminating them or at least preventing their 

spread. Under policy stated in Forest Service Manual 2903, invasive weeds and other invasive species in 

aquatic and terrestrial areas of the National Forest System are to be managed by using an integrated pest 

management approach. The integrated pest management approach recognizes that using only one treatment 

method is unlikely to be effective. Treatment methods used in conjunction with integrated pest management 

involve four broad categories: 

1. Mechanical/Physical (mowing, prescribed burning, etc.), 

2. Cultural (re-seeding, fertilizing, etc.), 

3. Biological (grazing, use of biocontrol agents, etc.), and 

4. Chemical (use of herbicides).

Weeds proposed for treatment are those on the New Mexico Department of Agriculture’s noxious weeds list 

at the time of this writing or in the future. As of this writing, 21 of the 37 listed weeds are known to occur in 

the Carson and Santa Fe National Forests, and 5 have the potential to occur. The two national forests do not 

intend to treat medicinal plant species such as St. John’s wort (Hypericum perforatum) and wild licorice 

(Glycyrrhiza lepidota).

Weed treatments would begin in 2017. During approximately the next 10 years, each national forest 

anticipates treating 300 to 800 acres per year, based on anticipated funding. The maximum acreage treated per 

year, given sufficient funding, would be 3,000 acres (1,500 acres on each forest). The implementation period 

could extend beyond 10 years if monitoring shows treatment results are within expected outcomes.

To treat weeds on the State’s noxious weed list, the following treatment methods are proposed:

• Hand pulling, grubbing with hand tools or hand operated power tools, mowing and disking, girdling, or 

plowing with tractor-mounted implements; 

• Biological control using insects or plant pathogens introduced into the weed habitat; 

• Controlled grazing using goats and sheep to intensively and repeatedly graze weeds; 

• Herbicide application using hand or vehicle-mounted sprayer applications; and 

• Prescribed burning using limited pile or broadcast burning to eliminate seed heads and resident 

populations of weeds. 

Reseeding or replanting after the initial treatment would follow in some situations, since this has been shown 

to increase the effectiveness of controlling weeds (Endress et al. 2012). 

The scope of the proposal includes treatments to existing weed infestations, as well as an adaptive strategy for 

responding to infestations not yet discovered or established. The adaptive strategy would evaluate new weed 

populations and allow immediate treatment, if the effects fall within parameters described in this final

supplemental environmental impact statement. Failure to deal immediately with these new—usually small—

infestations is likely to lead to larger scale treatments with greater impacts later.

Alternatives Considered in Detail 

This section summarizes the four alternatives considered in detail in the final supplemental environmental 

impact statement, the adaptive management strategy, treatment objectives and decision criteria, mitigation and 

monitoring requirements, and the forest plan amendment.
Final Supplemental Environmental Impact Statement

5

Alternative A–No Action. This is the baseline for comparing the other alternatives and is the alternative 

where proposed weed control actions would not occur on the two national forests.

Alternative B–Proposed Action. This is the agency’s proposed action as previously described, 

developed to fully meet the purpose and need for action while minimizing the risk of adverse impacts 

through design features and monitoring requirements. 

Alternative C–No Herbicides. This alternative eliminates herbicide use and was developed in response 

to public concerns raised about potential effects of herbicides on human health, fish, wildlife, and nontarget native vegetation. 

Alternative D–Herbicides Only. This alternative exclusively relies on herbicides and was developed in 

response to the cost effectiveness issue associated with proposed non-herbicide treatments. 

Adaptive Strategy

The action alternatives (alternatives B, C, and D) employ an adaptive strategy. Using this adaptive strategy, 

weed treatments would be monitored, evaluated, and modified as necessary to improve effectiveness of future 

treatments or reduce the potential for adverse effects to people and natural resources. This strategy also allows 

for applying the same weed control treatments to new weed infestations as long as the actions and effects 

(including decision-making criteria and limitations on treatments) are within the scope of the environmental 

impact statement and record of decision. 

The adaptive strategy would cover weeds found in newly surveyed areas, newly established populations, or 

weeds newly listed as noxious by the State of New Mexico in the two national forests. The Carson and Santa 

Fe National Forests propose an adaptive strategy with the following actions:

• Annually inventory portions of the two national forests that are likely to have new infestations (for 

example, areas burned by wildfires or recently disturbed) and map them. Budgets will govern the extent 

of these inventories. 

• Identify the weed treatment objective, priority, and methods to use for newly mapped infestations, based 

on the specific criteria described in the environmental impact statement. 

• Monitor the effectiveness and effects of weed treatment activities and associated design features. 

• Evaluate and disclose monitoring results, and use those results to determine appropriate modifications in 

treatment prescriptions, design features, or implementation practices. 

• Implement modifications or other feasible and appropriate treatment methods based on monitoring 

results, as long as the action and its effects are considered by an interdisciplinary team and determined by 

the responsible official to be within the scope of actions and effects evaluated in the environmental impact 

statement (in accordance with Forest Service Handbook 1909.15, Sec. 18).

Treatment Objectives and Decision Criteria 

Specific treatment objectives for a given weed species fall into one of the following categories: 

• Eradication 

• Containment (preventing small populations from expanding once eradication is no longer feasible) 

• Control (reducing or maintaining large populations over time) 

Treating every weed infestation within 1 to 2 years is beyond the budget and personnel resources of the two 

national forests. Therefore, a system for setting priorities is proposed so treatment concentrates on invasive 

species that have the greatest impact on the resource base, and those invasive plants that become more 
Invasive Plant Control Project

6

difficult to control if action is delayed. Weeds become much more difficult to control once they have spread. 

Thus, the highest priority is to eradicate new species occurrences on the two national forests and then to keep 

existing populations from spreading or increasing in size. 

In addition, new weed infestations found in the following locations would be considered for an elevated 

priority ranking: 

• Areas that are now relatively weed free and have little or no road access, such as areas designated as 

wilderness, roadless recreation or semi primitive, or nonmotorized, including the road corridors and trails 

that lead to those areas. 

• Areas that are now relatively weed free and provide unique and desirable wildlife habitat, such as 

recovery habitat for threatened or endangered species, deer and elk winter range; and riparian habitat. 

• Areas on the two national forests with weed populations adjacent to other land ownerships where land 

managers have active weed control programs.

• Areas of high human use, including, but not limited to, administrative sites, developed recreation sites 

such as campgrounds, scenic viewpoints, interpretive sites, and trailheads. 

Schedules for implementing weed treatments would be based first on the priorities just described and spread 

out over time based on levels of funding and staffing on the two national forests. 

Selection of various treatment methods may be based on treatment objectives for a particular site and by 

factors such as proximity to water or roads (which increases chance of weed spread) and the size of the weed 

infestation (small infestations are easier to eradicate). For the greatest likelihood of success, flexibility in 

treatment methods is needed to address differences in site-specific conditions. In particular, selection of 

treatment methods may take into consideration local resources of special concern:

• Areas of high human use such as a recreation site, administrative site, or area where people often collect 

plants. 

• Areas with a shallow water table (less than 6 feet deep) and soil with a high permeability rate, where there 

may be a risk of an herbicide leaching through the soil to the groundwater. 

• Riparian areas or areas next to live water bodies containing aquatic species. 

• Presence or proximity of threatened, endangered, or sensitive plant species. 

• Presence or proximity of threatened, endangered, or sensitive wildlife species. 

• Wilderness and designated nonmotorized areas. 

Mitigation and Monitoring 

This final supplemental environmental impact statement lists design features and monitoring requirements for 

all action alternatives. The mitigations were developed specifically for this project in order to avoid or 

minimize the risk of adverse impacts to human health and safety; native plants; special status plants or 

wildlife; air, soil, water, riparian and aquatic resources; and heritage resources. The bullets that follow 

summarize design features that are described in more detail in the final supplemental environmental impact 

statement.

• Human Health/Safety and General Mitigations: These govern herbicide application and use, public 

notification, traffic control, and other protection measures. 

• Native Vegetation and Treatment Effectiveness: These direct the treatments so they have a minimal 

impact on native vegetation. They include cleaning equipment, revegetation (or mulching as appropriate), 

and use of proper seed to revegetate. 
Final Supplemental Environmental Impact Statement

7

• Threatened, Endangered, and Sensitive Plants: These require survey and/or avoidance of occupied 

habitat. For Holy Ghost ipomopsis (Ipomopsis sancti-spiritu), buffers apply to treatments such as grazing, 

mowing, and prescribed burning. For spot applications, herbicide use is prohibited within, and for 25 feet 

around, Holy Ghost ipomopsis plants and occupied habitat. 

• Wildlife, including Threatened, Endangered, and Sensitive Species: Depending on the level of 

protection required by law, regulation, and policy, these measures require surveys, avoidance, or both and 

use of seasonal restrictions to reduce impacts during breeding periods. For example, managed grazing 

with sheep or goats is prohibited in Rocky Mountain bighorn sheep habitat. 

• Air, Soil, Water, Riparian, and Aquatic Resources: These measures restrict some treatments in certain 

places, such as slope restrictions for mechanical treatments and herbicide use restrictions near water. 

Although some herbicides may be permitted near water if registered for such use by the Environmental

Protection Agency, no direct application of herbicide to water is permitted as part of this project in order 

to avoid impacts to native fish. Procedural restrictions also apply. These include complying with smoke 

management for prescribed burns and evaluating watersheds for total herbicide use before proceeding. 

Potential for accidental spills of herbicides, gasoline, or other chemicals associated with treatments would 

be minimized by restrictions on where these chemicals can be handled. Spill prevention and cleanup plans 

and other established procedures also help reduce the impacts to soil, water, and aquatic resources. 

• Heritage Resources: A programmatic agreement exists to ensure that heritage resources would be 

protected in accordance with applicable law, regulation, and policy. The programmatic agreement spells 

out the requirements for conducting heritage resource inventories and evaluations for this project prior to 

implementation. It requires development of appropriate design features to avoid adverse impacts to 

heritage resources. 

• Monitoring and Adaptive Management: Inventory and mapping of weeds will be conducted annually. 

Newly found weed populations will be identified and prioritized for treatment. Treatments will be 

monitored for effectiveness and effects to other resources. If the treatments initially prescribed in the 

environmental impact statement are not effectively meeting the given treatment objective, another method 

may be used as long as the action and effects are within the scope of effects considered in the 

environmental impact statement. The evaluation and decision by the responsible official regarding 

consistency with the environmental impact statement will be documented in the project record.

Forest Plan Amendment

Alternatives B and D include a nonsignificant, programmatic amendment to the Santa Fe National Forest 

Plan. The amendment would allow the use of herbicides in places currently prohibited by forest plan 

standards and guidelines. These areas are in municipal watersheds and on soils with low revegetation 

potential. No amendment is proposed for the Carson National Forest Plan because it does not prohibit the use 

of herbicides in any specific areas.

To meet the purpose and need for this project and protect ecosystem diversity and sustainability in the long 

term, it may be necessary to occasionally apply herbicides within those areas if they are infested with weed 

populations that cannot be effectively treated with other methods. The proposed amendment would continue 

to protect municipal watersheds, soil productivity, and human health and safety. For instance, soil erosion 

rates would still be required to remain within tolerance levels based on the terrestrial ecosystem survey data, 

in order to maintain long-term soil productivity. Table S-2 shows the specific language changes in forest plan 

direction.
Invasive Plant Control Project

8

Table S-2. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76; bold text is new language)

Existing Forest Plan Direction Proposed Forest Plan Direction

5. Chemical treatments may be applied: 5. Chemical treatments may be applied:

a. when determined through an 

environmental analysis to be 

environmentally, economically, and socially 

acceptable.

a. when determined through an environmental analysis to 

have no adverse environmental, economic, or social 

impacts for longer than 6 months.

b. on areas outside municipal watersheds 

and human habitation.

b. within municipal watersheds only when the 

municipality concurs with the proposed treatment and 

design features. 

c. on soils with moderate or high 

revegetation potential.

c. on any soil provided that soil erosion on that site is 

not increased to above the tolerance level identified in 

the terrestrial ecosystem survey for the affected soil 

unit.

d. on areas that would benefit from 

selective control of plant species.

d. on areas that would benefit from selective control of 

plant species.

e. on areas where the chemicals will not 

violate State water quality standards.

e. on areas where the chemicals will not violate State 

water quality standards.

f. on soils with moderate to high cation 

exchange capacity.

f. In areas of human habitation: 

• Apply this adaptive strategy identified in the EIS 

in table S-10: Method(s) must have been 

documented to be low risk of causing harm to 

people. 

• Apply the design features listed in the EIS in table 

S-11 under “Human Health/Safety and General 

Mitigations.”

g. on piñon-juniper retreatment areas on 

stands where 80 percent of the trees are 

less than 6 feet in height, with more than 25 

trees per acre.

g. on piñon-juniper retreatment areas on stands where 80 

percent of the trees are less than 6 feet in height, with 

more than 25 trees per acre.

Environmental Consequences and Comparison of Alternatives 

This section provides a comparative summary of the alternatives in terms of the most significant issues or 

effects anticipated, based on the analysis in the environmental impact statement. 

Summary of Environmental Consequences

The most noticeable consequences from weed treatment alternatives B, C, and D would be the long-term 

beneficial improvements to native ground vegetation such as grasses, forbs, and shrubs. Riparian vegetation 

such as rushes, sedges, willows, and cottonwoods would particularly benefit from this project. Protecting and 

improving native plant communities would have positive effects on soil and water conditions, as well as 

wildlife and aquatic habitats (particularly due to enhancing riparian vegetation). 

Negative effects to native vegetation, soil, water, wildlife, and aquatic organisms would be minor and of short 

duration. The minor, short-term increases in sediment (more with alternative C) and herbicide delivery to 

streams (alternatives B and D) would have no significant consequences. There would be a low risk of adverse 

impacts to fisheries, including Rio Grande cutthroat trout (a sensitive fish species) or other aquatic organisms 

based on use of design features, risk assessments, and Environmental Protection Agency guidelines. 

Alternative C would cause more ground disturbance and associated impacts to soils, especially those with a 

severe erosion hazard rating. However, all alternatives would remain within soil erosion tolerance levels 

needed to protect long-term soil productivity. Soils with low revegetation potential would receive herbicide 

treatments under alternatives B and D. Reestablishing native vegetation could take longer under alternative C

due to soil disturbance and germination of weed seed from the seed bank. Mitigation requirements for all 
Final Supplemental Environmental Impact Statement

9

alternatives would ensure that vegetative ground cover is adequately reestablished. With the required design 

features, all soil and water quality standards would be met.

Differences between alternatives in their effects to air quality, heritage resources, livestock grazing, 

recreation, wilderness, and visual resources are expected to be negligible, such that they would not be given 

weight in the decision-making process. There would be minor increases in noise and traffic, although 

generally within background levels. 

By controlling the spread of weeds and protecting native plant communities, habitats, and watershed 

conditions on the two national forests, alternatives B and D would maintain or enhance social or economic 

conditions, particularly for local rural communities in northern New Mexico who typically rely on the two 

national forests’ natural resources for their livelihood, traditional culture, and quality of life. 

Comparison of Alternatives 

The alternatives are compared in terms of the significant issues and how well they meet the purpose and need 

(objectives) for the project. Table S-3 provides the comparison of alternatives, based on the detailed 

environmental analysis documented in the final environmental impact statement. The comparison table 

provides a basis for choice between alternatives.
Invasive Plant Control Project

10

Table S-3. Comparison of alternatives by issues and objectives (purpose and need)

Significant Issues 

and Objectives Alternative A Alternative B Alternative C Alternative D

Issue 1: Herbicides 

and Human Health 

No risk of health impacts from 

herbicide exposure (0 acres 

treated with herbicides). 

Low risk of health impacts to 

workers or general public from 

using herbicides based on 

Environmental Protection 

Agency registration, risk 

assessment data, and design 

features. Higher risk to people 

with multiple chemical 

sensitivities, although public 

notification requirement provides 

a means for people with this 

condition to avoid exposure to 

treated areas. 

No risk of health impacts from 

herbicide exposure (0 acres 

treated with herbicides). 

Slightly increased risk of 

exposure to smoke from 

prescribed burning. 

Same as alternative B but 

slightly higher risk of exposure 

for people with chemical 

sensitivities as 100 percent of 

treatments are with herbicides.

Issue 2: Herbicides 

and Wildlife 

No risk of herbicide impacts to 

wildlife. Weeds would degrade 

native plant habitats, especially 

riparian areas important to 

numerous species. 

Low risk of herbicide impacts to 

wildlife based on Environmental 

Protection Agency registration, 

risk assessments, and design 

features. Native wildlife habitat 

quality (especially riparian 

habitat) would improve as weeds 

are eradicated and controlled. 

No risk of herbicide impacts 

to wildlife. Less improvement 

in wildlife habitat. 

Same as alternative B 

Issue 3: Herbicides 

and Native Plant 

Communities 

No short-term impacts from 

herbicides. In the long term, 

weed-caused decline in 

abundance and diversity of 

native plant communities. 

Short-term reduction in some 

non-target plant species. Longterm improvement in abundance 

and diversity of native plant 

communities. 

Similar to alternative B for 

short-term reduction in nontarget plants. Low to 

moderate long-term 

improvement in native plant 

communities. Weed spread 

rate may equal or exceed

control rate without herbicide 

use. 

Same as alternative B

Issue 3 Continued: 

Rare or Sensitive 

Native Plant Species 

No risk of treatment-related 

impacts. In the long term, 

weeds may cause a decline in 

federally listed or sensitive 

plant species.

No impact to threatened or 

endangered plants due to 

mitigation measure. For 

sensitive plants, treatments “may 

impact individuals but are not 

likely to result in a trend toward 

Federal listing or loss of 

population viability,” due to 

design features and species 

locations. 

Same as alternative B Same as alternative B
Final Supplemental Environmental Impact Statement

11

Significant Issues 

and Objectives Alternative A Alternative B Alternative C Alternative D

Issue 4: Cost and 

Treatment 

Effectiveness (based 

on level of effort to 

meet objectives) 

No cost effectiveness; would 

incur much higher costs in 

future. 

Moderately cost effective. Least cost effective. Most cost effective. 

Objectives: Protect 

native plant 

communities, soil 

and water quality, 

wildlife habitat, and 

long-term ecosystem 

health 

No protection; no 

effectiveness. Weed-related 

impacts to vegetation, soil, 

water, riparian habitat, etc. 

would continue. 

Highest level of treatment 

effectiveness and resource 

protection from weed impacts 

due to combination of treatments 

including herbicides. 

Lowest level of effectiveness 

and resource protection from 

weed impacts. Fewer acres 

treated annually for a given 

budget due to need for repeat 

treatments on the same 

acreage more often than 

when combined with other 

methods. 

High level of effectiveness and 

resource protection from weed 

impacts. Not quite as effective 

as herbicides combined with 

other methods. 
Invasive Plant Control Project

12

Preface

Notes on This Document

• The pages in this supplement replace portions of the final environmental impact statement as noted in 

each section. Editorial notes are provided in bracketed, bold text. If something is not addressed or written

in this supplement, it means it has not been updated and the text in the 2005 final environmental impact 

statement is still valid. This final supplemental environmental impact statement is best read in conjunction 

with the final environmental impact statement. The 2005 final environmental impact statement has been 

posted on the two national forests’ websites: 

Carson National Forest website

Santa Fe National Forest website

• Tables and figure numbers are preceded by “S-.” Where a table or figure replaces one from the final 

environmental impact statement, it is noted. 

• A limited number of paper copies of the final environmental impact statement and final supplemental 

environmental impact statement are available from the Carson and Santa Fe National Forests.

• Throughout this document, the term used for invasive plants will be “weeds.” 

• “Design features” and “mitigation measures” are used interchangeably.

• This document contains revised acreage numbers. When consulting the final environmental impact 

statement, refer to this document for the correct acreages. 

• The risk assessments for certain herbicides have been updated; they replace or complement the earlier risk 

assessments. Any references to the risk assessments now include those listed in appendix 3 (Syracuse 

Environmental Research Associates, Inc. (SERA) 2003a–2007).

• Most resource specialists wrote their section directly into this document; thus, separate, updated specialist 

reports exist only for heritage resources and for social and economic resources. The information in this 

final supplemental environmental impact statement supersedes the specialist reports prepared for the 2005 

final environmental impact statement.
Final Supplemental Environmental Impact Statement

13

Chapter 1. Purpose of and Need for Action

Introduction and Setting

[No change from the final environmental impact statement]

Definition of Invasive Plant

[New section]

Executive Order 13112 defines an invasive species as “an alien species whose introduction does or is likely to 

cause economic or environmental harm or harm to human health.” This definition encompasses plants, 

animals, and microorganisms. Although invasive species come in many life forms, this document addresses 

invasive plants (weeds) only. Figure S-1 illustrates how a particular plant species may be determined to be

invasive, as interpreted by the authors of this supplement and further defined by the Invasive Species 

Advisory Committee (ISAC 2006). 

Figure S-1. An illustrative concept of the definition of an invasive plant, or “weed”

Noxious weed lists promulgated at the Federal, State, or County government levels are used to regulate 

invasive plants. Although most noxious weed lists are comprised mainly of invasive plants, not all weeds 

species found on these lists are necessarily invasive. For example, the lists may include agronomic weed 

species as well.

Purpose and Need for Action

[Replaces third paragraph]

In general, weed invasion and spread results in a loss of natural diversity and reductions in the quality of 

wildlife habitat, soil stability and water quality. Weeds can alter ecosystems by changing the frequency and 

intensity of wildfires (Quigley and Arbelbide 1997, DiTomaso 2000, Tu et al. 2001, ISAC 2006). More 

specifically, where weeds occur and continue to spread over native grasslands, riparian areas, rare plant areas, 
Invasive Plant Control Project

14

and other sites on the Carson and Santa Fe National Forests, they are reducing the abundance and variety of 

native plants. This, in turn, impacts the abundance and diversity of wildlife species that depend on those 

native habitats. In addition, the root systems of some weed species do not hold soil in place as well as native 

plants, resulting in increased soil erosion and streambank instability (Lacey et al. 1989, ISAC 2006). Some 

weeds, such as saltcedar (also known as tamarisk), reduce water quantity, which is particularly critical to the 

arid lands in New Mexico (ISAC 2006).

[Replaces fourth paragraph]

In New Mexico, the occurrence of weed species is increasing. Existing populations are predicted to spread, 

and new weed infestations are projected to appear each year (Renz 2004). While the number of known weed 

infestation sites on the two national forests is relatively small, occupying less than half of 1 percent of the 3 

million acres of land in the Carson and Santa Fe National Forests, there are likely more weed infestation sites 

that have not yet been discovered. Weeds typically spread at a rate of between 5 and 30 percent per year, 

depending on the plant species and site-specific conditions (DiTomaso 2000, Tu et al. 2001, Frid et al. 2013).

[Replaces 3rd bullet]

• Water quality is impacted by weeds. Across the two forests, almost 8,600 acres of known weed 

populations are found in valley bottom lands and within 150 feet of streams. As native vegetation changes 

to one or more weed species, the amount of surface water runoff and stream sedimentation is likely to 

increase as well. Weeds that displace native rushes and sedges along streams typically reduce the soil 

stability of those streambanks (Enloe et al. 2004). Water quality can become degraded from these changes 

in plant composition along streams. Water infiltration rates can be reduced where weeds dominate, and 

their presence influences soil moisture and nutrient availability (DiTomaso 2000).

[Replaces 2nd, 3rd, and 5th bullets, p. 15]

• Wildlife habitat is degraded or lost when weeds cause a decline in native vegetation that provides cover, 

seeds, and habitat for small mammals. Over decades, large areas of weeds would likely lead to a reduced

populations of deer, elk, and nongame wildlife populations (FICMNE 1998). Palatable forage for game 

and nongame wildlife species decreases as weeds take over (DiTomaso 2000). The North Ponil area on 

the Carson National Forest has more than 1,300 acres of bull thistle, along with small populations of 

knapweed and leafy spurge, threatening this area’s habitat quality. In addition, livestock and wildlife can 

be injured or die from weeds that are poisonous to animals that feed on them, such as black henbane and 

poison hemlock (FICMNE 1998). Yellow starthistle can induce a neurological disorder in wild or 

domestic horses that is usually fatal.

• Weeds can impact the quality of recreational activities on the two national forests. Along trails, hikers 

encounter thistles and knapweeds that have spiny flowers and leaves. Dead weed stalks are known to 

impede access to meadows and riparian areas or discourage return trips (FICMNE 1998). Increased weed 

spread is expected along popular recreation use corridors such as State Highway 38 (Questa Ranger 

District), State Highway 4 (Jemez Ranger District), and State Highway 63 (Pecos/Las Vegas Ranger 

District). The North Ponil area of the Questa Ranger District demonstrates this growing conflict as bull 

thistle populations spread through the Ponil Fire burned area. Saltcedar is becoming so dominant along 

some streams it is limiting public access to those popular streamside areas (USDA Forest Service 1998b, 

1998c). In addition, forest visitors and workers may come in contact with some weeds such as black 

henbane, which pose a health threat.

• Wilderness characteristics could be threatened as weeds spread into these areas and form monocultures, 

reducing the natural diversity and integrity of native plants and animals. These changes in plant 

composition lead to detrimental changes in ecological processes and functions. Known weed populations 

in wilderness areas on the two national forests total approximately 560 acres.
Final Supplemental Environmental Impact Statement

15

Background: Existing Condition

[Replaces entire section]

The New Mexico Department of Agriculture (NMDA) established a list of 37 weed species considered to be 

noxious and known to occur or with potential to occur within the State (NMDA 2009). The New Mexico 

Department of Agriculture categorizes the weeds into four classes:

• Class A weeds (21 species) are not present or have very limited distribution in the state 

• Class B weeds (10 species) exist only in particular areas of the state

• Class C weeds (6 species) are wide-spread throughout the state

• Watch list weeds (8 species) have the potential to become problematic, but more data is needed before 

listing them as noxious

Of the 37 noxious weeds listed with the New Mexico Department of Agriculture, 21 species are known to 

occur in the two national forests, and 5 species have potential to occur there. Table S-4 lists these species and 

their main threat to the two national forests. For a more detailed discussion, see appendix 2, “Weed Species 

Ecology and Impacts.”

Photo 1. Leafy spurge (Santa Fe National Forest photo)
Invasive Plant Control Project

16

Table S-4. Weed species locations and impacts (shows the changes from the final environmental impact statement only)

Weed Species and

NMDA Class Life Cycle1 Location Impact

Tree of Heaven

(Ailanthus altissima)

AIAL

(Class B)

Perennial Found in fence rows, roadsides, 

and waste areas.

Threat to natural areas because of 

tendency to invade.

Spotted knapweed

(Centaurea 

biebersteinii)

CESTM

(Class A)

Biennial or short-lived 

perennial.

Prefers disturbed areas to 

establish but can spread into 

undisturbed areas once in a site.

Highly adapted to capturing moisture 

and nutrients so it can spread and 

choke out native species. Decreases 

the water storage capacity of soil 

and can increase soil erosion 

potential by replacing native plants’ 

network root system with taproot.

(Fuller’s) teasel

(Dipsacus fullonum)

DIFU2

(Class B)

Biennial Found disturbed areas, abandoned 

fields, and along roadsides.

Prickly plant with spines or sharp 

edges, can crowd out native plants 

and is known to form a monoculture.

Cheatgrass

(Bromus tectorum)

BRTE

(Class C)

Annual Found on all exposures and types 

of topography desert valleys to 

mountains.

Quickly invades burned areas, 

roadsides, and other disturbed sites 

outcompeting desired perennial 

vegetation.
Final Supplemental Environmental Impact Statement

17

Weed Species and

NMDA Class Life Cycle1 Location Impact

Saltcedar

(tamarisk)

(Tamarix spp.)

TARA

(Class C)

Perennial shrub Riparian areas Replaces native wood species such 

as cottonwood, willow, and 

mesquite. Chemically alters the soil 

to eliminate competition from native 

species to reduce the habitat 

effectiveness for native wildlife 

species. Uses more water than 

native species and changes the 

flood/sediment deposition regime so 

that native species such as 

cottonwood cannot regenerate.

Remove field bindweed 

(COAR4) from list

1 The life cycle of a weed species along with its means of reproduction (seed, root sprouting, and so forth.) help determine how fast a weed species can take over a site, spread to new places, and 

how well it can be controlled. Perennial plants persist year after year and so can have a high capacity to spread by roots. These types of weeds can be rather difficult to control. Annuals grow and 

die after a single year and may be more vulnerable to control actions that disrupt this cycle pattern. Biennials take 2 or more years to complete their life cycle and may be the most susceptible to 

control efforts that disrupt their reproductive pattern.
Invasive Plant Control Project

18

Figure S-2 [replaces figure 2 in the final environmental impact statement] is a map of weeds in the project 

area, although the points on the map do not accurately represent the size or extent of each weed infestation.

For the last several years, resource specialists have noticed weed species increasing on the two national 

forests. Forest Service personnel started surveying weeds in 1997 and have continued up to the present. The 

first surveys sampled a portion of each ranger district and found 16 species. The surveys completed to date do 

not cover the entire project area. Not all disturbed sites (such as recent fires) have been completely surveyed, 

but these areas serve as likely places for weeds to gain a foothold. As summarized in Table S-6 and displayed 

in Figure S-2, of the 3,030,721 million acres of National Forest System lands in the project area, there are 

approximately 13,256 acres of known weed infestations in a wide range of sizes and a broad distribution. As 

shown in Table S-6, Canada thistle is the most abundant weed in the two national forests. Acreages of all 

weed species shown in the table do not reflect the density of weeds in each site since most of these sites also 

have native vegetation that would not be treated. The size of each weed infestation currently varies from less 

than 1 acre to over 1,000 acres. Most infestations (more than 75 percent) are less than 1 acre; an ideal size for 

effectively treating them (Frid et al. 2013). 

Table S-5 shows the distribution of known weeds in the project area by general landform type.

Table S-5. Weeds by landform type as of August 1, 2013

Infested Areas

Estimated 

Acres*

Minimum 

Size

Maximum 

Size

Average 

Size

Within 150 feet of open system roads 4,593 0.003 1,182 67

Within 150 feet of trails, motorized and 

nonmotorized

12,070 0.01 2,793 19

Riparian areas (150 foot buffer) 3,815 0.002 827 67

Valley bottoms (150 foot buffer) 4,777 0.004 850 76

Scattered 4,818 0.01 1,306 110

Within 50 feet of well pads (Jicarilla 

Ranger District) 

150 0.01 97 15

In wilderness 561 0.002 252 19

Within 150 feet of a trailhead 9 0.0002 3 1

* Some invasive plant populations may fall into more than one category and would be counted more than once.
Final Supplemental Environmental Impact Statement

19

Figure S-2. Weed distribution in the project area, August 1, 2013
Invasive Plant Control Project

20

Table S-6 shows weed species and their known abundance as of August 1, 2013.

Table S-6. Weed species and their abundance in the project area as of August 1, 2013

Common Name Scientific Name Forest Acres1

Russian knapweed Acroptilon repens Carson NF 41

Russian knapweed Acroptilon repens Santa Fe NF 69

tree of heaven Ailanthus altissima Santa Fe NF 0.1

cheatgrass Bromus tectorum Santa Fe NF 74

whitetop Cardaria draba Carson NF 49

whitetop Cardaria draba Santa Fe NF 8

musk thistle Carduus nutans Carson NF 585

musk thistle Carduus nutans Santa Fe NF 3,158

diffuse knapweed Centaurea diffusa Carson NF 394

diffuse knapweed Centaurea diffusa Santa Fe NF 108

yellow star-thistle Centaurea solstitialis Carson NF 1

spotted knapweed Centaurea stoebe ssp. micranthos Santa Fe NF 339

Canada thistle Cirsium arvense Carson NF 310

Canada thistle Cirsium arvense Santa Fe NF 5,325

bull thistle Cirsium vulgare Carson NF 1,647

bull thistle Cirsium vulgare Santa Fe NF 2,183

poison hemlock Conium maculatum Santa Fe NF 22

Fuller's teasel Dipsacus fullonum Santa Fe NF 0.1

Russian olive Elaeagnus angustifolia Carson NF 331

Russian olive Elaeagnus angustifolia Santa Fe NF 919

leafy spurge Euphorbia esula Carson NF 9

leafy spurge Euphorbia esula Santa Fe NF 0.02

black henbane Hyoscyamus niger Carson NF 44

perennial pepperweed Lepidium latifolium Carson NF 43

Dalmatian toadflax Linaria dalmatica Santa Fe NF 18

yellow toadflax Linaria vulgaris Carson NF 47

Scotch thistle Onopordum acanthium Carson NF 130

Scotch thistle Onopordum acanthium Santa Fe NF 392

tamarisk / saltcedar Tamarix ramosissima Carson NF 548

tamarisk / saltcedar Tamarix ramosissima Santa Fe NF 1,090

Siberian elm Ulmus pumila Santa Fe NF 1,509

1 Because more than one species may exist in a mapped footprint, the acres total more than the 13,256 acres known in the project area.

Smaller populations of weed species pose a threat because of their ability to take over a plant community and 

their potential to spread. Once they become established across large areas, these species are difficult to 

eradicate. Also, the weed survey results likely underestimate actual weed infestations on the two national 

forests, since many areas have not been surveyed. 

In valley bottoms or in riparian areas, complexes of saltcedar/Siberian elm/Russian olive/bull thistle are 

common, along with populations of bull thistle, Canada thistle, and musk thistle. Wildlife species depend 

heavily on riparian areas in the arid Southwest, and the ability of weeds to reduce native plant diversity has a 
Final Supplemental Environmental Impact Statement

21

magnified impact on the wildlife habitats. Travel corridors have the most known weeds. Weeds along roads 

and trails are easily surveyed, and weeds also tend to become established in disturbed areas such as rights-ofway. Bull thistle and Canada thistle are the most likely to spread, but small populations of leafy spurge found 

along Highways 285 and 64 near Tres Piedras also pose a threat of spread. 

Away from valley bottoms, riparian areas, and main travel routes, Canada thistle, musk thistle, and bull thistle 

pose the largest threat of spreading because of their ability to adapt to a wide variety of habitats. On the 

Jicarilla Ranger District, infestations of Scotch thistle and musk thistle are found at natural gas wellheads and 

along roads leading to these facilities. Although the amount of Scotch thistle is relatively small, the potential 

for spread is high because of the intermingled land ownership and use in this area. Along the Rio Tusas 

drainage, the amount of leafy spurge is relatively small, but when the threat is greater when seen in the 

context of infestations on adjacent private land. 

On average, weeds are projected to increase annually in the United States at a rate of 8 to 12 percent per year 

without treatment (FICMNE 1998). Projections on the two national forests indicate the spread is expected to 

be between 5 and 30 percent annually. The low end of this range is lower than the national average for some 

species based on arid growing conditions in the Southwest. Saltcedar found in riparian areas is expected to 

increase at a slower rate due, in part, to the release of the saltcedar leaf beetle (Diorhabda spp.) as a 

biocontrol agent. Leafy spurge would likely increase at the higher rate. For purposes of this analysis, an 

estimate of 8 percent per year is used in order to account for growth without overstating the estimates in the 

face of the variable nature of the species and other conditions. 

Appendix 7 lists the most effective treatments for known weed species on the Carson and Santa Fe National 

Forests. In most cases, weed-infested sites require repeat treatments in the same area to meet the treatment 

objectives (for example, complete eradication or long-term control). For most deep-rooted perennial weeds, 

effective control with the least amount of soil disturbance may only be achieved through herbicide 

application.

Management Direction–Desired Condition 

[No change from final environmental impact statement]

Other Direction

[Replaces entire section]

Other management direction relevant to this project includes the following:

Forest Service Manual 2900 – Invasive Species Management (December 5, 2011): Specifies 

management activities for invasive species will be based upon an integrated pest management approach. 

It prioritizes prevention, early detection and rapid response, control and management, restoration, and 

organizational collaboration as needed.

Executive Order 13112 (February 3, 1999): As pertains to this project, it directs Federal agencies to: ... 

(2)(b) detect and control [invasive] species; (c) monitor population of such species; and (d) provide for 

restoration of native species. 

“2008-2012 National Invasive Species Management Plan” (August 1, 2008): Directs Federal efforts 

(including overall strategy and objectives) to prevent, control, and minimize invasive species and their 

impacts through 2012. The plan gives Federal agencies, including the Forest Service, broad authority to 

prevent the spread of invasive species and authorizes them to assist State and private entities in their 

prevention efforts. 
Invasive Plant Control Project

22

“USDA Forest Service National Strategy and Implementation Plan for Invasive Species 

Management” (USDA Forest Service, October 2004): Provides overall strategic direction for addressing 

invasive species. It contains four elements: prevention, early detection and rapid response, control and 

management, and rehabilitation and restoration. 

New Mexico Executive Order 00-22 (NMEO 2000): Directs state executive agencies to manage weed 

infestations designated by the New Mexico Department of Agriculture as Class A weed infestations on 

state land rights-of-way by making use of integrated pest management techniques. 

Noxious Weed Management Act (1978): The State of New Mexico enacted this legislation to recognize 

the adverse economic and environmental impacts of weeds and the need for action to reduce this threat. 

Forest Service Manual 2150 – Pesticide-Use Management and Coordination (USDA Forest Service

2013b): Provides requirements for use of pesticides (including herbicides). 

Other laws, regulations, and policies will be followed as they apply to the control of weeds on National Forest 

System lands.

Proposed Action

[Replaces 1st paragraph]

The proposed action is an integrated set of management actions considered necessary to control weeds on the 

Carson and Santa Fe National Forests with the goal of completely eliminating them or at least preventing their 

spread. Under policy stated in Forest Service Manual 2903, invasive weeds and other invasive species in 

aquatic and terrestrial areas of the National Forest System are to be managed by using an integrated pest 

management approach. The integrated pest management approach recognizes using only one treatment 

method is unlikely to be effective. Treatment methods used in conjunction with integrated pest management 

involve four broad categories: 

1. Mechanical/Physical (mowing, prescribed burning, etc.), 

2. Cultural (re-seeding, fertilizing, etc.), 

3. Biological (grazing, use of biocontrol agents, etc.), and 

4. Chemical (use of herbicides).

Weeds proposed for treatment are those on the New Mexico Department of Agriculture’s noxious weeds list

at the time of this writing or listed in the future. As of this writing, 21 of the 37 listed weeds are known to 

occur in the Carson and Santa Fe National Forests, and 5 have the potential to occur. The two national forests 

do not intend to treat medicinal plant species such as St. John’s wort (Hypericum perforatum) and wild 

licorice (Glycyrrhiza lepidota).

[Replaces 1st paragraph, p. 29]

Treatments would begin in 2017 and would take place for at least 10 years:

1

♦ Each national forest expects to treat an average of 300 to 800 acres per year (600 to 1,600 per year for 

both forests on average) depending on funding and methods used.

♦ Each national forest expects to treat no more than 1,500 acres per year (3,000 per year for both forests 

as a maximum).

 1 The timeframe for the effects analysis in this supplement is 10 years. The two national forests expect to have controlled most weed 

populations by then; however, treatments are expected to be ongoing since completely preventing new introductions isn’t likely.
Final Supplemental Environmental Impact Statement

23

[Replaces 4th paragraph, p. 29]

The adaptive management approach was further defined in January 2005 when the Forest Service published 

planning rules that recognize the role of adaptive management in implementing forest plans:

Adaptive management is an approach to natural resource management where actions are designed and 

executed and effects are monitored for the purpose of learning and adjusting future management 

actions, which improves the efficiency and responsiveness of management. (36 CFR 219.16, 70 FR 

1060) 

In 2008, Forest Service National Environmental Policy Act regulations at 36 CFR § 220.3 defined adaptive 

management as “[a] system of management practices based on clearly identified intended outcomes and 

monitoring to determine if management actions are meeting those outcomes; and, if not, to facilitate 

management changes that will best ensure that those outcomes are met or reevaluated. Adaptive management 

stems from the recognition that knowledge about natural resource systems is sometimes uncertain.”

[Replaces last sentence of 1st paragraph, p. 30]

This strategy is consistent with Forest Service guidelines on applying adaptive management to site-specific 

environmental analysis for weed management projects (USDA Forest Service 2011b).

[Replaces all bullet points on p. 30]

The proposed weed control program involves the following steps:

• Inventory by searching places with a high likelihood for new weed populations, and enter new weed 

locations in the Geographic Information System (GIS) database. 

• Prioritize and select appropriate treatment methods based on criteria in the final environmental impact 

statement and this final supplemental environmental impact statement (chapter 2), including applicable 

design features based on site conditions.

• Develop an implementation plan that is reviewed and updated annually, including coordination with other 

agencies regarding weed control activities.

• Complete any needed heritage, plant, and wildlife surveys.

• Complete any needed permits (chapter 2).

• Notify the public about the annual weed treatment schedule and site-specific locations. 

• Implement weed control treatments. 

• Monitor for: 

♦ treatment effectiveness in meeting weed control objectives; 

♦ effects on other resources relative to those predicted in the final environmental impact statement and 

this final supplemental environmental impact statement; and 

♦ implementation and effectiveness of design features used to minimize adverse impacts.

• Evaluate and document monitoring results for use in future weed treatment prescriptions.

Forest Plan Amendment

[Replaces entire section]

Alternatives B and D include a nonsignificant, programmatic amendment to the Santa Fe National Forest 

Plan. The amendment would allow the use of herbicides in places currently prohibited by forest plan 
Invasive Plant Control Project

24

standards and guidelines. These areas are in municipal watersheds and on soils with low revegetation 

potential. Chapter 2 provides the exact language of the proposed amendment. The Carson National Forest 

Plan does not prohibit the use of herbicides in any specific areas.

Decision-making Framework

[Replaces “EIS” with “SEIS.” Adds this paragraph]

The incorporation of the amendment will be conducted through use of the 1982 rule procedures as allowed by 

the transition language of the 2012 planning rule (36 CFR 219.17(b)(3)).

The predecisional administrative review process (known as the objection process2

) required for the project 

will also be used for administrative review of the proposed amendment for the selected alternative (36 CFR 

219.59(b)).

Public Involvement

[Replaces entire section]

Collaboration and Scoping

In 1996 and 1997, the Forest Service met informally with other Federal, State, and County agencies to discuss 

the threat of weeds and coordinate treatments. Newspaper articles were also published to inform the public 

about the threat of weeds and the full range of treatment options, such as those being considered by the Forest 

Service. In 1998, the two national forests began scoping for this project, starting with public meetings held in 

Taos and Espanola. In March 2000, a scoping letter was sent to approximately 450 individuals, agencies, 

Tribes, and organized groups to inform them about the weed control treatment proposals. At that time, each 

forest was independently working on separate environmental assessments for forestwide weed control 

projects. As a result of the March 2000 scoping, a decision was made to combine the efforts of the two 

national forests and document the analysis in an environmental impact statement. 

In December 2000, the Forest Service sent a new scoping letter to the public about the proposed action. On 

December 15, 2000, the Forest Service published a notice of intent to prepare an environmental impact 

statement in the Federal Register. At the request of local citizens, a field trip was conducted to discuss weed 

infestations and show people the weed conditions on the Tres Piedras Ranger District. 

The Forest Service first contacted Tribal governments about treating weeds in 1999. They included the Tribal 

governments in their March and December 2000 scoping efforts. In December 2003, the Forest Service sent

another letter to all potentially affected Tribal governments to initiate consultation and solicit their comments 

about the proposed project. 

A total of 34 individuals and 30 organizations commented during scoping. The largest number of comments 

questioned the need for treatment when other solutions, such as eliminating grazing and closing roads (which 

they considered to be the source of weeds), were available. Education was also suggested as a means of 

dealing with the weed problem. Some respondents suggested education as a substitute for treatment; others,

presented it as a complementary activity.

The treatment that appeared to be of greatest concern to those who commented was the use of herbicides. 

Most opposition was based on concerns that herbicides could adversely impact human health, nontarget 

plants, and wildlife. Concerns over the impact to water quality and fish were also mentioned. Some 

respondents voiced concerns that herbicides were too nonselective and their impacts would be too broad. 

Potential impacts to people with multiple chemical sensitivities were mentioned as reason to avoid using 

 2 See 36 CFR 218, Final Rule for Project-level Predecisional Administrative Review Process
Final Supplemental Environmental Impact Statement

25

herbicides and any associated chemicals (for example, inert ingredients in the formulations). Suggestions 

were made to use a wide variety of nonchemical methods, such as hand digging (possibly enlisting volunteers 

to do this work) and using goats to graze the weeds where possible. In addition to the letters responding to the 

scoping letters, a petition with approximately 1,000 signatures was submitted stating opposition to the use of 

herbicides in managing weeds on the Carson National Forest. 

One comment also raised concerns with using biological agents because of the possibility of introducing an 

insect that would have unforeseen effects, such as getting out of control itself. 

Others stated chemicals might be used under controlled conditions so people who use the two national forests 

to collect and use certain products would not be adversely impacted from herbicides or other methods would 

not destroy these culturally and economically important plants. 

Another set of comments supported the need to treat weeds and supported use of the integrated approach 

(including herbicides), as long as appropriate oversight is given to the efforts so they are coordinated within 

the two national forests and with other agencies conducting similar efforts. Some comments in this set also 

noted strong monitoring should be a priority to be successful.

Using the comments sent during scoping, the Forest Service’s interdisciplinary team identified four 

significant issues (see “Issues” section). The team then created alternatives C and D to respond to these issues. 

In May 2004, a four-page update was mailed to known interested or affected parties. It described the final 

issues and alternatives, as well as the status of the draft environmental impact statement and estimated release 

date.

Public Comment on the Draft Environmental Impact Statement

On July 16, 2004, the Forest Service published a notice of availability of the draft environmental impact 

statement in the Federal Register. The legal notices announcing the start of the 45-day comment period were 

published in the newspapers of record on July 22, 2004. The Forest Service received 106 letters on the draft 

environmental impact statement; of these, 7 were received after the end of the comment period, which was 

August 30, 2004.

The Forest Service’s interdisciplinary team identified approximately 750 individual comments contained in

the letters. Use of herbicides continued to be a main concern among members of the public. In response, the 

final environmental impact statement clarified and expanded the discussion of the risks associated with the 

use of herbicides (see appendix 3 of the final environmental impact statement). Appendix 9 of the final 

environmental impact statement responds to comments received on the draft environmental impact statement. 

Other relevant comments were incorporated into the final environmental impact statement.

Appeal of the Record of Decision

On September 12, 2005, the Carson and Santa Fe National Forest Supervisors signed a record of decision 

selecting alternative B. The Forest Service published the notice of availability of the final environmental 

impact statement and record of decision in the Federal Register on November 18, 2005. The legal notices 

announcing the start of the 45-day appeal period were published in the newspapers of record on November 

23, 2005. Eight appeals of the decision were submitted. The Forest Service met with the appellants but was 

unable to resolve the issues stated. The Deputy Regional Forester reversed the decision on February 23, 2006.

Draft Supplemental Environmental Impact Statement 

The Forest Service prepared a draft supplemental environmental impact statement to correct the deficiencies 

identified by the Deputy Regional Forester and to update the analysis and facts where needed pursuant to 40 

CFR 1502.9(c)(1). In accordance with the Council on Environmental Quality regulations at §1502.9(c)(4), the

draft supplemental environmental impact statement was “prepare(d), circulate(d), and file(d) ... in the same 
Invasive Plant Control Project

26

fashion (exclusive of scoping) as a draft and final statement.” The project was not re-scoped, but the public 

had the opportunity to comment on the draft supplemental environmental impact statement before a final 

decision.

In February 2012, the Forest Service sent postcards to 274 people and organizations anticipating the draft 

supplemental environmental impact statement would be published that spring and asking them how they 

would like to be notified. Seventeen responses were received.

On March 21, 2014, the Forest Service published a notice of availability of the draft supplemental 

environmental impact statement in the Federal Register. The legal notices announcing the start of the 45-day 

comment period were published in the newspapers of record on March 24, 2014. The Forest Service received 

33 letters on the draft supplemental environmental impact statement.

The Forest Service’s interdisciplinary team identified approximately 75 individual comments contained in the 

letters. Use of herbicides continued to be a main concern among members of the public. Appendix 10 of the 

final supplemental environmental impact statement responds to comments received on the draft supplemental 

environmental impact statement.

The Forest Service has published regulations that institute an objection process in lieu of the appeal process. 

This project and its decision will fall under the objection process, whose regulations are found at 36 CFR 218.

Issues

[Add this sentence to first paragraph; otherwise, no change from final environmental impact statement]

For this final supplemental environmental impact statement, the responsible officials have retained the four 

significant issues from the final environmental impact statement. The analysis of the public’s comments 

conducted in 2004 remains valid.
Final Supplemental Environmental Impact Statement

27

Chapter 2. Alternatives, Including the Proposed Action

Introduction

[No change from the final environmental impact statement]

Alternatives Considered but Eliminated from Detailed Study

[Add sentences to end of section “Organic Treatment Methods”]

The Carson National Forest has inexpensively and effectively used plastic sheeting to cover and eradicate 

weeds on areas less than 1⁄4 of an acre. The drawbacks to this method are its unsightliness, time required to kill 

the weeds, lethal effects on non-target plants, and creation of bare ground that is susceptible to soil erosion. 

Nonetheless, weed barriers, when shown to be effective and to meet the criteria of the adaptive strategy in the 

final environmental impact statement, may be used by the two national forests. 

Alternatives Considered in Detail

Alternative A–No Action

[Replaces entire section]

Under the no-action alternative, weed treatments would not occur. This means neither forest would have an 

integrated, forest-wide approach to managing weeds. Previously approved, project-specific weed treatments, 

such as those along the lower Jemez River, would be implemented, along with those of other jurisdictions 

within the national forest boundaries, such as along Federal, State, and County roads. Weed inventories and 

prevention activities would continue to occur. 

Alternative B–Proposed Action (Integrated Strategy)

[Additional paragraph]

The known weed populations have a footprint of 13,256 acres. This is a snapshot in time and does not 

necessarily encompass the full extent of acreage proposed to be treated. The proposed action would treat 

existing weeds and new populations as they are discovered. Any new populations to be treated must be on 

New Mexico Department of Agriculture’s weed list and must follow the adaptive management strategy 

described in chapter 2.

[Remove figure 3 and refer to figure S-2] 

Figure S-2 on page 19 shows the locations of the known weed populations. Appendix 7 shows how each 

species would be treated. 
Invasive Plant Control Project

28

[New photo]

Photo 2. Hand-grubbed patch of bull thistle (Santa Fe National 

Forest photo)

[Replaces first two sentences of second paragraph of section under “Herbicides”]

Thirteen herbicides are proposed for use: 2,4-D, aminopyralid, clopyralid, chlorsulfuron, dicamba, 

glyphosate, hexazinone, imazapic, imazapyr, metsulfuron methyl, sulfometuron methyl, picloram, and 

triclopyr. The herbicide aminopyralid has been added as a proposed herbicide in this final supplemental 

environmental impact statement; the others were proposed and analyzed in the final environmental impact 

statement. Appendix 3 contains detailed information about each. Treatments using the herbicides are tailored 

to specific species and site conditions.

[Replaces entire section under “Mechanical”]

Mechanical control methods include actions such as mowing, girdling, or root tilling. Mowing cuts plants off 

above ground. Root tilling digs into the soil to unearth the roots. Girdling is a method that may be used for 

invasive trees, such as Siberian elm (photo 3). 

Photo 3. Girdled trees (photo courtesy of Tom Kaye, Institute for 

Applied Ecology) 
Final Supplemental Environmental Impact Statement

29

Mowing and root tilling employ large mechanized equipment such as tractors with specially designed 

attachments. These methods have not been demonstrated to be effective in eradicating or substantially 

reducing weed infestations, and typically require frequent repeat treatments. They do reduce plant and root 

vigor. Feasibility for these two methods is also quite limited on the two national forests due to the steep slopes 

and other common terrain features such as trees, boulders, or logs. Thus, this method is only likely to be for 

minor, incidental use, mainly along highways in conjunction with ongoing road maintenance actions. Most 

mechanical treatment is proposed in combination with another method.

[Replaces table 6]

The abbreviations shown below represent the kinds of treatments proposed in the action alternatives.

Treatment Method Abbreviation

Biological BIO

Grazing GR

Herbicides HE

Manual MA

Mechanical ME

Prescribed fire FR

Table S-7. Summary of treatments proposed for alternative B 

Treatment Acres 

Percent 

of Total

BIO, FR, GR, HE, MA, ME 4 0.03

BIO, FR, HE, ME 181 1

BIO, GR, HE 21 0.2

BIO, GR, HE, MA 1 0.005

BIO, GR, HE, MA, ME 16 0.1

BIO, GR, HE, ME 43 0.3

BIO, HE, MA 22 0.2

BIO, HE, MA, ME 4,052 31

BIO, HE, ME 400 3

FR, GR, HE, MA, ME 73 1

FR, GR, HE, ME 0 0.0003

FR, HE, MA, ME 14 0.1

FR, HE, ME 617 5

GR, HE, MA, ME 2,682 20

GR, HE, ME 2,999 23

HE, MA 497 4

HE, MA, ME 1,629 12

HE, ME 3 0.02

Grand Total 13,256
Invasive Plant Control Project

30

Alternative C–No Herbicides

[Additional paragraph]

The known weed populations have a footprint of 13,256 acres. This is a snapshot in time, and does not 

necessarily encompass the full extent of acreage proposed to be treated. Alternative C would treat existing 

weeds and new populations as they are discovered. Any new populations to be treated must be on New 

Mexico Department of Agriculture’s weed list and must follow the adaptive management strategy described 

in chapter 2.

[Remove figure 4 and refer to figure S-2]

Figure S-2 shows the locations of the known species of weed populations. Appendix 7 shows the method by 

which each species could be treated. Refer to page 29 for a key of abbreviations.

[Replaces table 7]

Table S-8. Summary of treatments proposed for alternative C

Treatment Acres

Percent of 

Total

BIO 12 0.09

BIO, FR, GR, MA, ME 4 0.0

BIO, FR, ME 181 1.4

BIO, GR 9 0.067

BIO, GR, MA, ME 16 0.1

BIO, GR, ME 43 0.3

BIO, MA 23 0.2

BIO, MA, ME 4,052 31.0

BIO, ME 400 3.0

FR, GR, MA, ME 73 1.0

FR, GR, ME 0 0.0003

FR, MA, ME 14 0.1

FR, ME 617 5.0

GR, MA, ME 2,682 20.0

GR, ME 2,999 23.0

MA 497 4.0

MA, ME 1,629 12.0

ME 3 0.02

Grand Total 13,256

Alternative D–Herbicides Only

[Additional Paragraph]

The known weed populations have a footprint of 13,256 acres. This is a snapshot in time, and does not 

necessarily encompass the full extent of acreage proposed to be treated. Alternative D would treat existing 

weeds and new populations as they are discovered. Any new populations to be treated must be on New 

Mexico Department of Agriculture’s weed list and must follow the adaptive management strategy described 

in chapter 2.
Final Supplemental Environmental Impact Statement

31

[Remove figure 5 and refer to figure S-2]

Figure S-2 on page 19 shows the locations of the known weed populations. Appendix 7 shows how each 

species would be treated.

[Replaces table 8]

Table S-9. Summary of treatments proposed for alternative D

Treatment Acres Percent of Total 

Herbicide 13,256 100

Total 13,256

Adaptive Strategy–All Action Alternatives

[No change from the final environmental impact statement]

Treatment Objectives, Priorities, and Decision Criteria

[No change from the final environmental impact statement]

Additional Criteria for Prioritizing and Determining Objectives and Methods

[No change from the final environmental impact statement]

[Replaces table 9]

Table S-10. Additional treatment criteria and limitations

Weed Site Conditions Treatment Method Limitations 

Area of high human use such as 

a recreation site, administrative 

site, or area where people often 

collect plants. 

Method(s) must have been documented to have a low risk of 

causing harm to people. Examples include non-herbicide methods 

with lowest risk (for example, those that avoid burning) or herbicide 

formulations and application methods having the lowest risk of 

harmful effects to humans (for example, aminopyralid, glyphosate, 

imazapyr, imazapic, metsulfuron methyl, clopyralid products would 

be available for use per risk assessment results found in appendix 

3). Also adhere to other design features that apply to protection of 

human health and safety (for example, notification). Use of 

herbicides shall occur during weekdays only.

Area where there is a shallow 

water table (no more than 6 feet 

deep) and soil with a high 

permeability rate, where there 

may be a risk of an herbicide 

leaching through the soil to the 

groundwater. 

Non-herbicide method(s) appropriate for the site conditions (manual 

pulling or mowing) or an herbicide appropriately labeled for use in 

these locations (for example, short-lived, non-leachable herbicides 

such as glyphosate, imazapic, imazapyr, metsulfuron methyl, 

clopyralid, chlorsulfuron) that have been registered by the 

Environmental Protection Agency for use on permeable soils with 

shallow water tables. Herbicides that use picloram as their active 

ingredient (for example, Tordon 22K) would not be used in these 

situations per risk assessment results. Also adhere to design 

features to protect soil and groundwater resources. 

In riparian areas, including 

outstanding national resource 

waters, or areas next to live water 

bodies containing aquatic 

species. 

Method(s) determined and documented to have low risk to fish or 

other aquatic species. Examples include a non-herbicide method (for 

example, mowing) that avoids erosion/sediment production or 

herbicides registered by the Environmental Protection Agency for 

aquatic habitats; for example, chlorsulfuron, glyphosate formulations 

such as Rodeo (which does not use the surfactant polyethoxylated 

tallowamine), imazapic, and imazapyr. Also adhere to design 

features to protect to riparian, water, and aquatic resources. 
Invasive Plant Control Project

32

Weed Site Conditions Treatment Method Limitations 

Threatened, endangered, or 

sensitive plant species are 

present. 

Method(s) determined and documented to have low risk to native 

plant species, such as non-herbicide methods (hand pulling) with 

appropriate disturbance controls. Herbicide applications include spot 

treatment (by hand or backpack spray) that avoid vehicle boom 

spray application of herbicides such as imazapyr, imazapic 

clopyralid, chlorsulfuron, because they have high potential to affect 

non-target plants up to several hundred feet away. Herbicides, if 

used from boom spray, could be used if risk ratings are similar to 

2,4-D, which has low risk of impact beyond 25 feet of drift. For Holy 

Ghost ipomopsis, see specific design features later in this section. 

Adhere to design features to protect threatened, endangered, or 

sensitive plant species, including limitations on herbicide spraying 

from vehicles. 

Occupied threatened, 

endangered, or sensitive wildlife 

species habitat. 

Method(s) used must have been determined to have low risk to 

wildlife species. These methods include non-herbicide methods at 

the proper timing (for example, burning outside seasonal 

restrictions). Herbicide applications must be shown to be below the 

level of concern through specific risk assessment for the herbicide 

used when applied in these habitats (see appendix 3). No direct 

application of herbicides to water would be permitted under the 

adaptive strategy even where formulations are registered for such 

use (for example, AquaKleen formulation of 2,4-D). This restriction is 

imposed because of possible effects of direct application to Rio 

Grande cutthroat trout. Also adhere to other design features to 

protect threatened, endangered, or sensitive wildlife species. 

Wilderness and designated 

nonmotorized areas. 

Motorized vehicles and mechanized equipment are prohibited in all 

wilderness areas. In the Pecos Wilderness, sheep or goat grazing 

for weed control would continue to be prohibited by an existing 

closure order. In other locations of Rocky Mountain bighorn sheep 

habitat, managed grazing for weed control would also be prohibited. 

See design features. 

Santa Fe and Gallinas municipal 

watersheds in the Santa Fe 

National Forest

Method(s) must have been documented to have a low risk of 

causing harm to people. Examples include non-herbicide methods 

with lowest risk (for example, those that avoid burning) or herbicide 

formulations/application methods having the lowest risk of harmful 

effects to humans. For example, aminopyralid, glyphosate, 

imazapyr, imazapic, metsulfuron methyl, and clopyralid products 

would be available for use per risk assessment results found in 

appendix 3. Also adhere to other design features to protect human 

health and safety (for example, notification). Method(s) used must be 

approved by the appropriate officials of the cities of Santa Fe and 

Las Vegas, New Mexico. Picloram will not be used in municipal 

watersheds.
Final Supplemental Environmental Impact Statement

33

Design Features and Monitoring Requirements

[Replaces table 10]

Table S-11. Design features and monitoring requirements for all alternatives

Row 

No. Description of Design Feature and Monitoring Requirement Alternatives

Human Health and Safety

1 Herbicide formulations (specific products including mixtures) will not be used 

unless they have been registered for use by the Environmental Protection 

Agency and all Environmental Protection Agency label requirements (including 

limitations) are strictly followed. Only herbicides with a completed risk 

assessment per Forest Service standards would be used.

B, D

2 In areas of human habitation or high use such as a recreation site, administrative 

site or area where people often collect plants, the treatment method must have 

low risk of harmful effects to humans. Examples include nonherbicide methods 

(manual/mechanical/grazing) or herbicides rated as having the lowest risk of 

harmful effects to humans (see appendix 3).

B, D

3 Herbicide application will strictly adhere to Environmental Protection Agency label 

instructions regarding temperature, humidity, wind speed and other weather 

variables, to avoid spray drift to nontarget plants or other resources while 

increasing treatment effectiveness.

B, D

4 Herbicide use will be restricted to Environmental Protection Agency-registered 

application rates (usually in terms of pound per acre of active ingredient applied) 

and conditions listed on the label. Follow-up application of a second herbicide to 

an area should be conducted only after reviewing best available information on 

compatibility with the previous application’s formulation.

B, D

5 Herbicides may only be applied by a trained applicator under supervision of a 

licensed applicator, in accordance with Forest Service directives.

B, D

6 Herbicide use will comply with the direction contained in Chapter 2150 of Forest 

Service Manual 2100 - Environmental Management (USDA Forest Service

2013b), including the requirement that a pesticide use proposal (form FS-2100-2) 

be completed for all proposed pesticide (that is, herbicide) uses on National 

Forest System lands.

B, D

7 Herbicide applicators will have the chemical spill plan and emergency cleanup kit 

onsite during treatments. The spill plan identifies methods to avoid accidental 

spills as well as how to report and clean up spills. The kit will contain appropriate 

spill cleanup supplies (see appendix 6).

3

B, D

8 Workers handling herbicides will be required to wear protective clothing, including 

a long-sleeved shirt and long pants to reduce worker doses. For herbicides 

containing hexazinone, respiratory protection would also be required per label 

direction. Clothes should be cleaned daily. Workers will also wear waterproofed 

boots, gloves, and other safety clothing and equipment listed on the herbicide

label. Workers mixing or loading herbicides will be required to wear eye 

protection (goggles or eye shields) and Tyvek suits or herbicide-resistant aprons.

B, D

9 A pesticide application record (PAR) will be completed on a daily basis for each 

project area detailing the herbicide application, treatment area, target species 

distribution and density, weather conditions, and recommendations for followup 

treatments or rehabilitation.

B, D

10 The Forest Service will provide public information about weed treatments using 

herbicides, including herbicide to be used, locations, application schedules, and 

so forth. This information will be posted on the Santa Fe and Carson National 

Forest websites and mailed to those who request it.

B, D

 3 A comment on the draft environmental impact statement submitted in 2004 by the New Mexico Environment Department states that 

in the event of spills, the Ground Water Quality Bureau Chief must be notified. This requirement is listed in Appendix 6 on page 295 

under “Major Spills”.
Invasive Plant Control Project

34

Row 

No. Description of Design Feature and Monitoring Requirement Alternatives

11 To further notify forest visitors and users, signs regarding herbicide use will be 

placed at access points to treatment areas prior to herbicide application. Signs 

will include the herbicide to be used, effective dates, and phone number for 

obtaining more information.

B, D

12 Traffic control and signing during weed treatment operations will be used as 

necessary to ensure safety of workers and the public. Recreation sites, roads, 

trails, or other areas scheduled for treatment may be temporarily closed during 

weed treatment activities to ensure public safety.

B, C, D

13 Weed treatments will be coordinated with potentially affected adjacent 

landowners and range allotment permittees. Cooperative efforts on adjacent 

lands and range allotments would increase treatment effectiveness and the ability 

to meet weed control objectives.

B, C, D

14 In highly used, developed recreation areas, use of herbicides would occur during 

weekdays only.

Native Vegetation and Treatment Effectiveness

15 Prescribed burning, digging, pulling, and tilling weeds, and other grounddisturbing activities will be designed to avoid or minimize impacts to native plants 

of cultural and traditional concerns. Prior to implementation, a Forest Service 

biologist or other qualified person will locate these plants to the extent possible.

B, C, D

16 Allotment permittees will be contacted about upcoming treatments (methods, 

locations, schedules, and so forth) that may affect their grazing operations. 

Annual operating instructions may be adjusted as needed. Early coordination will 

minimize the impact of adjusting grazing operations during and after treatments, 

the extent and duration of which will be determined by site-specific conditions 

and weed treatment objectives. 

B, C, D

17 Weed treatments will only be applied where weeds actually exist, not on areas 

with a potential for weed infestations.

B, C, D

18 Vehicles used for weed treatments will be properly cleaned prior to entering 

National Forest System lands and again before leaving the treated area to avoid 

further spread of weeds.

B, C, D

19 Where treatments result in exposing bare mineral soil, those sites will be 

evaluated to determine the need for revegetation (seeding, planting), mulching, 

or other erosion or sediment control measures. The evaluation would consider 

the potential for subsequent reinvasion by weed species, potential for erosion, 

water runoff, and stream sedimentation. Where seeding is used, certified weedfree seed will be required. Seed mixes will be based on site-specific conditions 

and objectives. Treatment combined with reseeding has been shown to be 

effective at controlling weeds (Endress et al. 2012).

B, C, D

20 Herbicides will not be applied if snow or ice covers the target weed plants to 

avoid runoff into soil and onto nontarget vegetation.

B, D

21 After treatment, livestock grazing will be deferred where needed to achieve weed 

treatment objectives, based on site-specific conditions. This will be accomplished 

by working with permittees and adjusting their annual operating instructions as 

necessary.

B, C, D

22 Biological agents will not be released until screened for host plant specificity and 

approved by the U.S. Department of Agriculture Animal Plant Health Inspection 

Service and the New Mexico Department of Agriculture.

B, C

23 All weeds that are mechanically or hand excavated after flower bud stage will be 

double bagged and properly disposed of at an approved facility (for example, a 

covered landfill).

B, C

24 Use of prescribed fire must adhere to restrictions contained in the forest plan and

Forest Service directives, such as those for using fire within wilderness (Forest 

Service Manuals 2324.2 and 2324.04(b)), requirements for detailed burn 

prescriptions, and other requirements intended to avoid unexpected 

consequences.

B, C
Final Supplemental Environmental Impact Statement

35

Row 

No. Description of Design Feature and Monitoring Requirement Alternatives

Threatened, Endangered and Sensitive Plants

25 The Santa Fe National Forest or Pecos-Las Vegas Ranger District will coordinate 

with the New Mexico Environment Department (NMED) and U.S. Fish and 

Wildlife Service to obtain the most current survey information on the Holy Ghost 

ipomopsis prior to implementing any weed treatments in occupied Holy Ghost 

ipomopsis habitat.

B, C, D

26 Ground-disturbing activities, such as tilling, pulling, and digging up weeds, will be 

designed to avoid trampling or other direct impacts to individual Holy Ghost 

ipomopsis plants or other threatened, endangered, and sensitive plants.

B, C

27 Herbicide use is prohibited within, and for 25 feet around, Holy Ghost ipomopsis 

plants and occupied habitat; only hand removal by pulling or digging up weeds 

will be permitted. From 25 to 50 feet, only hand application of herbicides by wick 

or rag will be permitted.

B, D

28 Prior to implementing any managed grazing, spray application of herbicides, 

mechanical (for example, mowing), or prescribed fire treatments within Holy 

Ghost ipomopsis or other sensitive plant species habitats, a Forest Service 

biologist or other qualified person will visibly mark a 50-foot buffer around groups 

or isolated individuals of the subject plants. 

B, C, D

29 Within, and for 25 feet around, other sensitive plants occupied habitats, only 

hand treatments will be permitted (for example, wick or rag to apply herbicides; 

shovel to dig up weeds); no spray herbicide application will be permitted.

B, C, D

30 A Forest Service biologist or other qualified person will be present during any 

ground-disturbing activity within Holy Ghost ipomopsis and other sensitive plant 

species occupied habitats.

B, C, D

31 Where Holy Ghost ipomopsis or other sensitive plant roots may be intermingled

with weed roots, a Forest Service biologist or other qualified person will 

determine how to safely remove the weed(s).

B, C, D

32 Herbicide use proposals within any threatened, endangered, or sensitive plant 

species potential habitat will require a survey of that habitat, if possible. If no 

survey is conducted, the potential habitat will be treated as if occupied by the 

threatened, endangered, or sensitive plant and all applicable occupied habitat 

design features will apply.

B, D

Wildlife, including Threatened, Endangered and Sensitive Species

33 For treatment areas exceeding 1 acre within threatened, endangered, or 

sensitive species wildlife habitat, surveys for the species will be conducted prior 

to implementation. If surveys are not conducted prior to implementation, that area 

will be treated as if occupied. Within occupied threatened, endangered, or

sensitive species habitats, loud, persistent noise disturbances or modifications of 

breeding habitat features will be avoided. If a potentially adverse effect cannot be 

avoided, prepare a supplemental biological assessment and consult with U.S.

Fish and Wildlife Service to determine the appropriate design features. 

B, C, D

34 For occupied Mexican spotted owl and southwestern willow flycatcher habitat, 

applicable breeding season restrictions will be implemented as specified in forest 

plans and U.S. Fish and Wildlife Service recovery plans for those species. 

B, C, D

35 In areas that have suitable habitat for wintering bald eagles and where weed 

treatments are proposed during that period (winter months through March), a 

presence/absence survey must be completed within a 0.5-mile radius of the work 

site before any work can begin and following any breaks of more than 10 days. If 

an eagle is present within the 0.5-mile radius, work will stop until the bird leaves 

of its own volition or if, in consultation with the U.S. Fish and Wildlife Service, a 

Forest Service biologist determines that the potential for harassment is minimal. 

If bald eagles nest on National Forest System land within 0.5-mile of areas 

planned for treatment, the U.S. Fish and Wildlife Service will be contacted to 

determine what additional consultation may be needed.

B, C, D
Invasive Plant Control Project

36

Row 

No. Description of Design Feature and Monitoring Requirement Alternatives

36 Survey to protocol must be completed for all treatment units within southwestern 

willow flycatcher occupied habitat (Carson National Forest) before treatment can 

begin, if the timing of treatment coincides with dates birds are likely to be present 

in the area. If the flycatcher is found, no treatments can occur; if the flycatcher is 

not found, treatment can proceed. 

B, C, D

37 No prescribed burns will be done within Mexican spotted owl protected activity 

centers. Treatments will be done by hand pulling, grubbing, or herbicide 

application during part of the breeding season (early June to mid-July) to be 

effective. Treatments will be short-duration, low-disturbance activities that would 

occur once or twice in a season (depending on size of the treatment area). A 

biologist can accompany applicators to monitor any owl activity that might occur. 

A year after treatment, monitoring would be done for any reoccurrence of the 

weed.

B, C

38 In areas proposed for treatment occupied by Forest Service sensitive wildlife 

species, and where individuals in the population may be impacted, a Forest 

Service biologist will prescribe design features to avoid or minimize the impacts 

to individuals, while continuing to maintain population viability and avoid a trend 

toward Federal listing.

B, C, D

39 Only herbicides documented to have a low risk to wildlife and domestic animals 

(for both ingredients and application rates) will be used. 

B, D

40 No controlled grazing with sheep or goats will be permitted in areas occupied or 

frequented by bighorn sheep (high country/wilderness).

B, C

41 No weed treatments will occur in Jemez Mountain salamander habitat during the 

late summer monsoon season when salamanders are above ground. In areas 

receiving 5 consecutive days of rain, treatments will be stopped until a Forest 

Service biologist or other qualified person determines the surface has dried 

sufficiently to resume treatment.

B, C, D

42 No herbicide or soil-disturbing treatments, including controlled grazing, will occur 

within 50 feet of Rio Grande cutthroat trout occupied streams between June 1 

and June 30 (spawning season).

Air, Soil, Water, Riparian, Fish, and Other Aquatic Resources

43 All prescribed burning must comply with the New Mexico smoke management 

requirements (permitting, monitoring, and so forth) to maintain levels of these 

emissions within State and Federal air quality standards.

B, C

44 Heavy mechanized equipment such as tractors with tillers or mowers will not be 

used on slopes over 40 percent, to minimize erosion potential.

B, C

45 Heavy equipment will not be used to mechanically dig up weeds within riparian 

zones unless a Forest Service soil, water or fisheries specialist examines the 

site-specific conditions and determines there would be no adverse impacts to 

water quality, stream morphology, or aquatic resources.

B, C

46 Herbicides used within 25 feet of a waterbody, or within riparian or other areas 

with a shallow water table, will be restricted to hand application of a short-lived, 

nonleachable herbicide that has been registered by the Environmental Protection 

Agency for use on permeable soils, near water, or in areas having shallow water 

tables (for example, 2,4-D, glyphosate, triclopyr). Herbicides with picloram as 

their active ingredient (for example, Tordon 22K) will not be used in these 

locations or within the municipal watersheds of the Gallinas and Santa Fe Rivers. 

A Forest Service soil, water, or fisheries specialist, or other qualified person will 

verify and map, and if necessary, visibly mark these areas. 

B, D

47 Herbicide application within a riparian area or 50 feet from a waterbody is limited 

to hand application onto individual weed plants (using backpack spray wand or 

glove, wick, or rag). Backpack spray application upwind of surface water or when 

precipitation is likely will be avoided. If necessary, a Forest Service soil, water, or 

fisheries specialist, or other qualified person will visibly mark these areas prior to 

implementation.

B, D
Final Supplemental Environmental Impact Statement

37

Row 

No. Description of Design Feature and Monitoring Requirement Alternatives

48 Mixing, pouring, loading, or transferring herbicides (even small amounts) will not 

occur within 200 feet of open water and will comply with the approved chemical 

handling, and spill prevention and containment plan (see appendix 6). In the 

event of a spill of sufficient quantity that would reasonably injure or be detrimental 

to human health, animal or plant life, or property, the Forest Service will contact 

the New Mexico Environment Department Ground Water Quality Bureau chief 

and Surface Water Quality Bureau chief. 

B, D

49 In riparian areas or next to live waterbodies containing fish, methods used must 

have been documented to have low risk to aquatic species.

B, C, D

50 Prescribed burning in riparian areas will be incidental to the primary activity (for 

example, pile burning slash from mechanical treatment of woody invasive 

species). No broadcast burning will be permitted in riparian areas solely for the 

purpose of treating weeds.

B, C

Heritage Resources

51 Adhere to “Appendix F - Standard Consultation Protocol for Noxious Weed 

Control” of the First Amended Programmatic Agreement Regarding Historic 

Property Protection and Responsibilities, including conducting preimplementation heritage inventories and evaluations, applying appropriate design 

features to avoid adverse impacts, consulting with the State Historic Preservation 

Office and Tribes, and monitoring treatment activities for effects to cultural 

resources. 

B, C, D

52 Ground-disturbing activities will be designed to avoid direct impacts to cultural 

resource sites. Root tilling, mowing, hand pulling, digging, or other weed 

treatments that disturb the soil beyond an aggregate of one meter square will 

require heritage inventory, evaluation, and consultation with the State Historic 

Preservation Office and Tribes. Follow the protection measures specified under 

stipulation 6 in appendix F of the protocol discussed in #51 above.

B, C

53 No herbicides will be applied from vehicles within 25 feet of cultural resources 

consisting of perishable materials with analytic or informational value, including 

wood, organic ceramic paints, datable materials, and residues on artifacts. Within 

25 feet of such cultural resources, herbicides must be applied by hand to 

individual weeds to avoid getting herbicides or carrier fluids onto those remains. 

Prior to implementation, a Forest Service archaeologist or other qualified person will 

mark areas for hand application or avoidance.

B, D

54 Apply the design features listed previously under Native Vegetation and 

Threatened, Endangered, and Sensitive Plants to minimize potential harm to 

plants of ethnographic concern and native plants.

B, C, D

55 Notification of Tribes and other traditional use groups will occur before herbicides 

are used to inform them of pending chemical treatment activities and schedules. 

This measure will reduce the risk to native plants used for traditional cultural 

purposes and the risk to the health of individuals who gather these plants. 

B, C, D

56 Sheep or goat grazing will not be used on heritage resource sites easily 

damaged by trampling as identified through heritage resource inventories prior to 

implementation.

B, C

57 Conduct fuel assessments and remove fuels from around cultural resource sites 

with perishable materials before prescribed burning or avoid burning around sites 

with perishable materials altogether. Use burn prescriptions that ensure low 

temperature, intensity, duration, and residence time on sites that fire will burn 

through.

B, C

Municipal Watersheds

58 Weed treatments within the Santa Fe and Gallinas municipal watersheds will be 

agreed to and coordinated with the appropriate officials for the cities of Santa Fe 

and Las Vegas, respectively. Proposed use of herbicides within these municipal 

watersheds would occur only upon agreement from officials of these cities.

B, C, D
Invasive Plant Control Project

38

Row 

No. Description of Design Feature and Monitoring Requirement Alternatives

Monitoring and Adaptive Management

59 Weed inventories and mapping will be conducted annually, and treatment of 

newly found populations will be identified and prioritized based on criteria in the 

“Adaptive Strategy” section of this chapter.

B, C, D

60 Treated sites will be monitored, evaluated, and the results documented to 

determine:

- Effectiveness of the method(s) used in meeting the objective;

- Whether impacts to resources or people were within the scope of predictions; 

and 

- Implementation and effectiveness of design features, and whether mitigations 

should be modified or added to enhance effectiveness.

B, C, D

61 Changes in prescriptions made as a result of monitoring and evaluation, and 

treatments for newly found weed populations must comply with all design 

features and monitoring requirements in the environmental impact statement. 

The actions and effects must be within the scope of those considered in the 

environmental impact statement. New actions or effects outside of those 

considered in this environmental impact statement will be evaluated in 

accordance with Forest Service Handbook 1909.15, Chapter 10, Section 18, to 

determine if additional environmental analysis under the National Environmental 

Policy Act is required. 

B, C, D

Forest Plan Amendment

[Additional paragraphs]

The incorporation of the amendment will be conducted through use of the 1982 rule procedures as allowed by 

the transition language of the 2012 planning rule (36 CFR 219.17(b)(3)).

As stated on page 24, the predecisional administrative review (objection) process employed for the project 

will also be used for administrative review of the proposed amendment for the selected alternative (36 CFR 

219.59(b)).
Final Supplemental Environmental Impact Statement

39

[Replaces table 11]

Table S-12. Proposed amendment to the Santa Fe National Forest Plan (pp. 75-76)

Existing Forest Plan Direction

Proposed Forest Plan Direction

(bold text shows new language) 

5. Chemical treatments may be applied: 5. Chemical treatments may be applied:

a. when determined through an environmental 

analysis to be environmentally, economically, and 

socially acceptable.

a. when determined through an environmental 

analysis to have no adverse environmental, 

economic, or social impacts for longer than 6 

months.

b. on areas outside municipal watersheds and 

human habitation.

b. within municipal watersheds only when the 

municipality concurs with the proposed 

treatment and design features.4

c. on soils with moderate or high revegetation 

potential.

c. on any soil provided that soil erosion on that 

site is not increased to above the tolerance 

level identified in the terrestrial ecosystem 

survey for the affected soil unit.

d. on areas that would benefit from selective 

control of plant species.

d. on areas that would benefit from selective 

control of plant species.

e. on areas where the chemicals will not violate 

State water quality standards.

e. on areas where the chemicals will not violate 

State water quality standards.

f. on soils with moderate to high cation exchange 

capacity.

f. In areas of human habitation: 

• Apply this adaptive strategy identified in 

the EIS in Table S-10: Method(s) must have 

been documented to be low risk of causing 

harm to people. 

• Apply the design features listed in the EIS 

in Table S-11 under “Human Health/Safety 

and General Mitigations.”

g. on piñon-juniper retreatment areas on stands 

where 80 percent of the trees are less than 6 feet 

in height, with more than 25 trees per acre.

g. on piñon-juniper retreatment areas on stands 

where 80 percent of the trees are less than 6 feet 

in height, with more than 25 trees per acre.

Permits and Authorizations Required

[Replaces entire section]

• Consult and obtain concurrence from the U.S. Fish and Wildlife Service on the Forest Service’s biological 

assessment and determinations of effects to threatened or endangered species. This will occur prior to 

signing a record of decision authorizing project implementation (Completed: Carson National Forest

Consultation # 2-22-00-I-237 and Santa Fe National Forest Consultation # 2-22-00-I-324 (USFWS 2005)

and recent consultation Santa Fe National Forest Consultation # 02ENNM00-2015-I-0149 (USFWS 

2015)).

• Consult and obtain concurrence from the New Mexico State Historic Preservation Officer regarding 

identification, evaluation, and determination of effects of the project on heritage resources. Final 

consultation and concurrence from the State Historic Preservation Office will occur prior to 

implementation (Pursuant to the programmatic agreement, subsequent initiation of noxious weed control 

projects will be contingent upon completion of the identification and protection of historic properties, and 

 4 In a 2004 comment on the draft environmental impact statement, the New Mexico Environment Department suggested the Forest 

Service may wish to “retain the prohibition on application of certain higher risk herbicides, such as picloram [in municipal 

watersheds].” Picloram would not be used in municipal watersheds. The design features listed in Table S-11 (such as rows 1, 4, 

and 46 to 49) and the requirement to obtain the concurrence of the municipality ensure the safety of the application method. Retaining 

flexibility in weed treatments is crucial to the success of this project.
Invasive Plant Control Project

40

compliance with applicable provisions of National Historic Preservation Act in accordance with Appendix 

F - Standard Consultation Protocol for Noxious Weed Control” of the First Amended Programmatic 

Agreement Regarding Historic Property Protection and Responsibilities.)

• Obtain concurrence from U.S. Department of Agriculture Animal and Plant Health Inspection Service 

(APHIS) and the State of New Mexico for any biological control method to be used.

• Forest Service employees or contractors supervising application of herbicides must first be certified by 

New Mexico Department of Agriculture (NMDA). Herbicide application must comply with all 

requirements found in Forest Service Manuals 2900 and 2150, including the Region 3 Supplemental 

Manual 2150.45. This includes pre- and post-implementation requirements as well as coordination with 

other agencies. 

• Following Forest Service policy and procedures, regional forester review and approval must be obtained 

before using herbicides in wilderness and any other situations as directed.

• Comply with the New Mexico Pesticide Control Act governing public applicators, record keeping, and 

other requirements.

• Prior to burning, a burn plan must be prepared and burn permit obtained from New Mexico Environment 

Department, Air Quality Bureau.

• Obtain a permit for any discharge of pesticides into “Surface Waters of the United States” as required by 

the Environmental Protection Agency’s National Pollutant Discharge Elimination System (NPDES) 

authorized under the Clean Water Act.

• Comply with the National Pollutant Discharge Elimination System interim guidance (January 9, 2012) 

and any future Regional guidance (as issued) governing compliance with the Environmental Protection 

Agency’s pesticide general permit (PGP) under the Clean Water Act. 

• Comply with the antidegradation policy of the New Mexico Environment Department governing 

protection of water quality in designated Tier 3 waters (outstanding national resource waters) under the 

Clean Water Act.5Consult with, and obtain concurrence from, the New Mexico Environment Department 

Surface Water Quality Bureau regarding any treatments that could result in short-term degradation to the 

chemical, physical, or biological integrity of these waters.

Comparison of Alternatives

[Replaces entire section]

This section provides a comparative summary of the alternative treatments and effects of implementing each 

alternative. Information is focused on activities and effects where different levels of effects or outputs can be 

distinguished quantitatively or qualitatively among alternatives. 

Likely the most important consequence of any of the action alternatives (alternatives B, C, and D) would be 

preventing the spread of weeds into large monocultures, which would then require more drastic means of 

treatment, like spraying herbicides from airplanes. The Carson and Santa Fe National Forests are uniquely 

positioned to prevent the spread of weeds because the populations are relatively small and isolated, when 

treatments in general are the most effective. 

Table S-13 provides a comparison of alternatives based on the significant issues or effects, as well as how 

well the alternatives meet the purpose and need (objectives) for the project. The comparison table is intended 

to provide the public and decision makers with a basis for choice between alternatives.

 5 http://www.nmenv.state.nm.us/swqb/onrw/
Final Supplemental Environmental Impact Statement

41

In addition to the summarized comparison of alternatives related to significant issues and project objectives, 

there are a few other key differences between the effects of each alternative, based on the effects analysis 

described in chapter 3. The most noticeable consequences from weed treatment under alternatives B, C, and D 

would be the long-term, beneficial improvements to native ground vegetation such as grasses, forbs, and 

shrubs. Riparian vegetation such as rushes, sedges, willows, and cottonwoods would particularly benefit from 

this project. Protecting and improving native plant communities would have positive effects on soil and water 

conditions, as well as wildlife and aquatic habitats (particularly due to enhancing riparian vegetation). 

Negative effects to native vegetation, soil, water and aquatic organisms would be minor and of short duration. 

The increases in sediment (more with alternative C) and any possible herbicide delivery to streams (for 

alternatives B and D) would have no measurable, long-term consequences. There would be a low risk of 

adverse impacts to fisheries, including Rio Grande cutthroat trout (a sensitive fish species) or other aquatic 

organisms based on application of design features, risk assessments, and Environmental Protection Agency

guidelines. Alternative C would cause more ground disturbance and associated impacts to soils, especially on 

soils with a severe erosion hazard rating. However, all alternatives would remain within soil erosion tolerance 

levels needed to protect long-term soil productivity. Soils with low revegetation potential would receive 

herbicide treatments under alternatives B and D. Reestablishing native vegetation could take longer under 

alternative C due to soil disturbance and germination of weed seed from the seed bank. Mitigation 

requirements for all alternatives would ensure that vegetative ground cover is adequately reestablished. With 

the required design features, all soil and water quality standards would be met. 

Differences between alternatives in their effects to air quality, heritage resources, livestock grazing, 

recreation, wilderness, and visual resources are expected to be negligible. There would be minor increases in 

noise and traffic associated with the action alternatives, although generally within background levels. 

By controlling the spread of weeds and protecting native plant communities, habitats, and watershed 

conditions on the two national forests, alternatives B and D would maintain or enhance social or economic 

conditions, particularly for local rural communities in northern New Mexico who typically rely on the forest

natural resources for their livelihood, traditional culture and quality of life.

Table S-13. Comparison of alternatives by issues and objectives (purpose and need)

Significant 

Issues and 

Objectives Alternative A Alternative B Alternative C Alternative D

Issue 1: 

Herbicides and 

Human Health 

No risk of health 

impacts from 

herbicide 

exposure (0 acres 

treated with 

herbicides). 

Low risk of health 

impacts to workers or 

general public from 

using herbicides based 

on EPA registration, risk 

assessment data, and 

design features. Higher 

risk to people with 

multiple chemical 

sensitivities, although 

public notification 

requirement provides a 

means for people with 

this condition to avoid 

exposure to treated 

areas. 

No risk of health 

impacts from 

herbicide exposure 

(0 acres treated with 

herbicides). Slightly 

increased risk of 

exposure to smoke 

from prescribed 

burning and slightly 

elevated risk of 

mechanical injuries 

to workers. 

Same as 

alternative B but 

slightly higher risk 

of exposure for 

people with 

chemical 

sensitivities as 

100 percent of 

treatments are 

with herbicides. 
Invasive Plant Control Project

42

Significant 

Issues and 

Objectives Alternative A Alternative B Alternative C Alternative D

Issue 2: 

Herbicides and 

Wildlife 

No risk of 

herbicide impacts 

to wildlife. Weeds 

would degrade 

native plant 

habitats, 

especially riparian 

areas important to 

numerous 

species. 

Low risk of herbicide 

impacts to wildlife based 

on EPA registration, risk 

assessments, and 

design features. Native 

wildlife habitat quality 

(especially riparian 

habitat) would improve 

as weeds are controlled. 

No risk of herbicide 

impacts to wildlife. 

Less improvement 

in wildlife habitat. 

Same as 

alternative B

Issue 3: 

Herbicides and 

Native Plant 

Communities 

No short-term 

impacts from 

herbicides. In the 

long term, weedcaused decline in 

abundance and 

diversity of native 

plant 

communities. 

Short-term reduction in 

some non-target plant 

species. Long-term 

improvement in 

abundance and diversity 

of native plant 

communities. 

Similar to alternative 

B for short-term 

reduction in nontarget plants. Low to 

moderate long-term 

improvement in 

native plant 

communities. Weed 

spread rate may 

equal or exceed 

control rate without 

herbicide use. 

Same as 

alternative B 

Issue 3 

Continued: 

Rare or 

Sensitive 

Native Plant 

Species 

No risk of 

treatment-related 

impacts. In the 

long term, weeds 

may cause a 

decline in 

federally listed or 

sensitive plant 

species 

No impact to threatened 

or endangered plants 

due to mitigation 

measure. For sensitive 

plants, treatments “may 

impact individuals but 

are not likely to result in 

a trend toward Federal 

listing or loss of 

population viability,” due 

to design features and 

species locations. 

Same as alternative 

B

Same as 

alternative B

Issue 4: Cost 

and Treatment 

Effectiveness 

(based on level 

of effort to meet 

objectives) 

Not cost effective; 

would incur much 

higher costs in 

future. 

Moderately cost 

effective. 

Least cost effective. Most cost 

effective. 

Objectives: 

Protect native 

plant 

communities, 

soil and water 

quality, wildlife 

habitat, and 

long-term 

ecosystem 

health 

No protection; no 

effectiveness. 

Weed-related 

impacts to 

vegetation, soil, 

water, riparian 

habitat, and other 

resources would 

continue. 

Highest level of 

treatment effectiveness 

and resource protection 

from weed impacts due 

to integrated 

combination of 

treatments including 

herbicides. 

Low level of 

effectiveness and 

resource protection 

from weed impacts. 

Fewer acres treated 

annually for a given 

budget due to need 

for repeat 

treatments on the 

same acreage more 

often than when 

combined with other 

methods. 

High level of 

effectiveness and 

resource 

protection from 

weed impacts. 

Not quite as 

effective as 

herbicides 

combined with 

other methods. 
Final Supplemental Environmental Impact Statement

43

Chapter 3. Affected Environment and Environmental 

Consequences

Introduction

[Replaces entire section]

This chapter summarizes the physical, biological, social, and economic environments of the project area and

the environmental consequences of implementing the proposed action and alternatives. The environmental 

consequences focus on the project’s purpose and need and the issues identified in chapter 1, providing the 

scientific and analytical basis for the comparison of alternatives presented at the end of chapter 2. As used in 

this final supplemental environmental impact statement, “impact” means a harmful, undesirable, or negative 

effect.

An agency-approved adaptive weed management strategy was incorporated into this proposed project to 

address uncertainties about new or undiscovered weed infestations as well as post-implementation monitoring 

results that may indicate a need to modify treatment methods to meet project objectives. In the context of this 

uncertainty, the effects described in this chapter include consideration of the adaptive strategy, including use 

of treatment method selection criteria, prioritization ratings, thresholds, limitations, design features, and 

monitoring requirements described in chapter 2.

Cumulative Actions for Cumulative Effects Analysis

[Replaces entire section]

This section discusses other activities and land uses occurring within and surrounding the Carson and Santa 

Fe National Forests that could contribute to cumulative effects when added to the effects of weed treatments 

in this project. Cumulative effects are those impacts on the environment resulting from the incremental 

impacts of the action when added to other past, present, and reasonably foreseeable future actions and can 

result from individually minor but collectively significant actions taking place over a period of time. 

Cumulative effects can be beneficial or adverse.

Unless noted in an individual resource section, the geographic extent for which cumulative effects have been 

evaluated consists of land administered by, and immediately adjacent to, the two national forests, based on the 

area directly or indirectly affected by project activities. The time period for cumulative effects is the time 

during which project activities are anticipated to occur: approximately 10 years (or more) beginning in 2017. 

The existing condition for each resource encompasses the past and present actions shown in table S-14. 

Because weed infestations are well distributed spatially, no concentration of treatment would occur across the 

3 million acres comprising the two forests.

Past and Present Actions (1987–2014)

On June 24, 2005, the Chairman of the Council on Environmental Quality provided guidance to agencies on 

the consideration of past actions in cumulative effects analysis (Connaughton 2005):

“The environmental analysis required under NEPA is forward-looking, in that it focuses on the 

potential impacts of the proposed action that an agency is considering. Thus, review of past actions is 

required to the extent that this review informs agency decision-making regarding the proposed 

action...Generally, agencies can conduct an adequate cumulative effects analysis by focusing on the 

current aggregate effects of past actions without delving into the historical details of individual past 

actions.”
Invasive Plant Control Project

44

Table S-14 shows past and present actions that have affected the composition of vegetation and presence of 

weeds in the cumulative effects area. The table provides a short description of the action; each specialist 

describes the effect or trend pertinent to their resource in their section. These actions form the baseline for the 

cumulative effects analysis.

Reasonably Foreseeable Actions

Table S-15 shows the reasonably foreseeable future actions that could cumulatively contribute effects from 

this project. It contains only human actions that are reasonably foreseeable as defined by the courts (for 

example, Weinberger v. Catholic Action of Hawaii, 454 US 139, 70 E.Ed.2d 289 (1981)). The table provides a 

short description of the action; each specialist describes the effect or trend pertinent to their resource in their 

section.

Table S-16 summarizes the cumulative effect to the key issues identified in chapter 1. The left column in the 

table states the key resource followed by the specific effect this project could cause that resource. The middle 

columns display other past, present, or foreseeable future actions expected to cumulatively contribute to, or 

counteract, the specific effect listed in the left column. The last column, on the right, predicts the overall 

cumulative effect to the resource listed.

Table S-14. Past and present actions (1987-2013) contributing towards the cumulative effects baseline

Action Description Comment

Annual treatment of noxious weeds in 

the Carson and Santa Fe National 

Forests

Removes noxious weeds by pulling, 

grazing, mowing, treating with 

chemicals, or other methods.

For example, herbicide treatment of 

saltcedar on the Jemez Ranger 

District from 1999 – 2002; goat 

grazing of yellow toadflax south of 

Tres Piedras; annual, ongoing 

manual control by both national 

forests (hand pulling)

Road construction and maintenance Uses heavy equipment to build or 

maintain permanent or temporary 

roads. 

Trail construction and maintenance Uses hand tools or light equipment 

(for example, all-terrain vehicle) to 

build or maintain trails.

Creation of unauthorized routes Created by repeated driving in the 

same place off system roads or 

trails.

Subdivision and development of 

private inholdings and land adjacent 

to the two national forests

Mining claims and development of 

mining 

Wildfires, including suppression and 

rehabilitation

This category includes suppression 

activities such as use of fire 

retardants and building fire line with 

hand tools or heavy equipment. It 

also includes rehabilitation work such 

as seeding and mulching to reduce 

erosion.

For a complete list of wildfires since 

1987 in the Carson and Santa Fe 

National Forests, see the project 

record.

Hazardous fuels treatment and 

prescribed burning

Thinning trees by hand or with 

equipment. Conducting prescribed 

fires.

For a complete list of hazardous fuels 

projects since 1987 in the Carson and 

Santa Fe National Forests, see the 

project record.

Livestock grazing Annual grazing of cattle pursuant to 

permit terms.
Final Supplemental Environmental Impact Statement

45

Action Description Comment

Jemez National Recreation Act This act established the Jemez 

National Recreation Area to 

conserve, protect, and restore the 

recreational, ecological, cultural, 

religious, and wildlife resource 

values of the Jemez Mountains. The 

Jemez National Recreation Area is 

comprised of 100,000 acres within 

the Jemez Mountains. The Santa Fe 

National Forest has developed 

numerous recreational facilities, 

campgrounds, day use sites, and 

fishing access, within the Jemez 

National Recreation Area.

Wild and Scenic Rivers – Pecos, East 

Fork Jemez, and Rio Chama (SFNF) 

and Rio Grande (CNF)

Designated these rivers for their 

"outstandingly remarkable scenic, 

recreational, geologic, fish and 

wildlife, historic, cultural, or other 

similar values, shall be preserved in 

free-flowing condition, and that they 

and their immediate environments 

shall be protected for the benefit and 

enjoyment of present and future 

generations" (Public Law 90-542, 

1968).

Creation of the Valles Caldera 

National Preserve

The creation of the Valles Caldera 

National Preserve made lands 

previously in private ownership open 

to public use. The Valles Caldera 

National Preserve is made up of 

89,000 acres within the Jemez 

Mountain Range and offers 

numerous recreational opportunities.

Land transfers from the Carson and 

Santa Fe National Forest to other 

entities, for example: San Ildefonso 

and Santo Domingo. 

Respect the Rio program The Respect the Rio program is a 

multi-faceted restoration and 

education program started in 2001 

and designed to balance the need for 

preservation of riparian and floodprone areas with needs of the public. 

The Respect the Rio Program seeks 

to do this by accomplishing the 

following goals:

1. Identifying and addressing water 

quality issues that have developed 

from recreational use.

2. Educating the public about habitat, 

habitat needs, and ongoing 

restoration projects.

3. Creating community partnerships.

4. Creating a program and materials 

easily adaptable to other forests 

and agencies.

Acquisition of lands, for instance 

Echo Amphitheatre (Carson National 

Forest)

The Forest Service acquires lands 

through purchase, exchange, or 

transfer. 

A comprehensive list of acquisitions is 

not available at this time.
Invasive Plant Control Project

46

Action Description Comment

Road decommissioning Removes roads from the landscape, 

usually using heavy equipment to 

restore the natural slope and reseed. 

Has also occurred naturally with 

vegetation growing in unused roads.

A comprehensive list of past road 

decommissioning is not available at 

this time.

Forest product collection This includes products covered by a 

permit, such as fuelwood and 

Christmas trees, and other products 

such as piñon and products used for 

religious ceremonies.

Administrative use This includes uses authorized by the 

Forest Service with a special use 

permit (excluding forest product 

collection) and the use of Forest 

Service roads by Forest Service staff 

to manage the national forests. 

Examples of activities authorized by 

a special use permit are access to 

communication sites, access to utility 

corridors, and outfitter and guide

operations. 

Weed treatments on land in other 

jurisdictions

Removes weeds by pulling, grazing, 

mowing, treating with chemicals, or 

other methods.

For example: mowing and herbicide 

application in rights-of-way by the 

New Mexico Department of 

Transportation; herbicide treatments 

by private landowners within or 

adjacent to the national forests, with 

or without the participation of local 

soil and water conservation districts 

(extent unknown); New Mexico Salt 

Cedar Control Project along the 

Pecos and Rio Grande Rivers (2002-

2003) by the New Mexico Association 

of Conservation Districts; treatment of 

Russian olive and saltcedar by 

various soil and water conservation 

districts (2003) under the Non-Native 

Phreatophyte Eradication Project 

along the Rio Grande; big sage 

control treatments on the Jicarilla 

Reservation; treatment of Siberian 

elm along the Santa Fe River by the 

Santa Fe Watershed Association and 

the City of Santa Fe; weed treatments 

on Bureau of Land Management

lands.

Oil and gas leasing The Jicarilla Ranger District (Carson 

National Forest) has over 800 gas 

wells with associated roads, 

pipelines, and other facilities. In 

November 2012, the Santa Fe 

National Forest signed a decision to 

amend the forest plan to allow oil and 

gas leasing with certain stipulations.

Preparation of travel management 

plans and motor vehicle use maps by 

other national forests and agencies

Designates a system of roads and 

trails where people are allowed to 

drive. Generally reduces the amount

of driving off-road allowed.

All national forests and grasslands in 

New Mexico, and some Bureau of 

Land Management districts.
Final Supplemental Environmental Impact Statement

47

Action Description Comment

Special Use Permits – acequia 

improvements, rights-of-way for 

pipelines (water/natural gas), 

driveways, communication sites, 

outfitter/guides, etc. 

Replacement and/or repair of 

acequia headgates and related 

infrastructure (rights-of-way for 

driveways, pipelines, electric lines, 

etc.) to private lands, authorization 

for outfitters and guides for 

recreational activities within, and 

adjacent to, National Forest System

lands. 

Table S-15. Reasonably foreseeable future actions (2015-2025)

Action Description Comment

Preparation of travel management 

plans and motor vehicle use maps by 

other national forests and agencies

Designates a system of roads and 

trails where people are allowed to 

drive. Generally reduces the amount 

of driving off-road allowed.

All national forests and grasslands in 

New Mexico, and some Bureau of 

Land Management districts.

Transfer of management of lands in 

Pecos Canyon from New Mexico 

Department of Game and Fish to the 

State Parks

Senate Joint Memorial 16 authorized 

New Mexico State Parks to enter into 

a joint powers agreement with the 

New Mexico Department of Game 

and Fish to better manage recreation 

on 186 acres of land divided among

six locations along the Pecos River. 

These locations provide fishing 

access, day use, and overnight 

camping opportunities along the 

Pecos River. 

Projects on the schedule of proposed 

actions

The project record contains the list of 

projects on the most recent schedule 

of proposed actions as of the date of 

this writing.

Geothermal leases in Coyote and 

Cuba Ranger Districts

The Santa Fe National Forest is 

expecting a geothermal leasing 

proposal in the near future. The 

proposal would be to drill exploration 

wells north and west of the Valles 

Caldera National Preserve. Small 

roads would be developed to access 

the exploration wells. If the project 

moves to completion, production 

wells and a powerline would be 

installed. 

The project record shows a map of 

the area expected for leasing. The 

grey striped area is where the 

proposed leasing would be requested.

Oil and gas leases in Cuba Ranger 

District

The proposal is to lease additional 

acreage adjacent to lands currently 

leased for oil and gas. Short roads 

would be developed to any new wells 

installed and would remain in use 

until the well is abandoned at which 

point the road would be reclaimed. 

The project record contains a map 

showing existing oil and gas leases 

(grey striped areas) and those 

proposed for expansion or 

improvement (red boxes, on legend 

as "Pending Expressions”).

Oil and gas development on the 

Jicarilla Ranger District

The reasonable foreseeable 

development scenario projects the 

addition of up to 700 new wells within 

the planning period. The actual 

number of wells depends on many 

factors, including the economy and 

changes in technology.
Invasive Plant Control Project

48

Action Description Comment

Acquisition of Miranda Canyon 

(Carson National Forest)

The Forest Service acquires lands 

through purchase, exchange, or 

transfer. This parcel is approximately 

5,000 acres.

Weed treatments on land in other 

jurisdictions

Removes weeds by pulling, grazing, 

mowing, treating with chemicals, or 

other methods.

For example, mowing and herbicide 

application in rights-of-way by the 

New Mexico Department of 

Transportation; herbicide treatments 

by private landowners within or 

adjacent to the national forests, with 

or without the participation of local soil 

and water conservation districts 

(extent unknown); New Mexico Salt 

Cedar Control Project along the 

Pecos and Rio Grande Rivers (2002 –

2003) by the New Mexico Association 

of Conservation Districts; treatment of 

Russian olive and saltcedar by 

various soil and water conservation 

districts (2003) under the Non-Native 

Phreatophyte Eradication Project 

along the Rio Grande; big sage 

control treatments on the Jicarilla 

Reservation; treatment of Siberian 

elm along the Santa Fe River by the 

Santa Fe Watershed Association and 

the City of Santa Fe; weed treatments 

on Bureau of Land Management 

lands.
Final Supplemental Environmental Impact Statement

49

Table S-16. Summary of cumulative actions by key resource

Key Resource and Effect 

to that Resource

Other Actions 

Contributing to the Effect 

to the Resource

Other Actions Countering 

the Effect to the Resource

Predicted Cumulative 

Effect

Human Health and

Safety: risk of health 

impacts from herbicide 

exposure 

Other actions that 

introduce chemicals into 

the environment include, 

but are not limited to: 

herbicides recently applied 

or expected to be applied 

in northern New Mexico by 

San Juan and Sandoval 

County Weed Management 

Areas, Soil and Water 

Conservation Districts, 

Bureau of Indian Affairs, 

Valles Caldera National 

Preserve, Bureau of Land 

Management, National 

Park Service, Santa Fe 

Watershed Association, 

The Nature Conservancy, 

and Audubon Society. 

Other actions that may 

introduce chemicals are

vehicle use; maintaining, 

constructing, and 

reconstructing facilities and 

roads; extracting oil, gas, 

geothermal, and mineral 

resources; and the aerial 

application of fire retardant. 

Creation of motor vehicle 

use maps (fewer places that 

people can drive); 

restoration projects (less 

chance of needing fire 

retardant) such as El Rito 

Canyon Landscape 

Restoration Project, 

Southwest Jemez 

Mountains Landscape 

Restoration Project, Upper 

Bitter Creek Project, and the 

Tio Gordito Project

The risk of exposure to the 

public or workers is 

considered to be negligible 

(unforeseen accidents 

excepted). Because the 

risk of exposure is 

immeasurable (below 

Environmental Protection 

Agency standards), the 

cumulative effect cannot be 

measured.

Native Vegetation: loss of 

native plants

Other actions that could 

cumulatively cause a loss 

of native plants are cutting 

trees and prescribed 

burning (for a season or 

less); grazing livestock; 

camping outside developed 

sites; constructing new 

facilities (for example,

Resumidero Campground; 

Buckman water diversion 

facilities, power lines, and 

road reconstruction); and 

clearing vegetation from 

highway rights-of-way. 

Other actions that would 

cumulatively promote native 

plants are cutting trees and 

prescribed burning (for 

example, in the same 

project as listed above), 

weed control activities on 

public and private lands, 

seeding, planting, and 

erosion control following 

wildfires, fuel reduction 

activities (by allowing more 

sunlight to reach the forest 

floor and promoting native 

grasses and shrubs), and 

meadow and riparian 

restoration projects.

Because the loss of native 

plants caused by the 

implementation of this 

project is expected to last a 

season or less, it would not 

cause negative effects 

when considered 

cumulatively with other 

actions.

Wildlife and Fish:

herbicide-related health 

risk

Same actions as described 

for “Human Health and

Safety.”

Same actions as described 

for “Human Health and

Safety.”

The risk of exposure to 

wildlife and fish is 

considered to be negligible 

(unforeseen accidents 

excepted). Because the 

risk of exposure is 

immeasurable (below 

Environmental Protection 

Agency standards), the 

cumulative effect cannot be 

measured.
Invasive Plant Control Project

50

Key Resource and Effect 

to that Resource

Other Actions 

Contributing to the Effect 

to the Resource

Other Actions Countering 

the Effect to the Resource

Predicted Cumulative 

Effect

Wildlife and Fish:

reduction in native 

vegetation and thus habitat

Other actions that could 

cumulatively, but 

temporarily, reduce native 

vegetation cover that may 

provide nesting, foraging or 

hiding cover habitat for 

some species include

thinning and removing 

trees, prescribed burning, 

livestock grazing, 

restoration projects along 

riparian areas, and weed 

control treatments on 

private or other public 

lands. These actions, 

however, tend to reduce 

native habitats for a 

season or less during and 

just after project activities. 

After a season, native 

vegetation is restored or 

increases. 

Wildfire burn area 

rehabilitation (seeding, 

planting, etc.), fuel reduction 

activities (such as the 

projects listed under Human 

Health and Safety), meadow 

and riparian restoration 

projects, and fish habitat 

improvement projects on 

public and private lands also 

contribute to restoration of 

high quality wildlife and fish 

habitat. Weed control 

activities on public and 

private lands add to the 

beneficial cumulative effects 

of the project by restoring 

diverse vegetation/habitat 

that is being displaced by 

weeds.

The overall effect of this 

project would be to 

promote native vegetation; 

cumulatively, it would 

contribute to improved 

habitat for fish and wildlife 

when considered in context 

with other landscape 

restoration projects.

Wildlife and Fish:

disturbance

Other actions that could 

disturb wildlife and fish by 

causing noise or having 

people and machinery 

present are maintaining, 

constructing, and 

reconstructing roads and 

facilities; oil and gas 

operations; forest thinning; 

prescribed burning; wildfire 

suppression; wildlife and 

fish habitat improvements 

(for example, eliminating 

exotic fish, building fish 

barriers for Rio Grande 

cutthroat trout); 

reintroductions of wildlife 

species; or animal control 

actions conducted by the 

New Mexico Department of 

Game and Fish; driving 

vehicles; and camping, 

picnicking, and other 

recreational activities. 

Actions that cumulatively 

reduce disturbance are road 

and area closures, road 

decommissioning projects, 

and travel management.

Disturbance from this 

project is expected to be 

negligible because the 

acreage of each habitat 

treated would be small. 

Because the direct and 

indirect effect would be 

immeasurable, there would 

be no cumulative effect. 
Final Supplemental Environmental Impact Statement

51

Key Resource and Effect 

to that Resource

Other Actions 

Contributing to the Effect 

to the Resource

Other Actions Countering 

the Effect to the Resource

Predicted Cumulative 

Effect

Soil and Water: risk of 

unacceptable levels of soil 

erosion, sedimentation, 

and/or chemical 

contamination

Actions that could 

cumulatively increase 

these impacts for a season 

or less are thinning, 

prescribed burning, 

livestock grazing, 

maintaining, constructing, 

and reconstructing roads 

and facilities, driving on 

and off roads and trails, 

camping, equestrian uses, 

gathering forest products, 

and weed control activities 

on private or other public 

land.

Actions that are expected to 

cumulatively stabilize soils, 

increase soil productivity, 

and improve water quality 

are weed control activities 

on private and other public 

lands (by reducing erosion 

caused by some weeds and 

restoring native plants that 

have better soil holding 

characteristics); wildfire burn 

area rehabilitation 

(erosion/sediment control); 

fuel reduction activities; 

meadow and riparian 

restoration; dispersed 

recreation site restoration; 

and road and trail closures.

The direct and indirect 

effects to soil and water 

are expected to be 

negligible because of the 

mitigations measures in 

place for each of the 

proposed treatments (for 

example, seeding bare soil, 

not using certain herbicides 

near water, and others). 

Because the direct and 

indirect effect would be 

immeasurable, there would 

be no cumulative effect. 

Air Quality: smoke or dust 

particulates 

Other prescribed burning, 

wildfires, and residential 

firewood and trash burning 

add to regional haze. 

Driving on dirt roads within 

and adjacent to the forests 

temporarily causes dust. 

Projects, such as thinning, 

that reduce the risk of 

wildfire.

Dust from this project 

would be negligible; 

therefore, there would be 

no cumulative effects. 

Smoke from prescribed 

burning is regulated by the 

State of New Mexico; thus, 

no cumulative effects can 

occur because no burning 

is allowed under conditions 

that smoke would exceed 

state levels.

Assumptions Common to the Analysis of Effects

[New section]

The interdisciplinary team used these assumptions when analyzing effects to the various resources. 

Assumptions specific to each resource are listed in each respective section.

For alternative A (no action):

• Weeds would spread, on average, at a rate of 8 percent per year (DiTomaso 2000, Tu et al. 2001, Frid et 

al. 2013). The rate of spread will not be uniform; it is species- and site-dependent. For instance, different 

species thrive at different elevations. 

For the action alternatives (B, C, and D):

• Alternatives B and D would result in the control or eradication of current weed populations in 

approximately a decade. Some populations would be easily eradicated; others would only be contained. 

• New weed populations will establish themselves. People, wind, and animals all spread weed seed 

“hitchhikers”.

• Alternative C would result in ongoing control without foreseeable eradication of current weed populations 

on the forests. The cost of mechanical treatment is very high, and the other methods are not as effective or 

efficient as the use of herbicides. 

• All pertinent design features and monitoring requirements would be implemented.
Invasive Plant Control Project

52

• The action alternatives will not result in a noticeable increase in the amount of traffic and noise over 

normal Forest Service business. The reason for this is that no new personnel would be hired to treat 

weeds. Even if contracted, contract crews would constitute a very small portion of the driving and work 

taking place in the project area on a given day.

• The Forest Service may drive off roads to treat weeds. This use is expected to be negligible, because most 

of the known weed infestations occur along roads and trails. Any off-road driving by agency personnel or 

contractors to treat weeds would be limited in time and space; it would not occur every day in the same 

place, nor is it projected to be a repeated event.

• Each national forest expects to treat an average of 300 to 800 acres per year (600 to 1,600 per year for 

both forests on average) depending on funding and methods used.

• Each national forest expects to treat no more than 1,500 acres per year (3,000 per year for both national 

forests as a maximum).

Vegetation

[Replaces entire section]

Affected Environment

The first part of this section discusses the weeds known to occur as well as other potentially affected 

vegetation. The second part focuses on sensitive plant species.

The Carson and Santa Fe National Forests lie within the Colorado Plateau Semi-Desert Province and ArizonaNew Mexico-Mountains Semi-Desert-Open Woodland-Coniferous Forest-Alpine Meadow Province 

(Mountains Regime) of the Tropical/Subtropical Steppe Division; and the Great Plains-Palouse Dry Steppe 

Province and the Southern Rocky Mountains Steppe-Open Woodland-Coniferous Forest-Alpine Meadow 

Province (Mountains Regime) of the Temperate Steppe Division within the Dry Domain. Fire, insects, and 

disease are the primary natural sources of disturbance to vegetation (McNab and Avers 1994).

Vegetation types follow altitudinal gradients similar to those in the southern Rocky Mountains. Dominant 

vegetation cover types occurring in the two national forests include grasslands, sagebrush, shrublands, piñonjuniper, oak, ponderosa pine, mixed conifer, spruce-fir and subalpine. Within each cover type, riparian 

vegetation is found along streams, around lakes, and in valley bottoms.

Weeds threaten the biological diversity of native plant communities, ecosystem processes, and rare or special 

status plants. Weeds are highly adaptable and adept at usurping available moisture and nutrients, quickly 

spreading, and supplanting native vegetation. Weed infestations invariably lead to (1) a decline in abundance 

of native plants that occupy the same or similar habitats as the weeds, (2) undesirable changes in site 

conditions such as soil pH that may be vital to native plant survival, and (3) an overall loss in the richness and 

diversity of native plants. The weed species known to occur on the two national forests are listed in chapter 1 

and described in detail in appendix 2. 

The final environmental impact statement listed the known weed populations in both national forests as being 

approximately 7,260 acres. Today, we are aware of about 13,260 acres of weeds. Though studies show 

expansion rates vary between 5 and 30 percent annually (Tu et al. 2001), the increase in weeds in the project 

area is mostly explained by more surveys of the locations of weeds by Forest personnel in the years since the 

final environmental impact statement was published.

Infestations of Russian knapweed, hoary cress, and yellow toadflax have been identified in highway rights-ofway within the national forest boundaries. Major wildfires have occurred on both national forests in recent 

years. Monitoring of recent high-severity burns has identified these areas as locations for new infestations.
Final Supplemental Environmental Impact Statement

53

The Jemez Ranger District of the Santa Fe National Forest completed the Jemez Riparian Enhancement 

Project in 2000, which shows that saltcedar, Russian olive, and Siberian elm trees can be effectively 

controlled using selective herbicides. Previously approved, small-acreage, weed control treatments have also 

occurred on the Carson National Forest, and on both national forests where other agencies have jurisdiction 

such as along highway rights-of-way.

Table S-17 displays the total acres of known weed infestations by vegetation cover type. The following 

paragraphs briefly describe the location of each vegetation cover type and list the inventoried weed 

infestations found in each. Figure S-3 displays the dominant vegetation types on the Carson and Santa Fe 

National Forests.

Grasslands (Blue Grama, Perennial Grass Mix, Upper Forb Mix)

Grasslands are widespread at all elevations within both forests, typically as openings within shrublands and 

forest cover types. Weed species include black henbane, bull thistle, Canada thistle, leafy spurge, musk thistle, 

Scotch thistle, yellow starthistle, and yellow toadflax.

Table S-17. Weed infestations by vegetation type as of August 1, 2013

Vegetation Type1 Total Acres2

Total Acres 

of Vegetation 

Type Infested 

with Weeds3

Percent of 

Vegetation 

Type Infested 

with Weeds

Percent of 

all Weeds in 

This 

Vegetation 

Type

Percent of 

Project Area

Aspen 79,044 214 0.27 1.6 0.01

Big sagebrush 177,218 391 0.22 2.9 0.01

Blue grama 16,826 19 0.12 0.1 0.001

Deciduous shrub 

mix

113,185 734 0.65 5.5 0.02

Juniper 229,178 961 0.42 7.3 0.03

Perennial grass mix 205,676 1,137 0.55 8.6 0.03

Piñon-juniper 411,180 1,552 0.38 11.7 0.05

Ponderosa pine 

mix

936,088 5,101 0.54 38.5 0.16

Sparsely vegetated 16,086 47 0.29 0.4 0.001

Spruce-fir 318,255 355 0.11 2.7 0.01

Upper deciduousevergreen forest 

mix

731,753 2,733 0.37 20.6 0.08

Upper forb mix 20,086 7 0.04 0.1 0.0002

Total 3,254,576 13,253 100.0 0.41

1. Vegetation types are from the mid-scale vegetation analysis.

2. Includes privately held lands within National Forest System boundary.

3. Total acreage is off by 3 due to rounding error (total acres of weeds is 13,256).

Sagebrush-Shrub (Big Sagebrush, Deciduous Shrub)

Sagebrush and shrub are widespread at lower and middle elevations (6,200 to 7,900 feet) within both national 

forests, typically as openings in forest cover types. Weed species known to be present include black henbane, 

bull thistle, Canada thistle, Dalmatian toadflax, musk thistle, perennial pepperweed, Russian knapweed, 

Scotch thistle, and spotted knapweed. 
Invasive Plant Control Project

54

Piñon-Juniper (Piñon-Juniper, Juniper)

Piñon-juniper cover types are widespread at lower and middle elevations (5,700 to 8,400 feet) within both 

national forests. Weed species known to be present include bull thistle, Canada thistle, Dalmatian toadflax, 

diffuse knapweed, leafy spurge, musk thistle, Russian knapweed, Scotch thistle, Siberian elm, and spotted 

knapweed. 

Ponderosa Pine Mix

Ponderosa pine cover types are widespread at middle elevations (7,200 to 9,000 feet) within both national 

forests. Weed species known to be present include bull thistle, Canada thistle, Dalmatian toadflax, diffuse 

knapweed, leafy spurge, musk thistle, Russian knapweed, Russian olive, Scotch thistle, and yellow toadflax.

Upper Deciduous-Evergreen Forest Mix and Aspen

Mixed conifer and aspen cover types are widespread at middle and upper elevations (6,900 to 11,200 feet) 

within both national forests. Weed species known to be present include black henbane, bull thistle, Canada 

thistle, diffuse knapweed, leafy spurge, musk thistle, Russian knapweed, Scotch thistle, spotted knapweed,

and yellow toadflax. 

Spruce-Fir 

Spruce-fir cover types are widespread at upper elevations (8,700 to 11,500 feet) within both national forests. 

Weed species known to be present include bull thistle, Canada thistle, musk thistle, Russian knapweed, and 

yellow toadflax. 

Riparian Areas and Valley Bottom Lands

Riparian areas and valley bottoms with wet soils are widespread throughout all elevations within both 

national forests. Riparian areas often overlap other cover types at the mapping scale used for this analysis. 

Where information indicated riparian areas present, the acres were subtracted from other cover types so they 

were not counted twice. Weed species known to be present include bull thistle, Canada thistle, Dalmatian 

toadflax, cheatgrass, hoary cress, musk thistle, poison hemlock, Russian knapweed, Russian olive, saltcedar, 

Scotch thistle, Siberian elm, spotted knapweed, yellow toadflax, and Fuller’s teasel.
Final Supplemental Environmental Impact Statement

55

Figure S-3. Dominant vegetation types on the Carson and Santa Fe National Forests
Invasive Plant Control Project

56

Environmental Consequences to Vegetation

Alternative A (No Action)

[Replaces first paragraph]

The no-action alternative would not meet the purpose and need. It would not help maintain or improve 

diverse, sustainable native plant communities in weed-infested areas. It would result in continued invasion 

and spread of weeds throughout the two national forests, particularly on, and near, acres currently infested. 

Without an overall system to treat weeds, the Forest Service would be required to complete National 

Environmental Policy Act analysis on individual projects to treat weeds using methods other than handgrubbing, which alone has not proven effective. Given the conservative estimate of an 8 percent spread per 

year, the number of acres impacted by weeds would double over the next 10 years. When the un-inventoried 

areas or unidentified weed populations are factored in, there may be 10 to 20 percent more weed-infested 

acres than are currently inventoried. 

[Additional paragraph]

The establishment of weed monocultures would probably occur in some areas, which could alter historical

trends and natural ecosystem functions and processes in native plant communities (DiTomaso 2000). For 

example, following the 1996 Dome Fire on the Santa Fe National Forest, cheatgrass became an established 

monoculture in Bland Canyon. This resulted in an earlier fire regime than what exists under native vegetation.

Similarly, the amount of culturally important plants (such as osha (Ligusticum porter)) could be reduced as 

they are replaced by invasive species.

[Replaces last sentence of 4th paragraph, p. 71]

Knapweed infestations would have long-term detrimental effects on soil and water resources (USDA Forest 

Service 2007).

Alternative B (Proposed Action)

[Replaces first paragraph]

Table S-18 through Table S-29 display the treatments proposed in the project area’s different vegetation types. 

The vegetation types are from the two national forests’ midscale vegetation analysis. Acreages of weeds do 

not match precisely for two reasons. First, rounding errors from the GIS analysis are present. Second, weed 

species would be treated by multiple methods, so the acres listed in these tables are double counted. For 

example, spotted knapweed could be treated using herbicides, grazing, and by manually pulling. Thus, these 

tables display the maximum number of acres that could be treated by the method listed. The project record 

contains the suite of methods proposed in each vegetation type.6

 6 VEG03_MidscaleVegDomTypeAlternativesAcres_20131021.xlsx
Final Supplemental Environmental Impact Statement

57

[The following tables replace tables 15 through 23]

Table S-18. Acres of treatment method in in aspen

Treatment Alternative B Alternative C Alternative D

Biological 15 15 0

Grazing 190 190 0

Herbicides 214 0 214

Manual 86 86 0

Mechanical 213 213 0

Prescribed fire 1 1 0

Total known acres of weeds 

in this vegetation type 

214

Table S-19. Acres of treatment method in big sagebrush

Treatment Alternative B Alternative C Alternative D

Biological 141 141 0

Grazing 146 145 0

Herbicides 391 0 391

Manual 231 231 0

Mechanical 391 391 0

Prescribed fire 55 55 0

Total known acres of weeds 

in this vegetation type

391

Table S-20. Acres of treatment method in blue grama

Treatment Alternative B Alternative C Alternative D

Biological 16 16 0

Grazing 0 0 0

Herbicides 19 0 19

Manual 3 3 0

Mechanical 19 19 0

Prescribed fire 0 0 0

Total known acres of weeds 

in this vegetation type

19

Table S-21. Acres of treatment method in deciduous shrub mix

Treatment Alternative B Alternative C Alternative D

Biological 193 193 0

Grazing 363 363 0

Herbicides 734 0 734

Manual 424 424 0

Mechanical 693 693 0

Prescribed fire 57 57 0

Total known acres of weeds 

in this vegetation type

734
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58

Table S-22. Acres of treatment method in juniper

Treatment Alternative B Alternative C Alternative D

Biological 577 577 0

Grazing 227 227 0

Herbicides 961 0 961

Manual 749 749 0

Mechanical 938 938 0

Prescribed fire 104 104 0

Total known acres of weeds 

in this vegetation type

961

Table S-23. Acres of treatment method in perennial grass mix

Treatment Alternative B Alternative C Alternative D

Biological 716 716 0

Grazing 378 373 0

Herbicides 1,137 0 1,137

Manual 951 951 0

Mechanical 1,094 1,094 0

Prescribed fire 7 7 0

Total known acres of weeds 

in this vegetation type

1,137

Table S-24. Acres of treatment method in piñon-juniper

Treatment Alternative B Alternative C Alternative D

Biological 782 782 0

Grazing 357 357 0

Herbicides 1,552 0 1,552

Manual 1,040 1,040 0

Mechanical 1,467 1,467 0

Prescribed fire 221 221 0

Total known acres of weeds 

in this vegetation type

1,552

Table S-25. Acres of treatment method in ponderosa pine

Treatment Alternative B Alternative C Alternative D

Biological 1,672 1,672 0

Grazing 2,099 2,094 0

Herbicides 5,101 0 5,101

Manual 3,626 3,626 0

Mechanical 4,870 4,870 0

Prescribed fire 295 295 0

Total known acres of weeds 

in this vegetation type

5,101
Final Supplemental Environmental Impact Statement

59

Table S-26. Acres of treatment method in sparsely vegetated areas

Treatment Alternative B Alternative C Alternative D

Biological 38 38 0

Grazing 0.01 0.0001 0

Herbicides 47 0 47

Manual 38 38 0

Mechanical 47 47 0

Prescribed fire 0.3 0 0

Total known acres of weeds 

in this vegetation type

47

Table S-27. Acres of treatment method in spruce-fir

Treatment Alternative B Alternative C Alternative D

Biological 37 37 0

Grazing 317 317 0

Herbicides 355 0 355

Manual 136 136 0

Mechanical 355 355 0

Prescribed fire 0 0 0

Total known acres of weeds 

in this vegetation type

355

Table S-28. Acres of treatment method in upper deciduous-evergreen forest

Treatment Alternative B Alternative C Alternative D

Biological 545 545 0

Grazing 1,762 1,759 0

Herbicides 2,733 0 2,733

Manual 1,695 1,695 0

Mechanical 2,619 2,619 0

Prescribed fire 149 149 0

Total known acres of weeds 

in this vegetation type

2,733

Table S-29. Acres of treatment method in upper forb mix

Treatment Alternative B Alternative C Alternative D

Biological 7 7 0

Grazing 0.004 0.004 0

Herbicides 7 0 7

Manual 7 7 0

Mechanical 7 7 0

Prescribed fire 0 0 0

Total known acres of weeds 

in this vegetation type

7
Invasive Plant Control Project

60

[Replaces third paragraph, page 76]

Biological methods avoid loss of non-target plants altogether, as the insects cannot be released without 

approval from the U.S. Department of Agriculture Animal and Plant Health Inspection Service, based on 

assurance the insects would only consume the target weed species. The effectiveness of using biological 

methods to control weeds and restore native species would be more gradual and would not be detectable in 

the short term. Manual methods would be able to usually avoid cutting or digging up non-target plants.

Herbicides applied manually or with backpack sprayers would use directional spray devices that minimize 

herbicide drift on non-target vegetation. Adherence to wind and weather condition requirements would 

minimize the amount of spray that would drift through the air onto non-target plants. Vehicle-mounted 

herbicide spraying is less precise but includes a directionally controlled wand and on/off switch to minimize 

application to non-target vegetation. Mechanical, grazing, and burning methods would impact entire roadsides 

or areas treated, unless a torch is used to burn just weed species. However, those three methods are expected 

to be used sparingly (appendix 7) so they would have very little effect on native vegetation across the two 

national forests. In addition, because methods like burning, grazing, and mowing only remove the tops of 

plants, they would have a less intense, short-term effect on the ground cover. On a landscape level, the 

temporary reduction in native species would be negligible. 

[Additional paragraph]

Managed livestock grazing can work in combination with other methods to reestablish healthy, resilient native 

plant communities. For example, cattle grazing, used appropriately through timing, duration, and intensity,

can effectively control cheatgrass. Altering the timing, intensity, and duration of livestock grazing in riparian 

areas that have been treated for saltcedar can favor reestablishment of the native riparian flora while slowing 

down the recovery of saltcedar. 

[Additional paragraph]

Alternative B is expected to be the most effective at controlling weeds; studies show herbicides alone are not 

as effective as when they are combined with other methods (DiTomaso 2000, Endress et al. 2012, Frid et al. 

2013). Frid et al. (2013) found early detection and treatment, before a seedbed is established, were key 

components of controlling weeds. The same study found seeding with native vegetation (cultural methods), in 

combination with other treatments, greatly reduced the chance weeds would reestablish.

Alternative C–No Herbicides

[Replaces entire section]

The most noticeable effects to native vegetation would be the beneficial increase in native species abundance 

and diversity on the treated acres, similar to effects described for alternative B. The main difference with this 

alternative is that for a given budget, fewer acres would be treated each year. More follow-up on the same 

sites would be needed to control weeds. In particular, most deep-rooted perennial weeds, such as Canada 

thistle or Russian knapweed, cannot be controlled effectively with mechanical and physical methods alone 

without repetitive treatments conducted at the site over a number of years. Biological controls would likely be 

effective in the long term, after biocontrol insect populations have grown enough to have a significant effect 

on weed populations, which could take years. The other non-herbicide treatment methods are generally not as 

effective against weed species as herbicide treatment in combination with these other methods. For a fixed 

amount of funding, the acres treated would logically be fewer in alternative C than alternative B. 

Regardless of the non-herbicidal methods used, follow-up weed treatments at relatively close intervals could 

potentially impact native vegetation because the treatment areas would be in a disturbed condition more often 

and for longer periods. Even though follow-up treatments would control weeds, each time an area was

retreated, soils and native vegetation would be disturbed, which could create favorable growing conditions for 

all plants, native and invasive. Under this alternative, it is likely the rate of weed spread would exceed the rate 
Final Supplemental Environmental Impact Statement

61

of weed control, and the Forest Service would not be able to get ahead of the weed problem. Thus, effects in 

the long term would be most similar to alternative A (no action). 

Alternative D–Herbicides Only 

[Replaces entire section]

Beneficial effects to native vegetation abundance and diversity on the treated acres would be very similar to 

effects described for alternative B. The key difference is the slightly reduced effectiveness of some herbicide 

treatments without the supplemental use of other methods. It is well known from past studies that the most 

effective weed control treatments are those utilizing a combination of herbicides and non-herbicide methods. 

This reduced effectiveness means repeated treatments may be required above what would be necessary if a 

combination of treatments were used.

Numerous species of weeds would not be controlled with herbicides alone. For example, saltcedar has been 

successfully treated with herbicides and mechanical treatments. The combination proved more effective at 

controlling or eradicating saltcedar than herbicides alone. 

Continuous use of herbicides alone can lead to other problems. DiTomaso et al. (2006) report the repeated use 

of herbicides can have a detrimental effect to the legume species that are important components of rangelands, 

pastures, and wildlands. Herbicidal control that lowers the abundance of these forbs may cause losses in the 

ecological function of rangelands and may ultimately accelerate further degradation (Endress et al. 2012). 

Repeated use can increase the abundance of other undesirable species, particularly annual grasses like 

medusahead. Finally, one population of yellow starthistle in Washington developed a resistance to picloram, 

and was cross-resistant to clopyralid, which acts in the same manner. Thus, the potential exists for weeds to 

develop resistance to herbicides if used year after year (DiTomaso et al. 2006).

Unlike alternative C, this reduced effectiveness would not likely result in a reduction in the number of acres 

treated because the cost-effectiveness of treating with herbicides is high.

Cumulative Effects –Vegetation

[Replaces entire section]

In all action alternatives, cumulative impacts to non-target plant species would stem from forest management 

activities, public land uses, and activities on other public and private lands, as described in the beginning of 

this chapter. 

Cumulative Impacts to Native Vegetation

The direct and indirect effects to native vegetation from controlling or eradicating weeds would be an increase 

in the amount, vigor, and diversity of native plants. The cumulative effect from projects affecting native 

vegetation is expected to be an overall increase in the amount, vigor, and diversity of native plants across the 

project area. The focus of forest management in the reasonably foreseeable future would primarily be 

restoring fire-adapted ecosystems, native vegetation, and ecosystem functionality.

Implementing this project would add to the short-term reduction in non-target vegetation from herbicides 

applied in other ongoing weed treatment projects on private inholdings and on other public lands in and

around the two national forests. Long-term ecosystem restoration projects would compensate for activities 

that remove or damage native vegetation, including short-term removal of non-target plants from this 

proposed project.
Invasive Plant Control Project

62

Photo 4. Russian knapweed in the Gallina area, 

Coyote Ranger District (Santa Fe National Forest 

photo)

Cumulative Impacts to Weeds

The predicted direct and indirect effect of this project is the reduction in the acreages and species of weeds 

present on the two national forests. The overall cumulative impact, when added to other, ongoing activities in 

the spatial area is difficult to assess. Some projects and activities would promote weeds, while others have a 

tendency to reduce them. On balance, it appears the overall trend is towards the establishment of new weed 

populations.

For example, weeds could establish themselves in areas where activities disturb soil, such as thinning, 

firewood gathering, prescribed burning, dispersed recreation, grazing, road maintenance, road building, and 

road decommissioning even with preventive measures in place. Ongoing, common activities in the Carson 

and Santa Fe National Forests by weekend recreationists, forest firefighting crews, grazing allotment 

permittees, or livestock all have the potential to unknowingly spread weeds from one location to another, 

bring them onto National Forest System lands, or spread them onto other lands. 

Wildfires that burn with moderate to high severity through populations of invasive weeds often result in an 

exponential growth of that population, both in homogeneity and spatial extent. Many weed species (such as 

cheatgrass) are fire-adapted and can quickly invade an area and spread beyond any ability to control them. 

During the suppression of large wildfires, firefighting personnel and equipment can be brought in from 

different locations within the United States. If the vehicles come from or pass through places with weed 

populations, they can introduce new weed species. Motor vehicles are capable of not only bringing invasive 

weeds onto the national forests but can just as easily transport weeds to other land ownerships. 

Cyclic changes in weather (drought, wet warm springs, and late winter weather) and subtle changes in climate 

can increase the establishment and spread of nonnative species. Many nonnative grasses and forbs are cool 

season plants that can take advantage of relatively warm, wet springs at lower elevations or drought 
Final Supplemental Environmental Impact Statement

63

conditions that leave many native species unable to compete for limited moisture and nutrients. Lower 

elevation ecosystems, such as piñon-juniper woodlands, naturally have high amounts of bare soil, warmer 

weather, less available moisture during the growing season, and are more susceptible to disturbance and 

invasive plant establishment when compared to higher elevations where moisture is generally not limiting and 

herbaceous plant communities are more resilient and more able to compete with weeds. 

The activities that would cumulatively reduce the amount of weeds in the two national forests are weed 

control projects on other lands and prevention and education efforts. Such projects would reduce the 

possibility of weed transport into the national forests. Conversely, treating weeds on the two national forests

would reduce the potential to transport weeds onto other lands. The preventive measures associated with 

public land projects, such as cleaning vehicles before they arrive at a site, would tend to reduce the 

introduction of new populations.

Special Status Plants

[Replaces entire section]

Special status plants are those listed as threatened or endangered under the Endangered Species Act or 

designated sensitive by the Southwestern Region regional forester of the Forest Service. The vegetation 

specialist report in the project file has detailed habitat information for each species.

Affected Environment for Endangered Plants

The only federally listed plant species in the project area is the endangered Holy Ghost ipomopsis (Ipomopsis 

sancti-spiritu) and its critical habitat (Table S-30). No threatened plants exist on either national forest. 

The only known population of the Holy Ghost ipomopsis exists in continuous scattered patches along 2 miles 

of Holy Ghost Canyon on the Santa Fe National Forest. The acreage of occupied habitat covers about 15 acres 

and the individual plants number approximately 2,500 (USDI 2002). In addition to the main population, Holy 

Ghost ipomopsis seedlings have been planted in Winsor, Panchuela, and Indian Canyons as part of a recovery 

effort. There are no known weeds currently growing within the Holy Ghost ipomopsis populations. Holy 

Ghost Canyon is the only designated critical habitat for this plant.

Table S-30. Threatened or endangered plant species

Plant Species Habitat

Estimated 

Acres of 

Habitat1

Acres of 

Known Weeds 

in the Habitat2

Proportion of 

Sensitive 

Species Habitat 

Affected

Holy Ghost 

ipomopsis and 

critical habitat

South aspect slopes in Holy 

Ghost Canyon, Santa Fe 

National Forest. Plants have 

been transplanted to other 

places to aid recovery.

15 0 0

1 Acres of habitat is based on known areas of occupancy.

2 Acres of weed infestations are populations known as of August 1, 2013. Comprehensive surveys of both national forests have not been 

completed.

Affected Environment for Sensitive Plants

Table S-31 identifies the sensitive plants growing or likely to occur in the two national forests. Acres of 

habitat are based on a combination of habitat type and known areas of occupancy. Acres of weeds in the 

habitat are based on known populations as of August 1, 2013. Where two numbers exist in a single cell, the 

top number is the Santa Fe National Forest and the bottom number is the Carson National Forest.
Invasive Plant Control Project

64

Table S-31. Forest Service Southwestern Region regional forester’s sensitive plant species, 2013, on the Santa Fe 

(SF) and Carson (C) National Forests

Sensitive Plant 

Species Forest Habitat

Estimated 

Acres of 

Habitat

Acres of 

Known 

Weeds in 

the 

Habitat

Proportion 

of Sensitive 

Species 

Habitat 

Affected

Alpine larkspur

Delphinium alpestre

C Alpine meadows. Potential habitat 

11,500-13,000 ft. Three known locales 

all Taos County; Latir Peak, Gold Hill 

and Wheeler Peak.

48,513 9 0.02

Arizona willow

Salix arizonica

SF

C

Subalpine, high elevation meadows. 

Pecos Wilderness and Midnight 

Meadows.

14,119

18,162

13

761

0.09

4.2

Chaco milkvetch

Astragalus 

micromerius

SF Rio Arriba County in two known locales. 104,018 312 0.3

Chama blazing star

Mentzelia conspicua

SF Upper Chama River valley. Specialized 

habitat on gray to red shale and clay of 

the Mancos and Chinle formations on 

slopes of road cuts.

3,021 132 4.4

Greene (Wheel) 

milkweed

Asclepius uncialis

SF Rare and small populations in stable 

grasslands but widespread through 

Plains states. Specimen from Mesita de 

los Ladrones, Anton Chico Grant. Small 

stature is easily overlooked. Found in 

juniper-savannah.

27,160 169 0.6

Heil’s alpine whitlow 

grass

Draba heilii

SF Specimen found in the Pecos 

Wilderness in open areas above 

timberline. Extreme rarity. Named in 

2009.

13,191 0.005 0.00004

Pagosa milkvetch 

Astragalus 

missouriensis var. 

humistratus

C Limited to clay soils of Mancos and 

Lewis formations. One location on 

Jicarilla Ranger District* on black 

Mancos shale. One herbarium record in 

NM Biodiversity.org

124,636 1,013 0.8

Pecos fleabane

Erigeron subglaber

SF

C

Subalpine meadows of high elevation 

coniferous forests. All in Pecos and

Wheeler Peak Wilderness, except one 

population on Elk Mountain.

5,491

256,990

0

75

0

0.03

Pecos (Gunnison’s) 

mariposa lily

Calochortus 

gunnisonii var. 

perpulcher

SF Type specimen found in the Pecos 

Wilderness 8,500 to 11,200 foot aspen 

glades, John’s Canyon, Beulah 

mountain meadows, Harvey’s Ranch 

near Las Vegas, New Mexico. 

Appearance is a pale yellow form of the 

flower.

50,615 78 0.2

Ripley’s milkvetch

Astragalus ripleyi

C Mainly Tres Piedras Ranger District and 

south of Questa. Obvious, pale lemon 

flowers, many acres in several 

localities. Sagebrush/shrubs and 

piñon/juniper/oak woodland/open 

ponderosa pine

175,908 704 0.4
Final Supplemental Environmental Impact Statement

65

Sensitive Plant 

Species Forest Habitat

Estimated 

Acres of 

Habitat

Acres of 

Known 

Weeds in 

the 

Habitat

Proportion 

of Sensitive 

Species 

Habitat 

Affected

Robust larkspur

Delphinium 

robustum

C Canyon bottoms and aspen groves 

from 7,000 to 10,000 ft. No populations 

known on Santa Fe National Forest. 

One specimen from Carson National 

Forest in Taos County on Camino Real 

Ranger District. Others from Eagle Nest 

and Angel Fire.

95,793 17 0.02

Small-headed 

goldenweed

Lorandersonia

(Ericameria) 

microcephala 

(=Happlopappus m.)

C Ponderosa pine zone. Narrow range 

near Tres Piedras, Petaca to Las 

Tablas west of forest road 519. Grows 

on granitic dome hills rock outcrops, 

rock cracks.

51 0 0

Springer’s blazing 

star

Mentzelia springeri

SF

Los 

Alamos 

County 

only

No specimens found on the Santa Fe 

National Forest. Occurs on pumice 

deposits.

13,947 169 1.2

Tufted (Galisteo) 

sand verbena

Abronia bigelovii

SF Occurs on gypsum deposits. One 

location on Santa Fe National Forest in 

Section 35, south of Navajo Peak.

8,805 437 5.0

Wood lily

Lilium 

philadelphicum 

(umbellatum)

SF Scattered locations throughout Santa 

Fe National Forest in cool, moist site 

openings. North slopes in ponderosa 

and mixed conifer. Vulnerable from 

damage to wetland areas and 

collecting. State endangered.

52,158 220 0.4

Yellow lady’s-slipper

Cypripedium 

parviflorum 

pubescens

SF Pecos Wilderness and adjacent areas. 

Rare. Small scattered populations very 

vulnerable to collecting. No specimens 

known for the Carson National Forest.

58,671 1,771 3.0

* RD= ranger district

Environmental Consequences to Special Status Plants

With the design features in place, determinations for the action alternatives are as follows:

• Not likely to adversely affect the Holy Ghost ipomopsis.

• No impacts are expected to the sensitive plants that occur in alpine and subalpine forest communities 

(alpine larkspur, Arizona willow, Heil’s alpine whitlow grass, Pecos fleabane, Pecos mariposa lily, and 

yellow lady’s-slipper).

• Based on design features for sensitive plants (pg. 35), no impacts are expected to lower-elevation 

sensitive plant species. These species are very uncommon or are found only in very limited environments 

or some are not found on National Forest System lands but occur within a county. An individual of a 

species may be impacted, but is not likely to result in a trend toward Federal listing or reduced viability of 

the population for the other species of sensitive plants (Chaco milkvetch, Chama blazing star, Greene 

milkweed, Pagosa milkvetch, Ripley’s milkvetch, robust larkspur, small-headed goldenweed, Springer’s 

blazing star, tufted (Galisteo) sand verbena, and wood lily).
Invasive Plant Control Project

66

Cumulative Effects to Sensitive Plants

The direct and indirect effects of this project would be short-term disturbance (less than 1 day) or less than 5 

percent of any plant’s habitat. Over time, the removal of weeds would promote or preserve the native 

vegetation. The direct and indirect effect to sensitive plants would be too small to measure, and would not 

contribute any noticeable cumulative effect when added to other activities in the analysis area.

Effects of Forest Plan Amendment to Vegetation, including Special Status 

Plants

The effects of the proposed plan amendment to vegetation in future projects would be the same as described 

in this “Vegetation” section. The amendment changes where and when weeds could be treated (in areas of 

high human habitation, in municipal watersheds, and on certain soils). Once cleared for treatment, the effects 

of treatments themselves would be the same as described in this section. Obtaining clearance or permission 

for treatment could take longer due to the consultation and analyses required.

Wildlife Resource

[Replaces entire section]

Methodology

Each species’ habitat was modelled using GIS by the particular vegetation type the species typically uses. 

The “Environmental Impact Statement for the Santa Fe National Forest Plan” (1987) used habitat as a proxy 

for the management indicator species chosen for the Santa Fe. The management indicator species were chosen 

based on commonly used habitats, their economic importance, or their high social interest.

Management indicator species are defined in the 1986 Carson National Forest Plan as, “[t]hose species 

selected in the planning process to monitor the effects of planned management activities on viable populations 

of all wildlife and fish species, including those species that are socially or economically important.” The 

Carson National Forest Plan designates specific management indicator species that could best be used to 

analyze the effects of site-specific proposals on the national forest. The Carson National Forest Plan allows 

flexibility on how management indicator species habitat and population trends are monitored. The 1986 

environmental impact statement for the Carson National Forest Plan described the habitat groups and 

characteristics, along with projected trends of management indicator species, based on current direction and 

management of these habitats. The basis for determining habitat trend is a comparison of estimated 

management indicator species habitats at the time of preparing the Forest Plan to the present. The methods 

used to determine current habitats were developed to approximate similarity (to the degree possible) to the 

acreages used in the 1986 Carson National Forest Plan environmental impact statement. In some cases, the 

estimated acres of management indicator species habitats are based on certain parameters of habitat quality. 

The rationale and methods used to reach the current habitat estimates are described for each species or group. 

The methods generally included developing queries from existing vegetation stand exam data. 

Environmental Consequences Common to All Species

This section describes effects common to all wildlife species. The analysis focuses on the key issues identified 

in chapter 1, which are (1) how the weed treatments may cause habitat disturbance (noise and visual 

disturbance), (2) negative health impacts from herbicides used, or (3) impacts to habitat quality from 

reductions in existing surface vegetation.
Final Supplemental Environmental Impact Statement

67

Alternative A–No Action

As described in the “Vegetation” section of this final supplemental environmental impact statement, without 

treatments, over time weeds would continue to reduce the abundance and diversity of native vegetation that 

provides habitat for native wildlife species. For species that rely on native habitat, a decline in habitat quality 

would occur. For species that do not rely on the displaced habitat, no effect would occur.

The no-action alternative would allow weed populations to continue to expand beyond the 13,260 acres of 

presently known weeds. Monocultures of weeds cause structural changes in habitat, altering habitat. The 

habitat elements that native plants provide for wildlife, such as nesting and ground cover, grass production, 

seed sources, and prey base, would be reduced. The reduction in the amount of these habitat elements would 

negatively affect populations of big game, predator, small mammal, bird, reptile, and amphibian species. 

Because the weed populations are presently small in proportion to the entire acreages of both national forests, 

immediate loss of habitat or forage is not expected. Untreated, however, weeds expand at an estimated rate 

between 5 and 30 percent annually (see “Vegetation” section), depending on the species and ecologic 

conditions at each infestation site.

Over time, weeds could displace native habitat on large acreages and cause detrimental impacts to wildlife on 

the two national forests. For example, the invasion of Russian knapweed in Colorado has resulted in a large 

reduction in the availability of winter range for wildlife. In Montana, it was estimated there would be a loss of 

220 elk annually due to weed invasions of big game winter ranges (FICMNE 1998). In Arizona, stands of the 

weed Lehmann lovegrass have fewer quail, small mammals, and seed-harvesting ants (FICMNE 1998). Frid 

et al. (2013) show weed populations are more difficult to eradicate once a seedbed has been established.

Alternative B–Proposed Action

Alternative B offers the most flexibility for controlling weed populations and thereby is predicted to result in 

the most improvement of native plant communities when compared to alternatives C or D. Because of the 

diversity of treatment methods available, weeds are the most likely to be successfully controlled under 

alternative B, thus restoring the most native vegetation and promoting biological diversity. 

Given the same level of funding, Forest personnel expect to be able to treat the most acreage with the most 

success under alternative B. For a number of weed species that resprout from roots left after mechanical or 

manual treatments (for example, Canada thistle or spotted knapweed), integrated treatments would be highly 

effective at reducing populations. As existing weed populations are controlled or eradicated, fewer treatments 

would be required after several years.

The treatment methods themselves pose a low risk to individual animals and no detectable effect to 

populations. A very small percentage (less than 1/100th of a percent) of habitat for any species would be 

treated in a given year. Because weeds exist in scattered patches across the two national forests, treatments 

would also be widely distributed. Weeds often establish themselves in disturbed areas, like road sides and 

recreation sites, which animals tend to avoid because of human presence. Thus, treatments are not expected to 

pose any additional disturbances to most wildlife.

The next paragraphs describe effects for the key issues:

Disturbance to Habitat: Disturbance to habitat from treatments is not expected to adversely impact wildlife 

species or populations. Mechanical methods (mowing, tilling), prescribed burning, and vehicle-mounted 

herbicide applications would cause the most noise. Biological controls would cause little to no noise 

disturbance. Manual methods, controlled grazing, and manual application of herbicides would cause minimal 

noise and habitat disturbance. Typically, the duration of traffic would be limited to 1 or 2 days and once 

complete, wildlife would soon return to these areas. The level of effect also depends on the current level of 

background noise for an area. Since many areas with weed infestations are near roads, trails, and high use 

recreation sites, wildlife that use these areas probably would be habituated to the presence of people.
Invasive Plant Control Project

68

Fluctuating noise levels may elevate heart rate, catecholamine levels, and corticosteroid levels in wild 

animals, but these elevated levels are generally of short duration, and animals often habituate to these 

disturbances over time. Short-term increases in these measures do not correlate well with actual stress 

experienced by animals. Finally, since most wildlife would avoid the treatment areas during activities, the risk 

of direct herbicide exposure to those animals would be minimal.

Modification of Habitat: Overall, treatments may result in modified habitat for a season or less; the longterm effect of promoting native vegetation (and thus habitat) would be beneficial. Weed treatments would 

cause temporary, localized reduction in existing vegetation, including some native vegetation that could be 

killed or removed along with the weeds. This would not measurably impact wildlife habitat due to the 

relatively small acreages that would be treated in a given time and habitat, along with the design feature

requiring prompt evaluation and revegetation of treated sites where bare soil is exposed. Ground cover would 

be expected to begin to return by the first growing season after treatment, and the abundance and diversity of 

native vegetation would gradually return over subsequent growing seasons.

Each method would have a slightly different, but minimal effect, on the structure and composition of wildlife 

habitat. None of the treatments would result in a loss of large trees, snags, or down log habitat components 

that are important for many species.

Managed grazing with sheep or goats would change the structure of vegetation, but the magnitude of this 

change would be small. The risk of transmitting disease to bighorn sheep would be avoided by not allowing 

sheep or goats to graze in bighorn sheep areas. The Carson and Santa Fe National Forests have a permanent 

closure order prohibiting pack goats in wilderness areas. 

Biological controls (introduction of insects) would not adversely affect habitat for wildlife since this method

would have been studied to ensure that the insects are plant-host specific. Thus the insects would not impact 

native vegetation or other beneficial insects.

Manual methods of weed control such as hand pulling, cutting, or digging would result in minimal changes in 

wildlife habitat quality, especially when conducted on such a small scale and spread widely across the 

national forests. Mowing or mechanical weed treatments would not result in any major alteration in habitat 

quality. 

Burning of individual weeds with a propane torch would leave the remaining habitat structure and 

composition intact. Broadcast burning weed infestations in grasslands or similar habitats conducive to burning 

would result in a minor and temporary change to the seral stage and vegetative community. A controlled 

surface burn would result in little, if any, loss of large snags or down logs, so it would not impact the habitat 

trend or populations of snag-dependent species such as hairy woodpecker.

The impacts from herbicide use on vegetation structure depend on the application method, type of herbicide, 

and rate and season of application. Effects would be a potential change in composition of forbs, grasses, and 

shrubs in treatment areas. Non-target plants could be damaged by unintentional application, drift, or residual 

herbicide in soil. These short-term impacts to plant composition and community diversity would likely be 

offset within the first growing season. There would be no long-term loss of species diversity of native 

vegetation due to the proposed treatments, and species composition under most treatments is expected to 

resemble native plant assemblages within 1 to 3 years. For additional discussion relative to vegetation, see the 

“Vegetation” section.

Herbicide Toxicity Effects: Risk assessments of the herbicide formulations proposed for use have considered 

the risk of harm that could be caused by their use (USDA Forest Service 1992, SERA 2002 to 2007). The risk 

assessments concluded that potential risks of harm to most wildlife species are low for herbicide formulations 

proposed for use at the rates and application methods proposed. 
Final Supplemental Environmental Impact Statement

69

When used at the application rates and concentrations listed on the labels, herbicides would have a very low 

risk of causing short- or long-term harm to wildlife species. There is a general lack of data and some 

uncertainty relative to herbicide effects on amphibians, so there is potential for an unquantifiable impact on 

amphibians from herbicide application. Based on design features and the risk assessments, the risk of toxicity 

to amphibians is considered low. Design features that minimize herbicide delivery in or near waterbodies, 

limit the amount of herbicide used within a given watershed, and limit the type of application permitted in 

riparian areas are required. Also, the extent of proposed herbicide treatments within potential amphibian 

habitat areas is very small. If herbicides were to impact individual amphibians on a local basis, it would not 

affect the population as a whole. Population or habitat trends would not be impacted for any wildlife species 

that occur on the national forests.

Alternative C–No Herbicides

Like alternative B, eradicating, controlling, or containing weeds under alternative C would improve native 

vegetation and help maintain or improve biological diversity on the areas treated. However, given the same 

level of funding as alternative B, fewer acres would be treated and the effectiveness of each treatment 

application would be less. For a number of weed species that re-sprout from roots left after mechanical or 

manual treatments (for example, Canada thistle or spotted knapweed), a greater number of return treatments 

would probably not be effective at reducing populations. Treating weeds in a given area would require 

concentrated effort over several years. In the places where weed treatments were not successful, or if the 

spread rate of weeds continued to exceed the rate of control, the long-term effects would be similar to 

alternative A. Thus, the beneficial improvements to native vegetation and wildlife habitat would be lower for 

this alternative.

Short-term disturbance effects and habitat alteration effects to wildlife would be similar to those described for 

alternative B, except there would be more repeat treatments to achieve the objective so recovery of native 

vegetation would probably take longer. This alternative would completely eliminate the risk to individual 

animals posed by herbicide toxicity. 

Alternative D–Only Herbicides

As with alternatives B and C, implementation of this alternative would improve native vegetation and help 

maintain biological diversity by eradicating, controlling, or containing weeds on the two national forests. 

Some species of weeds do not respond to treatments that apply herbicides alone; for these sites, repeated

treatments could be necessary and the expected effectiveness in meeting objectives would fall between 

alternatives B and C.

Effects of this alternative would be very similar to those described for alternative B. One difference would be 

it eliminates the risk to individuals posed by mechanical treatments. The level of noise and habitat disturbance 

would be slightly less than either alternative B or C as the use of herbicides would result in a reduced need for 

repeat treatments on many sites.

Cumulative Effects Common to All Species

In all action alternatives, cumulative impacts to non-target plant species would stem from forest management 

activities, public land uses, and activities on other public and private lands, as described in the beginning of 

this chapter.

The weed infestations occupy less than one-half of 1 percent of the acreage on the Carson and Santa Fe 

National Forests and are well dispersed. Treatments would be spread out in both time and space. The actual 

direct and indirect effects of each alternative on wildlife are predicted to be of such low magnitude they 

cannot be measured. In all action alternatives, treatment in specific species habitat would be limited to less 

than 5 percent of the habitat for any one species. Of the species analyzed, only three have more than 5 percent 

of their habitat affected by weeds, with the largest being about 17 percent for Gunnison’s prairie dog. The 
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addition of this disturbance to the amount of disturbance caused by other activities is not likely to overlap in 

space and time and would not be measurable. With the design features in place, concentrations of herbicides,

and the duration of exposure on the terrestrial environment would be small and well below levels at which 

chronic exposure effects are documented.

Although some individual animals may be affected (from short-term disturbance), no impact to population or 

habitat trends is predicted, even when considering this project’s impacts in addition to other impacts occurring 

in the project area.

Affected Environment for Management Indicator Species

Management indicator species were identified during development of the forest plans and are used to monitor 

effects of management activities on populations of wildlife and fish, including those that are socially or 

economically important. 

Table S-32 displays the two national forests’ management indicator species, the estimated acres of existing 

habitat, the habitat trend, the population trend, and the acres and percent of weed infestations within those 

habitats. The estimated acres and percent represent the maximum amount of habitat that would be treated 

given known weed populations as of this writing. 
Final Supplemental Environmental Impact Statement

71

Table S-32. Wildlife management indicator species, habitat, and weed infestation

Species1

National

Forest Habitat1

Habitat 

Trend1

Population 

Trend1

Estimated 

Acres 

(Miles) of 

Habitat

Estimated 

Acres (Miles) 

of Habitat with 

Weeds2, 4

Percent of 

Habitat 

with 

Weeds

Brewer’s 

sparrow

Carson Sagebrush Stable to 

increasing

Stable 96,083 377 0.4

Juniper 

titmouse

Carson PiñonJuniperDeclining Stable 352,263 1,445 0.4

Piñon jay Santa Fe PiñonJuniperDeclining Stable 362,176 1,381 0.4

Abert’s squirrel Carson Ponderosa 

Pine

Increasing Increasing 486,497 1,414 0.3

Merriam’s 

turkey

Carson Most 

habitat 

types

Increasing Stable to 

Increasing

574,875 1,431 0.3

Santa Fe Stable to 

Increasing

Stable 417,789 4,111 1

Hairy 

woodpecker

Carson Snags and 

down logs 

in all 

habitats

Increasing Stable 719,950 1,508 0.2

Santa Fe Increasing Stable 804,768 6,125 0.8

Rocky Mountain 

elk

Carson All 

habitats

Stable Stable 1,485,417 5,112 0.3

Santa Fe Stable Increasing 1,216,074 8,931 0.7

Mourning dove Santa Fe Most 

habitats

Stable to 

Increasing

Stable 908,160 6,866 0.8

Rocky Mountain 

bighorn sheep

Carson Alpine Stable Stable 9,474 4 0.04

Santa Fe Stable Stable 7,817 0.005 0.0001

White-tailed 

ptarmigan

Carson Alpine Stable Stable 48,513 9 0.02

Red squirrel Carson Mixed 

Conifer

Increasing Stable 486,497 1,414 0.3

Mexican 

spotted owl

Santa Fe Mixed 

Conifer

Declining Stable 198,889 660 0.3

Rio Grande 

cutthroat trout

Carson Aquatic Stable Stable (138) (1.8) 1.3

Santa Fe Stable Declining 3,924 5 0.1

Resident trout3 Carson Aquatic Stable Stable (770) (19) 2.3

Aquatic macroinvertebrates

Carson Aquatic Stable Stable (1,850) (44) 2.4

1. From Carson and Santa Fe National Forests forestwide management indicator species reports (USDA Forest Service 2011b, 2012). 

2. Acres of weeds are based on populations known as of August 1, 2013.

3. Resident trout include rainbow, German brown, brook, and Rio Grande cutthroat trout. The latter is addressed individually.

4. Acres of weeds located along linear miles of stream were calculated using a 66-foot buffer on each side of the aquatic habitat.

The discussion of each species below is taken from the forest plans and management indicator species reports 

(USDA Forest Service 1986a, 1987a, 2011, 2012).

Brewer’s Sparrow

Brewer’s sparrow is an indicator for sagebrush habitat. In northern New Mexico the habitat for Brewer’s 

sparrow is sagebrush; brushy plains; and the interface of piñon-juniper, woodlands, and sagebrush. Brewer’s 

sparrow is strongly associated with high sagebrush vigor throughout its range, preferring areas dominated by 
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72

high shrub cover, large patch size, and bare ground. The trend for habitat on the Carson National Forest is 

stable to increasing based on the gradual conversion of grasslands to sagebrush. The population trend for the 

Carson National Forest is considered stable.

Juniper (Plain) Titmouse

The juniper (plain) titmouse is an indicator species for the presence of piñon-juniper canopies. The titmouse is 

a resident of deciduous or mixed woodlands, favoring oak and piñon-juniper. The titmouse usually nests in 

natural cavities or old woodpecker holes primarily in oak trees, but it is capable of excavating its own cavity 

in rotted wood. The species feeds mainly on insects, seeds, and occasional fruits and also is a bark gleaner. As 

a cavity nester, large, older trees are an important feature. The Carson National Forest showed a decrease in 

acres of habitat from between 1986 and 2011. There is a downward trend in habitat, with a loss of about 4.0 

percent since 1986. The population trend, however, is stable. This titmouse is a common species on the 

Carson National Forest.

Piñon Jay

Piñon jays nest mainly in stands of piñon and juniper trees. They need open woodlands for nesting and an 

adequate supply of seeds, especially nuts. They are gregarious and breed in colonies up to 150. They spend 

the winters in large flocks of tens to thousands searching for piñon nuts, which are a primary food source. The 

forest plan modeling predicted piñon jay habitat would improve with the implementation of projects that 

would improve foraging habitat. In 2002, drought and subsequent invasion by the Ips beetle caused many 

piñon trees on the Santa Fe National Forest to die, resulting in a loss of about 18 percent of piñon jay habitat. 

Thus, the habitat trend for piñon jay is ranked as declining. The population trend for the Santa Fe National 

Forest is ranked as stable based on the management indicator species report and breeding bird survey routes 

located near the Santa Fe.

Abert’s Squirrel

Abert’s squirrel is an indicator for the presence of interlocking canopies in ponderosa pine. Abert’s squirrel 

depends on ponderosa pine for its life necessities and requires diversity of age classes and tree densities. Pine 

twigs, pine cones, pine seeds, pine bark, and truffles are used by Abert’s squirrel. In addition to pure 

ponderosa pine stands, Abert’s squirrels are also associated with Gambel oak, true piñon, juniper, quaking 

aspen, and Douglas-fir. Habitat on the Carson National Forest has increased just over 20 percent from 1986. 

The habitat condition for the species is considered poor to fair, but in an upward trend. The Abert’s squirrel 

population on the Carson National Forest is on an upward trend at this time.

Merriam’s Turkey

Merriam’s turkey has the widest distribution and is the most common subspecies of turkey. It is found in 

many mountainous areas of northern New Mexico. The bird uses ponderosa pine, a source of mast (nuts and 

seed) and its favorite roosting tree. The ponderosa pine is an essential component of its permanent habitat, 

while surface water is a range requirement. Turkeys prefer to roost in tall mature or overmature ponderosa 

pines with relatively open crowns and large horizontal branches starting at 20 to 30 feet from the ground. 

Trees with a diameter of over 14 inches are used as roosts. A healthy ponderosa pine understory provides the 

turkey cover as well as forage. The Santa Fe National Forest Plan modeling determined feeding habitat was 

the primary limiting factor for turkey, and timber harvest patterns promoting early-seral stages were the most 

beneficial for turkey. The turkey was used as an indicator for the presence of old-growth pine in the Carson 

National Forest Plan. The Santa Fe National Forest rates the habitat trend for turkey as stable to increasing; 

the Carson National Forest rates the trend as slightly upward. The Santa Fe National Forest management 

indicator species report rates the turkey population as stable. The Carson National Forest management 

indicator species report indicates a stable to upward trend for turkeys due to transplants into previously 

unoccupied habitat.
Final Supplemental Environmental Impact Statement

73

Hairy Woodpecker

The hairy woodpecker is a forest generalist, keying in on available snags and live aspen. On both national 

forests, this species is found in areas with abundant snags and downed logs. Nests are primarily in trees 

averaging 17 inches in diameter and approximately 60 feet high. The hairy woodpecker forages primarily on 

tree trunks averaging 17 inches in diameter and greater than 30 feet high. Down logs are important for 

foraging by providing insects. The habitat trend on the Santa Fe National Forest is upward. The habitat trend 

on the Carson National Forest is considered upward. Population trends on both national forests are considered 

stable.

Rocky Mountain Elk

Rocky Mountain elk inhabit most forest types with good forage and cover. These ungulates use a variety of 

habitat types during the course of their life. They appear to be extremely adaptable to a variety of successional 

stages and vegetation types. The habitat trends on the Santa Fe and Carson National Forests are rated as 

stable. The population trend for elk is rated as increasing on the Santa Fe National Forest and stable on the 

Carson National Forest.

Mourning Dove

Mourning dove habitat is abundant in the Santa Fe National Forest. They are found in ponderosa pine, sprucefir, aspen, and piñon-juniper forest types. Most nesting occurs in lower elevation habitats. The abundance of 

nesting and cover opportunities on the Santa Fe National Forest contribute to maintaining viable populations 

of mourning dove. The habitat trend for mourning dove is considered stable to increasing. The population 

trend for mourning dove on the Santa Fe National Forest is ranked as stable based on the statewide trend and 

breeding bird surveys in, and next to, the forest.

Rocky Mountain Bighorn Sheep

Rocky Mountain bighorn sheep inhabit cliffs, crags, and other extremely rocky areas in tundra and alpine 

areas from the summit peaks to around 200 meters (656 feet) below treeline in the northern New Mexico

mountains. Bighorn sheep prefer precipitous terrain adjacent to suitable feeding sites of high mountain 

meadows with grasses, forbs, and browse species. Currently, bighorn sheep occur in the Pecos, Latir Peak, 

and Wheeler Peak Wilderness areas and the Gold Hill area. For both national forests, the habitat and 

population trends are considered stable.

White-tailed Ptarmigan

The white-tailed ptarmigan is used as an indicator for the presence of alpine tundra and subalpine deciduous 

shrub. Little is known about this avian species in New Mexico because it lives on the windswept tundra above 

11,000 feet. The presence of high-elevation shrubby willows (Salix spp.) is likely the most important factor 

for successful overwintering of the species. On the Carson National Forest, ptarmigan habitat approximately 

coincides with the habitat for bighorn sheep. Ptarmigans are also considered to be present on Costilla, Latir, 

Wheeler, Truchas, and associated peaks. For the Carson National Forest, white-tailed ptarmigan habitat and 

population trend are considered stable.

Throughout its range, the white-tailed ptarmigan is listed as globally secure and common, widespread and 

abundant. There is no evidence of large-scale declines. While the actual number of ptarmigan on the Carson 

National Forest is uncertain (albeit low because New Mexico is the very southern end of its range), the 

species is still present and the population trend appears to be stable across the Forest. Although ptarmigan are 

on the forest in low numbers, it was never expected the Carson NF would achieve large breeding populations 

because of the limited amount of suitable habitat in the area (USDA Forest Service, Carson NF 2011). 
Invasive Plant Control Project

74

Red Squirrel

Red squirrels are an indicator species for the mixed conifer habitat type. The squirrels require mature 

coniferous trees as a source of cones and seed. The best cone production occurs in 200- to 300-year-old 

Douglas-fir, 40- to 300-year-old white fir, and 150- to 200-year-old Engelmann spruce. The red squirrel is 

predominantly found in areas with greater than 60 percent canopy closure. Red squirrel habitat on the Carson 

National Forest has increased approximately 20 percent from 1986. The habitat trend is considered upward. 

The population trend is considered stable.

Mexican Spotted Owl

The Mexican spotted owl is an indicator species of old growth, coniferous forest. Nesting and roosting habitat 

is characterized by steep topography, cool shady canyons, and mature, mixed conifer forest with high canopy 

closure. Protected activity centers are established by the Forest Service to protect territories of individual 

Mexican spotted owl. The Carson National Forest has very few areas suitable for Mexican spotted owls; there 

is one protected activity center on the Jicarilla Ranger District. The Mexican spotted owl population on the

Santa Fe is considered rare but the trend is rated as stable. Since the writing of the Santa Fe National Forest

Management Indicator Species Report, the Las Conchas Fire (June 2011) burned through nine Mexican 

spotted owl protected activity centers and habitat.

Rio Grande Cutthroat Trout

The Rio Grande cutthroat trout is one of 14 subspecies of cutthroat trout native to the western United States. 

Rio Grande cutthroat trout are an indicator of clear, cold mountain lakes and streams in the Rio Grande Basin 

in Colorado and New Mexico. The decline in Rio Grande cutthroat trout numbers in New Mexico is attributed 

to many factors, including, but not limited to, (1) introduction of nonnative trout species that either prey upon,

or hybridize with, Rio Grande cutthroat trout; (2) dewatering of streams for irrigation; and (3) altered stream 

habitat. On the Carson National Forest, Rio Grande cutthroat trout habitat and population trends are stable. 

On the Santa Fe National Forest, the habitat trend is stable and the population trend is downward. 

Resident Trout

Resident trout species are used as indicator species for quality perennial streams and riparian vegetation. 

Resident populations reproduce and sustain themselves in the wild. In the Carson National Forest Plan, 

resident trout are rainbow trout (Oncorhynchus mykiss), German brown trout (Salmo trutta), brook trout 

(Salvelinus fontinalis), and Rio Grande cutthroat trout (Oncorhynchus clarki virginalis). Except for the Rio 

Grande cutthroat trout, all resident trout in the Carson National Forest are nonnatives that have been stocked 

extensively in northern New Mexico over the past 100 years. Resident trout habitat and population trends are 

stable on the Carson National Forest.

Aquatic Macroinvertebrates

Aquatic macroinvertebrates, or aquatic insects, are found in lakes, streams, ponds, marshes, and puddles. 

They help maintain the health of the water ecosystem by eating bacteria and dead, decaying plants and 

animals. Local populations of certain aquatic macroinvertebrates are indicator species for high-quality water. 

They are an indicator of overall aquatic conditions, quality of fisheries, and associated riparian habitat. For the 

purpose of analyzing the effects of forest management activities, the primary habitat requirement for aquatic 

macroinvertebrates is perennial water which supports resident trout. For the Carson National Forest, aquatic 

macroinvertebrate habitat and population trends are currently stable.

Environmental Consequences to Management Indicator Species

Effects previously described for all wildlife habitat and populations on the Carson and Santa Fe National 

Forests apply to management indicator species. The following table provides additional information about the 

estimated effects of each alternative for each specific management indicator species on each national forest.
Final Supplemental Environmental Impact Statement

75

Table S-33. Effects to management indicator species

Management 

Indicator Species

Alternative A

(No Action)

All Weed Management Alternatives:

B, C, and D

Brewer’s sparrow No impacts to population or habitat 

trends are expected because 

sagebrush habitat is not threatened 

by weeds.

Same as alternative A.

Juniper titmouse No impacts to population or habitat 

trends because weeds are not 

expected to threaten the piñon pine 

canopy on which the juniper 

titmouse depends. 

No impacts to population or habitat trends 

are expected because weed treatments 

would not affect piñon pine canopy used by 

juniper titmouse. Any changes in understory 

structure as a result of weed treatments 

would not affect population or habitat trends 

because this isn’t a component the species 

depends on.

Piñon jay No impacts to population or habitat 

trends because weeds are not 

expected to threaten the piñon pine 

habitat on which the jay depends. 

No impacts to population or habitat trends 

are expected because weed treatments 

would not affect piñon pine trees used by 

piñon jay. Any changes in understory 

structure as a result of weed treatments 

would not affect population or habitat trends 

because this isn’t a component the species 

depends on.

Abert’s squirrel No impacts to population or habitat 

trends because weeds are not 

expected to affect interlocking 

canopies in ponderosa pine used 

by Abert’s squirrel.

No impacts to population or habitat trends 

are expected because weed treatments 

would not affect interlocking canopies in 

ponderosa pine used by Abert’s squirrel. Any 

changes in understory structure as a result 

of weed treatments would not affect 

population or habitat trends because this 

isn’t a component the species depends on.

Merriam’s turkey No impacts to population or habitat 

trends because weeds are not 

expected to affect the old growth 

pine (roost tree, roost tree groups) 

used by the turkey. Weeds would 

continue to displace native plants, 

grasses, and insects used by 

turkeys, so habitat quality would 

decline. 

No impacts to population or habitat trends 

are expected because weed treatments 

would not affect old growth pine (roost tree, 

roost tree groups) used by turkeys. No 

impacts to population or habitat trend are 

expected because weed treatments would 

result in improving native grasses and other 

surface vegetation so would improve turkey 

habitat. Some loss of vegetation for a 

season following treatments could cause 

temporary displacement.

Hairy woodpecker No impacts to population or habitat 

trends because weeds do not affect 

snags and down logs important to 

hairy woodpecker. 

No impacts to population or habitat trends 

because weed treatments would not cause a 

loss of large snags or down log habitat 

components on which the woodpecker 

depends. Any changes in understory 

structure as a result of weed treatments 

would not affect population or habitat trends 

because this isn’t a component the species 

depends on.

Rocky Mountain 

elk

Weeds would continue to displace 

grasses used as elk forage so 

habitat would decline in quality and 

quantity.

No impacts to population or habitat trend are 

expected because weed treatments would 

result in improving elk foraging habitat. 

Some loss of vegetation for a season 

following treatments could occur, but elk are 

wide ranging and would not be affected by 

this small change.
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Management 

Indicator Species

Alternative A

(No Action)

All Weed Management Alternatives:

B, C, and D

Mourning dove Weeds would continue to displace 

native habitat in a wide variety of 

habitats that this species depends 

upon, resulting in a decline in 

habitat. 

No impacts to population or habitat trend are 

expected because weed treatments would 

restore native vegetation that this species 

uses. Since the dove uses a wide variety of 

habitats, temporary changes to understory 

structure in small patches of its habitat as a 

result of treatments would not impact 

population or habitat trends.

Rocky Mountain 

bighorn sheep

No impacts to population or habitat 

trend are expected because weeds 

are expected to remain very limited 

in high elevation grassland bighorn 

sheep habitat.

No impacts to population or habitat trend are 

expected because weeds aren’t expected to 

thrive at these high elevation grasslands, so 

very little of its habitat would be treated on 

an annual basis. This means at any time, 

over 99 percent of bighorn sheep habitat 

would be intact.

White-tailed 

ptarmigan

No impacts to population or habitat 

trend are expected because weeds 

are expected to remain very limited 

in higher elevation alpine tundra 

and subalpine deciduous shrub 

habitat.

No impacts to population or habitat trend are 

expected because weeds aren’t expected to 

thrive at these higher elevation alpine and 

subalpine habitats, so very little of the 

ptarmigan habitat would be treated on an 

annual basis. This means at any time, over 

99 percent of white-tailed ptarmigan habitat 

would be intact.

Red squirrel No impacts to population or habitat 

trend are expected because weeds 

do not affect mature mixed conifer 

trees used as primary red squirrel 

habitat. 

No impacts to population or habitat trend are 

expected because weed treatments would 

not affect mature mixed conifer trees used 

as primary red squirrel habitat. Any changes 

in understory structure as a result of weed 

treatments would not affect population or 

habitat trends because this isn’t a 

component the species depends on.

Mexican spotted 

owl

Weeds would continue to displace 

native plants, grasses, and insects 

used by prey species of the owl, so 

habitat quality would decline.

No impacts to population or habitat trend are 

expected because weed treatments would 

compose a small percentage of protected 

activity centers and Mexican spotted owl

habitat. Treatments would prevent further 

spread of weeds into prey habitat, which 

would be beneficial to the prey species that 

the owl feeds upon and therefore beneficial 

to the owl.
Final Supplemental Environmental Impact Statement

77

Management 

Indicator Species

Alternative A

(No Action)

All Weed Management Alternatives:

B, C, and D

Rio Grande 

cutthroat trout

Weeds would continue to displace 

native plants and grasses within 

riparian, so habitat quality and 

perennial water quality would 

decline.

With design features in place the proposed 

action may have an indirect impact to 

individual Rio Grande cutthroat trout. The 

Rio Grande cutthroat trout is carnivorous, 

preying entirely on macroinvertebrates. If 

herbicide was to reach the aquatic 

environment, a reduction in aquatic 

vegetation and phytoplankton could occur, 

which could cause a trophic cascade (that is, 

a shift in the food chain), resulting in reduced 

aquatic invertebrate herbivore prey base for 

fish. Mechanical and grazing methods for 

weed removal could temporarily increase 

sedimentation due to ground disturbance in 

the riparian area. The impacts from 

alternatives B, C, and D would likely be a 

localized and small in scale. Therefore, the 

proposed action is not expected to decrease 

population viability or cause a trend to 

federal listing of Rio Grande cutthroat trout.

Resident trout Weeds would continue to displace 

native plants and grasses within 

riparian, so habitat quality and 

perennial water quality would 

decline.

With design features in place the proposed 

action may have an indirect impact to 

individuals of the resident trout. Resident 

trout are carnivorous, preying entirely on 

macroinvertebrates. If herbicide was to reach 

the aquatic environment a reduction in 

aquatic vegetation and phytoplankton could 

occur, which could cause a trophic cascade 

(that is, a shift in the food chain), resulting in 

reduced aquatic invertebrate herbivore prey 

base for fish. Mechanical and grazing 

methods for weed removal could temporarily 

increase sedimentation due to ground 

disturbance in the riparian area. The impacts 

from alternatives B, C, and D would likely be 

a localized and small in scale. Therefore, the 

proposed action is not expected to decrease 

population viability or cause a trend to 

federal listing of resident trout.

Aquatic 

macroinvertebrates

Weeds would continue to displace 

native plants and grasses within 

riparian, so habitat quality and 

perennial water quality would 

decline.

If herbicide was to reach the aquatic 

environment a reduction in aquatic 

vegetation and phytoplankton could occur, 

which could cause a trophic cascade (that is,

a shift in the food chain), resulting in reduced 

aquatic invertebrate abundance. Increased 

sedimentation from mechanical and grazing 

alternatives could impact aquatic macroinvertebrates by filling interstitial spaces in 

the substrate where these organisms dwell. 

Sessile species would be most likely 

impacted. However, the impacts from 

alternatives B, C, and D would likely be a 

localized and small in scale. Therefore, the 

proposed action is not expected to decrease 

population viability of aquatic 

macroinvertebrates.
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Cumulative Effects to Management Indicator Species

Because there are no measurable direct or indirect impacts to population or habitat trend for any management 

indicator species, there would be no cumulative effects from this project. Even though there are no predicted 

negative impacts to population or habitat trends for management indicator species, some habitats would be 

improved as a result of the action alternatives. Combined with past, present, and foreseeable actions such as 

restoration projects (for example, Southwest Jemez Mountains Landscape Restoration Project) on the two 

national forests, there would be an improvement in habitat at a landscape level.

Affected Environment for Threatened and Endangered Species

This section analyzes threatened or endangered wildlife species listed under the Endangered Species Act. 

Threatened, endangered, and sensitive plants are addressed in the “Vegetation” section. For purposes of this 

analysis, the affected environment includes the species actually found on the Carson and Santa Fe National 

Forests and the habitats they occupy or habitats suitable for occupation. The list of species was developed 

from information provided by the U.S. Fish and Wildlife Service. 

No analysis for the following species is required. The Arkansas River shiner (threatened), piping plover 

(threatened), and black-footed ferret (endangered) do not occur, or have habitat, on either national forest. The 

least tern (endangered) has only been found near Bitter Lake National Wildlife Refuge, approximately 190 

miles southeast of the Santa Fe National Forest. The Rio Grande silvery minnow is extirpated on the Santa Fe 

National Forest. Cochiti Reservoir is a permanent barrier to its upstream movement, and no critical habitat 

exists on either national forest.

Table S-34 identifies the species known to be present on the Carson and Santa Fe National Forests; critical 

habitat if present; each species’ status, habitat, and estimated acres of habitat; and acres of weeds within the 

habitat.

Jemez Mountains Salamander (Plethodon neomexicanus) and Critical Habitat

This lungless salamander is found primarily in mixed conifer habitats with abundant rocks and surface logs, 

especially on steep, north-facing slopes. It occurs in relatively high humidity microhabitats and on soils 

containing deep igneous, subsurface rock that is fractured to allow retreat underground to below the frost line. 

The species predominantly occurs at an elevation between 7,200 and 9,500 feet but has been found as low as 

6,998 feet and as high as 10,990 feet (USFWS 2012a). Much of the life cycle occurs underground, with 

surface activity inside rotted coniferous logs or under rocks during a brief period of the summer when 

conditions are warm and wet. Habitat is typically Douglas fir, blue spruce, Engelmann spruce, ponderosa 

pine, or white fir. There is no aquatic life stage for this salamander. Above-ground movement is likely 

associated with summer monsoon rains, generally July through August. When the temperatures are close to,

or within, the mean range of 43 to 63 degrees Fahrenheit, more salamanders will be found under logs 

compared to within logs when temperatures are outside this range (USFS 2011a). 

The salamander is endemic to north-central New Mexico Jemez mountain range where it is found in Los 

Alamos, Rio Arriba, and Sandoval Counties. The species likely occupied the Jemez Mountains for at least 

10,000 years to 1.2 million years (USFWS 2012b). The majority of the salamander habitat is on federally 

managed lands. The land managers in the area consist of the Santa Fe National Forest, the Valles Caldera 

National Preserve, the Bandelier National Monument, the Los Alamos National Laboratory, as well as the 

Santa Clara Indian Reservation, and other private landowners.

Mexican Spotted Owl (Strix occidentalis) and Critical Habitat

The Mexican spotted owl’s nesting and roosting habitat is characterized by steep topography, cool shady 

canyons, and mature mixed conifer forest having high canopy closure. Protected activity centers are 

established to protect the territories of individual Mexican spotted owls. Owls also use ponderosa pine and 
Final Supplemental Environmental Impact Statement

79

other vegetation types for foraging. The Carson National Forest has very limited areas suitable for Mexican 

spotted owl, with only one protected activity center on the Jicarilla Ranger District. Less than 1 acre of weeds 

has been found in this protected activity center.

Mexican spotted owl critical habitat is defined as suitable habitat found within critical habitat units that are

expected to provide the “primary constituent elements” for the owl. Primary constituent elements essential to 

the conservation of the Mexican spotted owl include those physical and biological features that support 

nesting, roosting, and foraging. Critical habitat is limited to areas that meet the definition of “protected” and 

“restricted” habitats, as described in the recovery plan (USDI Fish and Wildlife Service 1995). Excluded from 

the designation of critical habitat are those areas in restricted habitat that do not contain the primary 

constituent elements.

Table S-34. Threatened or endangered wildlife species

Species

Federal 

Status / 

National 

Forest Habitat

Estimated 

Acres of 

Habitat1

Acres of 

Known Weed 

Infestations2

Percent of 

Habitat 

Infested by 

Weeds

Jemez 

Mountains 

salamander

Endangered

/ Santa Fe

Forested areas within 

Valles Caldera and within 

5 miles of Valles Caldera 

boundary above 6,900 ft. 

except for grasslands 

and piñon-juniper

8,681 

(occupied)

15

(occupied)

0.2

Critical habitat Santa Fe Specific areas with the 

defined habitat.

56,779 142 0.3

Mexican spotted 

owl

(Strix 

occidentalis 

lucius) PACs

Threatened/

Carson and

Santa Fe

Old growth and mature 

mixed conifer habitat, 

narrow mesic canyons

33,182 (SF)

600 (C)

31 (SF)

>1 (C)

0.09 (SF)

0.2 (C)

Critical habitat Refer to project record 

for description

198,889 (SF)

23,275 (C)

660 (SF)

297 (C)

0.33 (SF)

1.3 (C)

Southwestern 

willow flycatcher

(Empidonax 

traillii extimus)

Critical Habitat

Endangered 

Carson

Low gradient riparian 

areas with open water 

and well- developed 

willow patches. Dense 

riparian vegetation and

well-developed willow 

patches along the Rio 

Grande del Rancho.

148 27 0.2

New Mexico 

meadow 

jumping mouse*

(Zapus 

hudsonius 

luteus)

Santa Fe

Carson

Wet meadows with tall 

grass in the Jemez and 

Sangre de Cristo 

Mountains 

18,158

7,554

821

377

4.5

5.0

Yellow-billed 

cuckoo

(Coccyzus 

americanus

occidentalis)

Santa Fe

Carson

Riparian areas along 

river systems in 

cottonwood forest.

639

1,006

10

33

1.6

3.3

1. Acres of habitat are based on a combination of habitat type, known areas of occupancy, and/or proximity to habitat features. 

2. Acres of weed infestations are populations known as of August 1, 2013. Comprehensive surveys of both national forests have not 

been completed.
Invasive Plant Control Project

80

Southwestern Willow Flycatcher (Empidonax traillii extimus) and Critical Habitat

The southwestern willow flycatcher nests in dense riparian vegetation including box elders, saltcedar, and 

willows. Nest sites have been found in pure stands of saltcedar in New Mexico. However, the species prefers 

more diverse native riparian vegetation that includes willow and cottonwood. It is known to occur in Rio 

Arriba and Sandoval Counties (Biota Information System of New Mexico).

The species is not federally listed in the Santa Fe National Forest. The flycatcher has been found in two 

locations on the Carson National Forest, within critical habitat on the Camino Real Ranger District in 

Peñasco, New Mexico.

Southwestern willow flycatcher critical habitat is defined as suitable habitat found within flycatcher critical 

habitat units that is expected to provide the “primary constituent elements” for the flycatcher. The primary 

constituent elements essential to the conservation of the southwestern willow flycatcher include those 

physical and biological features that support feeding, sheltering, and cover while breeding and migrating. 

Southwestern willow flycatcher constituent elements of critical habitat are found in the riparian ecosystem 

within the 100-year floodplain or flood prone area. The final rule in the Federal Register (78 FR 344)

identifies primary constituent elements.

New Mexico Meadow Jumping Mouse (Zapus hudsonius luteus) and Critical Habitat

Habitat requirements are characterized by tall (averaging at least 24 inches), dense herbaceous riparian 

vegetation composed primarily of sedges and forbs, associated with perennial flowing water (USFWS 2013b). 

The New Mexico meadow jumping mouse is considered a habitat specialist exclusively dependent upon 

riparian areas (Morrison 1990, 1992; Frey and Malaney 2009). This mouse has been found above 6,890 feet 

in the Jemez Mountains and at 3,937 feet in the Rio Grande Valley; in all cases they occurred within 150 feet 

of permanent free-flowing water (NMDGF 2008).

The New Mexico meadow jumping mouse eats mainly seeds and insects. Although primarily nocturnal, this 

mouse is also occasionally diurnal in its activity. In New Mexico, these mice are generally active three to four 

months of the year and hibernate through the winter months (USFWS 2013b). Jumping mice generally have 

limited ability to move and limited dispersal capabilities (Morrison 1988, p. 13). 

The New Mexico meadow jumping mouse occurs within eight conservation areas across its current range. 

The Jemez Mountains conservation area is located on the Jemez and Cuba Ranger Districts of the Santa Fe 

National Forest which contains seven known populations. Populations are loosely defined as a capture 

location or cluster of locations within a reasonable dispersal distance of one another (generally less than a half 

mile).

Yellow-Billed Cuckoo (Coccyzus americanus occidentalis)

The yellow-billed cuckoo breeds in riparian woodlands and similar habitats at lower (2,800 – 5,500 ft) to 

middle (5,000 – 7,500 ft) elevations where stream conditions provide sufficient permanent moisture for 

emergent plants, or for a narrow band of deciduous trees and shrubs. Populations fluctuate substantially in 

response to fluctuations in caterpillar abundance. Declines resulting from loss or disturbance of riparian 

habitat have been consistently reported in the West. The greatest factors affecting the yellow-billed cuckoo

have been the invasion of exotic woody plants into southwest riparian systems, and clearing of riparian 

woodlands for agriculture, fuel, development, and attempts at water conservation (BISON-M 2001).

The Carson and Santa Fe National Forests have less than approximately 640 acres of suitable habitat for the 

cuckoo. Approximately 10 acres of known weed infestations occur within the cuckoo’s habitat on both 

national forests. Yellow billed cuckoo habitat is very limited on the Forests, since the cuckoos’ are known to 

occur at elevations less than 7,500 ft. Non-native shrubs are one of the factors negatively impacting the 

cuckoo. 
Final Supplemental Environmental Impact Statement

81

Environmental Consequences to Threatened and Endangered Species

Effects of weed treatments described for all wildlife habitat and populations on the forests apply to threatened 

and endangered species. Table S-35 provides additional disclosures of estimated effects of each alternative for 

each threatened or endangered species. Effects are generally the same for all action alternatives other than the 

minor differences noted in the general wildlife effects, such as the slower rate of native vegetation recovery 

under alternative C. Also under alternative C, the low risk of impacts to individual animals from herbicides 

would be eliminated, and under alternative D, the low risk of impacts to individual animals from mechanical 

treatments would be eliminated. Action alternatives would not be likely to affect threatened or endangered 

species based on previous consultations with the U.S. Fish and Wildlife Service in 2005: Carson National 

Forest Consultation # 2-22-00-I-237 and Santa Fe National Forest Consultation # 2-22-00-I-324 (USFWS 

2005) and recent consultation Santa Fe National Forest Consultation # 02ENNM00-2015-I-0149 (USFWS 

2015).

Jemez Mountains Salamander (Plethodon neomexicanus) and Critical Habitat

With design features in place, alternative B, the preferred alternative, may affect but is not likely to adversely 

affect the Jemez Mountain salamander. Alternative B may affect but is not likely to adversely affect critical 

habitat. 

The Jemez Mountains salamander is present above ground only during late summer monsoon rains when 

rainfall is sufficient. Herbicide treatments would not take place in rainy weather as this makes the treatments 

ineffective. Treatments of grubbing, hand pulling, or controlled grazing would also not take place during the 

period when there is a risk to the Jemez Mountains salamander because it is above ground and could be 

inadvertently stepped on by a crew person. The cooperative management plan (New Mexico Endemic 

Salamander Team 2000) will be used to identify areas to protect the salamander. Rain for five consecutive 

days would delay treatment until the land surface conditions dried. During rainy weather, treatments other 

than herbicides would be possible on habitat known to not support the salamander. 

Mexican Spotted Owl and Critical Habitat

With design features in place, alternative B may affect but is not likely to adversely affect, and may be 

beneficial to the Mexican spotted owl. Alternative B may affect but is not likely to adversely affect critical 

habitat.

These determinations are based on the predicted increase in prey species in potential foraging areas for the 

Mexican spotted owl. The design features for the action alternatives listed in chapter 2 would prevent adverse 

effects to Mexican spotted owl and critical habitat. The treatments would be short duration, low disturbance 

activities which would occur once or twice in a season (depending on size of the treatment area).

Southwestern Willow Flycatcher and Critical Habitat

With design features in place, alternative B may affect but is not likely to adversely affect the southwestern 

willow flycatcher. For example, surveys would be performed if the proposed treatment would occur when 

flycatchers may be present in the area. If the flycatcher were found during the surveys, treatment would not 

take place until the birds completed nesting and their young dispersed. Further, the effects of treatment would 

last a year or less or to the end of the next growing season.

Alternative C would rely on mechanical treatments that, when implemented in riparian areas, could result in 

greater change in the short-term vegetation structure compared to alternatives B or D.
Invasive Plant Control Project

82

New Mexico Meadow Jumping Mouse (Zapus hudsonius luteus) and Critical Habitat

With design features in place for riparian areas, alternative B, the preferred alternative, may affect but is not 

likely to adversely affect the New Mexico meadow jumping mouse. Alternative B may affect but is not likely 

to adversely affect critical habitat. 

Design features for riparian areas would ensure the mouse would have no impacts from herbicides. Only 

small amounts of habitat would be treated each year within the riparian habitat of the mouse. Small areas 

could be treated by hand pulling or grubbing depending on the weeds species. Native vegetation would be 

avoided by identification before treatment. The mouse hibernates below ground for nearly 9 months and 

emerges in July. Any treatments would take place before the mouse emerged from hibernation in July.

Yellow-Billed Cuckoo (Coccyzus americanus occidentalis)

Yellow billed cuckoo habitat is very limited on the Forests, since the cuckoos’ are known to occur at 

elevations less than 7,500 ft. Non-native shrubs are one of the factors negatively impacting the cuckoo. 

Removal of these plants will improve the habitat for the cuckoo. Mitigation measures would prevent 

disturbance during the breeding season.

Herbicide application within a riparian area or 50 feet from a water body would be limited to hand application 

onto individual weeds (using backpack spray wand, glove, wick, or rag). For treatment exceeding 1 acre 

within threatened, endangered or proposed species, surveys for the species would be conducted prior to 

implementation. If surveys are not conducted, that area will be considered occupied. With mitigation 

measures in place, the proposed action may affect but is not likely to adversely affect the yellow-billed 

cuckoo.

Table S-35. Effects to, and determinations for, threatened or endangered species

Threatened or 

Endangered Species

Alternative A

(No Action )

Alternatives B, C, and D 

(All Weed Management Alternatives)

Jemez Mountains 

salamander

Weeds would continue to 

reduce vegetative 

invertebrate habitat used 

by the salamander as 

prey, thereby reducing the 

Jemez Mountains 

salamander prey base.

No effect. No treatments would occur when the 

Jemez Mountains salamander comes above 

ground after several consecutive days of rain. 

Herbicide treatments are not effective and would 

not be used in these conditions. The treatments of 

grubbing, hand pulling, or controlled grazing 

(goats) would also not take place during the period 

when there is a risk to the Jemez Mountains 

salamander because it is above ground and could 

be inadvertently stepped on.

Jemez Mountains 

salamander critical 

habitat

Weeds would continue to 

invade critical habitat 

making the surface 

inhospitable or 

inaccessible due to root 

density or dead plant litter.

May affect, but not likely to adversely affect with an 

overall beneficial effect because treatments would 

improve the habitat of the invertebrate prey of the 

Jemez Mountains salamander.

Mexican spotted owl 

(threatened)

Weeds would continue to 

reduce native understory 

vegetation used by owl’s 

prey, thereby reducing the 

owl’s prey base. 

May affect, but not likely to adversely affect with an 

overall beneficial effect because treatments would 

improve the habitat of the prey the owl feeds on. 

Negligible negative effects would be expected 

given the design features that avoid disturbing owls 

during the breeding season.

Mexican spotted owl 

critical habitat

Weeds would continue to 

displace native understory 

vegetation. The 

characteristics of critical 

habitat that favor prey 

habitat would be changed.

May affect, but not likely to adversely affect with an 

overall beneficial effect because treatments would 

improve the habitat.
Final Supplemental Environmental Impact Statement

83

Threatened or 

Endangered Species

Alternative A

(No Action )

Alternatives B, C, and D 

(All Weed Management Alternatives)

Southwestern willow 

flycatcher (endangered)

Weeds would continue to 

displace the native 

riparian vegetation that 

flycatchers prefer.

Treatments would improve native willow and 

cottonwood riparian habitats preferred by willow 

flycatchers. During treatments, some loss of 

existing vegetation would occur and could reduce 

suitability for use by flycatchers until native 

vegetation is reestablished. There would be a very 

low risk that some individual birds could be 

impacted by any treatments given the design 

features requiring surveys prior to treatments in 

potential habitat. 

Southwestern willow 

flycatcher critical 

habitat

Weeds would continue to 

displace native riparian 

vegetation within critical 

habitat.

No effect to critical habitat because the elements 

that compose it will not be changed. 

New Mexico meadow 

jumping mouse

The jumping mouse feeds 

on seeds of the riparian 

grass community. They 

depend on tall grasses in 

the narrow riparian zone. 

Weeds spreading within 

this habitat will decrease 

the suitability of the 

habitat. Weed populations 

would be expected to be 

robust and increase with 

constant soil moisture 

thus lessening the survival 

chances of the mouse.

Design features for riparian areas, the mouse’s 

habitat, would ensure the mouse would have no 

impacts from herbicides. Only small amounts of 

habitat would be treated each year within the 

riparian habitat of the mouse. Small areas can be 

treated by hand pulling or grubbing depending on 

the weeds species. Native vegetation would be 

avoided by identification before treatment. The 

mouse hibernates below ground for nearly 9 

months and emerges in July. Any treatments would 

take place before the mouse emerged from 

hibernation in July. The proposed action would not 

be expected to decrease population viability or 

cause a trend to federal listing of this species. 

Yellow-billed cuckoo

(Coccyzus americanus

occidentalis)

Continued decline in the 

extremely limited riparian 

cottonwood willow forest 

required by the cuckoo for 

nesting.

No direct impacts are expected to the westernyellow billed cuckoo because treatments would not 

occur during breeding season. 

Removal of nonnative invasive shrubs would

indirectly improve the cuckoo’s habitat. One of the 

greatest factors affecting the yellow-billed cuckoo is

the invasion of exotic woody plants into southwest 

riparian systems.

Cumulative Effects to Threatened and Endangered Species

Because there would be no negative direct or indirect effects to threatened or endangered species due to the 

design of the project, there would be no cumulative adverse effects. The action alternatives, however, are 

expected to have beneficial direct and indirect effects to native habitats. Combined with other projects that 

would improve habitats, such as the Southwest Jemez Mountains Landscape Restoration Project, there would 

be an overall cumulative beneficial effect to threatened and endangered species habitats.

Affected Environment for Sensitive Wildlife Species

The effects common to all species apply to the sensitive species described in this section. For purposes of this 

analysis, the affected environment includes the species actually found on the national forests and the habitats 

they occupy or are suitable for occupation. The list of species in the project area was developed from the 2013

list of sensitive animals and plants (USDA Forest Service, Southwestern Region, 2013). Sensitive aquatic 

species are discussed in the “Fisheries and Aquatics” section of this chapter. Acres of habitat come from GIS 

analysis through vegetative cover types and local specialists’ knowledge. The weed populations are those 

known as of August 1, 2013. Detailed descriptions of the species’ habitats and life histories are located in the 

project record. The roundtail chub does not occur on either national forest; thus, it will not be discussed 
Invasive Plant Control Project

84

further. The Canada lynx’s habitat is high-elevation, spruce-fir in Colorado, where it was introduced. It is not

historically known to occur on either national forest and will not be discussed further.

The next tables display each sensitive species, the national forest(s) on which it is found, its habitat, the 

amount of habitat, and the acres of habitat with weeds. Where two numbers exist in a cell, the top number 

represents the Santa Fe National Forest and the bottom number represents the Carson National Forest.

Table S-36. Sensitive species, amphibians

Species 

Name

National 

Forest Habitat

Estimated 

Acres or 

Miles of 

Habitat

Acres of 

Known Weed 

within Habitat

Percent of 

Habitat 

with 

Weeds

Northern 

leopard frog

(Rana 

pipiens)

Santa Fe

Carson

Associated with 

water

40,790

24,784

1,882

1,682

4.6

6.8

Western 

boreal toad

(Bufo boreas 

boreas)

Carson High-elevation lakes 

and forests. 

Reintroduced in one 

location 2008.

31,447 12 0.04

Table S-37. Sensitive species, birds

Species Name

National 

Forest Habitat

Estimated 

Acres or 

Miles of 

Habitat

Acres of 

Known Weed 

Infestations 

within Habitat

Percent of 

Habitat 

Infested 

with 

Weeds

American 

peregrine falcon1

(Falco peregrines 

anatum)

Santa Fe

Carson

High cliffs with 

horizontal breaks for 

nest ledges

89,213 1,063 1.2

Bald eagle

(Haliaeetus 

leucocephalus)

Santa Fe

Carson

Riparian areas along 

major river corridors, 

but winter habitat is

not always associated 

with riparian areas.

20,252

37,364

355

100

1.8

0.3

Boreal owl

(Aegolius 

funereus)

Santa Fe

Carson

High-elevation mature 

spruce-fir forests

193,548

179,652

620

52

0.3

0.03

Burrowing owl 

(Western)

(Aegolius 

funereus)

Santa Fe

Carson

Prairie dog towns 61,301

73,863

581

471

1.0

0.6

Gray vireo

(Vireo vicinior)

Santa Fe

Carson

Juniper grasslands 

with shrub component

178,430

119,437

919

951

0.5

0.8

Northern 

goshawk

(Accipiter gentilis)

Santa Fe

Carson

Most mature forested 

habitats except piñonjuniper

24,867

7,247

174

13

0.7

0.2

White-tailed 

ptarmigan

(Lagopus 

leucurus)

Santa Fe

Carson

Alpine areas 136,685

48,513

3

9

0.002

0.02

1. Habitat, including the known 12 post-fledging areas, for the peregrine falcon on the Carson National Forest has not yet been mapped. 

The effects, however, would be the same as for that described for the Santa Fe National Forest.
Final Supplemental Environmental Impact Statement

85

Table S-38. Sensitive species, mammals

Species Name

National 

Forest Habitat

Estimated 

Acres or 

Miles of 

Habitat

Acres of 

Known Weed 

Infestations 

within Habitat

Percent of 

Habitat 

Infested 

with 

Weeds

Cinereus 

(masked) shrew

(Sorex cinereus 

cinereus)

Santa Fe

Carson

Riparian areas in subalpine coniferous 

forest in Sangre de 

Cristo, Jemez, and 

San Juan Mountains 

unusually above 9,500 

feet

262,024

260,291

695

52

0.3

0.02

Preble’s shrew

(Sorex preblei)

Santa Fe Near permanent or 

intermittent streams in 

arid to semi-arid shrub 

or grassland or lesser 

into conifer forest

60,153 1,896 3.2

American water 

shrew

(Sorex palustris 

navigator)

Santa Fe

Carson

Permanent streams, 

seldom below 8,000

feet

60,153

37,997

1,896

1,083

3.2

2.9

Spotted bat

(Euderma 

maculata)

Santa Fe

Carson

Rock cliffs 60,153

37,397

1,896

1,803

3.2

4.8

Pale Townsend’s 

big-eared bat

(Corynorhinus 

townsendii 

pallescens) 

Santa Fe

Carson

Caves, mines or 

abandoned buildings

267,638

293,153

1,568

193

0.6

0.07

American marten

(Martes 

americana 

origenes)

Santa Fe

Carson

High-elevation sprucefir forests263,881

318,454

928

104

0.4

0.03

Gunnison’s prairie 

dog*

(Cynomys 

gunnisoni)

Santa Fe

Carson

Mountain meadows

Valley floors and plains

1,214

51,465

205

814

16.9

1.6

Pika

(Ochotona 

princeps saxatilis)

Santa Fe

Carson

Talus slopes in Pecos 

Wilderness in Santa 

Fe National Forest and 

locations within and 

outside Pecos 

Wilderness on the 

Carson National Forest

86,326

48,513

0.03

9

0.00004

0.02

Goat Peak pika

(Ochotona 

princeps 

nigrescens)

Santa Fe Talus slopes in the 

Jemez Mountains 

around the Valles 

Caldera National 

Preserve and west 

side of Los Alamos 

County

86,326 0.03 0.00004

* Indicates candidate species for Federal listing as threatened or endangered.
Invasive Plant Control Project

86

Table S-39. Sensitive species, snail

Species 

Name

National 

Forest Habitat

Estimated 

Acres or 

Miles of 

Habitat

Acres of 

Known Weed 

Infestations 

within Habitat

Percent of 

Habitat 

Infested 

with 

Weeds

Ruidoso 

snaggletooth

(Gastrocopta 

ruisdsensis)

Santa Fe Found on bare soil, under 

stones, and in thin 

accumulations of grass 

thatch and juniper litter on 

mid-elevation carbonate 

cliffs and xeric limestone 

grasslands along the eastern 

slopes of the Sangre de 

Cristo and Sacramento 

mountains in eastern New 

Mexico, where the only 

extant occurrences are.

16,912 16 0.1

Environmental Consequences to Sensitive Wildlife Species

Effects of weed treatments described for all wildlife habitat and populations on the forests apply to sensitive 

species. All the action alternatives would treat less than 0.1 percent (and in most cases, much less than that) of 

the species’ habitat in a given year. This means that the species would still have the vast majority of its range 

to forage and breed in. The disturbance caused by weed treatments, already composing a very low percentage

of total habitat, would last a season or less; the long-term result of reducing weed populations is expected to 

be beneficial to sensitive species by preventing weed expansion in native habitat. As a result, none of the 

action alternatives are expected to cause negative effects to the species or its habitat. The proposed action is 

not expected to cause a trend towards Federal listing for any sensitive species.

Amphibians

Effects to all sensitive amphibians are listed in Table S-40. The proposed action (alternative B) is not expected 

to decrease population viability or cause a trend to federal listing.
Final Supplemental Environmental Impact Statement

87

Table S-40. Sensitive species: Effects to amphibians

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management

Alternatives) Reason for Determination

Northern leopard frog There would be an 

increased loss of riparian 

and aquatic habitat. 

Weeds would continue to 

spread in this habitat 

decreasing its suitability for 

the northern leopard frog.

With design features for 

riparian and aquatic 

habitats in place, none of 

the action alternatives will 

have an impact to the frog.

The proposed action would not 

contribute to the primary threats 

to this species, which are

changes in wetlands, especially 

the alteration of marshy ponds to 

reservoirs; stocking of predatory 

fish; natural local extinctions as 

ponds dry up during years of low 

precipitation; and predation and 

competition by introduced 

bullfrogs (Biota Information 

System of New Mexico).

Western boreal toad There would be an 

increased loss of riparian 

and aquatic habitat near 

the Trout Lakes. Weeds 

would continue to spread 

in this habitat, decreasing

its suitability for the boreal 

toad.

With design features for 

riparian and aquatic 

habitats in place, none of 

the action alternatives will 

have an impact to the toad.

Recent surveys indicate the 

species may have declined in 

New Mexico in recent years, and 

it is believed to be extirpated. The 

design features for riparian areas 

would prevent any negative 

effects to the toad or its habitat.

Birds

Effects to all sensitive bird species are listed in table S-41. The alternative B is not expected to decrease 

population viability or cause a trend to federal listing.

Table S-41. Sensitive species: Effects to birds

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management 

Alternatives) Reason for Determination

American peregrine 

falcon

Nest habitat would not be 

affected. Cliff nesting 

areas do not have weeds 

but protected zones 

around the nesting areas 

could be subject to a slow 

decline in prey as its

habitat becomes more 

unsuitable due to the 

spread of weeds. 

Protection zones (A – D, with 

increased protections the 

closer to the nest site) are 

established for each nest 

site. Activities are subject to 

restrictions according to 

zone. With these in place, 

none of the alternatives will 

have an impact to the falcon.

Falcon habitat is primarily cliffs, 

where weeds do not tend to 

occur. Treatments would occur in 

less than 0.1 percent of foraging 

habitat in a given year.
Invasive Plant Control Project

88

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management 

Alternatives) Reason for Determination

Bald eagle Increased loss of riparian 

habitat as weed tree 

species displace the 

cottonwoods used as 

roosting trees and hunting 

perches. Weed trees do 

not grow large enough for 

eagle use. Decreased use 

of the winter habitat on 

the two national forests.

The bald eagle is only 

present during winter months 

(November through March). 

No treatments of any type 

would take place in winter to 

avoid disturbance to the 

eagle. Identification of 

herbaceous invasive species 

would be extremely difficult 

to impossible. Prescription 

burns (except burning of 

piled material in designated 

areas) would not be done in 

riparian habitat used by the 

eagle because of the 

detrimental effects of fire to 

large cottonwoods. 

Treatments that restore or

protect native vegetation 

(planting of cottonwoods and 

willow) over the long term 

benefit the eagle.

The design features specifically 

for the bald eagle would prevent 

negative impacts to the eagle or 

its habitat.

Boreal owl No impacts are expected 

to the boreal owl because 

its habitat is highly remote

(not very affected by 

weeds) and under snow 

in breeding season. 

No impacts are expected to 

the boreal owl because its 

habitat is highly remote and 

under snow in breeding 

season

Boreal owl habitat is remote and 

under snow in breeding season 

in early spring. Treatments could 

not occur in the habitat until late 

in the season when hatchlings 

have fledged.

Burrowing owl 

(western)

There would be a slow 

decrease in acres of 

prairie dog towns (prey) 

due to increased weed 

cover. Available nesting 

areas for the owl would 

decrease, leading to a 

lower population or 

abandonment of currently 

used areas.

No impacts to the owl are 

expected with the design 

features in place. 

Burrowing owls have only been 

located on the Carson. Some 

treatments, such as grazing and 

prescribed fire, would improve 

habitat for burrowing owls.

Gray vireo Slow decrease of 

understory preferred by 

the vireo for nesting and 

foraging for invertebrate 

prey. Habitat would

become less sustaining 

for the species.

No impacts to the gray vireo 

are expected with the design 

features in place.

Habitat is scattered and sparse. 

As displayed in the vegetation 

section, weed treatments are not 

expected to affect piñon-juniper 

habitat on which this species 

depends. 

Northern goshawk Slow decrease in habitat 

quality as the prey 

species food base is 

decreased by weeds.

No impacts to the goshawk 

are expected with the design 

features in place. Treatments 

would not occur in breeding 

habitat during breeding 

season around nest sites or 

on post-fledging areas.

With design features in place,

alternative B would have no 

impact to the northern goshawk 

because treatments would not 

occur in breeding habitat during 

breeding season.
Final Supplemental Environmental Impact Statement

89

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management 

Alternatives) Reason for Determination

White-tailed 

ptarmigan

Slow decrease of forbs 

preferred by ptarmigan for 

food. Habitat would

become less sustaining 

for the species.

With the design features in 

place no impacts are 

expected to the white-tailed 

ptarmigan. Less than 0.001

percent of its habitat would 

be treated, leaving most of 

its range undisturbed.

Ptarmigan habitat is extremely 

high elevation and is cold most of 

the year; treatments would only 

occur for short periods. Design 

features would avoid disturbance 

during the nesting period.

Mammals

Effects to all sensitive mammals are listed in Table S-42. The alternative B is not expected to decrease 

population viability or cause a trend to federal listing.

Table S-42. Sensitive species: Effects to mammals

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management 

Alternatives) Reason for Determination

Cinereus 

(masked) shrew

Impacts are not expected 

immediately as cinereus 

shrew feeds on insects. 

Weed populations 

increasing in the habitat 

would likely lead to 

decreased prey insects 

therefore less food 

available.

With the design features in 

place, no impacts to the 

cinereus shrew are expected.

This shrew is mainly at high 

elevation wet meadows / marsh 

areas. Weeds are uncommon in 

these habitats. Activities for weed 

control would be occasional and not 

cause a negative impact to the 

habitat of the shrew.

Preble’s shrew Impacts are not expected 

immediately as Preble’s 

shrew feeds on insects. 

Weed populations 

increasing in the habitat 

would likely lead to 

decreased prey insects 

therefore less food 

available.

With the design features in 

place, no impacts to the 

Preble’s shrew are expected.

This shrew is mainly at lower 

elevations in sage scrub areas. 

Weeds are uncommon in this 

habitat. Temporary activities for 

weed control would be occasional 

and not cause a negative impact to 

the habitat of the shrew. This shrew 

has only been found on the Santa 

Fe National Forest in Sandoval 

County.

American water 

shrew

Habitat could decrease as 

water quality decreases 

from sediment not 

captured by weeds before 

it reaches a stream.

With the design features in 

place, no impacts to the 

American water shrew are 

expected.

Water shrews feed on small 

minnow and insects in the water. 

Protecting water quality by 

removing weeds helps protect the 

habitat of the shrew.

Spotted bat Cave and cliff crevices do 

not support weeds, so no 

effect if the project did not 

occur.

Bat habitat is cave and 

crevices on cliff faces. No 

treatments would occur in 

these areas.

This species is rare throughout its 

range, indicating that its scarcity in 

New Mexico may be due to biology 

rather than due to other impacts 

(NMDGF 2006). This, combined 

with the design features, means 

that weed treatments are not 

expected to impact the species.
Invasive Plant Control Project

90

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management 

Alternatives) Reason for Determination

Pale 

Townsend’s bigeared bat

Cave and cliff crevices do 

not support weeds, so no 

effect if the project did not 

occur.

No impacts are expected to the 

pale Townsend’s big eared bat 

because its main threats are 

habitat loss, cave vandalism,

and disturbance by cave 

explorers at maternity and 

hibernation roosts. The design 

features associated with this 

project would prevent 

disturbance from the people 

conducting treatments.

The occurrence of this bat is 

correlated strongly with the 

availability of caves or cave-like 

roosting habitat (mines, buildings, 

snags, etc. (Perkins and Schommer 

1992), which are highly sensitive to 

disturbance and the presence of 

people. Weed treatments would not 

take place in roosting habitat 

because weeds don’t grow in them. 

The design features would prevent 

disturbance to the bat.

American 

marten

Indirect impacts to the 

marten would occur slowly 

as weeds decrease habitat 

quality for its prey species.

No impacts to the marten are 

expected because its main 

threats are timber harvest, 

trapping, snag removal, and 

firewood collection. This project 

does not propose any of those 

activities.

This project doesn’t propose any 

activities listed by scientific studies 

as the main disturbance factors to 

the marten.

Rocky Mountain 

bighorn sheep

Impacts are not expected 

as bighorn sheep feed on 

a diversity of plants and 

will avoid those weeds 

which are toxic. Only very 

small amounts of weeds 

would be expected to 

survive in their highelevation habitat.

No impacts to the bighorn 

sheep are expected because 

weeds aren’t expected to thrive 

at these high elevations, so 

little habitat would be treated 

on an annual basis. Goats are 

prohibited in bighorn sheep 

habitat by a permanent closure 

order to avoid introducing 

disease to the bighorn sheep 

population.

Same as at left.

Gunnison’s 

prairie dog

Impacts are not expected 

immediately as 

Gunnison’s prairie dog 

feed on common grasses 

and plants, avoiding those 

weeds which are toxic. 

Weed populations 

increasing in prairie dog

towns would likely lead to 

decreased health and loss 

of prairie dogs or 

abandonment of the 

prairie dog town.

No impacts to Gunnison’s 

prairie dog are expected 

because its main threats 

include predation, man, habitat 

loss, and sylvatic plague (Biota 

Information System of New 

Mexico). This project would 

improve habitat by increasing 

native plants that compose its 

habitat.

Same as at left.
Final Supplemental Environmental Impact Statement

91

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management 

Alternatives) Reason for Determination

American pika Pika feed on common 

grasses within their highelevation talus slope 

habitat. They cut and store 

grass to dry as hay for 

winter food. Weed 

populations would be 

expected to be small 

within the talus slopes. No 

increase in weeds and 

therefore no decrease in 

grasses are expected 

within the rocky, highelevation habitat. 

American pika inhabits highelevation rocky slopes in the 

Sangre de Cristo Mountains at 

elevations above 

approximately 10,000 feet. This 

species is an herbivore (Biota 

Information System of New 

Mexico). No impacts to the pika 

are expected because 

treatments would not occur in 

its habitat – rocky, talus slopes. 

The pika isn’t expected to be 

subject to disturbance from 

treatment. The proposed action 

would not be expected to 

decrease population viability or 

cause a trend to federal listing 

of this species.

No disturbance to the pika from 

treatments is expected (see left).

Weeds are generally not consumed 

by the pika as the preferred forage 

is grass.

Goat Peak pika Goat Peak pika feed on 

common grasses within 

their high elevation talus 

slope habitat. They cut 

and store grass to dry as 

hay for winter food. Weed 

populations would be 

expected to be small 

within the talus slopes. No 

increase in weeds and 

therefore decrease in 

grasses are expected 

within the rocky, highelevation habitat. 

Same as the American pika. Same as American pika.

Snail

Effects to the sensitive snail are listed in Table S-43. The proposed action (alternative B) is not expected to 

decrease population viability or cause a trend to federal listing.

Table S-43. Sensitive species: Effects to snail

Species

Alternative A

(No Action)

Alternatives B, C, and D

(All Weed Management 

Alternatives) Reason for Determination

Ruidoso 

snaggletooth

Impacts not 

expected as this 

snail feeds on 

dead or decaying 

plant material. 

Weeds in 

limestone habitat 

are low to none. 

Wildfire is the biggest threat to 

the snail because of the loss of 

cover and vegetative substrate 

in its habitat. This snail lives 

near limestone outcroppings 

where weed treatments are 

unlikely to occur. Since the snail 

feeds on dead or decaying 

plants, its food sources would

not be treated.

No impacts are expected to 

the Ruidoso snaggletooth. 

Design features will avoid 

impacts to the snail. The 

proposed action would not be 

expected to decrease 

population viability or cause 

a trend to federal listing of 

this species.

Cumulative Effects – Sensitive Species

Because there would be no measurable direct or indirect effects to sensitive species as a result of the 

protective design features being in place, there would be no cumulative effects.
Invasive Plant Control Project

92

Affected Environment for Migratory Birds

Presidential Executive Order 13186 (January 2001) requires unintentional take of migratory birds reasonably 

attributable to agency action be disclosed and the effects to migratory bird populations be determined, with 

emphasis on species of concern that emphasizes conservation of neotropical migratory birds. The Forest 

Service analyzes impacts of proposed forest management activities by addressing the following: (1) effects to 

“highest priority” species as identified by New Mexico Partners in Flight, (2) effects to important bird areas,

and (3) effects to important overwintering areas.

New Mexico Partners in Flight considers eight risk factors in identifying conservation priority species: (1) 

global abundance, (2) New Mexico breeding abundance, (3) global breeding distribution, (4) New Mexico 

breeding distribution, (5) threats to breeding in New Mexico, (6) importance of New Mexico to breeding, (7) 

global winter distribution, and (8) threats on the wintering grounds. Species with the highest risk factors are 

classified as highest priority for conservation action. This evaluation addresses general effects to migratory 

birds and specific effects to highest priority species for the main habitat types found in the project area.

Important Bird Areas. “Important Bird Area” is a designation created by National Audubon and Bird Life 

International7 to recognize the importance of specific areas for breeding or migrating birds. The important 

bird areas in, or near, the Santa Fe National Forest and Carson National Forest are Bandelier National 

Monument, Caja del Rio, Chama River Gorge/Golondrino Mesa, Randall Davey Audubon Center/The Nature 

Conservancy Santa Fe Preserve, Upper Rio Grande Gorge, and Valles Caldera National Preserve.

Important overwintering areas are often large wetlands. Areas considered important on the two national 

forests include the Rio Chama, Rio Grande at White Rock Canyon, Upper Rio Grande Gorge, and Pecos 

Canyon corridors. These areas provide wintering habitat for bald eagle.

Table S-44 lists highest priority migratory bird species either known to occupy, or are likely to occur in, the 

two national forests, based on appendix D of Partners in Flight and habitat on the forests. 

 7 http://iba.audubon.org/iba/siteSearch.do
Final Supplemental Environmental Impact Statement

93

Table S-44. Highest priority migratory birds and habitats used

Highest Priority Species Primary Habitat

Black swift High elevation riparian woodland

Red-naped sapsucker

Hammond’s flycatcher

Veery

American dipper

MacGillivray’s warbler

Lewis’s woodpecker Middle elevation riparian woodland

Red-headed woodpecker

Brown-capped rosy finch Alpine tundra

White-tailed ptarmigan

Williamson’s sapsucker Mixed conifer

Olive-sided flycatcher

Dusky flycatcher

Ferruginous hawk Piñon-juniper

Gray vireo

Black-throated gray warbler

Gray flycatcher

Bendire’s thrasher

Ferruginous hawk Plains and mesa grassland

Prairie falcon

Bendire’s thrasher

Long-billed curlew

Lark bunting

Lewis’s woodpecker Middle elevation riparian woodland

Red-headed woodpecker

Blue grouse Spruce-fir

Boreal owl

Flammulated owl Ponderosa pine

Virginia’s warbler

Grace’s warbler

Bendire’s thrasher Great Basin desert shrub

Sage sparrow

Loggerhead shrike

Sage thrasher

MacGillivray’s warbler Montane shrub

Green-tailed towhee

Black swift Cave/Rock/Cliff

Prairie falcon

Environmental Consequences to Migratory Birds

Effects previously described for all wildlife habitat and populations on the forests apply to migratory birds. 

Table S-45 provides additional disclosures of estimated effects of each alternative for migratory birds. No 

unintentional take of migratory bird species is anticipated because any disturbance associated with treatment 

would be short duration (less than a few days in a season) and on less than 0.1 percent of habitat, leaving the 

majority of forage and breeding habitat available. Over time, removal of weeds would promote native 

vegetation favorable to migratory birds.
Invasive Plant Control Project

94

Table S-45. Effects to migratory birds and habitats

High Priority 

Species

Migratory Bird 

Habitats

Alternative A 

(No Action)

Alternatives:

B, C, D1

(All Weed Management)

Black swift High elevation 

riparian woodlands

Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds. 

No unintentional take of these 

species is anticipated or 

expected. Treatments would 

benefit these birds because native 

plants would become more 

abundant, improving plant 

diversity and habitat quality once 

weeds are eliminated or 

controlled. Native plants provide 

important food sources to species 

directly, as seeds, or for the prey 

species of predators. No impact to 

population or habitat trends are

expected.

Red-naped 

sapsucker

Hammond’s 

flycatcher

American 

dipper

Veery

MacGillivray’s 

warbler

Wilson’s 

phalarope

Wet meadows Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds. 

Bobolink

Browncapped rosy 

finch

Alpine tundra Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality.

No unintentional take of these 

species is anticipated or 

expected. No treatments are likely 

to occur in this habitat, thus no 

impacts would be expected. 

Treatments would benefit these 

birds because native plants would 

become more abundant, 

improving plant diversity and 

habitat quality once weeds are 

eliminated or controlled. Native 

plants provide important food 

sources to species directly.

White-tailed 

ptarmigan

Northern 

goshawk 

Mixed conifer Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds. 

No unintentional take of these 

species is anticipated or 

expected. Treatments would 

benefit these birds because native 

plants would become more 

abundant, improving plant 

diversity and habitat quality once 

weeds are eliminated or 

controlled. Native plants provide 

important food sources to species 

directly (seeds) or for the prey 

species of predators. No impact to 

population or habitat trends would 

be expected.

Mexican 

spotted owl

Williamson’s 

sapsucker

Olive-sided 

flycatcher

Dusky 

flycatcher

Ferruginous 

hawk 

Plains/mesa 

grasslands

Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds.

Prairie falcon

Bendire’s 

thrasher

Long-billed 

curlew

Lark bunting

Ferruginous 

hawk 

Piñon-juniper Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

No unintentional take of these 

species is anticipated or 

expected. Treatments would Gray vireo
Final Supplemental Environmental Impact Statement

95

High Priority 

Species

Migratory Bird 

Habitats

Alternative A 

(No Action)

Alternatives:

B, C, D1

(All Weed Management)

Bendire’s 

thrasher

would reduce habitat quality, 

impacting these birds. 

benefit these birds because native 

plants would become more 

abundant, improving plant 

diversity and habitat quality once 

weeds are eliminated or 

controlled. Native plants provide 

important food sources to species 

directly, as seeds or for the prey 

species of predators. No impact to 

population or habitat trends would 

be expected.

Blackthroated gray 

warbler

Gray 

flycatcher

Lewis’s 

woodpecker

Mid-elevation 

riparian woodland

Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds.

Red-headed 

woodpecker

Blue grouse Spruce/subalpine 

fir

Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds. 

No unintentional take of these 

species is anticipated or 

expected. Treatments would 

benefit these birds because native 

plants would become more 

abundant, improving plant 

diversity and habitat quality once 

weeds are eliminated or 

controlled. Native plants provide 

important food sources to species 

directly (seeds) or for the prey 

species of predators. No impact to 

population or habitat trends would 

be expected.

Boreal owl

Flammulated 

owl

Ponderosa pine Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds.

Virginia’s 

warbler

Blackthroated gray 

warbler

Bendire’s 

thrasher

Great Basin desert 

shrub

Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds. 

No unintentional take of these 

species is anticipated or 

expected. Treatments would 

benefit these birds because native 

plants would become more 

abundant, improving plant 

diversity and habitat quality once 

weeds are eliminated or 

controlled. Native plants provide 

important food sources to species 

directly, as seeds, or for food 

species of prey for predators. No 

impact to population or habitat 

trends would be expected.

Sage sparrow

Loggerhead 

shrike

Sage 

thrasher

Green-tailed 

Towhee

Montane shrub Weeds would continue to 

spread and the loss of native 

plants and plant diversity 

would reduce habitat quality, 

impacting these birds. 

Black swift Cave/rock/cliff No weed infestations are 

known to occur in this habitat 

type.

No unintentional take of these 

species is anticipated or 

expected. No treatments are likely 

to occur in this habitat, thus no 

impacts would be expected. No 

impacts to population or habitat 

trends would be expected.
Invasive Plant Control Project

96

High Priority 

Species

Migratory Bird 

Habitats

Alternative A 

(No Action)

Alternatives:

B, C, D1

(All Weed Management)

Important Bird Areas: Bandelier 

National Monument, Caja del Rio, 

Chama River Gorge / Golondrino 

Mesa, Caja del Rio, Randall Davey 

Preserve / Santa Fe Canyon 

Preserve, Upper Rio Grande Gorge 

and the Valles Caldera National 

Preserve.

The important bird areas

encompass all habitat types 

from low elevation to upper 

elevation forest types. Weeds 

would continue to spread and 

the loss of native plants and 

plant diversity would reduce 

habitat quality, impacting birds 

that use these areas. 

Treatments would benefit birds 

because native plants would 

become more abundant, 

preserving native plant diversity

and habitat quality once weeds 

are eliminated or controlled. 

Native plants provide important 

food sources to species directly, 

as seeds, or for the prey species 

of predators. No impact to 

population or habitat trends would 

be expected.

Over-wintering areas Overwintering areas are 

associated with large river 

riparian areas. These areas 

are among the most heavily 

impacted by weeds such as 

saltcedar, which reduces 

habitat suitability for many 

migratory bird species.

Treatments reducing weeds such 

as saltcedar would maintain or 

enhance habitat quality and 

suitability of overwintering areas. 

1. Assumes full compliance with design features, conservation and recovery plans, and other project requirements.

Cumulative Effects to Migratory Birds

The direct and indirect effects of this project would be short-term disturbance (less than 5 days) on less than 

0.1 percent of habitat on an annual basis, leaving the majority of forage and breeding habitat available. Over 

time, the removal of weeds would promote native vegetation favorable to migratory birds. The direct and 

indirect effect to migratory birds would be immeasurable and would not contribute any noticeable cumulative 

effect when added to other activities in the analysis area.

Effects of Forest Plan Amendment to All Wildlife Species

The proposed amendment to the Santa Fe National Forest Plan allows weed treatment with herbicides in the 

currently restricted area of municipal watersheds and on soils with a low revegetation potential. The 

amendment would result in no long-term effects to wildlife resources presently or when future projects are 

implemented. 

The language of the amendment for municipal watersheds would not affect riparian or aquatic resources 

because of the design features in place for areas near water.

The language of the amendment for soils would not affect wildlife because ground cover needs to be restored 

quickly, thereby providing forage or cover vegetation preventing soil loss.

The deletion of language for soils with moderate to high cation exchange would not affect wildlife. These 

soils would still need to be revegetated or treated for regrowth of minimal vegetation providing forage or 

cover.

The modifications proposed by the amendment with design features and protocols included have minimal 

short-term disturbance effects to individuals but would not affect populations. The amendment is not expected 

to cause any long-term impacts to wildlife during the implementation of future projects because the intent of 

weed treatment is to preserve, restore, or improve habitat quality. Future projects in treatment areas would be 

analyzed for potential effects to wildlife at the appropriate level required by the National Environmental 

Policy Act.
Final Supplemental Environmental Impact Statement

97

Fish and Aquatic Resources

[Replaces entire section]

Affected Environment for Fish and Aquatic Resources

The affected environment for fish and aquatic resources is San Juan, Arkansas, and Rio Grande River basins 

in northern New Mexico (refer to the “Water Resources” section for a map and description of watersheds). 

Forty-eight of the 55 project watersheds have weeds infestations, the majority of which are found along roads 

and within 300 feet of perennial streams. Riparian areas (terrestrial habitat directly adjacent to streams) 

support a diverse assortment of both plant and animal species (Naiman et al. 1993). The ability of a nonnative 

species to establish in an area outside its native range in areas with high diversity can be greater than in less 

diverse areas (Planty-Tabacchi et al. 1996, Stohlgren et al. 1999). This is particularly important to consider in 

areas where high plant diversity is focused in the riparian zone, such as the arid Southwest (Knopf et al. 

1988). Riparian areas are vital to fish and aquatic resources because high-quality riparian areas and highquality streams are analogous, meaning you must have one to have the other (Hynes 1975). 

How Weeds Affect Fish and Aquatic Resources

The link between terrestrial environments and aquatic ecosystems can be difficult to understand, but the 

importance of streamside vegetation for stream health cannot be overstated. For example, the majority of 

productivity in mountain streams is the result of organic and nutrient inputs from surrounding areas 

(Cummins and Klug 1979, Vannote et al. 1980). The deposition of leaf litter into streams can provide large 

quantities of consumable nutrients for a variety of aquatic insects (Wallace and Webster 1996), which, in turn, 

are consumed by insectivorous fish (Sublette et al. 1990, Rinne 1995). Further, terrestrial invertebrates that 

fall from streamside vegetation into streams can constitute an important part of a fish’s diet (Rinne 1995). 

Streamside vegetation is also critical for preserving the integrity of stream channels (Gran and Paola 2001) 

and reducing excessive bank erosion (Beeson and Doyle 1995). The ability to stabilize stream banks varies 

between vegetation types and species (Lyons et al. 2000). A combination of grasses, shrubs, and trees may be 

the best at reducing erosion because the roots of each extend to different depths, holding a greater portion of 

the soil profile in place (Zuazo and Pleguezuelo 2008).

Weeds threaten the composition of riparian plant and animal species. Weeds have three things in common: (1) 

they are habitat generalists, meaning they can do well in most environments; (2) they are highly adaptable to 

change; and (3) they have high reproduction rates, meaning they produce offspring early and often (Sakai et 

al. 2001). Native vegetation often cannot compete with successful invaders and can become extirpated from 

an area (Lodge 1993). As invasive plants continue to spread and outcompete native species, a dramatic shift in 

species composition can occur, from a diverse community of plants to a monoculture with one species 

(Eiswerth and Johnson 2002). 

As the riparian plant community changes, so does the interaction between the vegetation and nearby stream. 

For example, deposition of leaf litter from an invasive shrub into an adjacent stream caused a four-fold 

decrease in aquatic insect abundance when compared to areas of native vegetation (Baily et al. 2001). Such a 

reduction in prey abundance could increase stress on fish and other insectivorous organisms. Additionally, a 

reduction in the variety of plants present could result in a less stable soil horizon, which could increase stream 

sedimentation because of stream bank erosion. Excessive sedimentation can reduce aquatic habitat for insects 

along the stream bottom, smother or damage fish eggs, and can cause damage to the gills of aquatic organisms 

because of abrasions (Newcombe and MacDonald 1991). It is important to note that only a few examples of 

how weeds may impact fish and aquatic resources are presented here and that other impacts from weeds may 

exist. 
Invasive Plant Control Project

98

Forest Sensitive Aquatic Species Analysis and Habitat Information 

The analysis of aquatic management indicator species appears in the “Wildlife” section of this chapter. In 

addition to being a management indicator species, the Rio Grande cutthroat trout is a Forest Service sensitive 

species and a candidate for listing under the Endangered Species Act; therefore, it will also be analyzed in this 

section. Table S-46 displays the Forest Service Southwestern Region sensitive aquatic species found on the 

Carson and Santa Fe National Forests and lists their occupied or suitable habitats. A full species description is 

located in the project record.

Table S-46. Sensitive aquatic species found on the Carson and Santa Fe National Forests and occupied or 

suitable habitats 

Species Name

National 

Forest Habitat

Estimated 

Acres or 

Miles of 

Habitat

Acres of 

Known Weed 

Infestations 

within Habitat*

Percent of 

Habitat 

Infested with 

Weeds

Lilljeborg’s pea-clam

Pisidium lilljeborg

Santa Fe Nambe Lake in the 

Pecos Wilderness, 

Santa Fe National 

Forest

0.1 0 0

Sangre de Cristo 

pea-clam

Pisidium 

sanguinichristi

Carson Only historical 

location is at Middle 

Fork Lake, Carson 

National Forest

8 0 0

Nokomis fritillary

Speyeria nokomis 

nokomis

Carson Wetlands associated 

with flowing water. 

Streamside meadows 

with an abundance of 

violets

37,398 1,803 4.8

Rio Grande chub

Gila pandora

Santa Fe

Carson

Headwater streams SF = 1,822

C = (78)

SF = 298 

C = (0.6)

SF = 16.4

C = 0.8

Rio Grande cutthroat 

trout

Onchoryncus 

virginalis clarkii

Santa Fe

Carson

Headwater streams SF = 3,924 

C = (138)

SF = 5

C = (1.8)

0.1

1.3

Rio Grande sucker

Catostomus plebius

Santa Fe

Carson

Headwater streams SF = 2,235 

C = (69)

SF = 367 

C = (0.4)

16.4

0.6 

* Acres of weeds located along linear miles of stream were calculated using a 66-foot buffer on each side of the aquatic habitat.

Lilljeborg’s Pea-clam

The New Mexico population of the species occurs in Nambe Lake, which is located in a glacial cirque about 

11,300 feet in elevation. The surrounding habitat includes rocky talus and stands of Englemann spruce.

Sangre de Cristo Pea-clam

The only known population of Sangre de Cristo Pea-clam occurs at Middle Fork Lake in the Sangre de Cristo 

Mountains of northern New Mexico at approximately 10,845 feet in elevation (Taylor 1987). Current 

population and distribution of this species are unknown.

Nokomis Fritillary Butterfly 

The Nokomis fritillary butterfly is found in streamside meadows and open seepage areas with an abundance 

of violets generally surrounded by desert landscapes (Pyle 1976). No confirmed sightings of this species are 

documented on National Forest System lands. Potential threats include weeds, insecticides, and elimination of 

food sources by herbicides. 
Final Supplemental Environmental Impact Statement

99

Rio Grande Chub 

Rio Grande chub are native to the Rio Grande basin in New Mexico but is also found in the Pecos and 

Canadian River drainages. Rio Grande chub inhabits cold water streams, and uses undercut banks, brush, and 

woody debris for cover (Rinne 1995b). The greatest threats to this species include degraded and fragmented 

habitat, invasive fish, and land use changes which reduce natural stream function (Rees et al. 2005). 

Rio Grande Cutthroat Trout

The Rio Grande cutthroat trout occurs in high-elevation mountain streams from south-central Colorado to 

southern New Mexico (Rinne 1995, Young et al. 2005). Rio Grande cutthroat trout occur in streams with 

clean gravel and cobble substrates, high habitat heterogeneity, and minimal influence from nonnative 

salmonid competitors (Harig and Fausch 2002). The greatest threats to this species include hybridization with 

nonnative trout, habitat degradation, and stream dewatering (Stefferud 1988).

Rio Grande Sucker 

Rio Grande sucker typically occurs in low-gradient streams at middle (6,600 to 8,600 feet) elevations 

(Calamusso and Rinne 1996, Calamusso et al. 2002). The greatest threats to this species include competition 

from the nonnative white sucker (Catostomus commersonii) and habitat degradation (Calamusso et al. 2002).

Environmental Consequences–Fish and Aquatic Resources

Methodology

Scientific literature was reviewed to evaluate the effects of herbicide application on fish and aquatic species. 

Additionally, to evaluate the risk of herbicides reaching aquatic ecosystems at levels that would cause harm, a 

“worst-case scenario” model was created using picloram as the representative herbicide because of its 

mobility in soil. The model used alternative D (herbicide only) and assumed all weed infestations (as of 2005) 

would be treated in the same year rather than being spread out over the next 10 years. The amount of picloram 

entering aquatic ecosystems with surface water runoff and overland flow after terrestrial application was 

modeled in the 11 representative watersheds (refer to appendix 5 of the final environmental impact statement).
Invasive Plant Control Project

100

Table S-47. Environmental consequences and determinations for fish and aquatic species

Species

Alternative A 

(No Action)

Alternatives B, C, and D

(All Weed Management Alternatives) Reason for Determination

Lilljeborg’s 

pea-clam

No impacts are expected 

because no known populations 

of weeds are found around 

Nambe Lake.

No impacts to the Lilljeborg’s pea-clam or its habitat 

are expected because no treatments would take place 

in or around the lake.

The design features that limit the use of certain 

herbicides in riparian environments would prevent 

adverse impacts to this species. Otherwise, no other 

kinds of treatments would occur in or around Nambe 

Lake, so there would be no effect to the clam.

Sangre de 

Cristo peaclam

No impacts are expected 

because no known populations 

of weeds are found around 

Middle Fork Lake.

No impacts to the Sangre de Cristo pea-clam or its 

habitat are expected because no treatments would take 

place in or around the lake.

The design features that limit the use of certain 

herbicides in riparian environments would prevent 

adverse impacts to this species. Otherwise, no other 

kinds of treatments would occur in or around Middle 

Fork Lake, so there would be no effect to the clam.

Nokomis 

fritillary

If weeds are not treated, the 

Nokomis fritillary butterfly’s 

food base may shift from native 

to nonnative vegetation. As this 

butterfly continues to forage, it 

could inadvertently pollinate 

nonnative plants, which would 

perpetuate the spread of 

undesirable weeds and further 

shift the butterfly’s food base. 

With design features in place the proposed actions may 

have an impact on the butterfly or its habitat. However, 

the unintentional application of herbicides to this 

species’ preferred forage would be minimal because of 

targeted herbicide application. Mechanical and grazing 

alternatives would have a greater impact to this species 

and its habitat because precise treatment of weeds 

would be difficult. However, less than 5 percent of the

species habitat is anticipated to be treated; therefore, 

the proposed treatments are not expected to decrease 

population viability or cause a trend to federal listing of 

Nokomis fritillary butterfly.

The design features requiring hand application of 

herbicide in this species’ habitat would greatly 

reduce the risk of accidental treatment of native 

plants. Furthermore, the scale at which weeds have 

infested Nokomis fritillary habitat is such that 

impacts from mechanical and grazing would be 

minimal.

Rio Grande 

Chub

Weeds would continue to 

displace native plants and 

grasses within riparian, so 

habitat quality and perennial 

water quality would decline.

With design features in place, the proposed treatments

could have an indirect impact to individuals of the Rio 

Grande chub. Rio Grande chub is carnivorous, feeding 

on zooplankton and aquatic insects. If herbicide was to 

reach the aquatic environment (alternatives B and D), a 

reduction in aquatic vegetation and phytoplankton 

could occur, which could cause a trophic cascade (that 

is, a shift in the food chain), resulting in reduced 

aquatic invertebrate herbivore prey base for fish. 

Mechanical and grazing methods for weed removal 

could temporarily increase sedimentation due to 

ground disturbance in the riparian area. The impacts 

from alternatives B, C, and D would likely be a 

localized and small in scale Therefore, the proposed 

actions are not expected to decrease population 

viability or cause a trend to federal listing of Rio Grande 

chub.

The design features for riparian areas are to avoid 

herbicide use within 50 feet on either side of 

streams of known Rio Grande chub occupancy 

during spawning season (March 1 to July 31). 

Furthermore, design features specify the quantity, 

duration, and type of herbicides to be used near 

fish-bearing streams, which would minimize 

negative impacts to Rio Grande chub. Additionally, 

ground disturbance from other alternatives would be 

localized and small in scale. Because treatments 

would occur outside of spawning season, no 

impacts to eggs would be expected. Fish are highly 

mobile and could temporarily seek better conditions 

if necessary.
Final Supplemental Environmental Impact Statement

101

Species

Alternative A 

(No Action)

Alternatives B, C, and D

(All Weed Management Alternatives) Reason for Determination

Rio Grande 

cutthroat 

trout

Weeds would continue to 

displace native plants and 

grasses within riparian, so 

habitat quality and perennial 

water quality would decline.

With design features in place, the proposed treatments

may have an indirect impact to individuals of the Rio 

Grande cutthroat trout. Rio Grande cutthroat trout is 

carnivorous, preying entirely on macroinvertebrates. If 

herbicide was to reach the aquatic environment

(alternative B and D), a reduction in aquatic vegetation 

and phytoplankton could occur, which could cause a 

trophic cascade (that is, a shift in the food chain), 

resulting in reduced aquatic invertebrate herbivore prey 

base for fish. Mechanical and grazing methods for 

weed removal could increase sedimentation due to 

ground disturbance in the riparian area. The impacts 

from alternatives B, C, and D would likely be a 

localized and small in scale. Therefore, the proposed 

actions are not expected to decrease population 

viability or cause a trend to federal listing of Rio Grande 

cutthroat trout.

The design features for riparian areas are to avoid 

herbicide use within 50 feet on either side of 

streams of known Rio Grande cutthroat trout 

occupancy during spawning season (March 1 to 

July 31). Furthermore, design features specify the 

quantity, duration, and type of herbicides to be used 

near fish-bearing streams, which would minimize 

negative impacts to Rio Grande cutthroat trout. 

Additionally, ground disturbance from other 

alternatives would be localized and small in scale. 

Because treatments would occur outside of 

spawning season, no impacts to eggs would be 

expected. Fish are highly mobile and could 

temporarily seek better conditions if necessary.

Rio Grande 

sucker

Weeds would continue to 

displace native plants and 

grasses within riparian, so 

habitat quality and perennial 

water quality would decline.

With design features in place, the proposed treatments

may have an indirect impact to individuals of the Rio 

Grande sucker. Rio Grande sucker is omnivorous, 

feeding on both aquatic vegetation (for example, algae) 

and aquatic invertebrates. If herbicide was to reach the 

aquatic environment (alternatives B and D), a reduction 

in aquatic vegetation and phytoplankton could occur, 

which could negatively impact Rio Grande sucker by 

limiting available forage as well as cause a trophic 

cascade (that is, a shift in the food chain), resulting in a 

reduced aquatic herbivorous invertebrate prey base for 

fish. Mechanical and grazing methods for weed 

removal could increase sedimentation due to ground 

disturbance in the riparian area. The impacts from 

alternatives B, C, and D would likely be a localized and 

small in scale. Therefore, the proposed actions are not 

expected to decrease population viability or cause a 

trend to federal listing of Rio Grande sucker.

The design features for riparian areas are to avoid 

herbicide use within 50 feet on either side of 

streams of known Rio Grande sucker occupancy 

during spawning season (March 1 to July 31). 

Furthermore, design features specify the quantity, 

duration, and type of herbicides to be used near fish 

bearing streams, which would minimize negative 

impacts to Rio Grande sucker. Additionally, ground 

disturbance from other alternatives would be 

localized and small in scale. Because treatments 

would occur outside of spawning season, no 

impacts to eggs would be expected. Fish are highly 

mobile and could temporarily seek better conditions 

if necessary.
Invasive Plant Control Project

102

Alternative A–No Action

Weed infestations would go untreated under alternative A. This alternative would likely result in a greater 

abundance of undesirable plants on the two national forests. Weeds would continue to displace native plants 

and grasses within riparian areas, reducing forage, habitat, and water quality, which would negatively affect 

fish and aquatic resources.

Effects of Ground Disturbance

There would be no sediment caused by ground-disturbing weed treatments under this alternative.

Effects of Herbicides

Since herbicides would not be applied under this alternative, no effects from herbicides to fish and aquatic 

resources would occur. 

All Action Alternatives (B, C, and D)

For all the action alternatives, the proportion of weed-infested habitat is small and the proportion expected to 

be treated each year even smaller, which reduces the risk of impact to an individual organism from any 

treatments. Alternative C would eliminate the risk from herbicides and alternative D would eliminate the risk 

of impacts from ground-disturbing activities. Alternative B (combination of alternatives C and D) is expected 

to be the most successful at eradicating weed infestations. The treatment and eradication of weed populations 

on the two national forests would have long-term beneficial effects for fish and aquatic resources. 

Effects of Ground Disturbance 

Mechanical and grazing methods of weed control could increase sediment transport to streams; however, 

because of the small scale of most treatment areas, increased soil erosion would likely be within acceptable 

limits as described in the “Soil Resources” section. Land devoid of vegetation post treatment would be 

planted with native plant species, which will reduce the risk of erosion. Based on the analysis presented in the 

soil, water, and vegetation section, along with design features to limit sediment transport, there would be a 

minimal increase in sediment delivery to streams, resulting in a low risk of impact to fish and aquatic 

resources. 

Effects of Herbicides

With the design features in place, concentrations of herbicides and the duration of exposure on the aquatic 

environment would be small and well below levels at which chronic exposure effects are documented for 

aquatic organisms. The risk assessments for each herbicide formulation include reviews of relevant 

information on an herbicide’s likely long-term effect, based on application rates used by the Forest Service. 

Furthermore, following label instructions and proper application procedures (as outlined by the herbicide 

manufacturer) would greatly reduce the likelihood of herbicides reaching the aquatic system. If an herbicide 

was to reach the aquatic environment, however, a reduction in aquatic vegetation and phytoplankton could 

occur. This could cause a shift in the food chain, resulting in fewer prey for fish. 

Results of “Worst-case Scenario” Analysis

This document analyzes three methods of potential contamination by herbicides: (1) leaching through soil to 

reach groundwater; (2) overland flow into water; or (3) accidental spills into water. 

1. Leaching through soil. The risk of herbicides leaching through the soil into groundwater is low. Soils are 

rarely a receptor for herbicide application because herbicides would be sprayed directly on weeds and not 

the soil, meaning little herbicide would touch soil in the first place. Herbicides on soil pose little risk to 

groundwater because chemicals typically disappear from the soil surface by plant uptake, volatilization, 

natural decomposition, or adsorption of the herbicide by soil particles. As Norris et al. (1991) indicates, 

leaching of chemicals through the soil profile is least likely to occur in undisturbed forest environments. 
Final Supplemental Environmental Impact Statement

103

The half-lives (the time it takes for half the active ingredient to degrade) of most of the herbicides are 24 to 

48 hours in water. Finally, the herbicides that pose the greatest risk in aquatic environments would be 

prohibited from use near such environments (see table S-11, rows 41-42 and 46-49). For example, 

picloram would not be used in an aquatic environment or in areas having a shallow water table. Another 

feature limits herbicide use to a short-lived, nonleachable herbicide registered by the Environmental 

Protection Agency for use on permeable soils with shallow water tables. Monitoring the effects of 

treatments and effectiveness of design features would further reduce the risk of unexpected impacts over 

the life of this project.

2. Overland flow. No measurable impacts to aquatic organisms are expected as a result of overland flow of 

herbicides. The risk of herbicides being carried in water from rain or irrigation to aquatic systems varies 

depending on soil type and the timing and intensity of rain following an application. Studies show that the 

risk of herbicides entering aquatic systems from overland flow runoff tends to be lower on well-vegetated 

forests and rangelands. Norris et al. (1991) indicated overland flow occurs infrequently on most 

undisturbed forest lands because the infiltration capacity of the forested soils is usually greater than the 

rate of precipitation. However, denuded and compacted soil, such as along roads, trails, and in campsites

where many known weeds are located, have potential to allow surface runoff. High-severity wildfires 

reduce soil infiltration rates, increasing the magnitude of erosion and runoff. This effect is greatly 

diminished by the second year after a fire because vegetation recovery begins and soil erosion is reduced 

once the erosion rills break through the soil hydrophobic layer (DeBano 2000).

The worst-case-scenario modeling performed for this analysis assumed all known weed infestations in

Ponil Creek and Lower Jemez River watersheds would be treated in the same year. The results of the 

model determined the level of herbicide that could potentially reach the water might exceed the “no effect” 

threshold. Because all weeds would not be treated in a single year (refer to the assumptions on page 51), 

the quantity of herbicide required to exceed the “no effect” threshold would not be applied within a 

timeframe to negatively affect fish and aquatic resources. Furthermore, herbicides selected for use in 

riparian areas or next to aquatic habitats would be restricted to those registered by the Environmental 

Protection Agency for use in aquatic habitats and documented as having a low risk to fish and other aquatic 

species. Monitoring the effects of treatments and effectiveness of design features would further reduce the 

risk of unexpected impacts over the life of this project.

3. Accidental spills. Accidental spills are possible, but considered unlikely with standard herbicide use and 

handling procedures in place. If a spill were to occur, the containment plan would reduce the risk of

negative effects.

Cumulative Effects to Fish and Aquatic Resources

The analysis area for cumulative effects on fisheries and aquatic resources is the San Juan, Arkansas, and Rio 

Grande River Basins. This boundary represents the areas where the actions proposed in this project are most 

likely to interact with other activities, in particular the weed treatments and ground disturbance on both 

national forests and other lands contained in these watersheds. 

Cumulative Effects of Ground Disturbance

The potential for weed treatments to increase soil erosion and sediment transport would be minimal (as just 

described) and thus would not contribute cumulatively to sediment production in any watershed, especially 

since all the activities that cause soil erosion would be widely distributed across the forests and occur at 

different times throughout the year. With no cumulative increase in sediment delivery from this project, there 

would be no cumulative effect to aquatic insects or fish and aquatic habitat. There would be few acres 

following treatment largely devoid of vegetation because weeds only compose a portion of the vegetation in a 

treatment area. Furthermore, design features require bare ground be revegetated with native plants (Table S11, row 19).
Invasive Plant Control Project

104

Cumulative Effects of Herbicides

As just described, the direct and indirect negative effects from herbicides to aquatic insects or fish and aquatic 

habitat would be low and of short duration (one to two days). To be cumulative, the effects from this project 

must overlap in space and time with the effects of other projects. Because of the short duration of treatment 

effects on National Forest System lands, a cumulative impact from herbicides originating on other 

jurisdictions would be unlikely. Fish and aquatic insects are not likely to be cumulatively exposed to 

herbicides from multiple jurisdictions at the same time.

Furthermore, most of the jurisdictions that use herbicides are required by law to follow similar, risk-reducing 

measures as presented in this document. Government agencies applying herbicides must all meet acceptable 

levels of water quality protection.

Generally, properties bordering the forests have small livestock and hay operations. The landowners do not 

typically use large amounts of herbicides, although this could increase as thistles and other weeds invade 

pasture lands. However, cumulatively, there would be a low risk herbicide use by the forests and adjacent 

landowners would exceed the “level of no concern” thresholds proposed by the two national forests. 

Cumulative Effects of Controlling or Eradicating Weeds

The direct and indirect effect of the action alternatives, as just described, would be to promote native 

vegetation, which would increase native habitat that aquatic insects and fish depend on. This project would 

cumulatively improve stream quality along with other projects that promote native vegetation along streams. 

The most likely cumulative effects from all weed treatments in northern New Mexico, together with other 

ecosystem restoration, travel management, and road closing and decommissioning projects, would promote 

the occurrence of native plants and subsequent soil stability, which would reduce sedimentation and improve 

aquatic conditions. 

Effects of Forest Plan Amendment to Fish and Aquatic Resources

Proposed amendments to the Santa Fe National Forest Plan allow weed treatment with herbicides in currently 

restricted areas (municipal watersheds) and on soils with a low revegetation potential. The amendment would 

result in no long term effects to fish and aquatic resources when future management projects are implemented 

using the new standard. The effects of future projects in watersheds and on soils with a low revegetation 

potential would be the same as those described in this section, with the resultant effect being increased native 

vegetation that is beneficial to aquatic species. Treatments in these areas would be subject to the design 

features and adaptive strategy which are designed to minimize impacts to wildlife and its habitat.

Water Resources

Affected Environment 

[No changes to the final environmental impact statement except as written in this section]

Watershed Characteristics

[Figure S-4 replaces figure 8]
Final Supplemental Environmental Impact Statement

105

Figure S-4. Locations of weeds in valley bottoms and riparian areas on the Carson and Santa Fe National Forests, August 1, 2013
Invasive Plant Control Project

106

[Table S-48 replaces table 31]

Table S-48. Watersheds on, or intersecting, the forests and the acreage of weeds on National Forest System 

lands

Fourth-level Basin Fifth-level Watershed Total Acres NFS Acres

Acres of 

Weeds

Canadian 

Headwaters

Headwaters Vermejo River 204,432 2,380 0

Outlet Vermejo River 150,409 46 0

Cimarron Ponil Creek 208,056 58,979 1,464

Eagle Nest Lake - Cimarron 

Creek

213,810 1,901 <1

Mora Upper Mora River 205,457 38,147 247

Coyote Creek 158,845 6,882 <1

Sapello River 187,617 27,179 3

Alamosa-Trinchera Punche Arroyo – Rio Grande 161,508 2,362 0

Conejos Rio de los Piños 98,967 58,003 0

Rio San Antonio 140,335 62,657 45

Upper Rio Grande Costilla Creek 248,591 39,874 51

Latir Creek – Rio Grande 182,066 6,779 4

Red River 121,273 99,927 95

Red River – Rio Grande 144,250 6,640 1

Rio Chama – Rio Grande 177,911 38,093 6

Rio Grande del Rancho 94,207 83,058 180

Embudo Creek 205,050 147,305 75

Arroyo Aguaje de la Petaca 158,474 92,115 49

Santa Cruz River 116, 772 69,564 71

Pojoaque Creek 123,993 44,459 139

Rio Pueblo de Taos 174,567 37,663 <1

Rio Pueblo de Taos – Rio 

Grande 

205,386 52,002 15

Rio Tesuque – Rio Grande 128,713 24,099 2

Rio Chama Chavez Creek 107,978 13,722 0

Chavez Creek-Rio Chama 145,309 674 0

El Vado Reservoir 177,883 201 0

Rio Nutrias-Rio Chama 152,301 45,229 44

Rio Cebolla 85,324 33,117 1

Rio Puerco 130,217 94,768 2,090

Arroyo Seco 103,523 82,386 0

El Rito 86,443 68,119 401

El Rito–Rio Chama 103,940 61,554 32

Rio Tusas 126,520 115,725 9

Rio Vallecitos 121,766 96,884 0

Rio Ojo Caliente 119,698 49,013 1

Rio Ojo Caliente-Rio Chama 88,597 53,492 99

Outlet Conejos River 166,122 568 0

Abiquiu Reservoir 168,403 128,630 1,632
Final Supplemental Environmental Impact Statement

107

Fourth-level Basin Fifth-level Watershed Total Acres NFS Acres

Acres of 

Weeds

Rio Gallina 179,293 131,378 1,711

Rio Grande-Santa 

Fe

Headwaters Galisteo Creek 222,374 35,934 253

Arroyo Tonque-Rio Grande 248,839 33,824 11

Outlet Galisteo Creek 206,318 515 2

Santa Fe River 163,876 32,808 37

Canada Ancha-Rio Grande 231,745 92,589 258

Jemez Upper Jemez River 128,582 35,007 858

Middle Jemez River 83,704 48,764 340

Rio Guadalupe 171,203 163,627 843

Rio Salado 158,058 2,465 0

Lower Jemez River 123,263 1,083 0

Rio Puerco La Canada de la Lena-Rio 

Puerco

112,114 5,411 22

Arroyo San Jose-Rio Puerco 164,268 54,945 336

Pecos Headwaters Cow Creek-Pecos River 222,190 167,941 406

Cow Creek 81,534 61,663 255

Tecolote Creek 181,571 41,817 78

Tecolote Creek-Pecos River 153,500 38,792 1

Headwaters Canon Blanco 107,249 22,700 243

Headwaters Gallinas River 200,949 30,887 4

Outlet Canon Blanco 165,401 20,372 0

Upper San Juan Canon Bancos 79,497 49,700 345

La Jara Creek 185,048 50,919 287

Navajo Reservoir 128,049 6,386 58

San Juan River – Navajo 

Reservoir

67,873 13,073 112

Blanco Canyon Tapicito Creek 117,542 4,922 < 1

Carrizo Creek 203,192 31,077 44

Canada Larga 189,991 7,928 0
Invasive Plant Control Project

108

[Table S-49 replaces table 32]

Table S-49. Characteristics of representative watersheds

Stream Name HUC 4 Basin Name 

(HUC code)

USGS Gaging 

Station Number USGS Gaging Station Name 

USGS Gaging 

Station Status 

Q 20 Flow 

May/Sept. (cfs)

Carson National Forest 

Red River Upper Rio Grande Basin 

(13020101) 

08266820 Red River below Fish Hatchery, near 

Questa, NM 

active 254/77

Rio Hondo Upper Rio Grande Basin 

(13020101)

08268700 Rio Grande near Arroyo Hondo, NM discontinued (2004) 1471/293

Rio Grande del 

Rancho

Upper Rio Grande Basin 

(13020101)

08276000 Rio Pueblo de Taos at Los Cordovas, NM discontinued (1965) 373/23

Canjilon Creek Rio Chama Basin 

(13020102)

08287000 Rio Chama below Abiquiu Dam, NM active 106/5

Rio Tusas/Rio 

Vallecitos

Rio Chama Basin 

(13020102)

08289000 Rio Ojo Caliente at La Madera, NM active 6613/1072

Ponil Creek Cimarron Basin 

(11080002)

07207500 Ponil Creek near Cimarron, NM active active

Santa Fe National Forest 

Santa Cruz River Upper Rio Grande Basin 

(13020101)

08291500 Santa Cruz River at Riverside, NM discontinued (1951) 1679/554

Pojoaque River Upper Rio Grande Basin 

(13020101)

08313000 Rio Grande at Otowi Bridge, NM active 571/16

Upper Jemez 

River 

Jemez Basin (13020202) 08321500 Jemez River below East Fork near Jemez 

Springs, NM 

discontinued (1990) 115/24 

Pecos River Pecos Headwaters Basin 

(13060001)

08378500 Pecos River near Pecos, NM active 512/96

Upper Gallinas 

River 

Pecos Headwaters Basin 

(13060001)

08382000 Gallinas River near Lourdes, NM active 24/9
Final Supplemental Environmental Impact Statement

109

There are approximately 1,713 miles of perennial streams on the Carson and Santa Fe National Forests.

Surface and Groundwater Quality

Surface water quality is generally good on the two national forests. Land management activities typically 

affect the amount of sediment and water most often. Activities that disturb vegetation or the soil surface have 

the greatest potential to produce sediment by increasing soil erosion. Sediment in streams and rivers varies 

naturally, with higher loads usually observed during spring runoff and summer storms.

Uses of water on the two national forests include coldwater fisheries, livestock and wildlife watering, 

recreation, domestic uses, and irrigation. Common sources of sediment to streams are livestock grazing, offroad-vehicle use, and poorly located or maintained roads (USDA Forest Service 1986a). 

Several stream or river segments within and near the national forests are on the 2014 to 2016 State of New 

Mexico’s Clean Water Act8 303(d) and 305(b) List of Impaired Waters (NMED 2014). The entire report can 

be found at New Mexico’s Environmental Department website. The report lists the probable causes of 

impairment (such as turbidity, stream bottom deposits, or temperature) as well as the probable sources of 

these impairments (for example, grazing, streambank modification, or removal of riparian vegetation). The 

impaired waterbodies in the representative watersheds are shown in Table S-50.

Table S-50. Impaired waterbodies in representative watersheds 2012-2014

Impaired Stream 

Name and 

Assessment Unit 

ID

Segment 

Length 

(miles)

Designated 

Use Not 

Supported

Probable Cause of 

Impairment Probable Source(s) of Impairment

Carson National Forest

Red River (Placer 

Creek to 

headwaters)

NM-2120.A_710

5.63 High quality 

coldwater 

aquatic life 

Nutrient/eutrophication 

biological indicators 

Source unknown 

Rio Hondo (Rio 

Grande to USFS 

boundary

NM-2120.A_600

8.5 High quality 

coldwater 

aquatic life 

Temperature, water Highway/road/bridge runoff (nonconstruction related), rangeland 

grazing, streambank 

modifications/destabilization 

Rio Grande del 

Rancho (Rio 

Pueblo de Taos to 

Hwy 518)

NM-2120.A_501

11.5 High quality 

coldwater 

aquatic life 

Nutrient/eutrophication 

biological indicators, 

specific conductance, 

temperature, water 

Flow alterations from water diversions. 

habitat modification - other than 

hydromodification, highways, roads, 

bridges infrastructure (new 

construction), natural sources, source 

unknown, streambank 

modifications/destabilization

Canjilon Creek 

(Perennial portions 

Abiquiu Reservoir 

to headwaters)

NM-2116.A_030

30.63 High quality 

coldwater 

aquatic life 

Nutrient/eutrophication 

biological indicators, 

specific conductance, 

temperature, water, 

turbidity

Agriculture, drought-related impacts, 

flow alterations from water diversions, 

highway/road/bridge runoff (nonconstruction related), livestock (grazing 

or feeding operations), loss of riparian 

habitat, on-site treatment systems 

(septic systems and similar 

decentralized systems), source 

unknown, streambank modifications

/destabilization, wildlife other than 

waterfowl.

 

8 Federal Water Pollution Control Act of 1948 as amended (that is, the Clean Water Act).
Invasive Plant Control Project

110

Impaired Stream 

Name and 

Assessment Unit 

ID

Segment 

Length 

(miles)

Designated 

Use Not 

Supported

Probable Cause of 

Impairment Probable Source(s) of Impairment

Rio Nutrias (Rio 

Chama to 

headwaters) 

NM-2116.A_060

34.63 High quality 

coldwater 

aquatic life 

Turbidity Crop production (crop land or dry land), 

loss of riparian habitat, 

highway/road/bridge runoff (nonconstruction related), livestock (grazing 

or feeding operations), loss of riparian 

habitat, rangeland grazing, streambank 

modifications/destabilization.

Rio Tusas (Rio 

Vallecitos to 

headwaters)

NM-2113.A_30

42.9 Coldwater 

aquatic life 

Nutrient/eutrophication 

biological indicators 

Crop production (crop land or dry land), 

highways, roads, bridges infrastructure 

(new construction), impervious 

surface/parking lot runoff, livestock 

(grazing or feeding operations), on-site 

treatment systems (septic systems and 

similar decentralized systems), 

rangeland grazing, wastes from pets, 

wildlife, other than waterfowl.

Rio Vallecitos (Rio 

Tusas to 

headwaters) 

NM-2112.A_00

36.31 High quality 

coldwater 

aquatic life 

Aluminum, 

temperature, water, 

turbidity

Channelization, highway/road/bridge 

runoff (non-construction related), 

irrigated crop production, loss of 

riparian habitat, natural sources, other 

recreation pollution sources, rangeland 

grazing, streambank 

modifications/destabilization, surface 

mining.

North Ponil Creek 

(South Ponil Creek 

to Seally Canyon) 

NM-2306.A_110

14.78 High quality 

coldwater 

aquatic life, 

primary 

contact

E. coli, 

nutrient/eutrophication 

biological indicators, 

temperature, water, 

turbidity

Forest roads (road construction and 

use), habitat modification - other than 

hydromodification, low water crossing, 

rangeland grazing, silviculture 

harvesting.

North Ponil Creek 

(Seally Canyon to 

headwaters)

NM-2306.A_162

7.03 High quality 

coldwater 

aquatic life, 

domestic 

water supply 

Aluminum, gross alpha 

- adjusted, Radium 

226, Radium 228, 

temperature, water, 

turbidity

Habitat modification - other than 

hydromodification, low water crossing, 

natural sources, rangeland grazing, 

source unknown, watershed runoff 

following forest fire, wildlife other than 

waterfowl.

Middle Ponil Creek 

(South Ponil to 

Greenwood 

Canyon)

NM-2306.A_121

10 High quality 

coldwater 

aquatic life

Benthic 

macroinvertebrate 

bioassessments 

(stream), temperature, 

water

Loss of riparian habitat

Middle Ponil Creek 

(Greenwood 

Canyon to 

headwaters) 

NM-2306.A_124

11 High quality 

coldwater 

aquatic life

Nutrient/eutrophication 

biological indicators

On-site treatment systems (septic 

systems and similar decentralized 

systems), rangeland grazing, source 

unknown, watershed runoff following 

forest fire, wildlife other than waterfowl

Greenwood 

Canyon (Middle 

Ponil Creek to 

headwaters)

NM-2306.A_22

5.24 High quality 

coldwater 

aquatic life

Aluminum Natural sources, source unknown

McCrystal Creek 

(North Ponil Creek 

to headwaters) 

NM-2306.A_112

6.81 High quality 

coldwater 

aquatic life

Temperature, water, 

turbidity

Loss of riparian habitat, source 

unknown 
Final Supplemental Environmental Impact Statement

111

Impaired Stream 

Name and 

Assessment Unit 

ID

Segment 

Length 

(miles)

Designated 

Use Not 

Supported

Probable Cause of 

Impairment Probable Source(s) of Impairment

Santa Fe National Forest

Santa Cruz River 

(Santa Clara 

Pueblo boundary 

to Santa Cruz 

Dam) 

NM-2111_50

8.1 Marginal 

coldwater 

aquatic life, 

primary 

contact

E. coli, temperature, 

water

Source unknown 

Pojoaque River 

(San Ildefonso 

boundary to 

Pojoaque 

boundary) 

NM-2111_20

0.6 Marginal 

coldwater 

aquatic life, 

warmwater 

aquatic life

polychlorinated 

biphenyls

Source unknown 

East Fork Jemez 

River (San Antonio 

Creek to VCNP 

boundary) 

NM-2106.A_13

10.39 High quality 

coldwater 

aquatic life

Aluminum, arsenic, 

temperature, water 

Highway/road/bridge runoff (nonconstruction related), natural sources, 

other recreational pollution sources 

Redondo Creek 

(Sulphur Creek to 

VCNP boundary)

NM-2106.A_25

0.73 High quality 

coldwater 

aquatic life

Turbidity Highway/road/bridge runoff (nonconstruction related), loss of riparian 

habitat, rangeland grazing

San Antonio Creek 

(East Fork Jemez 

to VCNP 

boundary)

NM-2106.A_20

11.28 Domestic 

water supply, 

high quality 

coldwater 

aquatic life

Aluminum, arsenic, 

temperature, water, 

turbidity

Forest roads (road construction and 

use), loss of riparian habitat, natural 

sources, other recreational pollution 

sources, rangeland grazing, site 

clearance (land development or 

redevelopment), streambank 

modifications/destabilization

Rio Puerco de 

Chama (Abiquiu 

Reservoir to Hwy 

96) 

NM-2115_20

8.81 Coldwater 

aquatic life, 

primary 

contact, 

warmwater 

aquatic Life

Aluminum, E. coli, 

nutrient/eutrophication 

biological indicators, 

temperature, water

Channelization, highway/road/bridge 

runoff (non-construction related), 

impervious surface/parking lot runoff,

loss of riparian habitat, on-site 

treatment systems (septic systems and 

similar decentralized systems), 

rangeland grazing

Poleo Creek (Rio 

Puerco de Chama 

to headwaters)

NM-2116.A_023

12.16 High quality 

coldwater 

aquatic life

Turbidity Forest roads (construction and use), 

loss of riparian habitat, natural sources, 

rangeland grazing, streambank 

modifications/ destabilization

Rito Resumidero 

(Rio Puerco de 

Chama to 

headwaters) 

NM-2116.A_025

2.75 High quality 

coldwater 

aquatic life

Benthic 

macroinvertebrate 

bioassessments 

(stream)

Source unknown 

Polvadera Creek 

(Canones Creek to 

headwaters) 

NM-2116.A_011

13.94 High quality 

coldwater 

aquatic life

Sedimentation or 

siltation, temperature, 

water

Loss of riparian habitat, natural 

sources, off-road vehicles, rangeland 

grazing

Willow Creek 

(Pecos River to 

headwaters) 

NM-2114.A_030

5.26 High quality 

coldwater 

aquatic life

Sedimentation or 

siltation, specific 

conductance

Source unknown 
Invasive Plant Control Project

112

On December 15, 2010, the New Mexico Water Quality Control Commission issued an order and statement of 

reasons (effective January 14, 2011) designating outstanding national resource waters. This designation 

applies to all streams and their tributaries and wetlands originating in wilderness areas administered by the 

U.S. Forest Service in the State of New Mexico. A list and maps of designated stream segments and wetlands 

can be found at the New Mexico Environment Department website.

Groundwater on the Carson and Santa Fe National Forests is widely variable and often associated with 

riparian areas and wetlands. Depths to groundwater can vary from shallow to several hundred feet or more 

depending on topography and geology. Typically, the mountainous terrain in the two national forests provides

areas of groundwater recharge. Shallow groundwater resources, such as those associated with wetlands and 

places adjacent to streams and riparian areas, are stored in saturated soils and deeper sediments and 

supplement surface waterbodies through discharge of groundwater during periods of low flow. Other 

groundwater resources, such as springs and seeps, are important sources of water for wildlife and habitat for 

groundwater-dependent species. Sources of potential contamination of groundwater are varied but commonly 

include fuels, oils, solvents, paints, and detergents, and the generation of solid and liquid wastes. Typical 

sources of contamination on National Forest System lands include mines, oil and gas wells, landfills, and 

septic systems and associated leach fields.

Drinking water wells in the two national forests range in depth from 55 feet to 150 feet or more. Yield of 

groundwater from these formations usually is low (less than 25 gallons per minute) (USDA Forest Service

1986a). In contrast, most valley bottoms have shallow groundwater in alluvial deposits. This groundwater is 

most likely closest to ground surface in May and June, declining through the summer as streams approach low 

flow conditions.

Groundwater quality on the forests is variable but generally thought to be high due to the remoteness of the 

resource to large sources of contamination, such as those described above. Groundwater quality near areas of 

urban development, mining activities, and oil and gas development is most likely to demonstrate a lower 

quality than areas far removed from these potential sources of contamination.

Analysis Methods

[No change from the final environmental impact statement]

Environmental Consequences to Water Resources

[Additional summary section]

Summary of Effects to Surface Water Quality

For any action alternative, a slight increase in sedimentation following treatment is expected when compared 

to alternative A. An increase in sedimentation means that surface water quality could decrease (for example, 

more turbidity). The no-action alternative would keep sedimentation at background levels initially, but as 

invasive species continue to spread in extent and displace native vegetation, water quality could be expected 

to decline. In the first 1 to 3 years, alternative C would probably produce the most sediment of the action 

alternatives because without the option of herbicides, most treatments would be ground-disturbing and would 

need to be repeated to control invasive species populations. After 3 years, the restoration of native plant 

communities and the revegetation of bare soil caused by these ground-disturbing treatments is likely to reduce 

the amount of sediment produced, with an overall improvement to surface water quality.

Summary of Effects to Groundwater Quality

For any action alternative, a slight risk of effects to groundwater quality exists, but this risk correlates to the 

amount of herbicide use when compared to alternative A. An increase in acres treated by herbicide application 

poses a slight risk of groundwater effects from application near shallow groundwater tables (riparian areas 
Final Supplemental Environmental Impact Statement

113

and wetlands) or accidental spills of herbicide. The no-action alternative would eliminate this risk as no weed 

treatments of any kind would occur. Compared to the other action alternatives, alternative C would also 

minimize or eliminate the potential for groundwater impacts because without the option of herbicides, most 

treatments would be mechanical or cultural in nature. Alternative B, which allows herbicide use with other 

specified treatment methods, may pose a slight risk of groundwater impacts, but design features would control 

and reduce this potential risk to groundwater resources. 

Summary of Effects to Outstanding National Resource Waters

from All Alternatives

The designation of a waterbody as an outstanding national resource water (ONRW) comes with an 

antidegradation policy (20.6.4.8 NMAC). The antidegradation policy requires the following:

That “water quality be maintained and protected in ONRWs” and the policy is interpreted to mean “no 

new or increased discharges to ONRWs and tributaries to ONRWs would result in lower water quality 

in the ONRW.” The policy states “temporary and short-term degradation resulting from nonpoint 

source discharges shall last no longer than the activity that causes the degradation and shall in no event 

last longer than six months.”

Under the no-action alternative, there would be no effects from this project to outstanding national resource 

water because no weed treatments would take place. There would be no nonpoint discharges from weed 

control projects.

Under all action alternatives, the risk of impacts to surface waterbodies and wetlands designated as 

outstanding national resource waters is low and would comply with the requirements of the antidegradation 

policy, meaning that impacts would be temporary and short term. With the design features requiring not using 

certain herbicides near water and of revegetating denuded areas, no new or increased discharges to 

outstanding national resource waters and tributaries are expected. Because the effects of herbicides last only 

several days, the expected effect to outstanding national resource waters from herbicide treatment would 

comply with the timeframe (less than 6 months) outlined in the antidegradation policy. Vegetation in riparian 

areas tends to grow back within a season, eliminating the risk of an increased discharge to an outstanding 

national resource water stream. Finally, the location of the current weed populations in wilderness areas is

such that the effects of any treatments are unlikely to reach streams.

Alternative A 

[No change from the final environmental impact statement]

Alternatives B and D

[No change from the final environmental impact statement]

Alternative C 

[No change from the final environmental impact statement]

Cumulative Effects to Water Resources

Under the no-action alternative, there would be no direct or indirect effects from weed treatments; therefore,

there would be no cumulative effects to surface water quality, groundwater quality, or outstanding national 

resource waters. The effect of not treating weeds is that weeds would continue to spread. This would increase 

the loss of desirable plant species and biological diversity, which in turn would likely cause increased surface 

water runoff, soil erosion, and sedimentation in watersheds with weeds and, in the long term, in watersheds 

currently not affected by invasive species populations. Without some type of control of current populations, it 

is likely invasive populations will expand via pathways (such as roads and trails) used by Carson and Santa Fe 

National Forest personnel and visitors. New populations are likely to establish and expand via other means 
Invasive Plant Control Project

114

such, as seed dispersal by wildlife and cattle. It is plausible that, by 2025, extensive herbicide treatment (for 

example, aerial application) could be required to gain control of weed populations that are rapidly spreading 

and increasing in size.

The direct and indirect effects to surface water quality from the action alternatives are likely to be a minor 

increase in soil erosion and subsequent sediment transport to surface waterbodies from ground disturbances 

during project implementation. Most ongoing and foreseeable future activities on the two national forests (see 

Table S-14 and Table S-15) would continue to contribute to erosion and sediment, including vegetation and 

fuel management projects; road maintenance, reconstruction, closing, and decommissioning; prescribed 

burning and wildland fires, livestock grazing, and all recreational uses. The amount of sedimentation caused 

by weed treatments is expected to be so minor as to be too small to measure; thus, when added to other 

cumulative actions, none of the action alternatives are expected to contribute cumulatively to sedimentation 

enough to change surface water quality (for example, cause a listing of impaired waters). Herbicide use by 

adjacent landowners and agencies would cumulatively result in minor and short-term herbicide loading to the 

environment. Those additional acres would cumulatively add a small amount but would be unlikely to exceed 

Environmental Protection Agency standards.

The direct and indirect effect to groundwater quality from the action alternatives is minor or too small to 

measure. Other than effects of accidental spills of herbicide, the effects to groundwater from treatment of 

invasive species through mechanical or other cultural practices are unlikely. Herbicide use by adjacent 

landowners and agencies may cumulatively result in minor and short-term herbicide loading to groundwater 

resources, but design features for the Forest Service’s use of herbicides would control and reduce this 

potential risk to groundwater resources. Those additional effects could cumulatively result in a perceptible 

effect but would be unlikely to exceed Environmental Protection Agency standards.

No measurable direct or indirect effects from the action alternatives to outstanding national resource waters 

would occur; therefore, there would be no cumulative effects.

Implementation of any action alternative would combine with other stream and watershed restoration 

activities that could move nonattainment streams toward attainment status.

Effects of Forest Plan

Amendment to Surface and Groundwater Quality

The proposed amendment would help achieve desired conditions described in the forest plan for soil, water,

and riparian conditions that would otherwise be threatened by the continued spread of weeds. Allowing

herbicide applications within municipal watersheds, on national forest land adjacent to homes, and on soils 

within certain tolerances expands the opportunity to control weeds in the future. Because the amendment 

includes a mitigation measure that requires sufficient ground cover to ensure that soil erosion does not exceed 

the tolerance level for that soil type based on the Terrestrial Ecosystem Survey for the Santa Fe National 

Forest (USDA Forest Service 1993), long-term soil productivity would be maintained in all future projects 

where herbicides would be applied. 

The proposed forest plan amendment would allow the use of herbicides (excluding picloram) in the Santa Fe 

and Gallinas municipal watersheds provided Santa Fe and Las Vegas city officials concur with the proposed 

treatment prescription and design features to be implemented. This stipulation could increase or decrease the 

amount of herbicide applications allowed in the future, depending on the personnel making decisions at the 

time. Allowing herbicides, as described throughout this chapter, is expected to increase the presence of native 

vegetation and thus is likely to improve water quality. Not allowing the use of herbicides is expected to have 

the opposite effect in this and future projects.

Other entities, including environmental organizations, have applied herbicides in the lower portions of these 

watersheds outside the national forest boundary. Allowing the use of herbicides in the watersheds would 
Final Supplemental Environmental Impact Statement

115

render treatments adjacent to the Santa Fe National Forest more effective in the future because weeds would 

be less likely to spread from the portion of the watershed on forest land to the lower watershed sections. 

Permitting the use of herbicides would improve the effectiveness of eradicating or controlling the spread of 

saltcedar, Siberian elm, Russian olive, and other weed species in the municipal watersheds and would 

contribute to improving water quality in the long term, and possibly even water quantity because of these 

species high water use. 

Soil 

[Replaces entire section; Figure S-5 replaces figure 10 and Figure S-6 replaces figure 11]

Methodology

A review of scientific literature provided the basis for the effects to soils from the use of herbicides.

Affected Environment

Soil landscapes on the Carson and Santa Fe National Forests can be subdivided into three provinces with 

distinct soil assemblages: Colorado Plateau Semi-Desert, Southern Rocky Mountain Steppe, and Southwest 

Plateau Provinces (Bailey 1995). The Rocky Mountain Steppe assemblage dominates the north-central region 

of New Mexico, the Colorado Plateau dominates the southern and western areas, and the Southwest Plateau 

occurs primarily in the Pecos-Canadian Plains and Valleys in the eastern part of the state. Specific soils 

associated with each assemblage on the forests are described in detail in the specialist’s report.

How Weeds Can Affect Soil

Weed infestations affect soil quality by outcompeting native species for water and nutrients (Olson 1999a). 

Broadleaf weeds often produce deeper taproot systems and less canopy cover compared to the native species 

that they displace (DiTomaso 1999). Due to these physiologic and morphologic differences, weed infestations 

can cause negative changes in overall soil quality. The weed species that occur on the two national forests, 

where dense, are assumed to be causing these effects.

Organic matter may be reduced or redistributed in weed-infested soil. Weeds may decay more slowly than 

native species (Olson 1999a; Olson and Kelsey 1997). Slower decay rates result in less annual input of 

organic matter to the soil. Since weeds also tend to have deeper roots and less foliage than native species, 

decay of these plants will contribute less litter and organic matter near the soil surface.

Infiltration can be reduced on weed infested sites due to reduced cover (DiTomaso 1999; Olson 1999a). Lacey 

et al. (1989) measured significantly greater surface water runoff, indicating less infiltration, from spotted 

knapweed dominated sites compared to adjacent native grass dominated sites. Decreased soil organic matter 

can reduce the amount of water held in the soil, especially near the surface (Brady and Weil 1999; Tisdall and 

Oades 1982).

Reduced cover - On weed-infested sites, reduced vegetative cover can result in higher evaporation from the 

exposed soil surface (Lauenroth et al. 1994, Olson 1999a). On sites where weeds are dense, the high 

transpiration rate may deplete water stored deeper in the soil (Olson 1999a).

Erodibility – Weed-infested soil has been shown to be more erodible than soil supporting native grass species 

(Lacey et al. 1989). With less cover than native species, weeds are less able to dissipate the kinetic energy of 

rainfall, overland flow, and wind that cause erosion (Torri and Borselli 2000; Fryrear 2000).

Biota - Since abundance of soil microbial biomass is generally related to the organic matter content of soils 

(Brady and Weil 1999), it is possible that weed-infested soils may support smaller populations of 

microorganisms than noninfested soils. Considering the deeper root distribution and reduced litter production 
Invasive Plant Control Project

116

of weeds compared to native grasses, it is possible weeds could result in a change of size or distribution of 

soil microbial populations.

Weeds directly limit nutrient availability through their ability to outcompete native species for limited 

resources. Weeds have high nutrient uptake rates and can deplete soil nutrients to very low levels (Olson 

1999a). Potassium, nitrogen, and phosphorous levels were 44 percent, 62 percent, and 88 percent lower in 

spotted knapweed infested soil than in adjacent grass covered soil (Olson 1999a). In addition, some weed 

species germinate prior to native species and take up nutrients and water before native species are actively 

growing (Olson 1999a). In instances where weed decomposition occurs slowly, nutrients remain immobilized 

in the plant tissue and are unavailable for uptake by other species. Weeds indirectly limit nutrient availability 

due to increased soil erosion that can occur in infested areas. Erosion selectively removes organic matter and 

the finer sized soil particles that store nutrients for plant use, leaving behind soil with a reduced capacity to 

supply nutrients (Brady and Weil 1999).

The Forest Service, through surveys, has characterized the properties of soils on the two national forests. 

These are described in the 1993 terrestrial ecosystem surveys. Two interpretations, erosion hazard and 

revegetation potential, are pertinent to this project. The erosion hazard (Figure S-5) describes the 

susceptibility of the soil to erosion upon removal of vegetation and litter. Revegetation potential (Figure S-6) 

refers to the probable success and ease of native grass establishment. Revegetation potential is influenced by 

climate, soil characteristics, and slope. The following tables show the how much of the project area is in each 

category.

Table S-51. Weed acres by erosion hazard class

Erosion Hazard Class Total Acres Acres of Weeds Percent

Interpretation not available 645,091 1,134 0.2

Slight 536,798 1,568 0.3

Moderate 2,427,040 6,218 0.3

Severe 1,613,463 4,329 0.3

Table S-52. Weed acres by revegetation potential class

Revegetation Potential Class Total Acres Acres of Weeds Percent

Interpretation not available 18,199 6 0.03

High 2,506,454 4,900 0.2

Moderate 1,254,155 4,967 0.4

Low 1,443,585 3,376 0.2
Final Supplemental Environmental Impact Statement

117

Figure S-5. Areas of slight, moderate, and severe erosion hazard on the Carson and Santa Fe National Forests
Invasive Plant Control Project

118

Figure S-6. Areas of revegetation potential (ranging from poor to high) on the Carson and Santa Fe National Forests
Final Supplemental Environmental Impact Statement

119

Environmental Consequences to Soil

Alternative A–No Action

Without action, weeds would continue to spread at the assumed average rate of 8 percent per year. Dense 

weed infestations are likely to result in the negative impacts just described in the “Affected Environment”

section. Erosion might increase and revegetation potential might decrease at the specific locations where 

weeds exist and at other locations.

Effects of the Action Alternatives Treatment Methods on Soil 

In summary, soil disturbance from this proposal would not be considered detrimental when considered with 

the beneficial, long-term improvements in soil quality and productivity in areas where weeds are treated and 

native vegetative is reestablished. For all methods, the size and extent of soil disturbance would be limited to 

the area treated, which is a small percentage of the project area overall (0.05 percent, based on an average of 

1,500 acres treated per year). The duration of the effect would be limited to the recovery period, which 

typically ranges from a few months to a year. The design features in chapter 2 (Table S-11, row 19) and the 

proposed plan amendment ensure that erosion rates would not exceed tolerance levels established in the forest 

plans. Finally, most of the known weed populations are near roads, campsites, trails, and other locations that 

already have an existing level of soil disturbance. Overall, any treatment method would improve soil quality 

by controlling weeds and minimizing the negative effects of weeds described in the “Affected Environment”

section.

The following paragraphs describe the effects the methods proposed are expected to have on soils.

• Mechanical methods, where heavy equipment removes or plows up weeds, are the actions most likely to 

leave bare soil or cause soil compaction following treatments. The design features that prohibit the use of 

heavy equipment such as mowers or mechanized diggers on slopes over 40 percent would reduce the 

potential for erosion. Methods that do not use herbicides are likely to require follow-up treatments, 

resulting in the potential for more ground disturbance than would occur from the use of herbicides. 

• Manual methods, such as incidental hand pulling and grubbing of weeds, would result in minor soil

disturbance where weeds are pulled. The size of the disturbed area would be negligible when considered 

against the size of the project area. Any disturbed soil would be outweighed by the benefit of removing 

the weeds.

• High-intensity, short-duration grazing can cause soil compaction that is proportional to the intensity and 

duration of grazing. The degree of compaction is not expected to reduce soil productivity because 

monitoring would control the amount of time herbivores would remain on a site. 

• Prescribed fire would result in little bare soil. Its use is governed by strict parameters designed to keep 

litter, duff, and some vegetation in place. 

• Biological methods, for example the release of insects, are expected to result in no ground disturbance 

because the biological agents attack the plant and leave the soil intact. These herbivorous insects have a 

high degree of host specificity and would not be expected to target beneficial, native vegetation. 

Biological control agents would provide the benefit of weed control without the potential for changes to 

soil biota communities.

Table S-53 shows the characteristics of herbicides proposed for use in the project area as they pertain to their 

behavior in soil. Half-lives for these herbicides range from days for up to a year. A half-life is the time it takes 

for a pesticide to be reduced by one-half. It is a measures of how long an herbicide is expected to remain 

present in the soil. In general, less than 3 percent of the original amount of pesticide would remain in a soil 

after five half-lives have passed. 
Invasive Plant Control Project

120

Of the methods proposed, herbicides have the most potential to affect soil quality, but the science is 

inconclusive. The complex interactions between soil biota, environment, and herbicide type make predictions 

of impacts to soil biota difficult. Certain herbicides, such as glyphosate and dicamba, have been observed to 

cause weight reductions or mortality in earthworms. Surviving earthworms would be expected to recover, but 

the population may be decreased after each herbicide application. Soils with reduced earthworm populations 

would exhibit reduced water infiltration, nutrient cycling, and fewer stable soil aggregates compared to 

similar soils with greater earthworm populations (Brady and Weil 1999). In areas where earthworms are 

susceptible to the type of herbicide applied, the population may remain suppressed until application ceases. A 

study of the effects of herbicides on soil arthropods found no significant change in the arthropod population 

occurred due to herbicide exposure (Fuhlendorf et al. 2001). 

Some research indicates herbicides can decrease the diversity and relative biomass of individual species of 

soil microorganisms (Forlani et al. 1995, Ka et al. 1995, SERA 2003a). Other researchers, however, found 

herbicides had no effect on soil bacteria, nematodes, or collembola beyond what was expected from the 

associated reduction in ground cover (Wardle et al. 2001). While herbicide exposure may influence the 

diversity of soil microorganisms, the reported data indicate this influence is transient as long as adequate time 

is allowed for the soil community to rebound between exposures. Brady and Weil (1999) report negative 

effects of most pesticides on soil microorganisms are temporary, and populations generally recover after a few 

days or weeks.

Alternative B–Proposed Action

Alternative B proposes the full suite of treatments, so all the effects described above are anticipated to occur. 

The maximum annual acreage expected to be treated in the project area is 3,000 acres (0.1 percent of the 

project area), with the acres widely distributed in space and treated at different times. As a result, the 

magnitude and intensity of any effect would be negligible.

For up to a year following treatments, erosion may increase and revegetation potential decrease at the specific 

locations where weeds are treated. These negative impacts would be offset by the long-term, beneficial effects 

of reestablishing native vegetation.
Final Supplemental Environmental Impact Statement

121

Table S-53. Characteristics of herbicides in soil

Herbicide Solubility (ppm) Potential For Mobility Half Life (Days)

Aminopyralid 212 (pH 5)

205 (pH 7)

High 5 to 343 depending on soil 

type

Chlorsulfuron 300 (pH 5)

7,000 (pH 7)

High

(increases with pH)

30 to 120

Clopyralid methyl 1,000 High 15 to 287

Dicamba 4,500 High 7 to 42

Glyphosate 12,000 to 900,000 Low 2 to 174

Hexazinone 33,000 High in soil, low in leaf

litter

30 to 180

Imazapic 2,200 Moderate

(increases with pH)

31 to 233

Imazapyr 11,272 Moderate to h igh Several months

Metsulfuron methyl 1,750 (pH 5.4)

9,500 (pH 7)

High

(increases with pH)

14 to 80

Picloram 430 High

(increases with pH)

20 to 300

Sulfometuron methyl 0 (pH 5)

300 (pH 7)

Low

(increases with pH)

30

2,4-D 890 to 800,000 High 30 or less

Triclopyr 23 to 2,1 00,000 Moderate 30 to 46

Alternative C–No Herbicides

Because alternative C is not expected to be as successful at controlling weeds across Carson and Santa Fe 

National Forests as quickly as the other action alternatives, weed populations would continue to spread and 

impact soils. In those areas, adverse effects on soil properties and soil quality would be similar to those

described under alternative A but on fewer acres. 

Without the option of herbicides, alternative C would require more digging, mowing, prescribed burning, 

grazing, and other non-herbicide treatment methods. It would also require more follow-up treatments to 

effectively control weeds on the same sites. This means the opportunity for soil disturbance and subsequent 

soil erosion would be greater than in the other action alternatives but is still considered negligible when 

considered in the context of the entire project area. Follow-up treatments would extend the duration soils are 

vulnerable to erosion, and repeated treatments over time would likely maintain the vulnerability of these sites 

to weed infestations, thus lowering soil productivity. This alternative eliminates the impacts from herbicides 

on the microbial community and earthworm populations. 

For up to a year following treatments, or possibly longer, erosion might increase and revegetation potential 

might decrease at the specific locations where weeds are treated. These negative impacts would be only 

partially offset by the long-term, beneficial effects of reestablishing native vegetation.

Alternative D–Only Herbicides

Alternative D reduces the potential for erosion and compaction caused by all the methods except herbicides. 

Since the acreage would only be treated with herbicides, all the soils would be subjected to the effects of 

herbicides described above.
Invasive Plant Control Project

122

For up to a year following treatments, erosion might increase and revegetation potential might decrease at the 

specific locations where weeds are treated. These negative impacts would be offset by the long-term, 

beneficial effects of reestablishing native vegetation.

Cumulative Effects to Soil

Alternative A–No Action

Forest activities that contribute to the introduction and spread of invasive weeds would add cumulatively to 

the impacts of alternative A. Failure to act to control weeds would add to the reduced soil quality caused by 

weeds and other activities that introduce and spread invasive weeds. Soil quality would degrade in proportion 

to the increase in weed spread. For several years, these additive effects would not cause a large-scale loss of 

soil productivity. Over time, as weed infestations continue to spread and become more dominant on the 

national forests, loss of soil productivity would become evident.

All Action Alternatives

All activities and land uses on the forests contribute to soil disturbance and some degree of erosion; most 

serve as vectors with the potential to introduce and spread invasive weeds. The action alternatives initially 

would cumulatively add minor, short-term increases in erosion for a season or less. However, management 

activities under the control of the Forest Service would include measures to avoid rates of erosion that exceed 

forest plan standards and to maintain soil productivity. Therefore, the cumulative effects of weed treatments 

and other activities occurring on the Carson and Santa Fe National Forests are expected to be negligible. 

In addition, most ongoing and foreseeable future activities have objectives aimed at enhancing and restoring 

ecosystem function and healthy water and soil conditions. Many recent projects have successfully improved 

soil productivity. These projects include closing and decommissioning forest roads, reducing camping and 

grazing in riparian areas, and reducing where motorized use may occur throughout the forests. These actions 

would have cumulatively beneficial effects and would combine with the long-term beneficial effects of the 

proposed weed treatment project to reduce soil erosion and sedimentation.

Cumulative impacts to soil quality also would occur from the herbicide loading in alternatives B and D when 

added to other public agencies and private landowners in the area conducting similar herbicide treatments. 

Cumulative effects would also occur to soil organisms from herbicide applications; however, these impacts 

are expected to be temporary and limited to the treatment sites. Cumulatively, treatments would not affect soil 

organisms located away from treatments (on forest or off). Beneficial cumulative effects would occur in 

treated areas as native vegetation becomes reestablished and soil qualities improve over the long-term.

Effects of Forest Plan Amendment to Soil

The proposed Santa Fe National Forest Plan amendment would modify the soil resource standards and 

guidelines. It would allow the Santa Fe to use herbicides on soils with a low revegetation potential. Not using 

herbicides on these soils would be counterproductive to meeting the purpose and need, and soils would be 

adequately protected by applying the adaptive strategy (Table S-10) and design features (Table S-11) listed. 

With the design features and adaptive strategy applied to this and all future projects, no negative impacts to 

soil productivity or characteristics would be expected to last longer than 6 months. Herbicides such as 

picloram, which are persistent in soil and are more mobile, would not be used near water (see chapter 2.) By 

controlling or eradicating weeds in this and future projects, an overall beneficial impact to soils is predicted; 

restoring native vegetation on soils generally reduces erosion, thereby increasing productivity. The design 

features and adaptive strategy listed in Table S-10 and Table S-11 replace the cation exchange standard and 

provide more protection to soils. Thus, deleting this standard from the forest plan would not be expected to 

reduce soil productivity or change soil characteristics in this or future projects that apply herbicides to certain 

soils. There would be no impact to soil resources, and erosion rates would not exceed the tolerance level 

identified in the terrestrial ecosystem survey for the affected soil unit.
Final Supplemental Environmental Impact Statement

123

Air Quality

[Replaces entire section]

Affected Environment

Introduction

The project area contains both the Carson and Santa Fe National Forests and is located within four major 

airsheds as defined by the New Mexico Environment Department: the Upper Rio Grande, the Middle Rio 

Grande, the Canadian River, and the Pecos (NMED 2003). All airsheds in New Mexico are based on 

watershed boundaries developed by the New Mexico Water Quality Control Commission. These airsheds 

cover many counties; however, the project area lies mainly in Rio Arriba, Taos, Colfax, Sandoval, Los 

Alamos, Santa Fe, Mora, and San Miguel Counties. The project area includes significant population centers 

along the Rio Grande – Santa Fe, Taos, Los Alamos, and Espanola – and many pueblos and small 

communities.

There are four class 1 areas within the project area: Wheeler Peak, San Pedro Parks and the Pecos Wilderness, 

which are all managed by the Forest Service; and Bandelier National Monument, which is managed by the 

National Park Service. Class 1 areas are identified in the Clean Air Act as areas that require the highest level 

of protection for air quality related values, such as visibility, in addition to the national ambient air quality 

standards (NAAQS).

Southwesterly winds typically blow across the mountainous region of northern New Mexico. Temperatures 

vary from an average daily maximum of 86 degrees Fahrenheit in July in Jemez Springs to an average daily 

minimum of 3 degrees Fahrenheit in Dulce in January (data from Western Regional Climate Center). 

Emissions

Emissions affecting air quality can come from a variety of sources. Emissions are typically associated with 

either point sources, such as large industrial facilities or power generation, or area sources, such as emissions 

from vehicles or fugitive dust from agriculture. Emissions and dust from as far away as California and Asia or 

as nearby as the Four Corners region can contribute to reductions in visibility, deposition of pollutants, and 

impacts to ambient air quality. For the purpose of this assessment, only emissions from the counties that 

contain the project area and some of the surrounding counties were considered because potential effects of 

herbicide drift and smoke affecting air quality is not likely to go farther than the area described. 

There are many offsite sources (facilities) capable of impacting air quality in the project area, such as power 

plants, oil and gas operations on the west side of the forests and Four Corners area, natural gas compressor 

stations and refineries in the San Juan Basin, mining operations in Taos, Santa Fe, and Rio Arriba Counties, 

biomass plants, and other sources such as foundries and landfills (Environmental Protection Agency national 

emissions inventory). 

Regulatory Environment

There are two primary regulatory considerations under the Clean Air Act for actions by the Forest Service: the 

national ambient air quality standards and the regional haze program. National ambient air quality standards

include primary standards to protect public health and secondary standards that protect the environment. The 

aim is to set standards for the concentration of certain pollutants in the ambient air so they are below levels 

that would impact public health or the environment. The regional haze program requires states or the Federal 

government to develop plans that reduce emissions from all sources across a state, so visibility returns to 

natural conditions without the impact of human-caused sources by 2064. 
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National Ambient Air Quality Standards

New Mexico and the Federal government have established air quality standards for specific criteria air 

pollutants. The criteria pollutants are carbon monoxide, lead, sulfur dioxide, particulate matter smaller than 10 

microns (PM10), particulate matter smaller than 2.5 microns (PM2.5), ozone, and nitrogen dioxide. Of the 

seven criteria pollutants, the pollutants of concern for this project are the particulate matter pollutants PM2.5

and PM10 from prescribed fire. Table S-54 shows the national and New Mexico air quality standards for PM2.5

and PM10. Primary and secondary national standards are the same and the New Mexico standards are the same 

as the national standards for the two pollutants. 

Air quality in the project area is classified as being “in attainment” for all criteria pollutants. A 

“nonattainment” designation means that violations of standards have been documented in the region. There 

are no nonattainment areas within the project area. Typically, all areas within the project area have very good 

air quality, with measured values that fall below all Federal and State standards. 

[Table S-54 replaces table 41]

Table S-54. National ambient air quality standards for criteria pollutants of concern. (New Mexico standards are 

the same as the national standards)

Pollutant Averaging Time Primary and Secondary Standard

PM10 24-hour 150 μg/m3

PM2.5 Annual (arithmetic mean) 12 μg/m3

24-hour 35 μg/m3

a. Concentrations are expressed in units in which they were promulgated. μg/m3 = micrograms per cubic meter. Units shown as μg/m3 

are based upon a reference temperature of 25o

C and a reference pressure of 760 mm of mercury.

b. Primary standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health.

c. Secondary standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of 

a pollutant.

Figure S-7 through Figure S-9 summarize the range of PM2.5 and PM10 pollutants found in or near the project 

area from the State’s air quality monitoring data from 2010 through 2012. For both PM2.5 and PM10, the 

measured values in Santa Fe and Taos are significantly below the standards. Both represent monitored values 

much closer to a variety of urban emission sources (primarily vehicles) and it is assumed values on the 

national forest are typically less than what is measured at either of these monitoring sites.
Final Supplemental Environmental Impact Statement

125

Figure S-7. PM10 24-hr maximum values in Taos and Santa Fe with 3-year moving average (micrograms per cubic 

meter)

Figure S-8. PM2.5 24-hr values for 98th percentile weather conditions in Taos and Santa Fe with 3-year moving 

average (micrograms per cubic meter)
Invasive Plant Control Project

126

Figure S-9. PM2.5 annual mean values in Taos and Santa Fe with 3-year moving average (micrograms per cubic 

meter)

Regional Haze–Visibility

Visibility is the condition that allows people to see and appreciate the inherent beauty of the landscape 

features. It can be greatly impacted by particulate matter and gases that are in smoke or dust (Malm 2000). 

Visibility and other air quality standards are most stringent within designated class 1 areas. Thus, most 

monitoring for visibility is conducted in class 1 areas, which for this project are San Pedro Parks Wilderness 

and Bandelier National Monument. The results of this monitoring and projections for visibility in the future 

are shown in the next two figures. 

The Regional Haze Rule sets a goal to return class 1 areas to natural visibility conditions by 2064. As of 2010, 

both class 1 areas were slightly ahead of schedule, but further improvements will be needed to meet the 

national visibility goal. In 2011, visibility was impacted at both monitoring locations as a result of smoke 

from the Las Conchas and Wallow Fires (Figure S-10 and Figure S-11).
Final Supplemental Environmental Impact Statement

127

Figure S-10. Visibility conditions on worst 20 percent visibility days for San Pedro Parks Wilderness and glide path to 2064 goal
Invasive Plant Control Project

128

Figure S-11. Visibility conditions on worst 20 percent visibility days for Bandelier National Park and glide path to 2064 goal
Final Supplemental Environmental Impact Statement

129

Environmental Consequences to Air Quality

None of the methods for treating weeds would result in emissions great enough to have a significant impact 

on human health or visibility. Weed treatments would be widely distributed across both national forests over 

time. Mandatory design features for protecting human health would continue to apply to herbicide application

in municipal watersheds or in areas of human habitation and with prescribed fire. Neither human health nor 

visibility would be affected by project activities.

Methodology

The mandatory design features for herbicide application and the scale of herbicide application and prescribed 

burns being proposed are such that both fall well below any limits for concern and meaningful quantification. 

Therefore only a qualitative discussion follows. 

Alternative A–No Action

Under the no-action alternative, there would be no impacts to air quality because the project would not occur. 

Because there would be no direct or indirect effects, there would be no cumulative effects.

Alternative B–Proposed Action

Though alternative B would cause emissions, the amount would not be great enough to impact human health 

or visibility. In summary, since weed treatments would be widely distributed across both forests over time, 

human health and visibility would not be affected by project activities.

Gaseous emissions would originate from combustion of fuel in vehicles used to transport workers to and from 

treatment sites, vehicle mounted spray units applying herbicides, and from heavy equipment doing 

mechanical treatments such as mowing. The amount of gaseous exhaust emissions depends on size, age, and 

fuel efficiency of the engines; however, this is considered insignificant at this scale. 

Vehicle traffic on forest roads would generate road dust. Dust caused by traveling to and from treatment areas 

would settle, typically within a few minutes, leaving no lasting impact. Spraying herbicides from a vehicle 

would produce little road dust because the speed would be slow. Similarly, dust from annual road-side 

mowing or root plowing would be minimal due to slow vehicle speeds and the low frequency of treatments 

(annually).

During herbicide applications, spray drift is expected to be contained near the application site, due to 

limitations restricting application under wind conditions that could result in drift. In addition, drift will be 

limited because the slow vehicle speed and low height of the spray boom would resulting in the herbicide 

depositing on the ground within a few feet of the target weed population. 

Smoke from prescribed burning would release particulate matter (PM10 and PM2.5) emissions. All prescribed 

burning used to treat weeds would comply with the New Mexico smoke management program requirement. 

The New Mexico Smoke Management Program is designed to prevent conditions adverse to human health 

and to protect visibility. Only a relatively small amount of acres per year would be treated by prescribed fire 

(approximately 100 acres per year maximum) to control for weeds. The vegetation being burned have a low 

fuel loading for the most part. In this case, a large amount of emissions is not expected and would fall well 

below standards. 

Alternative C–No Herbicides

Alternative C would potentially create more dust because of more mowing and root plowing and more 

particulate emissions from prescribed burning than would occur under alternatives B or D. This would result 

in a slight increase in PM10 and PM2.5 from dust and smoke. Otherwise, effects would be similar to alternative 

B. Because estimated emissions are low and these emissions would be distributed across the national forests 
Invasive Plant Control Project

130

and over time, concentrations of pollutants would not affect air quality standards. Human health and visibility 

would not be affected by project activities.

Alternative D–Herbicides Only

Impacts on air resources from alternative D would be similar to those under alternative B, except less dust 

would be created because there would be no mowing, root plowing, or other treatments with potential to 

produce dust and there would be no smoke emissions from prescribed burning. Because estimated emissions 

are low and these emissions would be distributed across the forests and over time, concentrations of pollutants 

would not affect air quality standards. Human health and visibility would not be affected by project activities.

Cumulative Effects

The spatial boundary for the analysis of cumulative effects on air quality is contained within the following 

four airsheds as defined by New Mexico Environment Department (NMED): the Upper Rio Grande, the 

Middle Rio Grande, the Canadian River, and the Pecos airsheds (NMED 2003). Airsheds are similar to 

watersheds in that they are defined geographic areas that, because of topography, meteorology, or climate, 

they are frequently affected by the same air mass. The difference with airsheds is that air masses and air 

pollutants move between airsheds mostly based upon larger meteorological patterns, rather than primarily by 

topography, as with water flowing through a watershed. However, for the purpose of this assessment, the area 

is contained to the counties identified earlier in this section for the same reason given. 

Current conditions for ambient air quality and visibility are good in the four airsheds that contain the project 

area. In terms of air quality impacts, neither human health nor visibility is expected to be impacted by project 

activities, and therefore there would be no cumulative effects. The particulate pollution and other 

contaminants in the air and the small amount of emissions produced during treatments at any given time and 

place would result in no noticeable cumulative increases in emissions within the airshed, even when 

considered with other ongoing and foreseeable future activities.

Effects of Forest Plan Amendment to Air Quality

Implementing future projects under the proposed amendment would have no effect on air quality, human 

health, or visibility. Mandatory design features for protecting human health would continue to apply to 

herbicide application in municipal watersheds or in areas of human habitation and with prescribed fire. The 

effects described in this section would be the same under the plan amendment.

Heritage Resources

Affected Environment

Introduction

[Replaces third paragraph]

The final environmental impact statement, completed in 2005, tiered to the 2004 Programmatic Agreement

(PA) titled “Invasive Weed Control” and was among the USDA Forest Service, Southwestern Region, Santa 

Fe and Carson National Forests, New Mexico Historic Preservation Officer, Advisory Council on Historic 

Preservation and in consultation with affiliated Tribes. That agreement expired in 2009. This final

supplemental environmental impact statement adheres to the requirements laid out in “Appendix F - Standard 

Consultation Protocol for Noxious Weed Control” of the First Amended Programmatic Agreement Regarding 

Historic Property Protection and Responsibilities. This agreement is binding among the national forests in 

New Mexico, New Mexico State Historic Preservation Office (SHPO) and the Advisory Council on Historic 

Preservation; it addresses applicable Section 106 requirements of the National Historic Preservation Act. 

Pursuant to the programmatic agreement, subsequent initiation of noxious weed control projects will be 
Final Supplemental Environmental Impact Statement

131

contingent upon completion of the identification and protection of historic properties, and compliance with 

applicable provisions of National Historic Preservation Act in accordance with appendix F.

[Replaces fourth paragraph]

Weed control methods such as manual and mechanized ground-disturbing treatments would need to follow 

the steps outlined in appendix F of the standard consultation protocol. Other methods, such as biological 

methods or direct hand application of herbicides to target weed species, were considered to have little or no 

effect on heritage resources and are exempt from further consideration under Section 106. The programmatic 

agreement and appendix F are available in the project record.

[Replaces sixth and seventh paragraphs and Table S-55 replaces table 45]

Heritage resource surveys have been conducted on approximately 221,805 acres (15 percent) of the 1.5-

million-acre Carson National Forest, and 278,000 acres (17 percent) of the 1.6-million-acre Santa Fe National 

Forest. Approximately 5,970 heritage resource sites have been recorded on the Carson National Forest, and 

9,800 heritage resource sites have been recorded on the Santa Fe National Forest. 

Table S-55 illustrates the number of known heritage sites completely within, or intersected by, currently 

inventoried weed infestations. Sites located completely within currently inventoried weed infestations on the 

Santa Fe National Forest consist of 101 sites with an average site size of 0.47 acre. Sites that intersect 

inventoried weed infestations on the Santa Fe National Forest consist of 215 sites with an average site size of 

10.6 acres. Of the 10,020 acres of weed infestations on the Santa Fe National Forest, heritage sites encompass 

approximately 350 dispersed acres (3.5 percent) across the entire project area.

Sites located completely within currently inventoried weed infestations on the Carson National Forest consist 

of 17 sites with an average site size of 0.79 acre. Sites that intersect inventoried weed infestations on the 

Carson National Forest consist of 128 sites with an average site size of 15.6 acres. Of the 3,235 acres of weed 

infestations on the Carson National Forest, heritage sites encompass approximately 259 dispersed acres (8 

percent) across the entire project area.

Table S-55. Affected heritage resource sites

National 

Forest

Total 

Sites

Sites Within Weed 

Infestations 

Average Size 

(Acres)

Sites Intersect 

Weed Infestations

Average Size 

(Acres)

Santa Fe 316 101 0.47 215 10.6

Carson 145 17 0.79 128 15.6

Totals 461 118 N/A 343 N/A

Archaeological Resources

[Delete second paragraph, page 148]

Ethnographic and Traditional Cultural Property Resources

[Replaces 5th paragraph, page 149]

Traditional cultural properties are often difficult to identify during standard heritage resource surveys, and 

none have been identified in the areas of potential affect during scoping and Tribal consultation activities 

conducted to date for this project. Scoping and consultation for the initial environmental impact statement was 

initiated in December of 2000, and an additional solicitation of comments was mailed to Tribes in December 

of 2003, prior to release of the draft environmental impact statement for public review. As a result of the 

expired programmatic agreement for the 2005 final environmental impact statement Tribal consultation, the 

Carson and Santa Fe National Forests conducted consultation with Tribes for the final supplemental 

environmental impact statement. Letters were mailed to the Tribes on September 19, 2013. 
Invasive Plant Control Project

132

Environmental Consequences to Heritage Resources

[No change from the final environmental impact statement]

Effects of Forest Plan Amendment to Heritage Resources

[Additional section]

The proposed amendment will have limited effect to archaeological resources in future projects. Effects from 

herbicides on the analytical potential of perishable materials such as wood, ceramic paint, datable materials,

and residues on artifacts has not been studied, but the overall effect is not likely to be adverse. Since little is 

known about the effects of herbicides on archaeological sites, monitoring will be used to collect additional

data on this treatment method.

The proposed amendment will have a short-term effect to ethnographic resources in future projects. 

Traditional plant habitats could be affected by herbicidal application to eradicate weeds and, if so, would

interrupt the plant collecting cycle for traditional communities. The timing of weed treatments, however,

would take into account the traditional cyclic calendar of local communities as identified through scoping.

Design features that include notifying Tribes before the use of herbicides occurs will reduce the risk to plants

used for traditional cultural purposes, and thus to the health of Native Americans who gather these plants

(Table S-11, rows 2, 10-12, 54-55).

With the design features and adaptive strategy applied to this and all future projects, no adverse effects to 

heritage resources (archaeological or ethnographical) are anticipated from the plan amendments. By 

controlling or eradicating weeds in this and future projects, an overall beneficial impact to soils is predicted; 

restoring native vegetation on soils generally reduces erosion, thereby increasing productivity and stabilizing 

heritage resources. The design features and adaptive strategies listed in Table S-10 and Table S-11 provide 

more protection to heritage resources than the existing forest plan standard. Thus, modifying the existing

standard would not adversely affect heritage resources in this or future projects that apply herbicides.

Recreation and Wilderness

[Replaces entire section; Figure S-12 replaces figure 12; Figure S-13 replaces figure 13]

Affected Environment

Introduction

The affected environment and environmental consequences sections on recreation resources focus on current 

conditions, historic trends, and environmental effects of each alternative in terms of recreation and wilderness 

areas. This section also describes past, present, and foreseeable future land use activities that could contribute 

to cumulative impacts when combined with the effects of this project. The cumulative effects from those 

activities are described at the end of the “Environmental Consequences” section.

General Recreation Trends

Recreation has increased as a proportion of overall national forest use. Outdoor recreation, specifically the 

component on public lands, is a multibillion dollar industry (Laitos and Carr 1999). In fact, recreation on 

National Forest System lands increased 1,161 percent between 1950 and 1995 and the Outdoor Recreation 

Coalition of America reported that in 1997 more than 90 percent of Americans over 16 years old were 

participating in outdoor recreation activities (Laitos and Carr 1999).

Visitors to the Carson National Forest and Santa Fe National Forest are predominantly local. On the Carson 

National Forest, greater than 60 percent of the visitors come from towns and mountain communities in Taos 

County, while around 5 percent come from out of state (USDA 2008, updated 2012). On the Santa Fe 

National Forest, greater than 60 percent of visitors come from Santa Fe, Albuquerque, or towns adjacent to 
Final Supplemental Environmental Impact Statement

133

the Santa Fe (Jemez Pueblo, White Rock, Las Vegas), while fewer than 1 percent of visitors are international 

(Kocis et al. 2010). On both national forests, visitors come from west Texas, Oklahoma, southern Colorado, 

and Kansas. 

The most recent National Visitor Use Monitoring data for both forests are shown in Table S-56. Of the 

estimated 1 million visitors for the year of the survey, about 80 percent contacted were visiting the Carson 

National Forest for the purpose of recreation. Of the estimated 1.5 million visitors during the survey year, 

about 65 percent contacted were visiting the Santa Fe National Forest for the purpose of recreation.

Developed Recreation

Developed recreation facilities include campgrounds, picnic areas, trailheads, and other areas containing 

specialized recreation facilities that are planned to accommodate a fixed number of people at one time. 

Currently there are approximately 54 developed recreation sites on the Santa Fe National Forest and 34 

developed recreation sites on the Carson National Forest. On the Santa Fe National Forest, most weeds 

mapped in or near developed recreation sites are located along the Jemez River, where saltcedar, Russian 

olive, and Siberian elm have overgrown fishing access sites and campgrounds (Figure S-12). Invasive weeds

are mapped within developed recreation sites on the Carson National Forest. The species include bull thistle 

and Canada thistle mapped at the June Bug, Elephant Rock, and Cebolla Mesa Campgrounds on the Questa 

Ranger District and Canada thistle at the Santa Barbara Campground on the Camino Real Ranger District. 

There are limited populations currently mapped within developed recreation sites, but the potential for 

expansion into more sites exists due to the existence of numerous weed populations along roads leading to 

recreation facilities on the two national forests.
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Table S-56. Recreational visits to the Carson and Santa Fe National Forests

Activity

Carson National Forest FY 2008a

Santa Fe National Forest

FY 2009b

% 

Participating

% that Consider 

Primary Activity

% 

Participating

% that Consider 

Primary Activity

Developed camping 3.9 0.4 5.1 2.3

Primitive camping 4.2 0.6 1.9 0.4

Backpacking 1.0 0.1 1.8 0.9

Resort use 1.3 0.0 0.7 0.0

Picnicking 4.9 1.3 7.7 1.7

Viewing natural features 30.9 4.1 32.4 9.5

Visiting historic sites 2.5 0.0 2.8 0.1

Nature center activities 1.5 0.1 4.2 0.0

Nature study 6.2 0.0 10.1 0.4

Relaxing 26.9 3.5 21.6 4.3

Fishing 7.2 5.8 9.1 5.3

Hunting 5.1 5.0 2.3 1.5

OHV use 2.4 0.8 0.4 0.0

Driving for pleasure 14.9 2.9 11.3 1.7

Snowmobiling 4.0 2.5 0.0 0.0

Motorized water activities 0.0 0.0 0.1 0.0

Other motorized activity 0.0 0.0 0.0 0.0

Hiking/walking 40.2 24.7 66.5 50.7

Horseback riding 1.4 0.0 0.6 0.1

Bicycling 1.0 0.2 2.6 2.0

Non-motorized water 0.1 1.0 0.9 0.8

Downhill skiing 35.4 33.4 8.5 8.3

Cross-country skiing 8.2 6.9 9.4 9.1

Other nonmotorized uses 0.7 0.3 2.2 0.6

Gathering forest products 6.5 2.3 3.2 0.1

Viewing wildlife 23.6 0.7 22.2 0.6

Motorized trail activity 2.9 0.1 0.8 0.0

Some other activity 6.4 4.1 3.3 1.9

No activity reported 0.0 0.6 0.2 0.2

a. From the National Visitor Use Monitoring Results, USDA Forest Service, Region 3, Carson National Forest, 2008.

b. From the National Visitor Use Monitoring Results, USDA Forest Service, Region 3, Santa Fe National Forest, February 2011. 

Ski areas, organizational camps, and recreation residences (summer homes) are also included in this 

recreation category as “private sector” recreation. The Santa Fe Ski Area, Taos Ski Valley, Red River Ski 

Area, Enchanted Forest Cross Country Area, and Sipapu Ski Area are located within the two national forests. 

In addition, one Boy Scout camp, one Girl Scout camp, and one YMCA camp are located within the two 

forests. Leafy spurge and bull thistle are currently growing on the Philmont Boy Scout Ranch, and yellow star 

thistle is growing on the Rancho del Chaparral Girl Scout Ranch.
Final Supplemental Environmental Impact Statement

135

Dispersed Recreation

Dispersed recreation includes activities in Table S-56 that do not occur in developed facilities. Some 

developed recreation facilities such as trailheads, parking areas and vista points link with trails which 

facilitate a variety of dispersed recreation opportunities.

There are 1,095 miles of trails on the Santa Fe National Forest, including 208 miles designated for motorized 

use. Of these, about half are associated with the San Pedro Parks, Dome, Pecos, or Chama Wilderness areas. 

There are 540 miles of system trail, including the Pecos Wilderness, on the Carson National Forest and 2,353 

miles of system travel ways. Trail use is predominantly recreation oriented. Travel ways are used primarily as 

4-wheel drive roads for recreation, livestock trails, and fire access routes.

Three nationally designated scenic byways are located on the two national forests: the Enchanted Circle 

Scenic Byway, the Jemez Mountain National Scenic Byway, and the Santa Fe National Forest Scenic Byway. 

Four congressionally designated wild and scenic rivers are all, or partially, on the two national forests: Rio 

Grande, Rio Chama, East Fork Jemez, and Pecos Rivers. There are populations of Canada thistle, saltcedar,

and Russian olive along the Rio Chama Wild and Scenic River. 

Most of the dispersed recreation occurs along streams and around waterbodies, as well as in wilderness and 

designated roadless recreation areas. Camping and other recreational activities in undeveloped areas often 

remove native vegetation and create disturbed soil conditions that are more susceptible to weed establishment. 

Horses and other pack animals frequently used for recreation on the two national forests, particularly in 

wilderness, can transport weeds, especially if hay and feed are brought in. Off road vehicle use is another 

common way for weed seeds to be spread along routes designated for off-highway vehicles.
Invasive Plant Control Project

136

Figure S-12. Weeds located near recreation sites, August 1, 2013
Final Supplemental Environmental Impact Statement

137

Figure S-13. Locations of weeds in wilderness areas, August 1, 2013
Invasive Plant Control Project

138

Wilderness

Eight designated wilderness areas are located on the two national forests: Wheeler Peak Wilderness, Latir 

Peak Wilderness, Cruces Basin Wilderness, Pecos Wilderness, Chama Canyon Wilderness, San Pedro Parks 

Wilderness, Dome Wilderness, and the Columbine-Hondo Wilderness. Currently, about 560 acres of invasive 

weeds are mapped within wilderness areas on the two national forests. The potential for further expansion 

into, and within, the wildernesses is high due to the existence of numerous populations along roads and trails 

which provide access to the wilderness areas. 

Motorized and mechanized weed treatments are not allowed within wilderness. Forest Service Manual 

2323.26b states:

Approve plant control only for...:

b. Noxious farm weeds by grubbing or with chemicals when they threaten lands outside wilderness or 

when they are spreading within the wilderness, provided that it is possible to effect control without 

causing serious adverse impacts on wilderness values.

Herbicide treatments in wilderness areas require review and approval by the regional forester (Forest Service 

Manual 2323.04c).

Wilderness character is composed of four qualities:

1. Untrammeled – the primary ideal for wilderness where it is essentially unhindered and free from modern 

human control or manipulation.

2. Natural – where the natural condition of the land, its plants, wildlife, water, soil, air, and the ecological 

processes are managed, protected, and preserved.

3. Undeveloped –where wilderness retains its primeval character and influence, and is essentially without 

permanent improvements or human occupation.

4. Solitude or Primitive and Unconfined Recreation – where wilderness provides these types of recreation 

opportunities.

Environmental Consequences to Recreation and Wilderness

Summary

The principal relationship between recreation and invasive weeds is that recreation is a vector for spread of 

weeds. Direct and indirect impacts on recreation, both within and outside wilderness, resulting from 

implementation of the action alternatives would include short-term encounters with weed treatment crews, 

short-term closures of areas during treatments, and visual impacts from wilting plants. In some cases,

herbicide treatment may be applied within a wilderness area. Some wilderness advocates would perceive that 

wilderness values were being reduced by the use of chemical weed control methods within wilderness. 

Cumulative effects resulting from action alternatives would be the protection of adjacent noninfested areas 

and preservation of intact plant communities, which would enhance recreation and wilderness experiences.

Direct and Indirect Impacts

Weeds can affect the recreation experience. Invading weeds such as spotted knapweed, Scotch thistle, and 

yellow star thistle detract from the desirability of using recreation sites and enjoyment of the wilderness. 

These species diminish the usefulness of sites because the stiff plant stalks, thorns, or sharp bristles can 

discourage or prevent walking, sitting, or setting up a camp. Weeds also detract from the recreation 

experiences by reducing the variety and amount of native flora to observe or study and reducing forage 

availability for wildlife and recreational livestock.
Final Supplemental Environmental Impact Statement

139

Alternative A–No Action

General Recreation Trends

Recreation on the forests is likely to cause the establishment of new weed populations, which would then 

spread at the assumed average rate of 8 percent per year. Weeds would typically spread along roads and 

motorized trails because motor vehicles are one of the main ways weed seed spreads. Roadsides and adjacent 

areas, such as turnouts, campgrounds, and firewood gathering areas, are usually disturbed, which favors the 

proliferation of most weed species.

The spread of weeds would degrade recreational values for people who understand and value natural 

conditions. The National Visitor Use Monitoring survey data (Table S-56 – Santa Fe National Forest) indicate 

32 percent of visitors surveyed enjoy viewing natural features, 10 percent enjoy nature study, and 22 percent 

enjoy viewing wildlife. 

Hunting opportunities would be reduced over time as weeds reduce the quality of forage and cover habitat for 

many wildlife species (refer to “Wildlife Resources” section).

Weeds such as spotted knapweed, Scotch thistle, and yellow star thistle would diminish the desirability of 

dispersed recreation opportunities because the rigid plant stalks, thorns, or sharp bristles would discourage or 

prevent walking, sitting, or setting up a camp. 

Recreational experiences and values would especially decline where tall, dense weeds such as saltcedar 

dominate and limit access to riparian areas and stream banks. The dense thickets of saltcedar along the Green 

River in Desolation Canyon have eliminated many of the campsites used by river runners for the first 20 miles 

downriver from the Bureau of Land Management Sand Wash boat ramp. Weed species that cause allergies 

(hay fever, skin reactions) would also diminish recreational experiences for susceptible people.

On the other hand, this alternative would avoid the temporary closures of some recreation sites, trails, or roads 

during and immediately after treatment activities. 

Wilderness

The no-action alternative would have the following effects on the four wilderness characteristics:

1. Untrammeled – Not allowing any treatments in wilderness would preserve the untrammeled quality of 

wilderness.

2. Natural – Not allowing any treatments in wilderness would result in the proliferation of weeds over time. 

This would not manage, protect, or preserve its natural ecological processes. This assumes weed 

proliferation outside and introduction into wilderness is not a natural ecological process. 

3. Undeveloped – The no-action alternative would have no effect on this quality because no permanent 

improvements or permanent occupation would occur. 

4. Solitude or Primitive and Unconfined Recreation – The no-action alternative would preserve solitude and 

primitive and unconfined recreation because no treatments would occur.

Alternative B–Proposed Action

General Recreation Trends

Recreation on the two national forests is likely to cause the establishment of new weed populations, which 

would then spread at the assumed average rate of 8 percent per year. Under this alternative, the Forest Service 

expects to be able to control or eradicate new populations. Because the new populations are most likely to 

establish along roads and trails, Forest Service personnel would be able to get to them easily for treatment.
Invasive Plant Control Project

140

The negative effects predicted for alternative A would not occur or would occur to a lesser degree, depending 

on how effectively new populations are eradicated.

Developed and Dispersed Recreation

Herbicide applications and other treatments may cause temporary visual disturbances to some people who 

encounter weed treatment personnel; however, on most sites, treatments would only last a few days or less. 

There would be an insignificant increase in the amount of noise and traffic associated with these treatment 

activities, primarily due to the short timeframe needed to treat weeds at most weed infestation sites and the 

relatively small number of personnel needed to implement treatments. Proposed treatments typically would

not require large crews of workers such as those used for thinning projects, prescribed burning, watershed 

restoration projects, etc. 

Temporary closure of roads, trails, or recreation sites during and immediately after herbicide applications 

would have a minimal impact on recreational opportunities because they would not typically last more than a 

day or two and would occur during weekdays.

Odors emitted by herbicides could cause anxiety in persons unaware of their presence, although it is unlikely 

herbicides would be applied along trails or in recreation sites during a time when visitors are present because 

the Forest Service would close sites during herbicide application. Signs would be posted at access points to 

recreation sites, roads, or trails where herbicides would be used. The “Human Health and Safety” section 

describes the effects of herbicides on human health in detail.

Areas of wilting, dying, or dead weeds and weeds removed, cut, or burned would be apparent for a short time 

in the localized treatment sites. This would diminish the natural appearance of the treatment site. Within a 

growing season or two, early seral vegetation would fill in and become more noticeable than the dead plants 

or bare soil areas. 

Wilderness

The effects of alternative B on the four wilderness characteristics would be as follows:

1. Untrammeled – For some people, the sight of agency personnel spraying herbicides or hand grubbing 

weeds within a wilderness may diminish the quality of their wilderness experience. 

2. Natural – Controlling weeds would promote native plants, which would be managing the natural 

condition of the land, its plants, wildlife, water, soil, air, and the ecological processes.

3. Undeveloped – Alternative B would have no effect on this quality because no permanent improvements or 

permanent occupation would occur.

4. Solitude or Primitive and Unconfined Recreation – No effect on solitude or primitive and unconfined 

recreation is expected because the acreage needing treatment is tiny compared to the acreage of the 

wildernesses. Temporary closures of sites during treatment are possible; the closures would generally last 

less than a week.

Alternative C–No Herbicides

General Recreation Trends

Alternative C would not be as effective at controlling newly established weed populations caused by 

recreational activities. The result on general recreation trends would be the same as alternative A but to a 

lesser extent. 
Final Supplemental Environmental Impact Statement

141

Developed and Dispersed Recreation

Due to the need for additional repeat treatments, there would be a slight increase in the amount of noise and 

traffic associated with treatments on the forest. Some recreation sites and trails being treated with manual or 

other non-herbicide methods would not need to be temporarily closed to the public which would maintain 

more recreation opportunities, especially for visitors who are sensitive to chemically treated environments.

Wilderness

The effects of alternative C on the four wilderness characteristics would be as follows:

1. Untrammeled – For some people, the sight of larger numbers of agency personnel treating weeds within a 

wilderness may diminish the quality of their wilderness experience, compared with alternative B. 

2. Natural – Controlling weeds would promote native plants, which would be managing the natural 

condition of the land, its plants, wildlife, water, soil, air, and the ecological processes; this alternative 

would be less effective than alternative B because small isolated populations are difficult to monitor and 

applying more repeated treatments for effective control would be more difficult.

3. Undeveloped – Alternative C would have no effect on this quality because no permanent improvements or 

permanent occupation would occur.

4. Solitude or Primitive and Unconfined Recreation – No effect on solitude or primitive and unconfined 

recreation is expected because the acreage needing treatment is tiny compared to the acreage of the 

wildernesses. 

Alternative D–Herbicides Only

General Recreation Trends

Effects under alternative D would be similar to effects under alternative B above. Ground-disturbing 

activities, such as mowing, tilling, digging, or burning, would not be implemented. Since these activities often 

need to be repeated in order to meet objectives, the effect over time would be a reduction in noise and traffic 

along roads and trails and within recreation sites during treatment activities.

The effects of alternative D on the four wilderness characteristics would be as follows:

1. Untrammeled – For some people, the need for fewer people performing weed control would diminish the 

sense of excessive human intervention, compared with alternatives B and C.

2. Natural – Controlling weeds would promote native plants, which would be managing the natural 

condition of the land, its plants, wildlife, water, soil, air, and the ecological processes. This alternative 

would be less effective than alternative B for species most effectively controlled by non-herbicide 

methods; and more effective than alternative C for species most effectively controlled by herbicides.

3. Undeveloped – Alternative C would have no effect on this quality because no permanent improvements or 

permanent occupation would occur.

4. Solitude or Primitive and Unconfined Recreation – No effect on solitude or primitive and unconfined 

recreation is expected because the acreage needing treatment is tiny compared to the acreage of the 

wildernesses. 

Cumulative Effects to Recreation and Wilderness

The cumulative effect of the no-action alternative would be an increase in the establishment of new weed 

populations. The direct and indirect effect of the no-action alternative is that new weed populations are likely 

to become established as a result of recreational activity. This would add cumulatively with other actions that 

cause the establishment of weeds, such as wildfires, some prescribed burns, construction of facilities, road 
Invasive Plant Control Project

142

maintenance, and firewood collection. The cumulative effect on recreation would be a decrease in the quality 

of recreational activities due to weeds with thorns and allergens and due to a loss of native vegetation.

The direct and indirect effect of the action alternatives and the cumulative effect are shown in Table S-57.

Table S-57. Cumulative effects to recreation and wilderness resources

Direct and Indirect Effect

Actions Contributing 

Cumulatively to the Direct And 

Indirect Effect Summary of Cumulative Effect

Loss of recreational opportunity 

where sites are closed during 

treatments, normally 1 to 5 days

The publication of Motor Vehicle 

Use Maps has reduced the 

places where people can drive in 

the forests. Areas are closed 

during administrative projects, 

such as prescribed burns and 

thinning operations. During times 

of high fire danger, the entire 

project area can be closed for 

several weeks.

Negligible. Weed treatments 

would be widely dispersed and 

closures would last for brief 

periods. This means people 

would still have ample 

opportunity for recreational 

activity across the project area.

Visual disturbance from wilted, 

dead, or dying plants

Prescribed burns, wildfires, and 

drought are the primary things 

that cause plants to die. 

Negligible because the effects 

would last a season or less and 

are not likely to occur in the 

same places.

Noise and visual disturbance 

from crews performing 

treatments, including in 

wilderness areas

All activities conducted by 

national forest personnel, such 

as prescribed burning, thinning 

operations, trail maintenance, 

cleaning recreational facilities, 

performing monitoring activities, 

laying out sites, and suppressing 

wildfires all cause noise and 

visual disturbance.

Negligible. No additional national 

forest personnel would be hired 

to treat weeds, so there would be 

no net increase in activities.

Effects of Forest Plan Amendment to Recreation and Wilderness

Part of the Santa Fe municipal watershed is located in designated wilderness. The effect of the forest plan 

amendment on wilderness during future projects depends on the municipality’s willingness to treat weeds 

using herbicides. If the municipality agrees to the use of herbicides (shown to be the most effective treatment 

against weeds in general), with the design features in place, the overall effect would be to promote the natural 

characteristic of wilderness by promoting native vegetation. Conversely, if the municipality prohibits the use 

of herbicides, then the natural characteristic might be compromised if weeds spread more quickly than the 

Forest Service can control them.

The plan amendment allows treatment in areas of human habitation, which is interpreted as recreation sites for 

this portion of the analysis. The effects of the amendment would be no different than those described in the 

direct, indirect, and cumulative effects because this project incorporates many elements (Table S-10 and Table 

S-11) to protect human health and safety.
Final Supplemental Environmental Impact Statement

143

Visual Resources

[Replaces entire section]

Affected Environment

Visual Quality Objectives

Five visual quality objectives have been prescribed in the forest plans for the Carson and Santa Fe National 

Forests. The visual quality objectives categorize lands according to scenic quality and viewer sensitivity. They 

are preservation, retention, partial retention, modification, and maximum modification. Preservation, for 

example, is the visual quality objective assigned to wilderness areas. When originally developed, the visual 

quality objectives described the existing condition of the national forests’ viewsheds. The visual quality 

objectives are not binding elements of the forest plans; however, the Forest Service makes every effort to 

ensure its management actions align with the existing visual quality objectives. See The Visual Management 

System (USDA Forest Service 1984) for definitions and descriptions of the visual quality objectives and the 

Carson and Santa Fe National Forest Plans (USDA Forest Service 1986b and 1987b) for an explanation of 

how visual quality objectives were applied to each national forests. 

Though visual quality objectives have been established for both national forests, they have not been 

completely mapped in electronic (GIS) format. Due to technological changes and budget constraints, the 

visual quality objectives have not been completely transferred from old Forest Service mylar maps. For 

example, 62 percent of the Santa Fe National Forest (mainly the west side) has the visual quality objectives 

mapped in the GIS dataset. 

Visual Elements

Four visual elements—form, line, color and texture—exist in any landscape. Depending on their composition 

and where they are viewed from, they exert differing degrees of influence. 

• Form: Landscape forms are determined by topography and vegetative pattern. The weed populations in 

the project area are relatively small and thus are indiscernible beyond foreground (up to 1⁄2 mile) views. 

Weeds do not dominate viewsheds in the project area.

• Line: Line is anything that is arranged in a row or sequence. It can be the silhouette of a form, the edge of 

a meadow, a ridgeline, a tree trunk, a river, the path of an avalanche, a road. Weeds, being plants, conform 

to the line of surrounding vegetation. 

• Color: Color enables people to distinguish among objects of identical form, line, and texture. Weeds are 

plants; thus, their colors conform to the surrounding vegetation and natural environment.

• Texture: Textures in the landscape are determined by geology, soils, topography, and vegetation. Weeds, 

as plants, conform to the textures of a forested or grassland environment.

Environmental Consequences to Visual Resources

Summary

Under the no-action alternative, the four visual elements would not noticeably change for many years.

Under all action alternatives, treating weeds would have a temporary effect on visual elements. All visual 

effects would be temporary because native vegetation is expected to grow back within a season or less. 

Further, all visual effects would be small because weed populations are currently small relative to the project 

area as a whole. Known weed populations cover 0.4 percent (13,256 acres) of the National Forest System 

lands in the project area (3,030,721 acres). The largest mapped patch of weeds is 2,793 acres of Canada thistle 
Invasive Plant Control Project

144

on the Santa Fe National Forest. The treatment sites are small and would not alter the overstory tree cover; 

thus, there would be minimal changes in form, line, color, or texture in the environment.

Direct and Indirect Effects

Visual Quality Objectives 

All the alternatives conform to the visual quality objectives assigned. The no-action alternative conforms to

visual quality objectives because weeds were part of the visual landscape when the visual quality objectives 

were assigned. 

Under the action alternatives, weed treatments would meet visual quality objectives. The visual effects of 

treatments, which are dead or dying plants, are temporary. Brown, dead, or dying vegetation would last no 

longer than it takes for native vegetation to grow back, normally a season. Dead or dying vegetation is a 

natural phenomenon, especially given the current drought. Even weed control treatments applied in 

designated wilderness would be expected to conform to the visual quality objective of preservation since 

treatments would not substantially alter the form, line, color, or texture of the landscape, or create a stark 

contrast with the surrounding vegetation.

Visual Elements 

Alternative A

Under alternative A, weeds are expected to spread at an average rate of 8 percent per year.

• Form: Over many years, weeds could dominate viewsheds. This, however, would not represent a 

significant change from the current landscape forms, which are dominated by “carpets” of trees or grass at 

the middleground and background views (photo 5).

Photo 5. Aerial view; example of current forest conditions in much 

of the project area. Note the uniform form, line, and texture

• Line: Without weed treatments, there would be no change in visual lines. Even with the continued spread 

of weeds, the lines formed would not be different from that presently found in a forested or grassland 

environment. 
Final Supplemental Environmental Impact Statement

145

• Color: There would be no change in color if weeds are not treated. Weeds, being plants, have colors 

naturally present in a forested or grassy environment.

• Texture: Because weeds are plants, there would be no change to visual texture from what is currently 

expected in a forested or grassland environment if weeds are not treated.

Alternatives B, C, and D

Overall, the treatment sites are small and would not alter overstory tree cover, thus there would be minimal 

changes in form, line, color, or texture in the environment. Of the 78 patches of weeds, 13 (17 percent) are 

200 acres in size or greater. Any visual effect to the four visual elements would be temporary (normally a year 

or less), lasting until native vegetation grows back. 

• Form: Because weed populations do not dominate viewsheds, treating them would not change landscape 

form in the middleground or background. In the foreground, people might observe dead or dying plants 

until native vegetation grows back; however, the presence of dead or dying vegetation is not uncommon 

in a forested environment and thus would not differ from current forms.

In the foreground view, the visual impacts resulting from mowing, hand grubbing, and hand pulling 

would be a change in the form because these methods result in localized soil disturbance. Root plowing 

would be more noticeable. Biological methods would not be visually noticeable in the foreground other 

than dead or dying weeds. Use of prescribed fire would cause the burned vegetation to appear brown or 

blackened for a short period and might result in patches of bare soil until the site is revegetated, similar to 

the visual effect of a naturally caused surface fire.

• Line: Treating weeds would result in new lines, where the edge of treatments (brown areas) would abut 

green areas. Lines from mowing, hand grubbing, and hand pulling would be noticeable in the foreground 

until native vegetation grows back; lines from prescribed fires could be noticeable in the middleground as 

well. The lines created by weed treatments would be normal in a natural setting in that they would not be 

straight.

• Color: Treating weeds from any method would result in brown vegetation. The color brown is common in 

a forested environment. The use of prescribed fire would cause blackened vegetation, also common in a 

forested environment. Because the color changes would be natural to a forested or grassy environment, 

there would be no direct or indirect effect.

• Texture: Dead and dying plants are part of the natural texture of a forested environment (for example,

piñon die-off of 2002 and wildfires); thus, treating weeds would not result in any unusual textures in the 

project area. Ground-disturbing methods, such as hand-pulling or mowing, would impact texture in the 

foreground by removing plants and leaving bare soil exposed until native vegetation grows back, 

normally a season. 

Cumulative Effects to Visual Resources

Visual Quality Objectives 

Because there would be no direct or indirect effect to visual quality objectives from any of the alternatives, 

there would be no cumulative effects.

Visual Elements 

Because alternative A (no action) has very little direct or indirect effects to the four visual elements, it would 

have no cumulative effects.

Table S-58 shows the anticipated cumulative effects for all action alternatives (B, C, and D) to the four visual 

elements.
Invasive Plant Control Project

146

Effects of Forest Plan Amendment to Visual Resources

The proposed plan amendment would have no effect to visual quality on future projects beyond what has been 

described in this section. The same effects to form, line, color, and texture described for this project would be 

the same for future projects under the plan amendment, which addresses where herbicides may be used.

Table S-58. Cumulative effects of action alternatives to visual quality

Item

Direct/Indirect 

Effect Overall Cumulative Effect

Past, Present, and Reasonably 

Foreseeable Future Actions that 

Cumulatively Contribute to the Effect 

Form No effect in 

middle- or 

background.

Temporary 

change in form 

due to dying 

vegetation or 

ground 

disturbance.

No direct or indirect effect; 

thus, no cumulative effect to 

middle- or background.

The effect of weed treatments 

in the foreground would 

contribute a negligible 

cumulative effect to form. It is 

unlikely, for example, that the 

change in form caused by 

weed treatments would be 

noticed against something 

like the Las Conchas Fire or 

the oil and gas pads present 

on the Jicarilla Ranger 

District.

Road construction and maintenance

Trail construction and maintenance

Creation of unauthorized routes

Construction and reconstruction of 

recreational facilities (such as 

campgrounds, fishing access, toilet 

installations)

Subdivision and development of private 

inholdings and land adjacent to the two 

national forests

Mining claims and development of mining

Wildfires, including suppression and 

rehabilitation

Hazardous fuels treatment and prescribed 

burning

Livestock grazing

Road decommissioning

Forest product collection

Administrative use

Weed treatments on land in other 

jurisdictions

Oil and gas leasing

Preparation of travel management plans 

and motor vehicle use maps by national 

forests and other agencies

Special Use Permits – acequia 

improvements, ROW for pipelines 

(water/natural gas), driveways, 

communication sites, outfitter/guides, etc.

Geothermal leases in Coyote, Cuba and 

Jemez Ranger districts

Oil and gas leases in Cuba Ranger 

District

Oil and gas development on the Jicarilla 

Ranger District

Line Temporary 

change in line 

where treated 

areas abut 

untreated areas.

The effect of weed treatments 

on line would be negligible 

when considered in context of 

the activities listed at left. The 

lines created by treatments 

would be relatively small 

(because of the small patch 

sizes), temporary, and would 

be “natural” in the sense they 

would not be straight. 

Color No effect. No direct or indirect effect; 

thus, no cumulative effect.

Texture Temporary effect 

of bare soil as a 

result of ground 

disturbance.

The cumulative effect to 

texture as a result of treating 

weeds would be negligible 

when considered in context 

with the activities listed at left. 

The size of patches to be 

treated is relatively small, and 

the effect would be temporary 

because of the mitigation to 

ensure that bare ground is 

revegetated.

Livestock Grazing

[Replaces entire section]

Affected Environment

Effects of Weeds on Livestock

Most livestock (and wildlife) depend on rangelands for grazing. Some weeds, such as larkspurs and 

locoweeds, are toxic when grazed (DiTomaso 2000). Due to their low palatability or toxicity, weeds can also 
Final Supplemental Environmental Impact Statement

147

reduce the forage available to livestock if extensive populations exist. Particularly troublesome are knapweeds 

because they are low in palatability and readily invade both disturbed and undisturbed sites (DiTomaso 2000). 

Downy brome (cheatgrass) is the most dominant weed in the West. Though it can be used as forage, in some 

years it only provides 10 percent of productivity of the perennial species it replaced (McHenry and Murphy 

1985). 

Effects of Livestock on the Spread of Weeds

Domestic livestock, particularly sheep, cattle, and horses, have grazed in the project area for over 200 years. 

Livestock grazing over an extended period of time greatly changes the plant composition from the original 

ecosystems and can result in the presence of weeds (Endress et al. 2012, Murphy 1986). LeJeune (2001) 

describes how weeds are more successful competitors when nitrogen in soils is present, a situation chronic 

livestock grazing (along with fire suppression) has enhanced. 

In the project area, the extent to which domestic livestock grazing has caused the spread of weeds is not 

known. Because the acreages of weeds in the project area are low, it can be assumed grazing management on 

the two national forests has been effective (for example, preventing severe overgrazing) at controlling the 

establishment and spread of weeds. Stipulations in grazing permits, such as not being allowed to feed hay on 

National Forest System lands, have likely prevented new weed populations from establishing.

The next two tables show the livestock grazing allotments administered by each national forest and the acres 

of known weed infestations in each allotment.

Table S-59. Grazing allotments with known weed infestations on the Carson National Forest

Name of Allotment

Size of Allotment 

(acres)

Acres with Weed 

Infestation*

Percent of Allotment 

Infested with Weeds

(nearest percent)

Angostura 17,716 0 0

Arroyo Hondo 18,974 2 0

Bancos 16,526 12 0

Black Copper / Red River 10,418 2 0

Black Lakes 12,038 0 0

Bobcat 6,284 3 0

Cabresto 26,907 256 1

Capulin 13,745 0 0

Carracas 32,554 331 1

Carson-Mojino 7,615 8 0

Columbine 9,016 1 0

Deer Creek Complex 5,379 1 0

East Piñon 3,051 1 0

El Rito Lobato 95,948 376 0

English 8,234 0 0

Flechado 6,365 1 0

Goose Creek 6,568 2 0

Jarita Mesa 63,676 5 0

La Cal 5,148 0 0

La Lama 15,628 8 0

Laguna Seca 29,122 31 0

Lakefork Baldy 8,271 19 0

Main Fork 4,191 2 0
Invasive Plant Control Project

148

Name of Allotment

Size of Allotment 

(acres)

Acres with Weed 

Infestation*

Percent of Allotment 

Infested with Weeds

(nearest percent)

Mesa 9,578 1 0

Midnight/Mallette 24,859 43 0

Miranda 8,069 30 0

Mogote 16,594 0 0

Olla-Ranchos 68,035 148 0

Private Land 61,214 24 0

Recreational 266 0 0

Red River 22,006 14 0

Rio Chiquito 29,129 6 0

Rio Pueblo 33,967 5 0

Rito Segundo 8,594 5 0

San Antone 41,843 13 0

San Antonio Mountain 7,478 0 0

San Cristobal 21,368 10 0

San Gabriel 3,969 1 0

Santa Barbara 34,235 39 0

Santos 8,800 5 0

Sawmill Park 2,055 1 0

Servilleta 10,263 2 0

Ski Area 1,167 0 0

Spring Creek 25,086 21 0

Sublette 10,940 0 0

TCLP 40,227 7 0

Tio Gordito 27,998 8 0

Tio Grande 31,986 32 0

Trampas 27,549 1 0

Tusas 43,641 0 0

Valencia 20,933 41 0

Valle Vidal 101,293 1,515 1

Vaqueros 31,818 175 1

* A zero means that less than 1 acre is infested with weed(s).

Table S-60. Grazing allotments with known weed infestations on the Santa Fe National Forest

Name of Allotment

Size of Allotment

(acres)

Acres with Weed 

Infestation*

Percent of Allotment 

Infested with Weeds

(nearest percent)

Alamo 22,478 227 1

Aspen Mountain 17,372 53 0

Barbero 19,185 362 2

Bear Lake 41,446 1 0

Bear Springs 2,301 0 0

Bland Canyon 8,814 0 0

Bull Creek 14,636 4 0

Caja del Rio 66,873 50 0

Capulin 7,214 230 3
Final Supplemental Environmental Impact Statement

149

Name of Allotment

Size of Allotment

(acres)

Acres with Weed 

Infestation*

Percent of Allotment 

Infested with Weeds

(nearest percent)

Cebolla / San Antonio 26,171 11 0

Chama 40,423 330 1

Chicoma 2,899 0 0

Chiquito 13,185 23 0

Colonias 24,073 45 0

Coyote 21,607 313 1

Cuba Mesa 7,374 96 1

Del Norte 7,890 4 0

Dome 3,426 1 0

El Cielo 12,175 4 0

El Invierno 45,695 114 0

El Pueblo 26,753 1 0

French Mesa 25,203 187 1

Gabaldon 8,571 46 1

Gallina Mountain 11,188 8 0

Gallina River 22,409 1,135 5

Glorieta 35,164 19 0

Gurule 8,361 1 0

Horse Thief 20,538 0 0

Jarosa 23,369 911 4

La Jara 17,549 104 1

La Presa 11,385 133 1

Las Conchas 1,396 2 0

Llaves 11,423 92 1

Los Indios 7,617 131 2

Macho 38,257 186 0

Mesa Alta 37,243 720 2

Mesa de las Viejas 20,942 2 0

Mesa del Medio 17,331 242 1

Mesa Poleo 25,972 530 2

Ojito Frio 10,603 45 0

Ojitos 18,527 29 0

Oso Vallecitos 44,991 6 0

Palomas 5,282 2 0

Penas Negras 16,734 69 0

Peralta 12,882 7 0

Pine Springs 30,949 5 0

Pollywog 20,845 64 0

Polvadera 21,027 16 0

Private land 29,566 2 0

Quemado 24,373 67 0

Recreational 4,106 260 6

Red Top 9,927 22 0

Rio de la Casa 17,882 18 0

Rosilla 18,763 46 0
Invasive Plant Control Project

150

Name of Allotment

Size of Allotment

(acres)

Acres with Weed 

Infestation*

Percent of Allotment 

Infested with Weeds

(nearest percent)

San Diego 102,739 984 1

San Jose 13,775 0 0

San Luis 39,730 249 1

San Miguel 21,916 176 1

San Pedro 21,634 53 0

Santa Fe Watershed 24,458 44 0

Sapello 6,601 0 0

Senorito 21,672 143 1

Sierra Mosca 44,531 3 0

Simon 12,506 4 0

Soldier Creek 15,883 98 1

South Ojitos 9,712 42 0

Springs 29,789 153 1

Tecolote 11,082 78 1

Vacas 8,034 46 1

Valle Osha 8,967 0 0

Vallecitos 16,255 272 2

V-Double Slash 37,408 39 0

Youngsville 31,729 659 2

* A zero means that less than 1 acre is infested with weeds.

Between 0 and 2 percent of most allotments are infested with weeds. The two largest acreages of infestations 

are on the Valle Vidal and the Gallina River allotments. The acreage of weeds on the Valle Vidal allotment 

reflects the effects of the 2002 Ponil Fire because weeds tend to colonize disturbed areas. Bull thistle became 

established primarily along drainages and at the base of burned evergreens within the high-intensity burned 

areas. In the San Diego allotment, the majority of the weeds consists of saltcedar along the Jemez River. 

Permitted livestock grazing has not been allowed along the lower Jemez River area since 1980. Prior to that 

time, much of it was privately owned. Since then, it has been designated as a national recreation area and 

several recreation sites have been developed.

Table S-61 shows the wild horse and burro territories in the project area. Two territories (Jarita Mesa and 

Jicarilla) are occupied. These overlap with cattle grazing allotments, so the acres of weeds present are counted 

in Table S-59 and Table S-60. 
Final Supplemental Environmental Impact Statement

151

Table S-61. Wild horse territories

National 

Forest

Name of Wild Horse 

or Burro Territory Acres

Acres with Weeds

(known as of 

Aug. 1, 2013)

Overlaps with Cattle 

Grazing Allotment(S) 

Listed Here

Carson Jicarilla 75,000 598 Carracas

Cabrestos

Bancos

Yso/Montosa 21,579 0.08 Canjilon

Mogote

Mesa De Las Viejas 20,942 2 Gallina Mountain

Rio Chama

Jarita Mesa 54,866 5 Jarita Mesa

Santa Fe Caja del Rio 12,500 0 Caja del Rio

Cochiti Pueblo (Tribal)

Chicoma 2,899 0 Chicoma

Oso Vallecitos

Dome 3,426 0.8 Alamo

San Diego 2,274 0 San Diego

Environmental Consequences to and from Livestock Grazing

Alternative A 

Effects of Weeds on Livestock

The acreage of weeds currently present in the allotments is low which means forage availability is high, and 

the risk of livestock poisoning is low. Without treatment, weeds would continue to displace palatable native 

vegetation and reduce forage. This is likely to take many years and should not be an immediate concern to 

permittees, but it should be a long-term concern. Weeds are persistent once established. Should weeds become 

the dominant plants on the allotments, they would be extremely difficult and expensive to remove (Frid et al. 

2013). 

Effects of Treatments on Livestock

Under the no-action alternative, there would be no risk of negative effects from treatments because they 

would not occur.

Effects of Livestock on the Spread of Weeds

There would be no change from what is described in the affected environment because this project does not 

propose to alter grazing practices. 

Alternatives B and D 

Effects of Weeds on Livestock

Presently, the amount and species of weeds on the two national forests have not reduced the amount of forage 

available for domestic livestock because the weeds compose a small percentage of the available forage on the 

allotments. Thus, the effect of alternatives B and D would be to prevent such a loss from occurring. Under 

alternatives B and D, the Forest Service expects to have controlled or eradicated the weed populations within 

a decade. This means native vegetation would be restored or promoted, resulting in long-term beneficial 

effects on the allotments. There would be increases in density and vigor of native and desired forage grasses 

within proposed treatment areas (See “Vegetation Resources” section for more detail). There would be

beneficial effects on soil and water resources that are important in maintaining quality rangeland conditions 

(See “Water Resources” and “Soil Resources” sections for more detail). 
Invasive Plant Control Project

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Because alternatives B and D would control or eradicate the weeds toxic to domestic livestock, there would 

be a reduction in the risk of toxic effects to cattle from ingesting weeds. The two national forests are not 

currently at a level of infestation where weeds are displacing grazing opportunities except in very small, 

localized situations. Over the long term, control measures taken now would avoid more significant impacts in 

the future.

Effects of Treatments on Livestock

No effects from treatments to livestock are expected to occur because the project design includes working 

with livestock permittees on the treatment schedule. It is anticipated permittees would manage their livestock 

so as to avoid potential effects.

Effects of Livestock on the Spread of Weeds

There would be no change from what is described in the affected environment because this project does not 

propose to alter grazing practices.

Alternative C–No Herbicides

Effects of Weeds on Livestock

Alternative C would result in the same type of beneficial effects as alternatives B and D but to a lesser extent. 

Because the effectiveness of alternative C in eradicating or controlling weed establishment and spread is 

expected to be less than with alternatives using herbicides, this alternative would not realize the same level of 

benefit as quickly. The risk to livestock from ingesting poisonous weeds would be less than in the no-action 

alternative but more than in alternatives B or D for the reason stated above.

Effects of Treatments on Livestock

No effects from treatments to livestock are expected to occur, because the project design includes working 

with livestock permittees as to the treatment schedule. It is anticipated permittees would manage their 

livestock so as to avoid potential effects.

Effects of Livestock on the Spread of Weeds

There would be no change from what is described in the affected environment because this project does not 

propose to alter grazing practices. 

Cumulative Effects

Effects of Weeds on Livestock

The direct and indirect effect of all the alternatives on the availability of forage is negligible; at present, weeds 

compose 2 percent or less of most of the allotments. Because the effect of the alternatives is negligible 

(immeasurable), there would be no cumulative effects.

Effects of Treatments on Livestock

Since there would be no direct or indirect effects to livestock from treatments due to the design of the project, 

there would be no cumulative effects.

Effects of Livestock on the Spread of Weeds

There would be no change from what is described in the affected environment because this project does not 

propose to alter grazing practices. Thus, there would be no cumulative effects.
Final Supplemental Environmental Impact Statement

153

Effects of Forest Plan Amendment to Livestock Grazing

The proposed plan amendment would have no effect on livestock grazing in the future because the restrictions 

imposed for herbicide use would not alter or affect grazing practices. Any effects from herbicide treatments in 

the future with the amendment in place would have the same effects as described in this section.

Social-Economic Resources

[Replaces entire section]

Issues Analyzed

From the comments made during scoping and notice and comment, the interdisciplinary team identified the 

following social issues to analyze in detail.

1. The proposed action may have a disproportionately high and adverse impact on the health of minority or 

low-income populations. This type of analysis is called “environmental justice” (Office of the President 

1994). This issue did not result in the creation of a new alternative.

a. Weed treatment activities have the potential to affect human health and safety in a number of ways, 

including exposure to machinery, equipment, or chemicals. Although exposure to machinery and 

equipment poses a safety risk, the larger public concern relates to the health risk posed by using 

herbicides. This risk is defined three ways:

i. By direct exposure during application.

ii. By contact with vegetation that has been sprayed and then collected for use.

iii. By direct or indirect exposure for people with heightened chemical sensitivities.9

This issue resulted in the development of alternative C, which does not include herbicide use.

b. On weed infestation sites where nonchemical methods are proposed for use without supplemental 

herbicides, weed control effectiveness would be lower and treatment costs higher.10 This issue did not 

result in the creation of a new alternative.

Analysis Area

The analysis area for this project includes the eight counties in which the Carson and Santa Fe National 

Forests are located: Colfax, Los Alamos, Mora, Rio Arriba, San Miguel, Sandoval, Santa Fe, and Taos 

Counties. The people living in these counties are the most likely to be affected by the project. 

Affected Environment for Low Income and Minority Populations

The issue analyzed here is “the proposed action may have a disproportionately high and adverse impact on the 

health of minority or low-income populations.”

Measure 

The measure is quantification of minority and low-income populations in the study area and comparison of 

potential impacts to health and the environment. 

Rationale 

Executive Order 12898 requires all Federal agencies to analyze, and if necessary, address high and adverse 

human health or environmental effects of their actions and policies to minority and low-income populations.

 9 Refer to page 33 of the FEIS for the complete wording of this issue.

10 Refer to page 34 of the FEIS for the complete wording of this issue.
Invasive Plant Control Project

154

Assumptions

• A population is considered a minority population if (a) the minority population of the affected area 

exceeds 50 percent or (b) the minority population percentage of the affected area is meaningfully greater 

than the minority population percentage in the general population or other appropriate unit of geographic 

analysis (Council on Environmental Quality (CEQ) 1997). 

• Minority populations and low-income groups are identified at the county level because this unit of 

measure does not artificially dilute or inflate the affected minority population, pursuant to the 1997 

guidance provided by the Council on Environmental Quality.

• Low-income populations are identified using the annual statistical poverty thresholds from the 2010 

census. The Census Bureau shows this data as a percent of the total population at different scales, shown 

below at the State and County levels.

• This analysis addresses the risks from exposure to herbicides of the general public. People employed by 

the Forest Service to treat weeds would be required to follow all safety regulations and the mitigation

measures listed in Table S-10 and Table S-11. Following these precautions would reduce the risk to 

workers to a negligible amount.

Methods

Minority and low-income populations within the project area were identified using 2010 census data at the 

individual county levels. Tribes were included with the census bureau’s data on the counties. 

Results

The 2012 population of the study area is estimated to be 420,038 people. Table S-62 shows the percentages 

broken down by ethnicity and race.

Table S-62. Ethnicity and race at the county scale (all figures are percentages)

Area

Ethnicity Race

Hispanic

NonHispanicNative 

American White

All Other 

Races

Colfax County 48.2 48.6 2.3 94.3 3.4

Los Alamos County 15.6 75.0 1.0 89.7 9.3

Mora County 80.6* 18.1 2.9 94.2 2.8

Rio Arriba County 71.3* 13.3 18.0* 78.5 3.5

Sandoval County 36.3 46.6 13.4* 79.6 7.1

Santa Fe County 50.9* 43.7 3.9 91.4 4.7

San Miguel County 76.9* 19.6 2.8 92.4 4.8

Taos County 56.2* 36.1 7.2 88.4 4.4

* These represent minority populations according to the Council on Environmental Quality guidance.

Based on the information above, racial and ethnic minority populations exist within the analysis area: 

• The Hispanic populations in Mora, Rio Arriba, Santa Fe, San Miguel, and Taos Counties

• The Native American population in Sandoval and Rio Arriba Counties
Final Supplemental Environmental Impact Statement

155

Table S-63. Percent of population below the Federal poverty level by county (all figures are percentages)

Area Percent of Population in 

Poverty, 2007 to 2011 

New Mexico 19.0

Colfax County 18.7

Los Alamos County 3.7

Mora County 16.3

Rio Arriba County 19.2*

Sandoval County 12.4

Santa Fe County 15.6

San Miguel County 26.2*

Taos County 21.5*

These represent low-income populations according to the Council on Environmental Quality guidance.

Those counties that show a greater percentage of the population below poverty than the state level are 

considered low-income populations. Based on the 2010 census data, low-income populations exist in the 

analysis area in Rio Arriba, San Miguel, and Taos Counties.

People from rural communities use the two national forests for recreation, traditional purposes, livestock 

grazing, fuelwood collection, and other activities. Fuelwood is essential to many residents in the area. 

Commercial and individual use of posts, poles, and vigas is extensive. The majority of permittees grazing 

livestock on the two national forests are residents of the small Hispanic or Native American communities. The 

national forests contribute substantial employment in these communities through firefighting, timber crews, 

and rangeland work. Native Americans and Hispanics, in particular, gather plants, animals, wood products, 

and clay on the two national forests for religious purposes.

Most rural communities in the area rely on the Carson and Santa Fe National Forests to augment their 

incomes or for self-sufficiency. Special forest products and small commercial ventures contribute toward 

household livelihoods in northern New Mexico. These communities have established a cultural value of 

stewardship through many generations of interactions with the natural resources in the area. Quite often it is 

imperative for these residents to have a hands-on relationship with the forest that has sustained them for 

generations, as it is part of their cultural identity. These communities maintain a certain degree of selfsufficiency by meeting many of their own needs through self, family, and friends. Sustainability of the land 

and its resources is a common need.

The primary influences on the local economy are recreation and tourism (service sector), and agriculture 

(ranching, small produce farming, and miscellaneous forest products). Many of the residents commute to 

larger commercial centers for employment opportunities in manufacturing, construction, retail, and 

government sectors.

Environmental Consequences to Low Income and Minority Populations

Direct and Indirect Effects to Human Health 

When determining whether human health effects are disproportionately high or adverse, the Council on 

Environmental Quality instructs agencies to consider the following three factors to the extent practicable 

(CEQ 1997):

(a) Whether the health effects, which may be measured in risks and rates, are significant (as employed 

by NEPA), or above generally accepted norms. Adverse health effects may include bodily impairment, 

infirmity, illness, or death; and
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156

(b) Whether the risk or rate of hazard exposure by a minority population, low-income population, or 

Indian tribe to an environmental hazard is significant (as employed by NEPA) and appreciably exceeds 

or is likely to appreciably exceed the risk or rate to the general population or other appropriate 

comparison group; and

(c) Whether health effects occur in a minority population, low-income population, or Indian tribe 

affected by cumulative or multiple adverse exposures from environmental hazards.

Alternative A

Under the no-action alternative, no weed treatments would occur; thus, there would be no human health 

effects to any population in the analysis area. 

Alternatives B and D

There would not be a disproportionately high and adverse effect on minority or low-income populations under 

these alternatives. Because of the design features listed in Table S-11 when using herbicides, the risks of 

exposure to the general public would be negligible. The minority and low-income populations, being tied to 

the land and tending to use the land for economic benefit and subsistence uses, could have a higher rate of 

exposure than the general population. An actual exposure to hazardous chemicals, however, is highly unlikely 

because of the design features listed in Table S-11. 

For example:

• The Forest Service will provide public information about using herbicides, including the herbicide to be 

used, locations, and application schedules using signs, public notices, and other means.

• Treatments will be coordinated with range allotment permittees.

• In areas used by people (human habitation, recreational sites, traditional plant collections), only 

herbicides rated as having the lowest risk of harmful effects to humans would be allowed.

Alternative C–No Herbicides

There would not be a disproportionately high and adverse effect on minority or low-income populations under 

this alternative because no herbicides would be used.

Cumulative Effects to Low-Income and Minority Populations

None of the alternatives would cause a disproportionately high and adverse effect on minority or low-income 

populations; therefore, there would be no cumulative effects. 

Affected Environment for Human Health and Safety

The issue analyzed here is “Weed treatment activities have the potential to affect human health and safety in a 

number of ways, including exposure to machinery, equipment, or chemicals. Although exposure to machinery 

and equipment poses a safety risk, the larger public concern relates to the health risk posed by using 

herbicides. This risk is defined three ways:

1. By direct exposure during application.

2. By contact with vegetation that has been sprayed and then collected for use.

3. By direct or indirect exposure for people with heightened chemical sensitivities.”

Measures

• Risk of exposure by application method 

• Potential length of exposure 
Final Supplemental Environmental Impact Statement

157

• Potential routes of exposure

• Toxicity of herbicides proposed for use

Rationale

Inherent to having confidence in the conclusions in this section is an understanding of what a reference dose 

is, how safe it is, and how it is determined. The U.S. Environmental Protection Agency develops reference 

doses for chemicals, including the herbicides proposed for use by the Forest Service. A reference dose is 

defined by the Environmental Protection Agency (1989) as an estimate of a daily dose over a 70-year life span 

a human can receive without an appreciable risk of deleterious effects. A reference dose is determined by 

subjecting animals to substances and determining the lowest observable effect level and the no observable 

effect level from the entire body of scientifically supportable studies performed for that substance. The no 

observable effect level represents the dose the Environmental Protection Agency believes would not result in 

an effect. Reference doses are calculated by dividing the no observable effect level, a level or dose already 

thought to not cause an effect, by a safety factor, usually 100, to account for extrapolation of animal data to 

humans and sensitive individuals. Therefore, the reference dose for a chemical is a dose at least 100 times 

lower than that shown to have an effect in any animal study performed with the subject chemical. 

Toxicological studies using animals typically involve a purposeful exposure to dosages high enough to cause 

an effect. The causal dose in toxicological studies is significantly greater than what a worker would be 

exposed to while applying herbicides or what the public may be exposed to walking through a treated field or 

living adjacent to treated land. Herbicide applicators and the general public are clothed and do not purposely 

ingest herbicides under the same conditions as animals in studies of toxicological significance.

Assumptions

• Workers applying herbicides are at a higher risk of exposure than the general public because they will be 

in more regular contact with herbicides. The maximum duration of exposure for workers on a yearly basis 

was estimated in the range of 10 to 40 days for commercial applicators (U.S. EPA 1995). This is far less 

than that used to establish reference doses, which assumes a daily exposure for 70 years.

• Workers will follow the instructions, application rates, and safety precautions on the labels of the 

herbicide.

• The public will avoid areas being treated with herbicides due to the Forest Service’s notification 

procedures (Table S-10 and Table S-11), such as signs and posting on the national forest websites.

• Safe re-entry in areas where herbicides have been applied is when the herbicide has dried on the leaf 

surface.

• The mitigations built into the project will prevent people from ingesting herbicides (Table S-11, rows 2, 

10-14, 54-55, 58).

• Chemically-sensitive individuals are generally aware of their sensitivities and would not be allowed to 

work on herbicide crews. They would not enter treated areas until either safe re-entry periods or a period 

they feel is adequate based on their personal knowledge of their sensitivity, has passed. 

♦ A small percentage of the population has a hypersensitivity to a wide variety of chemicals, including 

perfumes, household cleaners, construction products, industrial chemicals, and the herbicides 

proposed for use in this project (Gibson 2000, Barrett and Gots 1998). A 1997 New Mexico 

behavioral risk factor survey completed by the New Mexico Department of Health’s Office of 

Epidemiology indicated 2 to 3 percent of those responding to the survey instrument were chemically 

sensitive, with up to 16 percent of the New Mexico population possibly sensitive (Vorhees 1997).

♦ It is unknown what percent of this population frequents the Carson and Santa Fe National Forests.
Invasive Plant Control Project

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Methods

For a negative effect to human health to occur from an herbicide, a person must be exposed to it. The risk of 

exposure from herbicides was analyzed by reviewing the following scientific literature: 

• “The Risk Assessment for Herbicide Use in Forest Service Regions (RAHUFS) 1, 2, 3, 4 and 10 and on 

Bonneville Power Administration Sites” (USDA Forest Service 1992). This analysis was developed for 

the Forest Service specifically to address human health issues raised by the use of herbicides.

• “Assessing the Safety of Herbicides for Vegetation Management in the Missoula Valley Region: A 

Question and Answer Guide to Human Health Issues” (Felsot 2001).

• Risk assessments completed by the Forest Service under contract with Syracuse Environmental Research 

Associates for the chemicals proposed for use: 2,4-D, aminopyralid, picloram, clopyralid, dicamba, 

hexazinone, sulfometuron methyl, metsulfuron methyl, triclopyr, imazapic, and imazapyr (USDA Forest 

Service 1995d, 1996c, 1996d, 1997c, 1998b, 1998c, 1999b-d, 2002, 2001; SERA 2002-2007).

The risk assessments consist of three things: (1) a review of toxicity test data (acute, chronic, and subchronic) 

for the herbicides to determine dosage that could pose a risk to human health; (2) an estimate of exposure 

levels to which workers and the general public could be exposed during treatment operations; and (3) 

comparison of dose levels to toxicological thresholds developed by the Environmental Protection Agency to 

determine potential health risks.

The Forest Service has developed additional protection measures, found in Table S-10 and Table S-11, to 

further reduce the risk of exposure. The end result is the Forest Service’s application of herbicides exceeds the 

safety requirements and mitigations required by the Environmental Protection Agency.

Results

Method of Application

The risk assessments compared risks of exposure to workers from backpack, ground-mechanical, and hand 

application. 

The drift that can occur when spraying herbicides is a way people can become unintentionally exposed. Spray 

drift is when the herbicide is picked up by wind after leaving the nozzle and carried away from the intended 

treatment area. Spray drift is primarily a function of droplet size, release height, and wind speed (Teske and 

Thistle 1999). 

Wind speed increases the number of droplets leaving the treated area if the wind is blowing away from the 

release point. If the wind is favorable (blowing into the treatment area), drift is reduced. Studies have shown 

over 90 percent of droplets land in the target area, 10 percent or less move off-target, and the droplets that 

move off-target most typically deposit within 100 feet of the target area (Felsot 2001, Yates et al. 1978, 

Robinson and Fox 1978, Teske and Thistle 1999). 

Length of Exposure

The magnitude of a hazardous dose comes in three forms: (1) a single dose occurring at once (acute 

exposure); (2) multiple doses over longer periods (chronic exposure); or, (3) regularly repeated doses over 

periods ranging from several days to months (subchronic exposure). As described in the “Rationale” section, 

the Environmental Protection Agency describes exposure in terms of reference doses to determine potential 

hazards of herbicides to humans.

The reference dose for each herbicide in this project serves as a conservative toxicological threshold for two 

reasons. First, the reference dose assumes daily exposure over 70 years. Second, the reference dose is 

calculated from the no observed effect level that assumes humans are 100 times more sensitive than animals. 
Final Supplemental Environmental Impact Statement

159

Route of Exposure

Ingestion

Another measure for toxicity is LD50 (where LD stands for “lethal dose”). LD50 levels exist for oral, dermal, 

and inhalation exposure. LD50 is the dose that kills 50 percent of a test population, measured in one milligram 

of herbicide per kilogram of animal weight (U.S. EPA 1996a, 1996b). To arrive at LD50s in a laboratory 

setting, high doses of herbicides are given to animals orally, dermally, or by inhalation (U.S. EPA 1996c). 

These doses are much higher, by orders of magnitude, than any worker or member of the public would be

exposed to during this project. Ingestion is the least likely route of exposure; the design features discouraging 

people (Table S-11, rows 2, 10-14, 54-55, 58) from going into areas while an herbicide is still wet means the 

public will have no chance of exposure, even if collecting plants. Since people are not likely to ingest 

herbicides, there will be no effect from ingestion. Therefore, this route of exposure will not be discussed 

further.

Dermal Absorption

Studies show that human skin acts as a protective barrier that limits the amount of a chemical that passes into 

the body; only about 10 percent or less of the chemical passes through the skin to the bloodstream. In 

contrast, absorption of chemicals from the small intestine (oral ingestion) is quicker and more complete than 

from the skin (Ross et al. 2000). For this reason, a dermal LD50 is usually much higher than an oral LD50. This 

means that a person can tolerate greater doses of a substance without becoming sick when exposure is through 

skin contact rather than through ingestion (Hayes 1991).

Inhalation

Inhalation of chemicals causes illness more quickly than by oral or dermal contact due to the rapid entry of 

the substance into the blood stream. Studies of pesticide applicators, however, show dermal exposures are 

greater than inhalation exposures (Ross et al. 2000). 

Toxicity of Herbicides

A comparison of toxicity for the herbicides proposed for use is shown in Table S-64. 

Endocrine Disruption

Chemicals can interact with components of the endocrine system. Scientists have discovered that many kinds 

of chemicals, including natural food biochemicals as well as industrial chemicals and a few pesticides, can 

mimic the action of the hormones estrogen or testosterone. Concern has also been expressed about potential 

effects on the thyroid hormone during early development (Felsot 2001).

Environmental Consequences to Human Health and Safety

Effects from prescribed burning are analyzed in the “Air Quality” section of this report.

Direct and Indirect Effects of Alternative A

There would be no impacts to human health and safety from any proposed treatment because treatments

would not occur. 

The effect of continued weed spread on human health, such as allergies, would remain; however, this effect is 

likely very small given the size of the weed populations in relation to the project area. Known weed 

populations occupy approximately 0.5 percent of the 3 million acres in the project area. People suffering from 

allergies are far more likely to be affected by juniper pollen, for example, since juniper trees are common in 

the national forests. Nonetheless, approximately 10 to 15 percent of the United States population suffers from 

allergy symptoms from weed species such as knapweed. Knapweed pollen is a common and powerful allergen 

that peaks in August and produces strong allergy symptoms. Knapweed pollen has been implicated in causing 
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160

allergic rhinitis (Gillespie and Hedstrom 1979). Allergies to airborne seeds may also complicate or trigger 

asthma that may take up to 2 years to get completely under control. 

Table S-64. Comparison of the toxicity of herbicides proposed for use

Herbicide

Carcinogenic1

Estimated 

Exposure 

to Public2

Estimated 

Exposure to 

Worker2

Reference 

Dose

(mg/kg/day)

Mutagenic and 

Reproductive3

Acute Oral 

LD50 for Rats 

(mg/kg/day)

Aminopyralid E < RfD < RfD 0.5 No > 5,000

2,4-D D < RfD < RfD8 0.01 No 100 - 1,800

Chlorsulfuron E < RfD < RfD 0.05 No > 5,000

Clopyralid E < RfD < RfD 0.5 No 2,675 - 5,000

Dicamba D < RfD < RfD 0.03 No 757 - 1,701

Glyphosate E < RfD < RfD 0.1 No 2,000-6,000

Hexazinone D < RfD below to slightly 

above RfD7

0.03/0.054 No 1,690

Imazapic E < RfD < RfD 0.05 No 5,000

Imazapyr E < RfD < RfD 2.55 No > 5,000

Metsulfuron 

methyl

E < RfD < RfD 0.25 No to slight > 5,000

Picloram E < RfD < RfD6 0.2 No 3,000-5,000

Sulfometuron 

methyl

E < RfD < RfD 0.025 No > 5,000

Triclopyr E < RfD < RfD 0.005 No to slight 630 - 729

RfD = Reference dose; units expressed as milligrams of herbicide per kilogram of body weight 

LD50 = lethal dose in milligrams of herbicide per kilogram of body weight

1. Environmental Protection Agency carcinogenicity classification based on daily consumption for 70 years. D = Not classifiable as to 

human carcinogenicity; E = Evidence of non-carcinogenicity

2. Exposures under typical exposure scenarios. Accidental and extreme exposure scenarios may exceed the reference dose.

3. Unlikely the compound is mutagenic or would pose a mutagenic risk to humans at expected exposure levels. 

4. Two reference doses reported.

5. Provisional reference dose, the Environmental Protection Agency has not derived a reference dose for this compound.

6. USFS (1999b) reports workers wearing contaminated glove may receive an absorbed dose greater than the reference dose. The 

design features in Chapter 2 would prevent this scenario from occurring.

7. USDA Forest Service (1997a) reports over a range of plausible application rates, workers may be exposed to hexazinone at levels that 

exceed the reference dose.

8. USDA Forest Service (1998) reports workers involved in ground application of 2,4-D may be exposed to levels above the reference 

dose if effective methods to protect workers and minimize exposure are not employed. The design features in chapter 2 would 

prevent this scenario from occurring.

Cumulative Effects of Alternative A

The effect on human health under this alternative is aggravated allergies. This risk is considered too small to 

be measurable; thus, there would be no cumulative effects from the no-action alternative. 

Direct and Indirect Effects of Alternatives B and C

Biological Treatments 

Biological treatments would result in no known risks to human health because the biological control method 

is designed to target specific plants. No health effects to people have been documented from this method.

Managed Grazing

Managed grazing would result in no known risks to human health and safety. Humans have grazed livestock 

in the national forests for over 100 years without any documented, significant health effects.
Final Supplemental Environmental Impact Statement

161

Manual Treatments

Risks to worker’s health from manual methods are considered minor. The use of personal protective 

equipment like gloves, long sleeved shirts, and boots would prevent most skin irritations (such as cuts or 

blisters) from occurring. Rarer conditions can be triggered; for example, leafy spurge contains a latex-bearing 

sap that irritates human skin and may (rarely) cause blindness in humans upon contact with the eye (Callihan 

et al. 1991). There have also been claims (not medically supported) that hand-pulling knapweed may result in 

the formation of tumors on the hands. The risk of injury from repetitive motion and back and knee strain 

exists but would be no greater than any other physical labor normally performed by Forest Service 

employees. Workers with allergies to weeds would suffer the most from this method.

Because the public would not be treating weeds, there would be no effects from manual methods. 

Mechanical Treatments

Potential risks to human health from mechanical weed control methods are considered low. Mechanical 

methods, such as mowing or root tilling, are commonly used throughout the world. As a result, the mitigations 

to lesson risk (such as wearing hard hats, safety glasses, and ear protection) are well established and proven to 

work. A risk of physical injury due to accidents exists.

Because the public would not be treating weeds and would not be permitted entry when heavy equipment is 

operating, there would be no effects from mechanical methods. 

Direct and Indirect Effects of Alternatives B and D

Herbicides

Method of Application

Since the public will not be applying herbicides, their risk of exposure by any application method proposed in 

this project is zero.

Following the design features requiring the use of personal protective equipment, application rates, and the 

weather conditions means that a worker’s risk of exposure to herbicides would be negligible. The risk 

assessments prepared for this project show that ground-mechanical application resulted in a lower risk of 

exposure than other methods, even though the total amount of herbicide applied in a given day was higher. 

Risks from backpack and hand application have the highest risk of exposure because workers are closer to the 

nozzle and to the containers from which the herbicides are sprayed. Backpack and hand application were also 

reported to increase the likelihood of a worker receiving repeated exposures that may remain on the worker's 

skin for an extended time period. Training in the application of herbicides and use of appropriate personal 

protective equipment will minimize this risk.

Drift – Because the public would stay out of or be restricted from entering areas during herbicide application, 

no exposure to spray drift would occur. Further, the spray drift analysis (see page 158) shows the risk of 

exposure to the public from ground methods is low (USDA Forest Service 1992). The study defines low risk 

as less than one-in-a-million chance of developing systemic problems, reproductive problems, or cancer.

The risk of exposure to workers from drift would be less than the Environmental Protection Agency’s 

reference dose. Felsot (2001) used a model called AGDRIFT I to simulate herbicide sprays for several 

scenarios, including a truck mounted spray boom set at two heights. His study showed that a child (who 

would be more susceptible to harm because of lower body weight) standing 27 feet from the sprayed edge 

would not receive a dose greater than the Environmental Protection Agency’s reference dose. 
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162

Length of Exposure

Acute Toxicity – The exposure to the public or workers to herbicides would be far less than the 

Environmental Protection Agency’s reference dose. Where the reference dose assumes a daily exposure for 70 

years, workers (who would have more exposure than the public) would be exposed 10 to 40 days per year. 

Thus, the risk of acute exposure is zero for either workers or the general public. This conclusion is supported 

by various studies estimating the exposure to workers and the public under scenarios more conservative that 

what would actually occur in this project (USDA Forest Service 1995; 1996a; 1997a-c; 1998; 1998d; 1999c; 

1999d; 2000; 2001). The most reasonable interpretation of the risks associated with application of herbicides 

on national forest lands is that, except for accidental exposures or extremely atypical or implausible scenarios 

(that is, acute direct spray entirely covering a naked child), use of herbicides on National Forest System lands 

would not pose an identifiable risk to workers or the general public.

Subchronic and Chronic Toxicity – The likelihood of chronic or subchronic exposure to the public to 

herbicides is zero, based on the assumption that the public would avoid, or be restricted from, entering places 

where herbicides are being applied. The likelihood of a member of the public being repeatedly exposed to 

herbicides above the reference dose is nearly zero.

Workers, who are expected to apply herbicides for 10 to 40 days per year for up to 10 years, would still have 

an exposure less than the Environmental Protection Agency’s reference dose (daily exposure for 70 years). 

The mitigations built into this project would further reduce a worker’s risk of exposure. As noted in Table S64, two exceptions exist. A Forest Service research project (1997d) reports that over a range of plausible 

application rates, workers may be exposed to hexazinone at levels that exceed the reference dose. Likewise, 

there is reasonable concern that workers applying triclopyr over a prolonged period of time in the course of a 

single season and/or several seasons may be at risk of impaired kidney function (USDA Forest Service 

1996d). 

Route of Exposure

Dermal Absorption – The likelihood of a member of the public absorbing an herbicide through their skin is 

virtually zero. The mitigations are designed to inform the public of treatments, or restrict them from entering 

treated areas until the herbicide is absorbed by the plant. The likelihood of a member of the public being 

repeatedly exposed to herbicides through their skin above the reference dose is nearly zero.

Required personal protective equipment used by workers during pesticide application (gloves, waterproof 

boots, etc.) is designed to reduce exposure to sensitive areas on the body. Use of personal protective 

equipment is required by the Forest Service and would reduce the chance of dermal absorption. The use of 

personal protective equipment, combined with the fact that workers would be exposed only 10 to 40 days per 

year, means a worker’s exposure would be less than the LD50.

Inhalation – Studies show the risk of dermal exposure is higher than the risk of inhalation. Since the risk of 

dermal exposure is below the LD50, the risk of inhalation would be as well.

Toxicity of Herbicides

Controlled studies suggest nearly all of the herbicides proposed for use by the Forest Service are not 

carcinogenic. Recently, the International Agency for Research on Cancer of the World Health Organization 

has designated glyphosate as a “probable” carcinogen. However, the Environmental Protection Agency has 

not endorsed this designation through the risk assessment process as of the date of this document. Further, no 

evidence exists showing the herbicides proposed for use would result in carcinogenic, mutagenic, teratogenic, 

neurological or reproductive effects based on anticipated exposure levels to workers and the public (Arbuckle 

1999; Charles et al. 1996; Paustini 1996; Ibrahim, et al. 1991; Mattsson 1997; Mustonen 1986; Infoventures 

1995a-j; OSU 1996a-h; U.S. EPA 1990 and 1990a; USDA Forest Service 1995, 1996a, 1997a, 1997c, 1998,

1998d, 1999c-d, 2000, 2001, 2001b; SERA 2002 - 2007).
Final Supplemental Environmental Impact Statement

163

With respect to herbicides proposed in this project, it has been estimated in nearly all cases the dose a worker 

or a person from the public would be exposed to would be below the reference dose. 

This conclusion excludes accidental spills and implausible exposure scenarios (spray over entire naked body 

or wearing heavily contaminated gloves for an extended period).

Synergistic Interactions – Concerns are occasionally raised about potential synergistic interactions of 

herbicides with other herbicides in the environment or when they are mixed during application. No one can 

guarantee the absence of a synergistic interaction between herbicides and/or other chemicals to which workers 

or the public might be exposed. For example, exposure to benzene, a known carcinogen that comprises 1 to 5

percent of automobile fuel and 2.5 percent of automobile exhaust, followed by exposure to any of these 

herbicides could result in unexpected biochemical interactions (USDA Forest Service 1997b). Analysis of the 

infinite number of materials a person may ingest or be exposed to in combination with the herbicides 

proposed here is outside the scope of this analysis; however, because the risk of exposure to the public is 

nearly zero to begin with, the chance of a synergistic interaction from this project is also very low. 

Impurities and Inert Ingredients in Herbicide Formulations – During commercial synthesis of some 

pesticides, byproducts can be produced and transferred into the product eventually formulated for sale. 

Occasionally, byproducts or impurities are considered toxicologically hazardous, and their concentrations 

must be limited so potential exposures do not exceed levels of concern (Felsot 2001). The byproducts raised 

as points of concern are hexachlorobenzene, dioxins (especially tetrachlorodibenzo-p-dioxin), inert 

ingredients, dyes, and surfactants. The effects of each are summarized here; a more detailed examination 

exists in the project record. 

Hexachlorobenzene

The use of clopyralid or picloram in accordance with the label would not result in increases in the general 

exposure of either workers or members of the general public to hexachlorobenzene. The central estimates of 

worker exposure to hexachlorobenzene under normal conditions were estimated to be lower than the 

background levels of exposure by factors of about 1,000.

Dioxins (especially tetrachlorodibenzo-p-dioxin)

Current quality control procedures during manufacturing have essentially eliminated any dioxin congeners of 

concern from domestic 2,4-D formulations. Thus, use of 2,4-D products manufactured in the United States, 

whether at home or in the national forests, does not contaminate the environment with the dioxin of greatest 

regulatory concern, tetrachlorodibenzo-p-dioxin (U.S. EPA 2000, chapter 8 of the Draft Dioxin Assessment).

Inert Ingredients

The proprietary nature of herbicide formulations limits the understanding of the risks posed by inert 

ingredients in herbicide formulations. Studies on the toxicity of technical grade formulations, which often 

contain the inert ingredients, account for the toxicity of the inert ingredients, and as has been reported here, 

these studies show the use of herbicides by the Forest Service would not expose workers or the public to 

levels of concern.

Dyes

Limited information is available on the toxicity of the majority of dyes used in the industry. There has been 

considerable concern over the carcinogenic potential of less used dyes Rhodamine B and Basic Violet 3. The 

Forest Service completed a risk assessment of Rhodamine B and Basic Violet 3. It estimated the excess cancer 

risk for Rhodamine B, assuming a lifetime of occupational exposure, was extremely low (USDA Forest 

Service 1997e). The excess cancer risk for Basic Violet 3 was estimated to be about twice that of Rhodamine 

B. Both estimates suggest use of these dyes does not pose an unacceptable health risk.
Invasive Plant Control Project

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Surfactants

Like dyes and other inert ingredients, there is often limited information on the types of surfactants used and 

the toxicity of surfactants, especially since the industry considers the surfactant to play a key role in the 

effectiveness of the herbicide formulations. Most knowledge of surfactants is kept as proprietary information 

and not disclosed. This is not always the case. The Forest Service (1997c), which attempted to assess the 

effects of surfactant formulations on the toxicity of glyphosate, reported the toxicity of glyphosate alone was 

about the same as the toxicity of the glyphosate and surfactant mixed and greater than the toxicity of the 

surfactants alone. Whether this same pattern would hold true of other herbicides having the same or different 

surfactants is unknown. If so, the toxicological studies performed on herbicide formulations (which contain 

the inert ingredients and surfactants) may accurately portray the toxicity and risks posed to humans by the 

surfactant.

Endocrine Disruption

In the live animal studies to date, only a handful of chemicals, including natural food biochemicals, a few 

pesticides, and several industrial chemicals show endocrine disrupting effects (Felsot 2001). With one 

exception, the drug diethylstilbestrol, any effects observed were in tests with doses at least thousands of times 

greater than environmental or dietary concentrations.

In virtually all published cases where a series of doses are tested, endocrine effects did not occur below some 

threshold dose (U.S. EPA 1997a). The Environmental Protection Agency (1997a) concluded, with few 

exceptions (for example, diethylstilbestrol), a causal relationship between exposure to a specific 

environmental agent and an adverse effect on human health via an endocrine disruption has not been 

established.

Uncertainty

With the exception of accidental exposures, workers and the general public would not be exposed to any 

herbicides at concentrations that result in an adverse health effects. This conclusion is predicated on Forest 

Service employees wearing appropriate personal protective equipment, applying herbicides in accordance 

with the label, and implementing the job hazard analysis as prescribed for this project (chapter 2). By doing 

so, possible exposure by contact or through drift would result in a potential dose below that determined to be 

safe by the Environmental Protection Agency over a lifetime of daily exposure. It is also predicated on the 

findings, backed by toxicological studies, that a person can be exposed to some amount of a contaminant and 

not have an adverse effect (the dose determines the effect).

Comparison of Alternatives B, C, and D

Alternative C, which proposes no herbicide use, would have no effects to human health from herbicides. It 

would, however, have the highest risk of physical injury (such as slips, trips, strains, and falls). Nonetheless, 

the risk of physical injury is considered to be low and no greater than from other Forest Service activities.

Alternative D would have the highest risk of accidental spills of herbicides, since herbicide use is the only 

method proposed. More time spent mixing and applying herbicides increases the risk of a spill. The public 

may be exposed to a spill should the herbicide reach surface or groundwater. The indirect effects of a spill 

would be commensurate with the proximity of the spill area to the public and public exposure pathways. In 

terms of effects to human health and safety from routine application of herbicides without spills, the 

discussion above shows the risk is expected to be low, meaning it would be lower than the exposures shown 

by the Environmental Protection Agency to cause health effects. We also recognize, in the discussion of 

uncertainty, there cannot be a 100 percent guarantee of no effect.

Alternative B contains the same risks described in alternatives C and D, but at lower levels. 
Final Supplemental Environmental Impact Statement

165

Cumulative Effects of Alternatives B, C, and D

The spatial “boundary” of the effects considered here is an individual. The temporal boundary is from the start 

of this project for 10 years, anticipated to be from 2017 through 2027. This is the period of time during which 

the Forest Service anticipates having controlled or eliminated its known weed populations. Table S-65

displays the cumulative effects to human health and safety.
Invasive Plant Control Project

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Table S-65. Cumulative effects to human health and safety

Method of 

treatment Direct and Indirect Effects

Actions that Cumulatively Contribute to 

the Direct and Indirect Effect Cumulative Effect

Biological No measurable effect to workers 

or the public

Not applicable Since there is no direct or indirect effect from 

biological methods to human health and safety, 

there would be no cumulative effect.

Controlled grazing No measurable effect to workers 

or the public

Not applicable Since there is no direct or indirect effect from 

grazing to human health and safety, there would 

be no cumulative effect.

Manual Risk of slips, trips, sprains, and 

falls to workers.

Trail construction and maintenance

Construction and reconstruction of facilities

Suppression and rehabilitation of wildfires

Hazardous fuels treatment 

Prescribed burning

Other projects involving physical work 

A cumulative effect to overall physical health (in 

terms of flexibility and soundness) is possible if the 

same workers conduct multiple projects, as is often 

the case with Forest Service employees.

Mechanical Risk of physical injury, primarily 

due to accidents, to workers

Road construction and maintenance

Trail construction and maintenance

Construction and reconstruction of facilities

Suppression and rehabilitation of wildfires

Hazardous fuels treatment 

Prescribed burning

Other projects involving physical work

Other projects involving heavy equipment

Forest Service employees experiencing moderate 

or severe injuries due to accidents are put on “light 

duty” and would not continue with the physical 

activities until they were well. Thus, there would be 

no cumulative effects.

A cumulative effect to overall physical health (in 

terms of flexibility and soundness) is possible if the 

same workers conduct multiple projects, as is often 

the case with Forest Service employees.

Herbicides

Method of 

application

No effects to the public since 

they would not be applying 

herbicides.

Risk of exposure to workers 

exists (dermal contact has the 

highest likelihood of resulting in 

exposure); however, it would be 

well below Environmental 

Protection Agency’s reference 

dose.

Not applicable Since there is no direct or indirect effect to the 

public, there would be no cumulative effects.

The risk of an effect to health to a worker is small 

enough to be immeasurable; therefore, there 

would be no cumulative effects.
Final Supplemental Environmental Impact Statement

167

Method of 

treatment Direct and Indirect Effects

Actions that Cumulatively Contribute to 

the Direct and Indirect Effect Cumulative Effect

Length of exposure The use of herbicides on 

National Forest System lands 

would not pose an identifiable 

risk to workers or the general 

public, either for acute, subchronic, or chronic toxicity. In all 

cases, the likely exposure would 

be far less than Environmental 

Protection Agency’s reference 

dose.

Not applicable The risk of health effects to a worker or the public 

is small enough to be immeasurable; therefore, 

there would be no cumulative effects.

Route of exposure The amount of dermal exposure 

expected for workers would be 

less than the LD50 and would be 

negligible. Inhalation would be 

even less.

No risk of dermal exposure to 

the public. Very low risk of 

inhalation exposure for the 

public.

Not applicable The risk of health effects to a worker or the public 

is small enough to be immeasurable; therefore, 

there would be no cumulative effects.

Toxicity of 

herbicides 

Studies suggest the herbicides

proposed for use by the Forest 

Service are not carcinogenic 

and do not cause other health 

effects.

Not applicable Since the herbicides themselves are not expected 

to cause health effects, there would be no 

cumulative effects.

Synergistic 

interactions

There would be a risk of 

synergistic interactions that 

would cause negative effects to 

human health. Studies covering 

the effects of exposure to the 

infinite combinations of 

chemicals that exist in society 

do not exist.

There is no way to compile a complete list due 

to the sheer number of chemical that exist in 

society today. Examples are gasoline, 

household cleaning products, construction 

materials, cigarette smoke, etc.

A cumulative effect exists but cannot be quantified 

due to the unknown exposures that an individual is 

subject to in their daily routine.

Hexachlorobenzene The use of clopyralid or 

picloram in accordance with the 

label would not result in 

increases in the general 

exposure of either workers or 

members of the general public 

to hexachlorobenzene.

Not applicable Since there would be no increase in exposure to 

hexachlorobenzene, there would be no direct or 

indirect effect to human health; thus, there would 

be no cumulative effects.
Invasive Plant Control Project

168

Method of 

treatment Direct and Indirect Effects

Actions that Cumulatively Contribute to 

the Direct and Indirect Effect Cumulative Effect

Tetrachlorodibenzop-dioxinThe use of 2,4-D products 

manufactured in the United 

States do not contaminate the 

environment with

tetrachlorodibenzo-p-dioxin. 

Thus, there would be no human 

exposure to tetrachlorodibenzop-dioxin from this project.

Not applicable Since there would be no direct or indirect effects to 

human health from tetrachlorodibenzo-p-dioxin, 

there would be no cumulative effects.

Inert ingredients Studies on the toxicity of 

technical grade formulations, 

which often contain the inert 

ingredients, account for the 

toxicity of the inert ingredients, 

and these studies show the use 

of herbicides by the Forest

Service would not expose 

workers or the public to levels of 

concern.

Not applicable Since there would be no direct or indirect effects to 

human health from the inert ingredients contained 

in the herbicides proposed for use in this project, 

there would be no cumulative effects.

Dyes Use of dyes does not pose an 

unacceptable health risk in the 

context of this project, which 

would not entail a lifetime of 

application.

Not applicable Since there would be no direct or indirect effects to 

human health from the dyes contained in the 

herbicides proposed for use in this project, there 

would be no cumulative effects.

Surfactants A risk to human health may 

exist from the surfactants 

contained in herbicides, but this 

risk has not been studied and 

quantified. Most information on 

surfactants is proprietary and 

not disclosed.

There is no way to compile a complete list of 

products that contain surfactants to which an 

individual would be exposed during the same 

timeframe of this analysis. Too many of them 

exist, and it is not possible to identify the daily 

habits and exposures of the workers 

A cumulative effect exists, but cannot be quantified 

due to the unknown exposures that an individual is 

subject to in their daily routine.

Endocrine 

disruption

No causal relationship between 

exposure to a specific herbicide

and an adverse effect the 

endocrine system has been 

established.

Not applicable Since there would be no direct or indirect effects to 

the endocrine system from the herbicides 

proposed for use in this project, there would be no 

cumulative effects.
Final Supplemental Environmental Impact Statement

169

Cost-Benefit Analysis

The issue analyzed in this section is: “On weed infestation sites where nonchemical methods are proposed for 

use without supplemental herbicides, weed control effectiveness would be lower and treatment costs higher.”

Measure

Economic efficiency is measured in present net value. 

Rationale

Present net value is a common and widely accepted measure of economic efficiency for all kinds of projects. 

Assumptions

• This is not an exhaustive economic determination, but rather an estimate of economic efficiency. Some 

values are unknown, others are difficult to determine, and still others are dependent on the quality of the 

data provided. 

• Estimates from employees are used for local costs such as fence building.

• The workforce used to treat weeds, either contracted or Forest Service employees, would not exceed 30 

individuals on a part time or temporary basis.

• Only costs and benefits contained in published Forest Service documents that relate directly to this project 

are included.

• Sunk costs are not part of the analysis.

• Nonmarket or indirect values such as detoxification and decomposition of toxic waste or potential 

property value changes are not used in the Quicksilver economic estimations (State of the Southern 

Rockies - San Juan-Sangre de Cristo Bioregion, 1998).

Methods 

Quicksilver, a public domain computer program, was used to model the economic efficiency of the 

alternatives. This program estimates present net value based on costs and benefits of the treatments contained 

in each alternative.

Results

Present net value shows whether an investment will be profitable. It measures present cash outflow to 

projected inflows over the life of the project. For this analysis, it is used to show the relative benefit among 

alternatives, not their exact cost. The project record contains the estimated costs of various treatments used in 

the model. 

In business, a negative value means that a project would not go forward because it would lose money, and that 

the result for the money spent would not be economical. This concept does not completely apply to forest 

management, because there is no projected cash inflow as a result of doing the project. However, using 

present net value shows the relative cost of the alternatives.

Alternative A (no action) has a negative value because Forest Service staff will continue to monitor known 

and new weed populations. An additional cost associated with the no-action alternative (not included in the 

present net value calculation) is that of performing National Environmental Policy Act analyses to treat 

individual weed infestations. The other three alternatives, B, C, and D, include the cost of treating and 

monitoring known and new weed infestations over time. 
Invasive Plant Control Project

170

Table S-66. Present net value (rounded to nearest dollar) of the alternatives

Alternative A

(No Action)

Alternative B

(Proposed Action)

Alternative C

(No Herbicides)

Alternative D

(Herbicides Only)

-4,324 -99,325 -92,956 36,963

Source: Quicksilver analysis

Alternative D appears to be the most cost effective because the use of herbicides has been demonstrated to be 

more effective at controlling and eliminating weeds than other methods, so fewer treatments would be 

required. Using herbicides would also require fewer personnel. 

The proposed action appears to be the most expensive because it encompasses all the methods of treatment. 

The present net values show that non-herbicidal methods are likely to cost more than herbicides. Frid et al. 

(2013) found that strategies that prioritize targeting small, new infestations consistently outperform strategies 

that target large, established patches.

Effects of Forest Plan

Amendment to Social and Economic Resources

The proposed plan amendment limits herbicide use to “when determined through an environmental analysis to 

have no long-term adverse environmental, economic, or social impacts.” This modified language would be 

more clearly and consistently interpreted than the vague original language. The modified language would also 

provide for greater consistency with environmental analysis requirements under the National Environmental 

Policy Act, which is appropriately based on estimated impacts rather than on the “acceptability” of a proposed 

action. 

Environmental Justice

The proposed plan amendment would have no effect on environmental justice in future projects. The 

amendment would allow chemical treatments “when determined through an environmental analysis to have 

no adverse environmental, economic, or social impacts for longer than 6 months.” First, this restriction 

applies to all areas equally and does not favor any specific group. Second, an analysis of environmental 

justice would be applied for individual projects. The design features and mitigations listed in the amendment 

would protect low-income and minority populations during herbicide use in future projects. 

Human Health and Safety

The design features listed in the amendment would protect people during herbicide use in future projects.

Cost-Benefit

The proposed plan amendment is likely to increase the cost of future projects that use herbicides by requiring 

an analysis of effects up to 6 months, and monitoring for whether soils are within the standards listed.
Final Supplemental Environmental Impact Statement

171

Consistency with Forest Plan, Laws, and Policies

[New paragraph]

All alternatives are consistent with Environmental Protection Agency, Occupational Safety and Health 

Administration, and Forest Service regulations for herbicide use and worker safety. An amendment to the 

Santa Fe National Forest Plan has been proposed; otherwise, this project is consistent with the Carson and 

Santa Fe Nation Forest Plans.

Other Required Disclosures

Short-term Uses and Long-term Productivity

[No change from final environmental impact statement]

Unavoidable Adverse Effects

[No change from final environmental impact statement]

Irreversible and Irretrievable Commitments of Resources

[No change from final environmental impact statement]

Incomplete or Unavailable Information

[New section]

All of the herbicides proposed for use by the Forest Service must be registered for use by the Environmental 

Protection Agency and the New Mexico Department of Agriculture. Registration of these herbicides and 

Federal regulations adopted to protect workers and the general public have required more scientific 

information and justification for use of herbicides. Nevertheless, there are many reports in the scientific 

literature that document associations between herbicide exposure and alterations of the immune system, 

autoimmune disorders, and increases in the probability of carcinogenesis. Samsel (2013), Missoula CityCounty Health Board (2001), Citron (1995), Environmental Protection Agency (1995) Glover-Kerkvliet 

(1995) are just a few references that provide information on such effects. The body of literature on herbicide 

effects raises concerns about additive and synergistic effects of exposure to more than one herbicide, 

unstudied or unknown consequences of low-level chronic exposures, toxicity of inert ingredients, by-products 

or contaminants of herbicides, and uncertainties about the health effects of sensitive populations. There is also 

the realization that it is difficult, if not impossible, for government or any scientific agency to fully evaluate a 

chemical and all the potential combinations of them to ensure that there would not be an adverse effect.

It would be inappropriate to suggest that use of herbicides to control weeds is without risk to workers and the 

general public. If herbicides are used, there is the possibility of worker and general public exposure, no matter 

how many design features are implemented. All chemical exposure results in some level of health risk, the 

risk primarily being a function of the dose, or amount a person or organism is exposed to over a period of 

time.

It is equally inappropriate to conclude that any exposure, regardless of dose, would result in an effect. It is 

easy to find a report showing a health effect caused by the exposure to an herbicide or any other chemical. 

The toxicological studies are purposely done using high doses to demonstrate an effect. It is the herbicides 

that show effects at low levels of exposure or those levels anticipated when in use that should raise concern. 

With respect to this project, the potential dose received by the worker or member of the public does not 

approach the exposure levels shown by Forest Service risk assessments to cause acute, chronic, or subchronic 

toxicity. Acute effects occur at doses thousands to tens of thousands of times higher than those estimated for 
Invasive Plant Control Project

172

the worker or public for this project. Likewise, chronic effects reportedly occur at doses significantly higher 

than that expected for this project.

There are simply too many variables (receptor sensitivity, dose received, use of personal protection, and so 

forth) for anyone to predict with 100 percent certainty the potential health risk of herbicide use and exposure. 

What is known is that through a process of continual review of toxicological data on herbicides, the 

Environmental Protection Agency, using very conservative assumptions, has determined a dose they believe 

would not result in an adverse health effect for herbicides proposed for use on this project. Some studies show 

that exposure to the herbicides proposed for use at high doses can cause deleterious effects. The risk 

assessments, however, have been completed to determine the estimated dose a worker or person of the general 

public might be exposed to under varying exposure scenarios. Most important, we know through a 

comparison of Environmental Protection Agency-established safe doses and estimated exposures that the 

estimated dose that a worker or person of the general public may be exposed to through use of an herbicide on 

this project would be below that determined to be safe by the Environmental Protection Agency for a lifetime 

of daily exposure. Therefore, no health effects or risks to workers and the general public are anticipated by the

use of herbicides for this project.
Final Supplemental Environmental Impact Statement

173

Preparers and Contributors

[Revised section]

From 1999 to 2002, the Forest Service worked with a team of contractors to develop the first draft of the 

environmental impact statement. From 2003 to 2005, an expanded interdisciplinary team composed of Forest 

Service staff and contractors prepared the final environmental impact statement published in 2005. That team 

is listed on pages 185-186 of the 2005 final environmental impact statement. The following lists the Forest 

Service personnel who prepared this final supplemental environmental impact statement. 

Name Position Contribution

Education and 

Experience

Julie Bain Forest NEPA Coordinator, 

Santa Fe National Forest

Project leader, National 

Environmental Policy 

Act compliance, editor of 

Vegetation and 

Livestock Grazing 

sections, writer

MS Environmental Studies

18 years’ experience

Francisco 

Cortez

Carson National Forest 

Wildlife, Fish, Rare Plant 

Program Manager

Wildlife, fisheries and 

aquatic resources

BS Wildlife Biology

21 years’ experience

Jennifer Cramer Forest Planner, Santa Fe 

National Forest

Forest plan amendment PhD Plant Biology

6 years’ experience

Timothy 

Downing

GIS Specialist, Santa Fe 

National Forest

GIS MS Natural Resource 

Management

3 years’ experience

Michael Frazier Staff Officer, Santa Fe 

National Forest

Recreation, wilderness, 

and visual resources

BA Liberal Arts

BS Forestry

42 years’ experience

Michael Gatlin Fisheries Biologist, Carson 

National Forest

Fish and aquatic 

resources

BS and MS, Fisheries and 

Aquatic Ecology and 

Management

5 years’ experience

Antonio Griego Biological Technician, 

Santa Fe National Forest

Project record and 

mailing list management

BS Biology

3 years’ experience

Josh Hall Air and Water Quality 

Specialist, New Mexico 

National Forests

Air quality MS Environmental 

Science, MS Natural 

Resource Management 

and Environmental Policy

8.5 years’ experience

Hillary Hudson GIS Specialist, Santa Fe 

National Forest

GIS MS Environmental Science

15 years’ experience

Allan Lemley GIS Coordinator, Carson 

National Forest

GIS BS Geology/Physics

13 years’ experience

Jason McInteer Assistant Forest 

Archaeologist, Santa Fe 

National Forest

Heritage resources MA Anthropology 

12 years’ experience

Greg Miller Forest Soil Scientist, 

Carson National Forest

Soil and water BS Soil Science

34 years’ experience

Skip Miller Forest Archaeologist, 

Carson National Forest

Heritage resources MFA in Native American 

Art History and Ceramics

34 years’ experience in 

Archaeology, cultural 

anthropology and

museums
Invasive Plant Control Project

174

Name Position Contribution

Education and 

Experience

Mary Orr Wildlife Biologist

Espanola and Coyote 

Ranger Districts

Wildlife, fisheries and 

aquatic resources

BS Biology

BS Wildlife Biology

33 years’ experience

Judy York Forest Service writereditor

TEAMS Enterprise Unit

Editing, publication,

layout

BS Wildlife Resources

MS Natural Resources 

Communications

25 years’ experience

Sandra ImlerJacquezForest NEPA Coordinator, 

Santa Fe National Forest

Project Leader, National 

Environmental Policy 

Act compliance, 

writer/editor

BS Natural Resources

10 years’ experience

MS = Master of Science degree, BS = Bachelor of Science degree, MA = Master of Arts degree, MFA = Master of Fine Arts degree, BA = 

Bachelor of Arts degree, PhD = Doctor of Philosophy degree.

Distribution of the Supplemental Environmental Impact 

Statement

The draft supplemental environmental impact statement was distributed, or made electronically available, to 

over 200 individuals and groups who specifically requested a copy of the document or commented during 

public involvement opportunities. In addition, copies were sent (or in some cases made electronically 

available) to Federal agencies, federally recognized Tribes, State and local governments, and organizations 

that have requested to be involved in the development of this analysis. These entities include the U.S. 

Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Department of the Interior, Federal

Highway Administration, Advisory Council on Historic Preservation, USDA National Agricultural Library,

State wildlife and fisheries management agencies, Tribes, county commissions, and local community 

governments. Due to the number of people, agencies, and organizations, a complete listing has been omitted 

from this environmental impact statement, but is available upon request.

The final supplemental environmental impact statement was distributed, or made electronically available, to 

individuals and groups who commented during public involvement opportunities. In addition, copies were 

sent (or in some cases made electronically available) to Federal agencies, federally recognized Tribes, State 

and local governments, and organizations that have requested to be involved in the development of this 

analysis. These entities include the U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, 

U.S. Department of the Interior, Federal Highway Administration, Advisory Council on Historic Preservation, 

USDA National Agricultural Library, State wildlife and fisheries management agencies, Tribes, county 

commissions, and local community governments. Due to the number of people, agencies, and organizations. 

An electronic copy was also made available on the project website 

(http://www.fs.usda.gov/project/?project=27249). 
Final Supplemental Environmental Impact Statement

175

References

The citations here are those listed in this supplement.

Arbuckle, T. 1999. Exposure to phenoxy herbicides and the risk of spontaneous abortion (abstract). 

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Appendix 1. Past, Present, and Future 

Weed Control Activities

[No change from the final environmental impact statement]

Appendix 2. Weed Species Ecology and Impacts

[Remove Field Bindweed (Convolvulus arvensis) (COAR4)]

The abbreviation for saltcedar (Tamarix spp.) is TARA.

The abbreviation for spotted knapweed (Centaurea biebersteinii) is CESTM.

[Add the following three species]

Cheatgrass (Bromus tectorum) (BRTE)

This description comes from Utah State University11.

Cheatgrass was introduced to North America through contaminated 

grain seed, straw packing material, and soil used as ballast in ships 

sailing from Eurasia. This first occurred between 1850 and the late 

1890s. During this time, overgrazing coupled with drought left 

many Great Basin rangelands in poor condition. Cheatgrass was 

able to occupy areas where the native vegetation had been reduced, 

beginning its persistent march across the landscape. It can now be 

found across the landscape from the bottoms of desert valleys to 

mountain peaks as high as 13,000 feet. The plant communities most 

affected by cheatgrass invasion are those below 6,000 feet in 

elevation. These include piñon/juniper woodlands, sagebrush, and 

salt-desert shrub community types.

As a winter annual, cheatgrass seeds germinate at low fall 

temperatures. Seedling roots continue to grow throughout the 

winter, and by spring, are capable of out-competing native species 

for water and nutrients because most native vegetation is just getting 

started. Cheatgrass completes its life cycle quickly and can become 

dry by mid-June.

Cheatgrass is a prolific seed producer, and large seedbanks can 

develop. It only takes a few plants in a sagebrush/perennial grass community to produce enough seeds to 

overwhelm native perennials in seedling-level competition.

Fuller’s Teasel (Dipsacus fullonum) (DIFU2)

This description is taken from southwestlearning.org and the USDA’s Fire Effects Information system, 

accessed on December 12, 2013. (Image courtesy of USDA PLANTS Database, USDA NRCS PLANTS 

Database, Bugwood.org.)

 11 http://www.usu.edu/weeds/plant_species/weedspecies/cheatgrass.html
Invasive Plant Control Project

186

Fuller’s teasel is a biennial plant that grows a two- to eight-foot 

flowering stem. The flowers are very small and packed into dense, 

cone-shaped heads. Once the plant has flowered, it becomes woody 

and persists through the winter. It is currently found in most of the 

50 states. Native to Europe and temperate Asia, teasel may have 

been introduced to North America as early as the 1700s. It was 

likely cultivated for its role in producing wool or as an ornamental. 

Its frequent use in dried flower arrangements may aid its dispersal; 

for example, it is often found in and near cemeteries.

It occupies sunny and open sites, such as riparian areas, meadows, 

grasslands, roadways, forest openings, and disturbed sites. It may 

not seriously reduce biodiversity, but it has the potential to become 

more of a problem. Although few studies indicate the methods by 

which teasel impacts its nonnative habitats, several studies report 

that teasel may develop large monocultures, negatively impact 

riparian area integrity, and occupy habitats important to sensitive or 

threatened plant species. 

Although several researchers and land managers consider teasel a potentially invasive nonnative species, 

common teasel was not a high-priority species in a list ranking those species thought to seriously reduce 

biodiversity. Common teasel was listed number 80 in a prioritized list of 81 nonnative invasive species in 

natural Canadian habitats. However, several morphological and reproductive characteristics suggest teasel has 

the potential to be a problematic invasive species. 

A review reports that teasel's thick, well-developed taproot allows for substantial nutrient and water storage, 

which increases the potential for regrowth after damage and/or survival of inclement conditions. Barbs and 

spines defend teasel against herbivory and may focus grazing or browsing on unprotected associated 

vegetation. High levels of seed production, high seed germinability, and little dormancy in fresh seed allows 

for rapid establishment in open areas, and death of the parent provides habitat for future seedling recruitment. 

While some teasel plants may be killed by cutting or mowing, many sprout and some may still produce seed. 

Typically, researchers and land managers suggest that belowground cutting is most effective, but plants may 

still regenerate. Reduced seed production and plant death are most likely if plants are cut just before or as they 

flower. However, viable seeds may be produced on cut stems, making disposal of flowering stems in cut areas 

important to successful teasel control.

Tree of Heaven (Ailanthus altissima) (AIAL)

This information comes from the National Park Service’s Integrated Pest Management Manual. (Image

courtesy of USDA PLANTS Database, USDA NRCS PLANTS Database, Bugwood.org.)

Tree of heaven is in the family Simaroubaceae. It was introduced into the United States from China as a host 

tree for the Cynthia moth, Samia cynthia (Drury), which was introduced for silk production. It was brought to 

the eastern United States as nursery stock because of its ability to grow quickly under adverse conditions. 

Chinese miners also brought the seeds with them to California because of their medicinal and cultural 

importance. Distribution in the United States is from Massachusetts to Iowa and Kansas and south to southern 

Texas and Florida. Tree of heaven has established to a lesser extent in the western United States from southern 

Rockies to the Pacific Coast states. 

It is a tall (to 60 feet), deciduous, polygamous tree and often colonizes by root sprouts. Stump sprouts can 

grow 6-12 feet in length in a single summer. Flowers are present in late May through early June in 12-inch-
Final Supplemental Environmental Impact Statement

187

long terminal panicles. A large cluster of pink fruits develops from July to October. The flowers and 

vegetative parts, if bruised, are ill scented, almost nauseating, on hot days.

Tree of heaven is intolerant of deep shade and occurs most 

commonly along fence rows, roadsides, and waste areas. It is 

tolerant of urban conditions, including compacted, poor soils, and 

polluted air, and is common in dusty, smoggy areas such as inner 

cities where most other trees fail.

It is often used as an ornamental in urban areas. It spreads rapidly 

in disturbed areas and can quickly take over forest openings 

created by gypsy moth damage or fire. It can pose a serious threat 

to natural areas. It has been found growing up to two air miles 

from the nearest seed source.

Cutting the tree by removing all above-ground growth does not 

prevent regeneration of sprouts from the stump. Current treatment 

consists of felling the tree and treating the stump with herbicide. 

Chemical treatment kills remaining tissue and prevents regrowth 

of stump sprouts. Trees may be frilled and treated with felling, 

treated by injection, or treated by hack and squirt. The latter 

technique involves cutting into the cambium and applying 

herbicide into the wound.

Final Supplemental Environmental Impact Statement

189

Appendix 3. Herbicides: Characteristics, Effects, and 

Risk Assessments

[Replaces introductory paragraphs and Table S-67 replaces table 57]

This appendix provides a summary of the available scientific information about the characteristics and effects 

of herbicides proposed for use in this project. Detailed information can be found in literature cited in the 

environmental impact statement as well as on national and regional Web sites managed by other agencies and 

organizations including the Environmental Protection Agency, USDA Forest Service, The Nature 

Conservancy, and the Colorado Department of Agriculture.

A key component of this analysis is the individual risk assessments developed by the Forest Service for each 

herbicide. Each risk assessment discusses the formulations analyzed for use in this project. These risk 

assessments were developed to determine the risk of using each herbicide, with worksheets provided to 

evaluate the risk at project level circumstances (such as application rate and application method). The risk 

assessments provide Forest Service officials with a summary of the most relevant information available. They 

are not comprehensive summaries of all the available information. After comments on the 2004 draft 

environmental impact statement raised concerns about whether the evaluation of effects was adequate, the risk 

assessments were reexamined. As a result, this appendix incorporates by reference the 13 risk assessments 

available to date: 

Table S-67. Risk assessments

Herbicide Name Date Prepared Reference

1 Aminopyralid June 28, 2007 SERA 2007

2 2,4-D September 30, 2006 SERA 2006

3 Clopyralid December 5, 2004 SERA 2004c

4 Chlorsulfuron November 21, 2004 SERA 2004a

5 Dicamba November 24, 2004 SERA 2004b

6 Glyphosate March 25, 2011 SERA 2011a

7 Hexazinone October 25, 2005 SERA 2005

8 Imazapic December 23, 2004 SERA 2004f

9 Imazapyr December 16, 2011 SERA 2011b

10 Metsulfuron December 9, 2004 SERA 2004d

11 Sulfometuron December 14, 2004 SERA 2004b

12 Picloram September 29, 2011 SERA 2011c

13 Triclopyr March 15, 2003 SERA 2003b

Any cited references to the risk assessments in the final environmental impact statement, the draft 

supplemental environmental impact statement, or the remainder of these appendices are hereby updated with 

the ones listed above.
Invasive Plant Control Project

190

Program Description

[Add aminopyralid (see Table S-68) to table 58] 

Table S-68. Herbicide use program description

Herbicide Name Other Information

1 Aminopyralid A reduced risk herbicide used post-emergence to control annual, biennial,

and perennial broadleaf weed species including thistles and knapweeds.

Also has excellent pre-emergence soil residual activity.

Application Methods

[No change from final environmental impact statement]

[Add aminopyralid (see Table S-69) to table 59)]

Table S-69. Herbicides formulations, application rates, target plants

Herbicide 

Name Trade Name(s)

Application Rate

(pounds per acre) Target Invasive Plants

1 Aminopyralid Milestone, 

Milestone VM

0.03 to 0.11 Thistles, knapweeds, yellow 

starthistle

[Add aminopyralid (see Table S-70) to table 60] 

Table S-70. Herbicide risk assessment standard terminology

Term Abbrev Explanation (see risk assessments for specific definitions)

Lowest Observed 

Effect Concentration

LOEC Used for plants to determine the lowest concentration at which a 

concentration of herbicide had no effect.

Overall Conclusions

[No change from the final environmental impact statement]

Human Health Risk Assessment

[No change from the final environmental impact statement]

Factors Affecting Hazard of Herbicides

[No change from the final environmental impact statement]]

[Add aminopyralid to table 61 as shown in Table S-71] 

Table S-71. Herbicide characteristics

Herbicide Carcinogenic1

Mutagenic and 

Reproductive2

Acute oral LD50 for rats 

(mg/kg/day)

Aminopyralid E No >2000

1. Environmental Protection Agency carcinogenicity classification based on daily consumption for a 70-year life span. D = Not Classifiable 

as to Human Carcinogenicity; E = Evidence of Non-Carcinogenicity

2. Unlikely that compound is mutagenic or would pose a mutagenic risk to humans at expected exposure levels.

Source: SERA 2007.
Final Supplemental Environmental Impact Statement

191

[This section updated]

Potential for Exposure

While the toxicity of a substance is the first part of the risk assessment, the second equally important 

consideration is the potential for exposure. The dose level that causes an effect in many toxicological studies 

is exponentially greater than what an applicator would be exposed to while applying herbicides. The method 

of exposure to herbicides in animal studies is also different than that of a worker or the general public, which 

also magnifies the chemical effect. In animal studies, herbicides are commonly pumped into stomachs, put 

directly into food, or placed directly on shaved skin. Potential exposure levels to workers and the general 

public associated with use of herbicides on forest lands have been estimated to be at or below Environmental 

Protection Agency reference doses. Therefore, dosages would not exceed acute toxicity dose levels when 

applying herbicides on forest lands. 

Herbicide applicators and the general public are clothed and do not purposely ingest herbicides under the 

same conditions as animal studies of toxicological significance. Estimates of exposure to workers and the 

general public to herbicides applied to forest lands have been reported under various conservative exposure 

scenarios. The most reasonable interpretation of the risks associated with application of most herbicides on 

national forest lands is that, except for accidental exposures or extremely atypical and perhaps implausible 

exposures scenarios (for example, acute direct spray entirely covering a naked child), the use of herbicides on 

National Forest System lands would not pose an identifiable risk to workers or the general public.

Exposures under typical exposure scenarios (those following guidelines on the label) would be below the 

reference dose, a dose level determined to be safe by the Environmental Protection Agency over a lifetime of 

daily exposure.

There are exceptions worth noting that may help identify protective measures that could be instituted when 

applying herbicides.

• USDA Forest Service (SERA 2005) reports that, over a range of plausible application rates, workers may 

be exposed to hexazinone at levels exceeding the reference dose.

• Likewise, there is reasonable concern that workers applying triclopyr over a prolonged period of time in 

the course of a single season or several seasons may be at risk of impaired kidney function (SERA 2003). 

• SERA (2006) reports if 2,4-D were applied directly to fruits and vegetables at anticipated application 

rates, the consumption of vegetables would be undesirable and could lead to health effects. These reports 

also point out the likelihood of such an exposure seems remote when applying on forest lands. Given the 

concern with the consumption of forest vegetation by the local population, this route of exposure is more 

likely than elsewhere in the United States and should be considered in the implementation process to 

avoid these exposures.

• SERA (2006) reports exposure levels for workers involved in ground or aerial application of 2,4-D may 

exceed the reference dose slightly, based on central estimates of exposure, or substantially, based on upper 

limits of exposure. They indicate 2,4-D can be applied safely (exposure doses below the reference dose) if 

effective methods are used to protect workers and minimize exposure (personal protective equipment).

• SERA (2003) reported no evidence that typical exposures to picloram would lead to a dose level 

exceeding the reference dose or level of concern, with the exception of wearing contaminated gloves for 1 

hour, which results in estimates of absorbed doses that exceed the reference dose.

• SERA (2003) notes exposure of workers to formulations of triclopyr over a long duration could exceed 

the level of concern and these levels should be avoided.

• SERA (2007) explains the Environmental Protection Agency has judged aminopyralid to be a reduced 

risk herbicide. This judgment by the Environmental Protection Agency is supported by the current risk 
Invasive Plant Control Project

192

assessment. Aminopyralid is an effective herbicide. As with any effective herbicide applied to terrestrial 

weeds, adverse effects in nontarget terrestrial plants are plausible. There is no indication, however, that 

adverse effects on workers, members of the general public or other non-target animal species are likely.

This assessment of aminopyralid is tempered by the lack of information on aminopyralid in the open 

literature. All of the information on the toxicity of aminopyralid comes from studies submitted to the 

Environmental Protection Agency in support of aminopyralid registration. While these studies have been 

reviewed and the bulk of these studies appear to have been appropriately designed, conducted, and 

reported, the available information on aminopyralid is much less diverse than the information available on 

herbicides used for many years and for which the open literature is rich and varied. 

How herbicides are applied can have a direct impact on the potential for human exposure and subsequent 

adverse health effects. According to risk assessments completed on herbicide usage on national forest lands, 

herbicide applicators are at a higher risk than the general public from herbicide use. The risk assessments 

compared risks to workers for all types of application, including aerial, backpack, ground-mechanical, and 

hand applications. Lower risks were estimated for aerial and ground-mechanical application as compared to 

other methods, even though the total amount of herbicide applied in a given day was higher (SERA 1995-

2007). 

Risks associated with backpack and hand application of herbicides were estimated to be the highest, due to 

workers being closer to the nozzle and to the containers from which the herbicides were sprayed. Backpack 

and hand application was also reported to increase the likelihood of a worker receiving repeated exposures 

that might remain on the skin for an extended period. The Environmental Protection Agency, in its 

reregistration of picloram (EPA 1995), also noted the highest risk for herbicide applicators was for those using 

the backpack application method, the lowest for aerial and ground-boom applicators. Although this is true in 

general, risk assessments worksheets run on the likely application rates and methods for the two national 

forests found this exposure reversed for 2,4-D applicators.

Route of Exposure

[Add aminopyralid to table 62 as shown in Table S-72] 

Table S-72. Exposure risk of herbicides

Herbicide

RfD1

(mg/kg/day)

Estimated Exposure to 

Public2

Estimated Exposure to 

Worker2

Aminopyralid 0.5 Less than RfD3 Less than RfD (0.001 – 0.002)

1. RfD = reference dose. A daily dose expressed as milligrams of herbicide per kilogram of body weight = mg/kg 

2. Exposures under typical exposure scenarios. Accidental and extreme exposure scenarios may exceed the reference dose.

3. Based on modeling of the most exposed individual, SERA found “based on a generally conservative and protective set of assumptions 

regarding both the toxicity of aminopyralid and potential exposures to aminopyralid, there is no basis for suggesting that adverse 

effects are likely in either workers or members of the general public even at the maximum application rate that might be used in Forest 

Service [or National Park Service] programs.” 

Source: SERA 2007

Wildlife Risk Assessment

[No change from the final environmental impact statement, except 13 herbicides (not 12) are proposed 

for use]

[Add aminopyralid to table 63 as shown in Table S-73]
Final Supplemental Environmental Impact Statement

193

Table S-73. Relative risk of each herbicide Herbicide Worker Risk Public Risk Risk of Carcinogenicity

Risk to Plants, 

Direct

Rick to Plants, 

Drift/runoff

Aquatic Plants 

Risk

Animals Direct 

Risk

Aquatic Animal 

Risk

Notes

Aminopyralid 1 1 NA 2 3 3 1 1

1 = lowest relative risk, 5 = highest relative risk
Invasive Plant Control Project

194

[Add aminopyralid to table 64 as shown in Table S-74]

Table S-74. Effects of each herbicide

Herbicide

Carcinogen 

(Cancer)

Teratogen 

(Birth 

Defects)

Mutagen

(Genetic 

Damage)

Reproductive 

Inhibitor

Skin 

Irritant

Eye

Irritant

BioAccumulate

Toxicity to 

Birds

Toxicity 

to Bees

Toxicity 

to 

Mammals Target Plants

Aminopyralid No No No No Slight None Minimal Practically 

nontoxic

Practically 

nontoxic

Low Broadleaf plants
Final Supplemental Environmental Impact Statement

195

Aquatic Risk Assessments 

[No change from the final environmental impact statement except to add aminopyralid to table 65 as 

shown in Table S-75] 

Table S-75. Level of Concern for Chemical Use Using the Risk Quotient Method

Chemical

1/20 Of LC50 

(ppm)1 EEC2 (ppm)

Risk 

Quotient3

Level of 

Concern

Aminopyralid (Milestone) 6.0 0.1 0.1 Low

1. LC50 = Lethal concentration where 50 percent mortality occurs. The current risk assessment will use no observable effect concentration 

values rather than LC50 values for risk characterization. For aminopyralid, however, the resulting numbers are essentially identical to 

those of the Environmental Protection Agency because most of the >LC50 values used by U.S. EPA/OPP-EFED (2004) are actually no 

observable effect concentration values – that is, no mortality or sublethal effects were observed.

2. EEC = expected environmental concentration; ppm = parts per million.

3. This is below the level of concern by a factor of 10 (SERA 2007).

Specific Herbicide Characteristics and Environmental Effects

[Add aminopyralid, otherwise no change from the final environmental impact statement]

Aminopyralid

Aminopyralid is a relatively new pyridine carboxylic acid herbicide for controlling weeds and invasive plants 

on rangeland and pastures, rights-of-way, and wildlife habitat areas. It is particularly effective on musk and 

Canada thistles; spotted, diffuse, and Russian knapweeds, yellow starthistle, and other difficult-to-control 

broadleaf weeds (SERA 2007). It is primarily a post-emergence herbicide but has excellent pre-emergence 

soil residual activity. Aminopyralid can be applied to weeds at any stage of growth, but it works best when 

used during the specific weed(s) optimal growth stages for control. Residual activity control can last into the 

season after treatment on certain weed species.

Aminopyralid translocates throughout the entire plant, accumulating in meristematic tissues including the 

roots, effectively disrupting the plants’ growth metabolic pathways and eradicating susceptible broadleaf plant 

species. Aminopyralid has been shown to cause little or no injury to desirable cool- and warm-season grasses. 

Aminopyralid will not cause injury to mature tree species, such as pine, maple, and ash but can cause some 

leaf discoloration, curling, or other foliage symptoms from over-application. Leguminous trees, such as black 

locust and honey locust, can be seriously injured by under-tree application.

The Environmental Protection Agency considers aminopyralid a reduced risk herbicide because there is no 

evidence of adverse effects on workers, members of the general public, or wildlife and domestic animals.

However, as with all relatively new herbicides, there is little information available in the published literature 

on the toxicity of aminopyralid to humans or other mammalian species. The few currently available for 

assessing potential hazards in humans are those supporting its registration. 

Acute toxicity data indicate aminopyralid has low mammalian toxicity via oral, dermal, and inhalation routes 

of exposure (U.S. EPA 2005) for both technical and end-use formulations. The acute oral LD50 and dermal 

LD50 in rats were greater than 5,000 milligrams per kilogram, respectively, while the acute inhalation LC50

was greater than 5.5 milligrams per liter. In a metabolism study in rats, it was rapidly absorbed, distributed, 

and excreted following oral administration. Dermal irritation was negative for the aminopyralid technical. Eye 

irritation ranged from a slight, transient irritation to irritating for aminopyralid formulations. 

Aminopyralid has been classified as “not likely” to be carcinogenic to humans; nor has it been found to be 

teratogenic, mutagenic, neurotoxic, or a reproductive hazard. It has tested negative for genotoxicity in both in
Invasive Plant Control Project

196

vitro and in vivo systems with no long-term (chronic) toxicity evident. The aminopyralid human health and 

risk assessment (SERA 2007) and the Environmental Protection Agency determined no risks to workers or 

members of the general public are anticipated. 

Toxicity studies on terrestrial plants reveal broadleaf plants are substantially more sensitive to aminopyralid

than monocots (for example, grasses), which is consistent with the recommended uses of aminopyralid. As 

would be expected from an herbicide, some aquatic plants are more sensitive than aquatic animals to the 

effects of aminopyralid.

Relatively little information is available on the standard acute and chronic toxicity of aminopyralid to 

terrestrial invertebrates or terrestrial microorganisms. Based on bioassays in honeybees, earthworms, and soil 

microorganisms, aminopyralid does not appear to be very toxic to terrestrial invertebrates or soil 

microorganisms nor is there any indication it is likely to be toxic to aquatic animals, based on bioassays in 

fish and invertebrates. 

Inert/Other Ingredients 

[Add aminopyralid to table 66 as shown in Table S-76] 

Table S-76. Herbicide formulations, impurities, other ingredients

Herbicide Name Hazard Identification

1 Aminopyralid Impurities, adjuvants and metabolites are considered together in the risk 

assessment. Formulations covered in this risk assessment contain only the 

triisopropanolamine (TIPA) salt of aminopyralid and water. 

Triisopropanolamine would be classified marginally as Category III (Caution), 

which applies to compounds with oral LD50 values in the range of >500 to 

5,000 milligrams per kilogram.
Final Supplemental Environmental Impact Statement

197

Appendix 4. Effects of

Non-Herbicide Weed Control Methods

[No change from the final environmental impact statement]

Appendix 5. Herbicide

Model for Watershed Analysis

[No change from the final environmental impact statement]

Appendix 6. Chemical Spill

Prevention and Cleanup Plan

[No change from the final environmental impact statement]

Appendix 7. Weed Populations and Treatments

[Replaces entire section]

This appendix lists the weed species known in the project area as of August 1, 2013 and the proposed 

method(s) by which they would be treated. Where several species grow in the same vicinity, they are grouped 

together. More than one treatment is listed in alternatives B and C because different species respond to 

different treatments depending on their ecology and location. Thus, the tables show the maximum number of 

acres that would be treated by the method shown.

Note that treatments are not limited to only the known weed populations. The adaptive nature of this project, 

described in chapter 2, will allow the Carson and Santa Fe National Forests to treat new populations of weeds 

as they are discovered. In fact, recent studies show treating new populations before the seedbed is established 

is the most effective and least costly strategy for reducing and eliminating weeds (Frid et al. 2013).

The acreages and treatment methods provided here are a snapshot in time, helpful as a basis for evaluating the 

effects of weeds and the treatments.
Invasive Plant Control Project

198

Keys to abbreviations:

Weed species

Code Scientific Name Common Name

ACRE3 Acroptilon repens hardheads; Russian knapweed

AIAL Ailanthus altissima tree of heaven

BRTE Bromus tectorum cheatgrass

CADR Cardaria draba whitetop; hoary cress

CANU4 Carduus nutans nodding plumeless thistle; musk thistle

CEDI3 Centaurea diffusa diffuse knapweed

CESO3 Centaurea solstitialis yellow star-thistle

CESTM Centaurea stoebe ssp. micranthos spotted knapweed

CIAR4 Cirsium arvense Canada thistle

CIVU Cirsium vulgare bull thistle

COMA2 Conium maculatum poison hemlock

DIFU2 Dipsacus fullonum Fuller's teasel

ELAN Elaeagnus angustifolia Russian olive

EUES Euphorbia esula leafy spurge

HYNI Hyoscyamus niger black henbane

LELA2 Lepidium latifolium broadleaved pepperweed

LIDA Linaria dalmatica Dalmatian toadflax

LIVU2 Linaria vulgaris butter and eggs; yellow toadflax

ONAC Onopordum acanthium Scotch cottonthistle

TARA Tamarix ramosissima saltcedar

ULPU Ulmus pumila Siberian elm
Final Supplemental Environmental Impact Statement

199

Abbreviations for treatment methods

Treatment Method Abbreviation

Biological BIO

Grazing GR

Herbicides HE

Manual MA

Mechanical ME

Prescribed fire FR
Invasive Plant Control Project

200

Table S-77. Summary of treatments for the action alternatives

Plant Species Alternative B Treatments Alternative C Treatments Alternative D Treatments Treatment Acres1

ACRE3 GR, HE, MA, ME GR, MA, ME HE 93.5

ACRE3 CADR GR, HE, MA, ME GR, MA, ME HE 0.2

ACRE3 CANU4 GR, HE, MA, ME GR, MA, ME HE 0.2

ACRE3 CEDI3 GR, HE, MA, ME GR, MA, ME HE 0.0

ACRE3 CEDI3 ELAN TARA BIO, GR, HE, MA, ME BIO, GR, MA, ME HE 0.1

ACRE3 CIVU GR, HE, MA, ME GR, MA, ME HE 0.1

ACRE3 TARA BIO, GR, HE, MA, ME BIO, GR, MA, ME HE 16.0

AIAL ULPU HE, MA, ME MA, ME HE 0.1

BRTE FR, GR, HE, MA, ME FR, GR, MA, ME HE 73.4

BRTE CANU4 HE, MA, ME MA, ME HE 0.5

CADR BIO, HE, MA, ME BIO, MA, ME HE 34.7

CADR CIVU ELAN TARA ULPU FR, HE, MA, ME FR, MA, ME HE 1.7

CADR CIVU TARA FR, HE, MA, ME FR, MA, ME HE 1.0

CADR ELAN ULPU FR, HE, MA, ME FR, MA, ME HE 0.7

CADR ONAC BIO, HE, MA, ME BIO, MA, ME HE 18.7

CANU4 HE, MA, ME MA, ME HE 1,309.7

CANU4 CIAR4 GR, HE, MA, ME GR, MA, ME HE 2,265.7

CANU4 CIAR4 CIVU GR, HE, MA, ME GR, MA, ME HE 2.8

CANU4 CIVU HE, MA, ME MA, ME HE 137.5

CANU4 CIVU ELAN TARA ULPU FR, HE, MA, ME FR, MA, ME HE 10.3

CANU4 CIVU ONAC HE, MA, ME MA, ME HE 3.4

CANU4 CIVU TARA HE, MA, ME MA, ME HE 1.8

CANU4 COMA2 HE, MA, ME MA, ME HE 0.1

CANU4 ELAN HE, MA, ME MA, ME HE 0.0

CANU4 LIDA BIO, HE, MA, ME BIO, MA, ME HE 8.3

CANU4 LIDA ONAC HE, MA, ME MA, ME HE 0.8

CANU4 ONAC HE, MA, ME MA, ME HE 1.4

CANU4 TARA HE, MA, ME MA, ME HE 0.3

CANU4 ULPU HE, MA, ME MA, ME HE 0.6

CEDI3 HE, MA, ME MA, ME HE 173.1

CEDI3 ELAN TARA BIO, HE, MA, ME BIO, MA, ME HE 328.4

CESO3 BIO, FR, GR, HE, MA, ME BIO, FR, GR, MA, ME HE 0.6

CESTM HE, MA MA HE 25.9
Final Supplemental Environmental Impact Statement

201

Plant Species Alternative B Treatments Alternative C Treatments Alternative D Treatments Treatment Acres1

CESTM CIAR4 GR, HE, MA, ME GR, MA, ME HE 313.3

CIAR4 GR, HE, ME GR, ME HE 2,999.4

CIAR4 CIVU GR, HE, MA, ME GR, MA, ME HE 6.3

CIAR4 CIVU ELAN TARA ULPU BIO, FR, GR, HE, MA, ME BIO, FR, GR, MA, ME HE 3.7

CIAR4 CIVU TARA BIO, GR, HE, MA, ME BIO, GR, MA, ME HE 0.3

CIAR4 ELAN ULPU FR, GR, HE, ME FR, GR, ME HE 0.0

CIAR4 LELA2 LIVU2 HYNI BIO, GR, HE, ME BIO, GR, ME HE 43.0

CIAR4 ONAC GR, HE, MA, ME GR, MA, ME HE 0.2

CIAR4 TARA BIO, GR, HE, ME BIO, GR, ME HE 0.0

CIVU BIO, HE, MA, ME BIO, MA, ME HE 2,877.6

CIVU COMA2 BIO, HE, MA, ME BIO, MA, ME HE 0.0

CIVU ELAN TARA ULPU BIO, HE, MA, ME BIO, MA, ME HE 693.5

CIVU LIVU2 GR, HE, MA, ME MA, ME HE 0.1

CIVU ONAC BIO, HE, MA, ME BIO, MA, ME HE 26.8

CIVU TARA BIO, HE, MA, ME BIO, MA, ME HE 63.7

COMA2 BIO, HE, MA BIO, MA HE 22.2

DIFU2 HE, MA, ME MA, ME HE 0.1

ELAN HE, ME ME HE 3.3

ELAN TARA BIO, HE, ME BIO, ME HE 27.6

ELAN TARA ULPU BIO, FR, HE, ME BIO, FR, ME HE 116.2

ELAN ULPU BIO, FR, HE, ME BIO, FR, ME HE 64.4

EUES BIO, GR, HE BIO, GR HE 8.9

HYNI HE, MA MA HE 0.6

LELA2 GR, HE, ME GR, ME HE 0.1

LIDA BIO, GR, HE BIO HE 8.6

LIDA ONAC BIO, GR, HE, MA BIO, MA HE 0.6

LIVU2 BIO, GR, HE BIO HE 3.6

ONAC HE, MA MA HE 470.6

TARA BIO, HE, ME BIO, ME HE 372.9

TARA ULPU FR, HE, ME FR, ME HE 0.2

ULPU FR, HE, ME FR, ME HE 617.1

1. A value of 0.0 means that less than one-tenth of an acre of a species exists.

Final Supplemental Environmental Impact Statement

203

Appendix 8. Implementation and Monitoring

[No change from the final environmental impact statement]

Appendix 9. Response to Comments on the Draft 

Environmental Impact Statement

[No change from the final environmental impact statement]

Appendix 10. Response to Comments on the Draft 

Supplemental Environmental Impact Statement

[New section]

NEPA

Concern: The Forest Service failed to implement NEPA properly because it has prepared a hybrid of the 

programmatic and site-specific analysis that suffices as neither. 

Response: The final environmental impact statement and final supplemental environmental impact 

statement provide project-level analysis of this proposal. It is not programmatic. The proposal 

presents a limited, specific set of treatments on a specific set of plants on National Forest System 

lands of the Carson and Santa Fe National Forests (final supplemental environmental impact 

statement, chapter 2 pp. 27-42). The known extent of weed populations (that is, site specific locations 

where treatments would begin) are displayed (figure S-2, p. 19). The direct, indirect, and cumulative 

effects of each kind of treatment to natural, cultural, and socioeconomic resources are thoroughly 

analyzed and presented in chapter 3 of the final environmental impact statement (pp. 63-184) and 

final supplemental environmental impact statement (pp. 43-168).

The adaptive management component of the project further ensures the effects will not extend beyond 

the scope of the predicted effects at any given location with any given treatment. The Forest Service 

must monitor the effects of treatments and adjust future treatments to remain within the scope of this 

environmental impact statement or do additional National Environmental Policy Act analysis (final

supplemental environmental impact statement p. 38, design feature #61).

Associated Comments

It does not contain site-specific analytical data. 40 C.F.R.§ 1502.1. Its data are internally inconsistent 

and not of the required "high quality," 40 C.F.R. § 1500.1(b), and "scientific accuracy, 40 C.F.R. § 

1502.24. 

In this case, the Forest Service declined to prepare a programmatic EIS for the control of invasive 

plants on the Santa Fe and Carson National Forests. If that course had been followed, then less detailed 

site-specific analysis (Environmental Assessments) could have been prepared to address the impacts of 

site-specific projects. Instead, the Forest Service prepared a hybrid of the programmatic and sitespecific analysis that document that suffices as neither. This DSEIS and its accompanying FEIS neither 

provides the decision-maker with a detailed environmental disclosure nor provides the public with the 

high quality information needed to evaluate environmental consequences. As documented below, such 

action is clearly contrary to NEPA. 
Invasive Plant Control Project

204

If the quantitative data needed to accurately evaluate site-specific impacts of herbicides on soil and 

water is lacking, NEPA requires disclosure of this fact. 40 C.F.R. § 1502.22. The DSEIS does not 

disclose this fact, instead analyzing cumulative impacts based on erroneous assumptions in violation of 

NEPA’s requirement that analytical information must be of high quality. 40 C.F.R. § 1500.1(b). 

Concern: The Forest Service has failed to analyze the effects of the design features as required by NEPA.

Response: Table S-11 (final supplemental environmental impact statement pp. 33-38) shows the 

"design features" and monitoring requirements for all the alternatives. Since these features are built 

into the proposed alternatives, their effects were analyzed for each resource area (final supplemental 

environmental impact statement p. 51).
Final Supplemental Environmental Impact Statement

205

Associated Comments: 

It does not analyze the so-called "design features." "'A mere listing of mitigation measures is 

insufficient to qualify as the reasoned discussion required by NEPA.'" Neighbors of Cuddy Mountain 

v. United States Forest Service, 137 F.3d 1372, 1380 (9th Cir. 1998) 

In other words, mitigation measures must be analyzed in detail and must explain their effectiveness in 

mitigating adverse environmental 10 impacts. Without analytical data to support this analysis and 

explanation, the mitigation measures/design features amount to nothing more than a “mere listing” of 

good management practices.

Concern: The Forest Service has not provided adequate rationale for the geographic scope of the project and 

does not consistently describe its temporal bounds.

Response: The Forest Service has considerable leeway when choosing the locations of its projects. In 

this case, it made sense for the Carson and Santa Fe National Forests to work together on invasive 

weed treatment because the forests are adjacent, share management of the Pecos Wilderness, and 

often share resources and personnel. Also, as described in the final supplemental environmental 

impact statement (beginning on page 24), the Carson and Santa Fe National Forests simultaneously 

started considering weed treatments in the mid-1990s and decided to work together in 1998.

The timeframe for the effects analysis (direct, indirect, and cumulative) is 10 years. The actual 

implementation period could extend beyond 10 years if monitoring shows the results of treatments 

remain within the expected sideboards. Language in the final supplemental environmental impact 

statement has been corrected accordingly.

Associated Comments: 

The Forest Service failed to disclose to the public its reason for establishing the geographic scope of 

the project as the Santa Fe and Carson National Forests. Why not New Mexico’s three northern 

National Forests or all five? A rationale for selecting two is never presented. Since the geographic 

scope of the project is critical to evaluating cumulative impacts, this omission fatally flaws the 

analysis. In addition, the project’s time frame is presented in some cases as 10 years and others as 

“approximately 10 years (or more)”. Equivocal time limits and designation of arbitrary project 

boundaries are actions contrary to NEPA’s requirement that EISs be properly defined. 40 C.F.R. § 

1502.4(a). 

Concern: Some comments revealed a lack of understanding of the proposal.

Response: We regret any confusion our wording has caused. The distinction between design features 

and mitigation measures has evolved and become clearer since the writing of the final environmental 

impact statement in 2005. For this project, these terms are used interchangeably (final supplemental 

environmental impact statement p. 12).

The only herbicides that would be approved for use are the 13 listed in the final supplemental 

environmental impact statement (p. 28). As proposed, use is consistent with law, regulation, and 

policy, including restrictions which apply to on the Santa Fe National Forest (final supplemental 

environmental impact statement p. 167). Any new herbicides proposed for use would need to undergo 

analysis as required by the National Environmental Policy Act.

The final supplemental environmental impact statement discloses cumulative actions considered in 

the effects analysis. Table S-14 (pp. 44-47) lists projects considered as past and present actions. Table 

S-15 (pp. 47-48) lists projects considered as reasonably foreseeable future actions. A summary of 

cumulative actions for each key resource is provided in Table S-16 (pp. 49-50). Specific information 

on past, present, and reasonably future weed control activities are described in appendix 1 of the final 

supplemental environmental impact statement (pp. 201-211). Because no forest-wide, integrated weed 
Invasive Plant Control Project

206

treatment strategy exists, any herbicide use proposed for these projects would have been considered

on a project-by-project basis in the appropriate National Environmental Policy Act analysis. 

Associated Comments: 

I also note a disturbing change in nomenclature since the FEIS, now referring to “mitigation measures” 

as “design features”. This appears to be an attempt at linguistic detoxification, to make it sound like 

there are no hazards that need to be “mitigated”. But this name change will not affect the toxicity of 

herbicides. 

If, based on the Project, new herbicides become available in the future, then they too can be used 

without further analysis of their impacts.

In the FEIS (p. 64), past and present ongoing weed treatments in the forest are mentioned, but no dates 

are given, it does not say whether those treatments are ongoing or not, it does not say if the FS violated 

the ban on herbicide use in the Santa Fe National Forest. And what of the riparian areas?

Concern: Never before have I heard of a USFS line-officer proposing to amend their forest plan to allow 

more people to be exposed to a carcinogen and then call it “nonsignificant.” Purge this from the final EIS. The 

New Mexico politicians will have fun with this.

Response: This project's forest plan amendment for the Santa Fe National Forest will be conducted in 

conformance with the 1982 planning rule provisions as allowed by the 2012 Planning Rule since the 

amendment process was initiated prior to May 9, 2012 (36 CFR 219.17(b)(3)). Under the 1982 

planning rule provisions, a significant amendment results when: 1) the proposal will significantly 

alter the long-term relationship between multiple-use goods and services originally projected or 2) the 

proposal will affect land and resources throughout a large portion of the planning area during the 

planning period (Forest Service Manual 1926.52).

Law, Regulation, Policy

Concern: The preferred alternative is a violation of Forest Service Manual 2323.26b (page 133 DSEIS)) 

because it will have serious adverse impacts on wilderness values, which includes environmental illness and 

wildlife impacts. The Forest Service needs to re-evaluate the project's impact on wilderness values, perhaps 

through a health impact assessment or other evaluation of publicly held wilderness values.

Response: Page 135 of the final supplemental environmental impact statement, cited by the 

commenter, lists the Forest Service manual direction stating the conditions under which weeds may 

be treated in wilderness. The commenter provides no evidence that treating weeds will adversely 

affect wilderness values. Pages 135 through 139 describe the predicted effects to the four wilderness 

characteristics: untrammeled, natural, undeveloped, and solitude/primitive and unconfined recreation. 

No lasting, significant effects to these characteristics are expected. Visual changes may occur from 

wilted, dead, or dying plants. Small portions of the wilderness could be closed for 1 to 5 days during 

treatments, and during this time, Forest Service personnel would be on site treating weeds. None of 

these are considered to be lasting, significant effects to the wilderness experience.

The potential for effects to human health and safety was identified as an issue to analyze in detail 

(final supplemental environmental impact statement pp. 33-34 and pp. 149-150). Analysis is provided 

in chapter 3 of the final supplemental environmental impact statement (pp. 149-161).
Final Supplemental Environmental Impact Statement

207

Associated Comments

This plan can be classified as a Violation of Forest Service Manual 2323.26b (page 133 DSEIS)) as it 

can be considered to have "serious adverse impacts on wilderness values" which includes 

environmental illness, wildlife impacts, etc ....The use of herbicides which causes mortality of natives 

and non-natives could be argued as an ineffective method of protection of wilderness in comparison 

with manual alternatives; the opportunities for visitation and recreation would be negatively impacted 

for those with environmental illness should Alternative C be used; and it can be argued that the use of 

herbicides is not a "preservation" of nature, nor is it spiritually inspiring. The impact on scenic views 

may be negligible. The recreational value is further addressed when the USFS admits on p 137 that 

"Alternative C would not be as effective at controlling newly established weed populations caused by 

recreational activities." For these reasons we request a re-evaluation of the impact on wilderness 

values, perhaps through a health impact assessment or other evaluation of what the publicly held 

wilderness values are that the USFS claims will not be seriously adversely effected. 

Best Available Science

Concern: The Forest Service should provide the dates that data on invasive plants was collected and include 

it in the maps presented in the DSEIS.

Response: The data presented show invasive plants surveyed as of August 1, 2013 (final

supplemental environmental impact statement, p. 20). The final supplemental environmental impact 

statement has been updated to include this date on the appropriate maps and tables. 

Associated Comments

We would like to point out that maps in DSEIS are not dated; but they were in FEIS. Why the 

discrepancy? We request that all maps include dates of data collected. The FEIS maps are dated, and 

the DSEIS maps are not dated (accidental or deliberate?). The lack of data you provide in the DSEIS 

does not provide us with enough information to compile thoroughly worthwhile comments within the 

current time frame. 

We request that all maps include dates of data collected. 

Concern: The model used to depict how herbicides travel within watersheds after application is inadequate, 

and therefore the Forest Service's conclusion that no harm will result from using herbicides is incorrect.

Response: The model used in this analysis simulates the potential concentrations of herbicide in a 

stream draining a watershed subject to weed treatment. The model calculates dilution of herbicide in 

primary streams of representative watersheds for two time periods – May and September, 

representing typical time periods when discharge is near the peak (May) and near the minimum 

(September). Picloram was selected because of its “high risk quotient” for fisheries and aquatic life, 

and a worst-case scenario was developed that represented the treatment of all weed acres at one time 

under alternative B. 

Modeling assumptions were clearly articulated and disclosed (final environmental impact statement 

pg. 292). Modeling results are illustrated in Table 66 (final environmental impact statement pp. 293-

294), and two watershed were found to potentially exceed the recommended threshold indicating that 

some effect to soil and water resources would be expected (loss of fish or aquatic insects). The 

interdisciplinary team considered these potential risks and developed design features to limit or avoid 

treatment scenarios in which the impacts would be likely to occur (final supplemental environmental 

impact statement pp. 33-38). Mitigation measures include limitations on herbicide treatment near 

streams and water bodies, use of only hand application onto individual weed plants in riparian areas, 

choice of herbicide method of application documented to be of low risk to aquatic species, prohibiting 

mixing and loading of herbicides near live water, etc. 
Invasive Plant Control Project

208

While the commenter(s) may feel the model is inadequate, it meets the requirements of the National 

Environmental Policy Act to disclose the effects of a proposed action to the public and develop 

mitigation to address those impacts.

Associated Comments

Faced with a persistent gap in its understanding of herbicide behavior, the Forest Service prepared an 

“Herbicide Model for Watershed Analysis” that purportedly models 11 watersheds to determine the 

impacts of herbicide application (FEIS, p. 291, unchanged in DSEIS). However, this model is woefully 

inadequate, in part, because it continues to assume with no discernible basis that herbicides respond in 

the field as they do in the controlled conditions of a laboratory. [16-11] The FEIS’s appendix 5 

(unchanged in the DSEIS) presents a theoretical model of 11 watersheds on the two forests purportedly 

showing that the project’s use of herbicides will not harm aquatic species or water quality. The results 

of this modeling exercise are further used to justify the removal of thresholds that would trigger further 

analysis (FEIS, p. 342). The critical assumptions of this analytical model are: 1) unsubstantiated by 

appropriate research or practical literature; 2) contain numerous questions which cannot be answered 

from information presented in the FEIS; 3) lacks the quality necessary for critical examination; and 4) 

as used in the FEIS, is non-empirical and hence not of high scientific quality. Attachment 8 (project 

record, original FEIS) is a critique of the watershed model prepared by Dr. Kim Kirkpatrick.

Concern: The Forest Service fails to use the best available science on the effects of herbicides. The risk 

assessments cited are out of date.

Response: The information included in the risk assessments comes from the most recent studies 

available at the time the assessments are prepared (final supplemental environmental impact 

statement p. 185). If some information is dated, it is because no recent studies have superseded the 

findings. Some commenters provided citations purportedly containing more up-to-date information. 

Upon review, however, these citations do not apply to the proposal, are not peer-reviewed scientific 

literature, or are inappropriately applied. 

The Environmental Protection Agency developed a methodology to allow the use of the best available 

science to determine the risk of harm, either short term or long term. The dose-response method 

developed by the Environmental Protection Agency is widely accepted in the scientific community. 

Limitations of the method are described by the Environmental Protection Agency. For example, the 

reference dose applies to effects that are threshold related (for example, assumed that below some 

threshold, no effects will occur). The assumptions have been tested over a number of years. Safety 

factors are incorporated. Assumptions are reasonable and supported by facts. The Environmental 

Protection Agency states the reference dose is an estimate (with uncertainty spanning perhaps an 

order of magnitude) of a daily exposure to the human population (included sensitive subgroups) likely 

to be without an appreciable risk of deleterious effects during a lifetime. 

Associated Comments

The DSEIS relies on risk assessments and studies that are woefully out-of-date (ranging from mid-90’s 

to early to 2000’s) to dismiss health concerns from exposure to herbicides. The Forests need to go 

back to the drawing board and do an updated and more accurate assessment of herbicide impacts, 

especially to humans. This should include a thorough review of herbicide research by independent 

sources. Relying on outdated Risk Assessment documents is insufficient. A new analysis also must 

take into account the broad range of human vulnerability to herbicides, rather than make generalized 

statements about their harmlessness to the public. Research cited is outdated. New research is not 

always considered. Sources in the DSEIS come from as far back as 1987 (glyphosate drift), 1989 (2, 

4-D) 1990(hexazinone & chlorsulfuron), and 1995 (picloram). The majority of herbicide-safety 

research cited is from 2003 or prior, though some citations from 2013 are included. However, the body 

of research emerging within the last 5 years regarding endocrine disruption and cell death based on 

toxicity of residue rather than over application. New Research For Mobility of Herbicides & the Role 
Final Supplemental Environmental Impact Statement

209

of Surfactants is not included. We request that new information be considered regarding the mobility 

of herbicides in soils as outlined on (p. 116) & the impact of surfactants or inert ingredients (165) on 

toxicity. Research such as those listed below suggest that herbicides, specifically glyphosate is more 

toxic when used with a surfactant than when used alone. Also of concern is the lack of inability to 

assess the inert ingredients and surfactants do to their proprietary nature. We therefore request that the 

USFS consider this new information when considering environmental and health impacts.

Public Involvement

Concern: The Forest Service is not providing people with the information they need to comment in a timely 

manner.

Response: In 2012, the Forest Service asked every person (274 individuals and organizations) who

commented during the development of the final environmental impact statement or appealed the 2005 

decision whether they wanted to receive paper or electronic copies of the draft supplemental 

environmental impact statement. Seventeen people responded. When the draft supplemental 

environmental impact statement was ready in 2014, we notified 298 individuals and organizations of 

its availability, including sending the paper or electronic copies to the 17 people who had responded 

to our 2012 inquiry. Legal notices were also published in the Albuquerque Journal and The Taos 

News. Each of the 2014 notifications included information on how to find the documents online, how 

to calculate the comment period, and the names and contact information for obtaining more 

information. Anyone who commented on the draft supplemental environmental impact statement will 

automatically receive notification of the availability of the final supplemental environmental impact 

statement and draft decision. A limited number of paper copies will be available.

We are appreciative of the comment stating that the Forest Service needs to be clear as to the location 

of the notices in the Federal Register. We erroneously assumed people knew where to look, so your 

advice is well-taken.

Associated Comments

Referencing your “File Code: 1950” from the original FEIS you note: “Staying informed: Those who 

comment will automatically receive a copy of the final supplemental EIS and draft record of decision, 

both prepared after we review your comments. The record of decision will include a decision from 

each forest supervisor.” This did not happen, and thus delayed significantly the time that the original 

FEIS commenters had to comment on this DSEIS. One commenter received the documents. Most 

received only a form letter, and some received no letter at all. This delayed the number of days people 

had to respond. 

We found absolutely nothing listed about the Project under the “Forest Service” heading in the Federal 

Register. We reviewed all the possible dates in the Federal Register and found nothing. The 

assumption one would have then would be that it had not yet been published in the Federal Register. 

You told us that the federal register is the only source we should use, and that any other source is not 

reliable in determining the comment due date. Only later, after one person saw a posting in the legal 

notice of the Albuquerque Journal, and noted that the EPA was referenced in that posting, did we then 

go back to the Federal Register and find the Project listed under ENVIRONMENTAL PROTECTION 

AGENCY. This is a significant communication error on your part, as NOWHERE in the DSEIS or the 

cover letter is the EPA mentioned as the source of the Project listing. As a result, numerous days were 

lost by the individual commenters. Your overly burdensome expectation that you put on us caused us 

lost time....(And in the future, you need to note in the document that the Project is listed under “EPA,” 

and not “Forest Service.”) 
Invasive Plant Control Project

210

Proposed Action

Concern: The Forest Service has changed the proposed action from the original FEIS.

Response: The regulations at 40 CFR 1502.9 state the purpose of a supplemental environmental 

impact statement is as follows:

"[The agency shall] prepare supplements to either draft or final environmental impact statements if:

(i) The agency makes substantial changes in the proposed action that are relevant to environmental 

concerns; or

(ii) There are significant new circumstances or information relevant to environmental concerns and 

bearing on the proposed action or its impacts.

Thus, changes to the proposed action are perfectly acceptable. The commenter does not elaborate on 

the issues they have with the changes, so no further response is required.

Associated Comments

The Forest Service has now let eight years pass, and comes back with almost the same proposal that 

was already rejected, except that the few protections for the environment that were contained in the 

first version have now been eliminated.

The preferred alternative in the FEIS only contemplated using herbicides on 22% of the treatment 

areas, or 1,644 acres. The preferred alternative now contemplates using herbicides on all treatment 

areas without exception, or 13,256 acres. The Forest Service's response to letters and petitions from 

well over one thousand people opposing any herbicide use is to increase the area it wants to spray 

eightfold. The number of different herbicides to be used has increased from 12 to 13. The statement 

that only 8 of them will be "primarily" used has been deleted. The number of weed species to be 

eradicated has increased from 32 to 37. The prohibition on using herbicides within the boundary of 

the known population, or occupied habitat, of threatened, endangered, or sensitive species of plants, 

has been deleted. This has been changed to not using herbicides within 25 feet of individual plants. 

The prohibition on the use of high-risk herbicides within a 1,000-foot buffer around the habitat of 

sensitive species has been deleted. Now both "low-risk" and "high-risk" herbicides are to be permitted 

within 25 feet of individual plants. 

The requirement to limit the use of herbicides, grazing, fire, and heavy machinery near certain heritage 

resources has been deleted. 

The requirement in the Forest Plan Amendment that only allowed herbicide applications if "effective 

ground cover is quickly restored" has been deleted. 

The phrase "mitigation measures" no longer appears in the document. These are now called "design 

features."

The absolute prohibition on broadcast burning in riparian areas has been deleted. Now it is only 

banned if it is "solely for the purpose of treating weeds." If treating weeds is one of the purposes, this 

is now permitted. 

The Forest service has added a provision allowing it to "drive off roads to treat weeds.”

The FEIS specified that treatments were only going to occur "along riparian areas, roads, trails, 

recreation sites, administrative sites, gas/oil pads (and pipelands) and range improvements" and in 

"areas of recent disturbance." That limitation has been deleted; the DSEIS permits herbicides 

everywhere.
Final Supplemental Environmental Impact Statement

211

Concern: The Forest Service is proposing to use herbicides in the Gallinas Watershed when no evidence of 

invasive plants being in the watershed exists.

Response: The Forest Service's intent is to be able to treat weeds using the methods, including the 

specific herbicides listed, as they are discovered in the future (final supplemental environmental 

impact statement p. 27). Page 22 of the final supplemental environmental impact statement states, 

"Weeds proposed for treatment are those listed on the New Mexico Department of Agriculture's 

noxious weeds list, at the time of this writing or listed in the future." 

Naturally, no treatments of any kind would occur where weeds do not exist. No weed treatments 

would occur in the Gallinas watershed unless officials from the City of Las Vegas approve the 

treatment (final supplemental environmental impact statement, p. 37, design feature #58).

Associated Comments

An article, published in the Las Vegas Optic, on January 19th, 2006, under the headline ‘Council 

rejects herbicide plan – Forest Service says weeds not a problem now’ continues to confuse our 

community: EXCERPT: “ Two Forest Service Officials – Joe Reddan and Dolores Maese – were on 

hand to defend the agency’s plan. They distributed a letter from Clifford Dils, acting forest supervisor 

for the Santa Fe National Forest. The letter states that the agency has found no noxious weeds or 

invasive plants in the Gallinas Watershed part of the forest.” (Las Vegas Optic, Jan. 19, 2006). Why 

then was the Gallinas Watershed on the list for herbicide applications if, as the FS later admitted, they 

found no invasive plants up there? 

Concern: The Forest Service needs to implement a robust monitoring program if it uses herbicides to treat 

invasive plants. 

Response: The cornerstone of this project is monitoring and adaptive management. The Forest 

Service will be required to monitor for 1) the treatment's effectiveness, 2) the effects on other 

resources relative to those predicted, and 3) the effectiveness of design features used to minimize 

adverse impacts (final supplemental environmental impact statement, pp. 23 and 38, design features 

#59-61). If monitoring shows treatments are failing or causing unacceptable effects, the method of 

treatment will be adjusted (this is the adaptive part).

Associated Comments

Failing to require substantive post-treatment monitoring to accurately determine if the thousands of 

pounds of herbicides to be applied over the next decade will contaminate water resources or increase 

soil erosion also flaws the project. 

Concern: The Forest Service proposes to treat 12,713 by mechanical methods, even though its own analysis 

states that "[t]hese methods have not been demonstrated to be effective," and that they "reduce plant and root 

vigor" by compacting the soil.

Response: It appears that the proximity in the final environmental impact statement of Table S-7 to 

the text quoted by the commenter may contribute to some confusion. Table S-7 (p. 29) shows the 

maximum acreage that could be treated by the combination of methods shown. Weed species would 

be treated by multiple methods, using those that are most effective. For example, spotted knapweed 

could be treated using herbicides, grazing, and by manually pulling. Appendix 7 (final supplemental 

environmental impact statement pp. 193-196) displays the treatments expected to be most effective 

for each species. More than one treatment is listed in alternatives B and C because different species 

respond to different treatments depending on their ecology and location.

Mechanical methods may include mowing, girdling, or root tilling (final supplemental environmental 

impact statement p. 28). Mechanical treatments may be a preferred method of control given specific 
Invasive Plant Control Project

212

site conditions. The conditions under which a given treatment method could be used and limitations

are provided in Table S-10 (p. 31). 

The full paragraph referenced by the commenter is found on p. 29 of the final supplemental 

environmental impact statement and discusses mowing and root tilling as types of mechanical 

controls which may occur incidental to road maintenance actions, and does not propose a presumably 

ineffective treatment method. In full, the paragraph reads, “Mowing and root tilling employ large 

mechanized equipment such as tractors with specially designed attachments. These methods have not 

been demonstrated to be effective in eradicating or substantially reducing weed infestations, and 

typically require repeat treatments. They do reduce plant and root vigor. Feasibility for these two 

methods is also quite limited on the two national forests due to the steep slopes and other common 

terrain features such as tree, boulders, or logs. Thus this method is only likely to be fore minor, 

incidental use mainly along highways in conjunction with ongoing road maintenance actions. Most 

mechanical treatment is proposed in combination with another method.”

Associated Comments

Mechanical treatment, employing heavy equipment such as tractors, has increased even more 

spectacularly. The FEIS only proposed to do this on 162 acres. Now the DSEIS proposes to treat 

12,713 acres this way, even though, on the same page that it proposes to do this (p. 17), it states that 

"[t]hese methods have not been demonstrated to be effective," and that they "reduce plant and root 

vigor" by compacting the soil.

Concern: The Forest Plan amendment should not be "nonsignificant" because it allows the use of herbicides 

in municipal watersheds, in areas of human habitation, and on soils with low revegetation potential.

Response: This project's forest plan amendment for the Santa Fe National Forest will be conducted in 

conformance with the 1982 planning rule provisions as allowed by the 2012 Planning Rule since the 

amendment process was initiated prior to May 9, 2012 (36 CFR 219.17(b)(3)). Under the 1982 

planning rule provisions, a significant amendment results when: 1) the proposal will significantly 

alter the long-term relationship between multiple-use goods and services originally projected or 2) the 

proposal will affect land and resources throughout a large portion of the planning area during the 

planning period (Forest Service Manual 1926.52).

Associated Comments

The Forest Plan Amendment, now allowing the use of herbicides in municipal watersheds, in areas of 

human habitation, and on soils with low revegetation potential, is suddenly labeled a "nonsignificant" 

amendment.

Concern: The Forest Service should not use herbicides to treat weeds because the need to do so has not been 

proven. The acreage of weeds appears to be holding steady without the use of herbicides. Since most 

infestations are still small, herbicides are not necessary.

Response: In New Mexico, the occurrence of weed species is increasing. Existing populations are 

predicted to spread, and new weed infestations are projected to appear each year (Renz 2004). While 

the number of known weed infestation sites on the two national forests is still relatively small, 

occupying less than half of 1 percent of the 3 million acres of land in the Carson and Santa Fe 

National Forests, there are likely more weed infestation sites not yet discovered (final supplemental 

environmental impact statement, p. 14).

Chapter 1 of the final environmental impact statement (pp. 13-34) and final supplemental impact 

statement (pp. 13-26) describes the reason the two forests have pursued this project. As noted, the 

small amount of infestations can be controlled now rather than later, so impacts of treatment would be 

smaller and the costs lower. The potential impacts of weeds known to exist on the Santa Fe and 
Final Supplemental Environmental Impact Statement

213

Carson National Forests are provided in appendix 2 (final environmental impact statement pp. 213-

221 and final supplemental environmental impact statement pp. 181-183). The final supplemental 

environmental impact statement and final environmental impact statement examine three alternatives 

to controlling current (and newly found) infestations. Comparison of effectiveness of the three 

alternatives is provided. The project is consistent with law, regulation, and policy, and is consistent 

with the Santa Fe National Forest Plan (final supplemental environmental impact statement p. 167). 

The risk assessments provide a review of the use of herbicides in riparian areas and the potential 

impact to aquatic plants and animals. Selecting the proper herbicide formulation for the situation and 

then following label directions assures this risk remains low. Some weed species, such as saltcedar, 

are most effectively controlled with the use of herbicides; other weeds can be eradicated by manual or 

mechanical means only.

The final supplemental environmental impact statement discloses cumulative actions considered in 

the effects analysis. Table S-14 (pp. 44-47) lists projects considered as past and present actions. Table 

S-15 (pp. 47-48) lists projects considered as reasonably foreseeable future actions. A summary of 

cumulative actions for each key resource is provided in Table S-16 (pp. 49-50). Specific information 

on past, present, and reasonably future weed control activities are described in appendix 1 of the final 

supplemental environmental impact statement (pp. 201-211). Because no forestwide, integrated weed 

treatment strategy exists, any herbicide use proposed for these projects would have been considered

on a project-by-project basis in the appropriate National Environmental Policy Act analysis. 

Associated Comments

The Forest Service admits that the Carson and Santa Fe National Forests are not being inundated by 

weeds, and that the area occupied by weeds is no larger now than it was nine years ago. It now says 

that 15,260 acres are occupied by weeds, up from 7,260 acres, but the agency states that "the increase 

in weeds in the project area is mostly explained by more surveys of the locations of weeds," and not by 

an actual increase. Yet the agency has come back with a plan to spray, in perpetuity, lands throughout 

the over 3 million acres of these forests, including wilderness areas, inventoried roadless areas, wild 

and scenic rivers, research natural areas, endangered species habitat, municipal watersheds, highly 

used developed recreation areas, and areas of human habitation, repeatedly with up to thirteen different 

toxic herbicides, which do not distinguish between healthy and sick, young and old, and which will 

render all of our public lands permanently inaccessible to a large disabled population. The DSEIS did 

not fully disclose under what guidelines the FS has been managing the invasive plants since that time. 

Specifically what measures have been used in the past 8-10 years since the ROD reversal, and where? 

If noxious plants were such a problem back in 2004 when the FEIS came out, how and where has the 

FS been addressing the problem in the meantime while the DSEIS was being written? Was the problem 

ignored? Was a nonchemical approach used? If so, how successful was it? If successful, why not 

continue with a non-herbicide approach? Was the herbicide ban lifted without the affected 

communities being informed, including the City of Las Vegas which passed a resolution in 2006 in 

strong opposition to the FEIS, including herbicides in the Gallinas Watershed? Though general 

comments were made (nearly identical to the FEIS), no specific explanation was presented in the 

DSEIS. The DSEIS states that “[m]ost infestations [of invasive plants] (more than 75 percent) are less 

than 1 acre” DSEIS at 6. This fact makes it clear that the invasive plant problem on the Carson and 

Santa Fe forests is still at a point where it can be managed without widespread herbicide use.

Note: The estimated acres occupied by noxious weeds is actually 13,260. There was a typographical 

error in the draft SEIS that reported the acres as “15,260”. The estimated acres are 13,256 which is 

rounded to 13,260. 

Concern: The design features and monitoring requirements for this project do not include any instruction for 

monitoring for potential spread or introduction from controlled grazing operations. It is important to include 

direction for this specific project method in order to ensure that grazing is not inadvertently facilitating the 

spread of invasive plants to other forest lands or outside forest lands.
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Response: The final supplemental environmental impact statement and final environmental impact 

statement recognize the potential for controlled grazing to inadvertently disperse weed seeds and 

proposes counteractive measures through management considerations. Pages 39 - 40 of the final 

environmental impact statement state,"... sheep and goats will not typically graze the target weed 

species to the exclusion of native plants. Another consideration is that weed seeds may adhere to the 

coats of long-haired breeds of goats, or the fleece of sheep, which could contribute to the spread of 

weed seeds if not addressed in the application of the method (that is, require animals to be sheared 

prior to entering an infestation). Animals should be confined to a restricted area for an appropriate 

length of time after moving from an infested area when there is a concern that viable weed seeds may 

be spread through the animals’ feces." 

Further, controlled grazing is proposed as a minor, incidental treatment method requiring evaluation 

for its effectiveness. A site-specific operation plan, which could include the measures suggested by 

the commenter, would be developed for each treatment area. The plan would consider the target 

species, type of livestock, forage preference, planned grazing intensity, herding characteristics, 

topography, water availability, season of use, and a monitoring program (final environmental impact

statement, p. 40).

Finally, the Forest Service recognizes the potential for native plants to be removed causing soil

exposure and proposes a mitigation measure for it (final supplemental environmental impact 

statement, p. 34, design feature #19). Effectiveness monitoring will be incorporated as described at 

design feature #60 (p. 38).

Associated Comments

One of the proposed methods for invasive plant removal through this project is “[c]ontrolled grazing 

using goats and sheep to intensively and repeatedly graze weeds.” DSEIS at vi. The treatment 

objectives for this project are eradication, control, and containment. DSEIS at vii. The DSEIS asserts 

that “[p]roperly managed, controlled livestock grazing can work in combination with other methods to 

reestablish healthy, resilient native plant communities.” DSEIS at 50. While targeted grazing by sheep 

and goats can successfully control some invasive plant populations, there is also a risk of spread of 

invasive plants by ungulates through seed dispersal, selective grazing, and soil disturbance. (Vavra et 

al. 2007). Therefore, this type of invasive control method should be carefully implemented and 

monitored. However, the design features and monitoring requirements for this project do not include 

any instruction for monitoring for potential spread or introduction from controlled grazing operations. 

It is important to include direction for this specific project method in order to ensure that grazing is not 

inadvertently facilitating the spread of invasive plants to other forest lands or outside forest lands. We 

recommend including the following restrictions for sheep and goat grazing as part of this project: 

• Sheep and goat grazing should be restricted to areas in which seasonal seeding has not yet 

occurred

 • Keep sheep and goats that have grazed on invasive plants in a holding field for 24-48 hours 

before relocating them 

• Maintain intensity and duration of grazing at a level that minimizes disturbance to native plants

Concern: The requirement to reseed or replant after treatment has been deleted. The Forest Service no longer 

pretends to care whether anything grows back, least of all native plants. The only important purpose of this 

project is evidently to use as many chemicals as possible regardless of the outcome.

Response: Reseeding after treatment remains an option (final supplemental environmental impact 

statement, p. 34, design feature #19). The mandatory requirement to reseed has been removed 

because in some situations, native plants will naturally recolonize.
Final Supplemental Environmental Impact Statement

215

Alternatives

Concern: The Forest Service fails to consider the reasonable alternative of preventing weeds and educating 

people about the spread of invasive plants.

Response: The Forest Service considered the alternative of preventing weed infestations (final 

environmental impact statement p. 36). It is not an alternative analyzed in detail for three reasons: 1) 

National Environmental Policy Act analysis is not required to implement prevention measures, 2) 

prevention alone would not meet the purpose and need, and 3) the Carson and Santa Fe National 

Forests regularly implement prevention measures as part of other projects (for example, requiring 

vehicles to be washed prior to entering project areas).

As discussed on page 31 of the final environmental impact statement, the scope of this project and 

decision does not extend to weed prevention and education activities. While the staff on the Carson 

and Santa Fe National Forests recognizes prevention and education are essential components of an 

overall integrated weed management strategy, proactive weed prevention and educational activities 

are already being implemented and do not require additional environmental analysis and decisionmaking under the National Environmental Policy Act.

As discussed on page 36 of the final environmental impact statement, the "prevention" alternative 

would not meet the purpose and need because it would not effectively reduce existing weed 

infestations or address the detrimental impacts of those infestations. It would not reduce the threat 

from undiscovered weeds that exist now or are expected to invade despite preventative measures. 

Weed prevention is already being used on both national forests and is often integrated as a mitigation 

measure during planning for ground-disturbing projects, such as the requirement to wash vehicles 

prior to use on the two national forests.

Associated Comments

The people need to be made aware of the different toxic weeds. I have seen people pick the weeds 

because they have a pretty bloom not knowing how toxic the weeds are to people and animals. I have 

also seen hunters just drive their 4 wheelers through the weeds. Which that means they are carrying the 

weed seeds on the tires and distributing them elsewhere. Also hikers and horseback riders do the same 

thing....My biggest complaint about the weeds is that everyone just rides, walks and pick them. Those 

people are not realizing that they are transplanting everywhere. The project fails to consider the 

reasonable alternative of prevention....The DSEIS fails to consider the reasonable alternative of 

prevention. The purpose of the project is “controlling invasive plants designated by New Mexico as 

weeds” (FEIS, p. 13). (“The purpose and need for controlling or eradicating weed infestations on the 

Forests is to maintain or improve the diversity, function, and sustainability of desired native plant 

communities on the Forests”; “Controlling the spread of weed species is now a regional and national 

priority in the Forest Service....”). Prevention is widely acknowledged to be an effective means of 

controlling weed infestations. Nonetheless, the USFS refused to consider an alternative that contained 

thorough measures to prevent the spread and establishment of weeds....The DSEIS briefly 

acknowledges that weed infestations occur along roads and at natural gas wellheads but never discloses 

or discusses other causes. Having failed to fully and thoroughly disclose the causes of weed 

infestation, the DSEIS then refuses to consider prevention as a viable alternative. In several places, 

the DSEIS defines the project’s purpose as weed control. Prevention is an obvious and reasonable

approach to achieving that purpose. Prevention reduces the frequency and severity of weed 

infestations, including reinfestation after treatment....NEPA requires the consideration of all reasonable 

alternatives; there is no exception, and no apparent basis in the DSEIS, for refusing to evaluate an 

action that is already being done. Moreover, the claim is not supported by the record. At most, the 

DSEIS supports a conclusion that the prevention activities are sporadic. For example, the only specific 

prevention measure mentioned is washing vehicles, and even then, the DSEIS does not say which 

vehicles, where, when and how. Certainly, the USFS is not monitoring all the roads and trails in the 

national forests, hoses at the ready. The DSEIS also suggests that some individual projects contain 

weed prevention measures, but it is not clear which projects, what measures and how 
Invasive Plant Control Project

216

effective....Because prevention is a reasonable alternative to achieving weed control, both now and in 

the future, the Forest Service’s failure to consider it violates NEPA. The USFS has a legal duty to 

evaluate all reasonable alternatives, and the prevention alternative satisfies the project purpose. Other 

national forests have adopted a wide range of prevention measures to control weeds, including 

cleaning vehicles entering the national forest, requiring certified weed-free hay for pack animals, 

designing projects to minimize impacts to weed-suppressing canopy-type vegetation, minimizing soil 

disturbance and other conditions that promote weed germination and establishment, revising grazing 

allotment management plans to incorporate invasive plant control measures such as closing infected 

pasture, designating infected pastures as unsuitable until infestations have been treated, managing the 

timing, duration, and intensity of grazing to maintain the vigor of native plants and retain live plant 

cover and litter, and restoring areas of concentrated use such as loafing and watering sites, controlling 

vehicle traffic through areas of known weed infestation, and enforcing OHV restrictions. The 

managers of these forests, 8 like many weed experts, understand that these measures are easier, more 

environmentally desirable, 

The Forest Service clearly acknowledges the problem of continued introduction and spread of invasive 

plants, and concedes that “it appears the overall trend is towards the establishment of new weed 

populations.” DSEIS at 53. For example, weeds could establish themselves in areas where activities 

disturb soil, such as thinning, firewood gathering, prescribed burning, dispersed recreation, grazing, 

road maintenance, road building, and decommissioning even with preventive measures in place. 

Ongoing, common activities in the Carson and Santa Fe National Forests by weekend recreationists, 

forest firefighting crews, grazing allotment permittees, or livestock all have the potential to 

unknowingly spread weeds from one location to another, bring them onto National Forest System 

lands, or spread them onto other lands. Id. However, this proposed project does nothing to address 

those sources or reduce the continued introduction of invasive plants. Without including a 

comprehensive strategy to address introduction and spread of invasive plants, it is impossible for the 

Forest Service to assert in good faith that carrying out any alternative will result in the eradication and 

containment of all invasive populations on these forests. See DSEIS at 42. 

Concern: The Forest Service should use herbicides only in extreme situations where other methods are found 

to be ineffective. If the Forest Service makes a decision to retain herbicide use as an allowable action for this 

project, it should limit such use to areas in which no other methods would be effective, effectively making 

herbicide use a treatment of last resort.

Response: Through experience with similar Forest Service efforts, we know herbicides are the most 

effective treatment method for eradicating or controlling the weed species that currently exist on the 

two national forests, especially when used in conjunction with an integrated treatment effort that 

improves the effectiveness of nonchemical treatments, either concurrently or as follow-up treatments. 

Herbicides are being proposed for weed sites where non-herbicide methods do not seem feasible or 

appropriate, due to ineffectiveness of other treatments, species characteristics, population size, 

treatment priority and objective, or access or terrain limitations of other methods (final environmental 

impact statement, p. 37). 

Associated Comments

According to the Forest Service’s summary of treatments for Alternative B, herbicides could 

potentially be used on every single affected acre within the Forest. DSEIS at 17, tbl. S-7. As 

Alternative C demonstrates, herbicides are not necessary to eradicate or control invasive plants. Rather, 

if implemented properly using an adequate number of Forest Service personnel and volunteers, a 

variety of other methods can lead to the eradication and control of invasive plant species. Therefore, 

the Forest Service should use herbicides only in extreme situations where other methods are found to 

be ineffective. If the Forest Service makes a decision to retain herbicide use as an allowable action for 

this project, it should limit such use to areas in which no other methods would be effective, effectively 

making herbicide use a treatment of last resort.

Concern: The Forest Service does not discuss the fact that volunteers and community members would be 

available to assist in execution of this project, especially if the project does not require the application of 
Final Supplemental Environmental Impact Statement

217

herbicides requiring special training. The Forest Service should more seriously consider the potential 

availability of volunteers and how this may facilitate faster and more effective treatment under Alternative C.

Response: The Forest Service relies on volunteers for many types of field work. In 2014, volunteers 

contributed approximately 13,000 hours of work for the Santa Fe National Forest alone. The types of 

work performed were clearing and repairing trails, repairing bridges, cleaning up trash, inspecting 

trails, and installing signs. We expect some people would be interested in treating weeds but 

anticipate it would be a very small percentage, and even smaller in backcountry locations. We do not 

anticipate, based on past interest in weed treatment projects, volunteers would be able to treat 

significant acreages of weeds in a manner that would completely eradicate them; for example, some 

weed patches would need repeated treatment for up to 10 years before weeds would be eliminated.

Associated Comments

The Forest Service relies on the fact that due to funding levels “the acres treated would logically be 

fewer in alternative C than alternative B,” therefore under Alternative C “it is likely that the rate of 

weed spread would exceed the rate of weed control.” DSEIS at 51. However, the Forest Service does 

not discuss the fact that volunteers and community members would be available to assist in execution 

of this project, especially if the project does not require the application of herbicides requiring special 

training. The Forest Service should more seriously consider the potential availability of volunteers and 

how this may facilitate faster and more effective treatment under Alternative C.

Concern: Include information about alternatives to herbicides and why these alternatives were not used in 

lieu of herbicides to control invasive plants. If the alternatives to herbicides weren’t used because of extra 

cost, indicate the cost difference between the alternatives and herbicides. If the alternatives are less effective 

than herbicides include data and information supporting the claim. Purge the EIS of all insane statements 

describing the false dangers of these methods.

Response: Alternative B (the proposed action) proposes an integrated approach to control invasive 

plants, recognizing one treatment method alone is not likely to be effective. The integrated approach 

includes herbicides, biological controls, grazing, manual removal, mechanical treatments, and 

prescribed fire. A cost-benefit analysis was provided in the final supplemental environmental impact 

statement (pp. 165-166), which included the treating and monitoring of known and new weed 

infestations.

Alternative C was developed as an alternative which involves conducting weed treatments over the 

same acres as Alternative B, except no herbicides would be used. Table S-13 (final supplemental 

environmental impact statement p. 13) provides a comparison of alternatives based on the significant 

issues or effects, as well as how well the alternatives meet the purpose and need (objectives) for the 

project. The comparison table is intended to provide the public and decision makers with a basis for 

choice between alternatives.

Effects Analysis

Concern: No scientific consensus on the effects of herbicides to human health exists. Thus, the burden of 

proof showing that herbicides cause no harm to people is on the Forest Service. Until the agency can prove 

that no harm will be done, it should abstain from using herbicides.

Response: The precautionary principle has another aspect, which is a lack of scientific evidence does 

not preclude action if damage would otherwise be serious and irreversible. If there are threats of 

serious or irreversible environmental damage from not acting, a lack of full scientific certainty should 

not be used as a reason for postponing measures to prevent environmental degradation. 
Invasive Plant Control Project

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In its proposal, the Forest Service has undertaken careful measures to avoid, wherever practicable, 

harm to people, wildlife, and other natural resources when using herbicides. The 58 design features 

listed on pages 33 through 38 of the final supplemental environmental impact statement ensure the 

risk of herbicide use is at a minimum. For instance, areas would be closed during application. Further, 

Environmental Protection Agency registration includes an assessment of risk given the toxicity of a 

substance and expected use and exposure. The Environmental Protection Agency regulates the use of 

registered products so the more likely a dose is to exceed the level of concern, the more heavily 

regulated the use. This provides an overall level of assurance no harm will come to people or animals 

from the use of the products.

When viewed against the extremely low risk of exposure, the environmental damage posed by not 

controlling or eradicating weeds is much greater. As described in the final environmental impact 

statement and final supplemental environmental impact statement, weed invasion and spread results 

in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water 

quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental 

impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13-

14). The potential impacts of specific weeds known to exist on the Santa Fe and Carson National 

Forests are provided in appendix 2 (final environmental impact statement pp. 213-221 and Table S-53 

(p. 118) of the final supplemental environmental impact statement.

Associated Comments

While concerns about non-native species are justified, it is rarely mentioned that by far the most 

destructive invasive species in the U.S. are non-native humans. This proposal is a prime example of the 

human compulsion to meddle in processes largely beyond our control with the likely outcome that 

many of the actions taken will cause more harm than good. In the case of using herbicides, the hazards 

are certainly not worth the risks. requested that USFS address the concern of cumulative effects. The 

DSEIS does include a section with this topic but includes statements such as (P 40)"risk of exposure 

[to wildlife] is immeasurable" so "cumulate effect cannot be measured" but "unforeseen accidents 

expected." We propose that this immeasurable risk is too much risk and should either be soundly 

measured or this alternative should be rejected on the basis of the precautionary principle. 

The Forest Service relies on the fact that “risk assessments concluded that potential risks of harm to 

most wildlife species are low for herbicide formulations proposed for use at the rates and application 

methods proposed” for the conclusion that “herbicides, when used at the application rates and 

concentrations listed on the labels, would have a very low risk of causing harm (short or long term) to 

wildlife species.” DSEIS at 60. However, a risk remains and there is no information available at this 

time as to the effects on wildlife species from exposure to the combination of herbicides that could 

potentially be used in this project. Moreover, the herbicides proposed for use, as identified in the 

DSEIS at pg. 160, table S-64, have been found to have negative impacts on plant and animal species. 

See DSEIS at Appx. 3. Additionally, numerous other studies have identified negative impacts on plants 

and animals from these herbicides. Aminopyralid and picloram can negatively impact ponderosa pine. 

(Wallace et al. 2012). 2,4-D is an endocrine disrupting chemical that has been documented to harm 

wildlife species through hormone disruption. (Colborn et al. 1993). Dicambia, glycophosate, triclopyr, 

and 2,4-D can cause animal mortality and other adverse effects. (USDA 2007). While these impacts 

may be mitigated by the amount of herbicides used in project treatments and through other mitigation 

measures, it is likely that chemical application throughout forest lands will negatively impact wildlife 

in some way. Moreover, use of herbicides always involves a risk to human health and safety. The 

Forest Service should take a precautionary approach to actions that have the potential to negatively 

impact plant and animal populations on National Forests, especially where the possible effects are 

uncertain. Due to the wide variety of other methods available to deal with the invasive plant problem 

on the Carson and Santa Fe National Forests, the Forest Service should avoid using herbicides for this 

project to minimize risk and prevent unintended or unforeseen negative impacts to plant and animal 

species. 
Final Supplemental Environmental Impact Statement

219

Concern: The proposal to treat over 15,000 acres with a variety of herbicides will result in decreased viability 

and the unacceptable death of some native plants.

Response: The Forest Service would treat weeds by the method best suited for eradicating or 

controlling them. Though herbicides are listed as an option for treating all weed species (final 

supplemental environmental impact statement, appendix 7 pp. 193-196), they may not be the first 

choice or most effective method for the species or combination of species present. 

The Forest Service expects to treat an average of 600 to 1,600 acres of weeds each year, with a 

maximum of no more than 3,000 (final supplemental environmental impact statement, p. 52). 

Protections for native plants are mandated (final supplemental environmental impact statement, pp. 

34-35, design features #15-32). By treating smaller acreages, the Forest Service will be able to 

monitor the effects of treatments on native plants and adjust future treatments accordingly to prevent 

harmful effects (final supplemental environmental impact statement, p. 38, design features #60-61).

On balance, weeds are more harmful to native plant communities than weed treatments. Weeds 

threaten the biological diversity of native plant communities, ecosystem processes, and rare or special 

status plants. Weeds are highly adaptable and adept at usurping available moisture and nutrients, 

quickly spreading, and supplanting native vegetation. Weed infestations invariably lead to (1) a 

decline in abundance of native plants that occupy the same or similar habitats as the weeds, (2) 

undesirable changes in site conditions such as soil pH that may be vital to native plant survival, and 

(3) an overall loss in the richness and diversity of native plants (final supplemental environmental 

impact statement p. 52).

The potential effects to vegetation, including native species, and to special status plant species is 

presented in the final supplemental environmental impact statement (pp. 56-65). 

Associated Comments

One of the purposes of the project was originally to encourage "culturally important plants such as 

osha, wild spinach, willow, and purslane" which decline where weeds occur. This purpose has been 

deleted, perhaps because those culturally important plants will be decimated, not encouraged, by the 

quantities of herbicides now envisioned. However, as currently proposed, Alternative B and 

Alternative D would allow the use of herbicide application on every acre needing treatment, either 

alone or in conjunction with other treatment methods. DSEIS at 47-50. Due to the functionality of 

herbicides, it is likely that treating over 15,000 acres with a variety of herbicides will result in 

decreased viability and death of some native plants within both the Carson and Santa Fe National 

Forests. The Forest Service recognizes those threats in the DSEIS: “Effects [of herbicide use] would be 

a change in composition of forbs, grasses, and shrubs in treatment areas. Nontarget plants could be 

damaged by unintentional application, drift, or residual soil activity of herbicides.”

Concern: The Forest Service has not addressed the possibility that invasive plants will become resistant to 

herbicides, thus requiring treatment with new herbicides and the hazards that go along with them.

Response: The final environmental impact statement addresses the possibility invasive plants will 

become resistant to herbicides (pp. 37-38). Weeds can potentially develop resistance to herbicides if 

used repeatedly (final supplemental environmental impact statement, p. 61). To reduce this 

possibility, herbicides would be used in rotation with other methods (final environmental impact 

statement, p. 38). Where weeds have demonstrated resistance to herbicides (expected to be a rare 

occurrence in the two national forests) mixtures could be used (final environmental impact statement, 

p. 37).

Only those herbicides analyzed for use (final supplemental impact statement, p. 28) can be used under 

this decision. New herbicides would be subject to additional NEPA analysis.
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Associated Comment

Herbicides are not a viable option for use in perpetuity: Page 33 of the DSEIS states that "activities are 

anticipated to occur over approximately 10 years (or more)..." with activities increasing over the 10 

year period (p 34). We wish to raise concerns regarding the development of resistance which is 

happening in other areas which have been treated with herbicides over a number of years, requiring 

that they be treated with alternative herbicides....Why are herbicides not used only as a last resort? 

What steps will be taken to address the possibility of the development of resistance?

Concern: The length of time that herbicides remain in soil is not consistently described in the effects analysis, 

thereby rendering a sound decision on their effects to resources impossible.

Response: The length of time (half-life) herbicides remain in soil is dependent on many factors. 

Among these are the method and amount of herbicide actually applied to the soil (surface application 

of a herbicide directly onto or into the soil, incidental “drip” onto the soil surface from application to 

weed foliage), and the volatility characteristics of a particular herbicide. This analysis offered a 

variety of studies examining this question, each with variables that make direct comparison of the 

results of those studies difficult. Mitigation measures and design features included in the final 

environmental impact statement and the final supplemental environmental impact statement were 

developed to minimize the risk of direct application of herbicides to the soil and focus treatment 

methods directly to the weed species being treated rather than broad scale and indiscriminate 

application of herbicides that would surely increase the risk and effects to the soil, water, and aquatic 

life resources. Specific herbicide characteristics, including half-life, is provided in appendix 3 of the 

final environmental impact statement (pp. 223-285) and final supplemental environmental impact 

statement (pp. 185-192).

Associated Comments

What is the half-life of the herbicides? 24 hours? One year? Three years? More? Does anybody know? 

The Forest Service seems to use whatever number it needs in order to support the point that it wants to 

make on a particular page. On page 95 of the DSEIS it claims that "[t]he risk of herbicides leaching 

through the soil into groundwater is low" because "[t]he half-lives (the time it takes for half the active 

ingredient to degrade) of most of the herbicides are 24 to 48 hours." Therefore, it says that "[t]he direct 

and indirect effect to groundwater quality from the action alternatives is minor to immeasurable." (at p. 

108). Then a few pages later, it says that "[h]erbicides are expected to have effects on soils for a year." 

(at p. 115). Then it says that glyphosate has a half-life of up to "several years." (at p. 116). Then it says 

that picloram "last[s] longer in soil" and is highly leachable. (at p. 118). And the FEIS says that 

"[p]icloram can be highly leachable in some soils" (at p. 319), that it "maintain[s] toxicity to plants for 

up to 3 years" and that "[t]he half-life can vary from one month to 3 years." (at p. 273).

Concern: The following statement contained within the DSEIS is misleading and arbitrary and should be 

removed: By controlling the spread of weeds and protecting native plant communities, habitats and watershed 

conditions on the two national forests, alternatives B and D would maintain or enhance social or economic 

conditions, particularly for local rural communities in northern New Mexico who typically rely on the two 

national forests’ natural resources for their livelihood, traditional culture and quality of life. DSEIS at xii, 29. 

Alternative C would also maintain social and economic conditions by achieving the same result, albeit 

through different means. By abstaining from including Alternative C in this paragraph, the Forest Service 

suggests to readers that it would negatively impact social or economic conditions, which is unsupported by 

any evidence presented by the Forest Service.

Response: Upon review, we agree with the comment. Any of the action alternatives are expected to 

maintain or enhance social or economic conditions for local rural communities over the no action 

alternative. Alternatives B and D would treat more acreage with more success than alternative C in

the same period. The statement has been removed from the final supplemental environmental impact 

statement.
Final Supplemental Environmental Impact Statement

221

Associated Comments

Finally, the following statement contained within the DSEIS is misleading and arbitrary and should be 

removed: By controlling the spread of weeds and protecting native plant communities, habitats and 

watershed conditions on the two national forests, alternatives B and D would maintain or enhance 

social or economic conditions, particularly for local rural communities in northern New Mexico who 

typically rely on the two national forests’ natural resources for their livelihood, traditional culture and 

quality of life. DSEIS at xii, 29. Alternative C would also maintain social and economic conditions by 

achieving the same result, albeit through different means. By abstaining from including Alternative C 

in this paragraph, the Forest Service suggests to readers that it would negatively impact social or 

economic conditions, which is unsupported by any evidence presented by the Forest Service.

Concern: Herbicide use in areas having low revegetation potential will result in increased rates of soil 

erosion because studies show that these areas will not revegetate over more than 10 percent of their area 

within 6 months.

Response: Revegetation potential of a soil is defined by physical characteristics (texture, depth, etc.) 

of the soil and prevailing climate characteristics of the locale. While there is some risk of soil loss and 

loss of water quality associated with soils with low revegetation potential, there is far greater risk to 

soil and water resources from establishment and spread of invasive weeds on these sites. Without 

treatment to address the establishment and spread of invasive weeds on soils with low revegetation

potential, the risk of resource impacts and loss of ecosystem services is far more likely. This project 

includes a design feature #19 to specifically address the need to revegetate soils (final supplemental 

environmental impact statement p. 34)

Associated Comments

Concerning the clause of the amendment allowing spraying in areas with low re-vegetation potential 

(P117), we disagree that negative impacts will be overcome within 6 months. Other research has 

shown areas with low re-vegetation potential may not recover more than 10% of their vegetation cover, 

which still exposes 90% of the ground to potential erosion by wind and water. Sites with low re 

vegetation potential tend to already have low hydrologic integrity. (http://ageweb.nmsu.edu/saltcedar/Restoration%20in%20the%20Southwest.htm <http://ageweb.nmsu.edu/saltcedar/Restoration%20in%20the%20Southwest.htm> ) We...more attend be paid to 

mitigation efforts and find that the current mitigation techniques proposed are inadequate or none. 

Without such mitigation, higher rates of soil erosion could result in decreased water quality, exceeding 

the MCL/TDML within the river, leading to noncompliance with the Clean Water Act and potentially 

addition...impacts on downstream municipalities.

Wildlife

Concern: The Forest Service fails to adequately analyze the effects of the project on the white-tailed 

ptarmigan.

Response: Additional information concerning white-tailed ptarmigan population trends has been

added to the final supplemental environmental impact statement. The effects of all alternatives on the 

white-tailed ptarmigan were analyzed in the final supplemental environmental impact statement (pp. 

65-94). On page 70 of the final supplemental environmental impact statement, Table S-32 shows

population and habitats for white-tailed ptarmigan. On page 75 of the final supplemental 

environmental impact statement, Table S-33 (effects to management indicator species) displays

effects of the alternatives to white-tailed ptarmigan as a management indicator species. The weed 

management alternative B, C, and D would results in “No impacts to population or habitat trend are 

expected because weeds aren’t expected to thrive at these higher elevation alpine and subalpine 

habitats, so very little of the ptarmigan habitat would be treated on an annual basis. This means at any 

time, over 99 percent of the ptarmigan’s habitat would be intact.” On page 83 of the final
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222

supplemental environmental impact statement, Table S-37 shows the estimated amount of habitat for 

white-tailed ptarmigan (Forest Service sensitive species) with the estimated acreage of known weed 

infestations within associated habitat and percent of habitat infested with weeds. On page 87 of the 

final supplemental environmental impact statement, Table S-41(sensitive species: effects to birds)

analyzes and discusses the alternatives and effects to the white-tailed ptarmigan and its habitat. Also, 

the biological evaluation, page 9, states that there will be no impacts expected to the white-tailed 

ptarmigan. The proposed action would not be expected to decrease population viability or cause a 

trend to federal listing of this species.

Associated Comments

The status of the white-tailed ptarmigan has not been further investigated....Deciding Officer 

specifically instructed the Forest Service to do this. Yet the DSEIS retains the identical language that 

was in the FEIS: "Little is known about this avian species in New Mexico, for it lives on the 

windswept tundra above 11,000 feet." The only difference between the two documents is that in the 

DSEIS the Forest Service adds a single unreferenced, unsubstantiated sentence saying "white-tailed 

ptarmigan habitat and population trend are considered stable"-a statement that is contradicted by the 

statement that "little is known" and that was clearly added for the sole purpose of addressing the 

objection of the...Deciding Officer. A statement that addresses the form and not the substance of her 

objection does not comply with NEPA's requirement for a detailed analysis. 

There is still inadequate analysis of the population trend for ptarmigan. 

Concern: The Forest Service fails to sufficiently analyze the effects of the project on the American pika.

Response: The effects of all alternatives on the American pika were analyzed in the final

supplemental environmental impact statement (pp. 65-94). Page 84, Table S-38 (sensitive 

species/mammals), shows the estimated amount of habitat for pika with the estimated acreage of 

known weed infestations in associated habitat and percent of habitat infested with weeds. “The 

American pika inhabits high elevation rocky slopes in the Sangre de Cristo Mountains at elevations 

above 10,000 feet (final environmental impact statement, pg. 89, Table S-42)." Page 89, Table S-42

(sensitive species: effects to mammals), analyzes and discusses the alternatives and effects to the pika 

and its habitat. The American pika was also fully analyzed in the biological evaluation for the final 

supplemental environmental impact statement. The evaluation, p. 12 states the proposed action will 

have no impact on the American Pika as no activities would occur in habitat used by this species.

Associated Comments

The American Pika has been sighted in areas not previously listed hence need more studies to 

determine the claim that there will be no disruption to the American Pika....As sightings of American 

Pika have been confirmed by individuals in areas not currently listed as known habitat. For this reason, 

intensive surveying will have to be done before herbicides can be allowed in an area, as outlined the 

USFS plan. Additionally, it is stated on page 81 that American Pika will not be impacted by herbicide 

spraying as it does not use weeds as a forage. As herbicides are non-specific they will not only kill 

weeds, but impact other palatable plants to the Pika and will therefore pose a threat to an endangered 

species. AMERICAN PIKA, Serpent Lake, 2012: 20 And what of the small bodies of water like this –

the Pika’s watering hole? How is this species to be protected from ingesting herbicides? “No increase 

in weeds and therefore no decrease in grasses are expected within [the pika] habitat.” Not only is that 

not backed up by science, but it’s not even logical. Since their populations are not properly mapped, 

and since the DSEIS provides no documentation or even logic re: the pika’s proposed food supply, this 

species is at risk due to the Project’s Alternative B. The same can be said for the Goat Peak Pika. 21 

The American Pika is now being seen in areas not previously listed. More studies are needed. Who 

will fund those studies? In the above recent photos, taken by Cynthia Riley (one of our individual 

commenters listed here), these American Pika were spotted at Serpent Lake. It is woefully inadequate 

to simply say, as the DSEIS states on p. 81, “no disturbance to the pika from treatments is expected. 

Weeds are generally not consumed by the pika.” Also, with 2,4- D consuming all plants as it is 
Final Supplemental Environmental Impact Statement

223

nonspecific, protection of the Pika food supply will be negatively impacted. And with 2,4-D increasing 

palatability of plants, and as the normal food supply decreases, this increases the poison risk to the 

Pika. And in the FS own words: “Analyses suggest that both chronic stresses (average temperature 

during all of summer, snowpack and growing-season precipitation), acute (hot and cold) temperature 

stresses, and vegetation productivity may all be playing a role in pika declines in the Basin over the 

last decades.” (http://www.fs.fed.us/ccrc/topics/wildlife/mammals/) Will there be carcass searches as 

part of the follow-up protocol, e.g., for at least 14 days depending on the species? Herbicide 

applications are frequently being delayed now due to decreased assurance of the timing of the 

hibernation period for multiple species, including the meadow jumping mouse. (e.g., 

http://www.pesticides.montana.edu/Present/Environmental/Anticoagulants%20training%20A 

ugust%202013%20[Compatibility%20Mode].pdf) 

Concern: The Forest Service fails to sufficiently analyze the cumulative effects on wildlife.

Response: Cumulative impacts of the alternatives are evaluated on past, present, and reasonably 

foreseeable future actions whose direct and indirect effects have the potential to overlap with the 

direct and indirect effects of the alternatives in both time and geographic space. 

This analysis uses current environmental conditions as a proxy for the impacts of past actions. This is 

because existing conditions reflect the aggregate impact of all prior human actions and natural events 

that have affected the environment and might contribute to cumulative impacts.

The cumulative impacts analysis does not attempt to quantify the effects of past human actions by 

adding up all prior actions on an action-by-action basis. A catalog and analysis of all past actions 

would be impractical to compile and unduly costly to obtain. Current conditions are the result of 

innumerable past actions, and trying to isolate the individual actions that continue to have residual 

impacts would be nearly impossible. 

Providing the details of past actions on an individual basis would not be useful to predict the 

cumulative impacts of the alternative. Focusing on individual actions would be less accurate than 

looking at existing conditions. There is limited information on the environmental impacts of 

individual past actions, and one cannot reasonably identify each and every action that contributed to 

current conditions. By looking at current conditions, we capture residual effects of past human actions 

and natural events regardless of which particular action or event contributed to those effects. 

The Council on Environmental Quality issued an interpretive memorandum on June 24, 2005, 

regarding analysis of past actions, which states, “agencies can conduct an adequate cumulative effects 

analysis by focusing on the current aggregate effects of past actions without delving into the historical 

details of individual past actions” (Connaughton, 2005). 

“Reasonably foreseeable future actions are those federal or non-federal activities not yet undertaken, 

for which there are existing decisions, funding, or identified proposals” (36 CFR 220.3). “Identified 

proposals for Forest Service actions are those for which the Forest Service has a goal and is actively 

preparing to make a decision on one or more alternative means of accomplishing that goal and the 

effects can be meaningfully evaluated (40 CFR 1508.23)” (36 CFR 220.4(a)(1)). 

On pages 44-47 and 49-51 of the final supplemental environmental impact statement, Tables S-14 and 

S-16 discuss past and present actions contributing to the cumulative effects baseline and the summary 

of cumulative actions by key resource, including wildlife and fish. 

On pages 65-94 of the final supplemental environmental impact statement, each grouping of wildlife 

species (management indicator species, threatened and endangered species, Forest Service sensitive 

species, and migratory birds) has a cumulative effects analysis section. Cumulative effects analysis is 
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224

provided for fish and aquatic resources on pages 94-102 of the final supplemental environmental 

impact statement.

Associated Comments

The Forest Service has still not analyzed the cumulative effects on wildlife....Deciding Officer clearly 

instructed the agency to "strengthen" and "document" the section on cumulative effects with respect to 

wildlife. The Forest Service has utterly failed to do this. "Strengthening" does not mean merely 

repeating the same conclusory sentence four more times. Yet that is exactly what the Forest Service 

has done, and no more, in the DSEIS. There is still inadequate evaluation and documentation of 

environmental cumulative effects. For example, there is no mention of piscicides being regularly used 

by the NM Game & Fish Department in the Carson Forest, and no analysis of the cumulative impact 

on fish exposed to piscicides along with herbicides applied in or near water. 

Concern: The Forest Service has failed to completely analyze the effects of herbicide use on pollinators.

Response: Per Appendix 9 (Response to Comments) 2005 final environmental impact statement. 

“The DEIS/FEIS, Appendix 3 discusses the known effects to a variety of species. The summary in 

Appendix 3 reflects knowledge presented in the risk assessments. The most likely known information 

involves honey bees because the EPA requires tests on bees as part of the product registration 

process. The risk assessments describe known effects of the proposed herbicides to a variety of other 

species, where studies have been conducted. Indirect effects of the vegetation treatments have also 

been included for MIS and TES species as directed. The risk assessments present information about 

other species, including beneficial invertebrates.” 

Furthermore, Table S-47 (p. 98) of the final supplemental environmental impact statement includes

discussion and analysis of the alternatives and effects of herbicide to the Nokomis fritillary butterfly 

as a pollinator.

Associated Comments

Please no herbicides - they are killing the bees and our environment - don't make it worse by using 

more of these poisons. We remain concerned that the DEIS and the previous one that was appealed in 

2005 failed to completely analyze the effects of pesticide use. Your species of concern, Including 

pollinators (bats, bees, butterflies, etc.) and Amphibians (frogs, toads, lizards, etc.)...All the above 

species are in severe decline both locally and worldwide. The current drought and climate change 

(warming, increased storms, increased erosion etc.) only further threaten populations and habitat of 

these species.... Yet The DEIS fails to acknowledge these species, their declines and how 4) With the 

exception of the Jemez salamander we did not see any discussion of the impact of herbicide use on the 

vital pollinator species-or upon other frogs, toads and lands,... 5) Because of threats to pollinators 

world-wide especially 1) colony collapse disorder in bees. 2) White nose syndrome in bats. 3) Chytrid 

fungus in frogs. These species are threatened with extinction and herbicide use puts them at further 

risk. Because bees, butterflies and bats rely upon plants for host sites, pollen, and nectar. Plants like 

these and the invasive (olive, salt cedar) provide housing for these species. So treatments using 

herbicides on such invasiveness has the potential to harm any bees, bats butterflies, moths and other 

species. The DEIS supplement failed to address their concern or even analyze it. The airborne species 

are critical for ecosystem health and pollination. Herbicide use threatens their viability especially with 

cumulative impacts of airborne diseases, habitat loss and climate change. Also butterflies and moths 

they visit hundreds of plants both native and non-native (invasive and non-invasive included). 

Herbicide use would negatively affect (A likely kill) such species, yet no analysis.... A beneficial 

insect census should accompany these treatments, as bees and butterflies, pollinators especially for 

which flowers are their habitat and they don't discriminate against "weeds". Removing food supplies 

by the acre may be the sort of imbalance that effects hives.... 

Concern: The mitigation of deferring pastures from livestock grazing after herbicide application may protect 

cattle, but is inadequate for protecting wildlife that might ingest plants sprayed, specifically those sprayed 

with 2, 4-D.
Final Supplemental Environmental Impact Statement

225

Response: Per Appendix 9 (Response to Comments) in the final environmental impact statement,

“The DEIS/FEIS, Appendix 3 2,4-D risk assessment describe the toxicity, the likely means of 

exposure, the dose at which harm occurs, and the risk that use at proposed application rates would 

reach such a level. The risk assessment concludes that the risk of reaching levels of exposure that 

would cause harm to people, animals or non-target plants are low. The risk assessment has also 

concluded that links to cancer have not been established. The risk assessment also notes that 2,4-D 

does not contain dioxin, that Agent Orange contained 2,4,5-T, which had a form of dioxin as a 

byproduct of 2,4,5-T manufacture. Herbicides using this active herbicide ingredient are no longer sold 

for use in the U.S. 

The final supplemental environmental impact statement (p. 68, the “Environmental Consequences 

Common to All Species and under Alternative B (Proposed Action)” section) discusses the herbicide 

risk assessments used to evaluate herbicide toxicity effects (USDA Forest Service 1992, SERA 2002-

2007). The risk assessments concluded potential risks of harm to most wildlife species are low for 

herbicide formulations proposed for use at the rates and application methods proposed.

Table S-42 (p. 88) of the final supplemental environmental impact statement includes discussion and 

analysis of the alternatives and effects of herbicide to Spotted and Pale Townsend’s big-eared bats.

Associated Comments

For instance, the FEIS p 167 the statement is made: "The application of the herbicide 2,4-D has been 

shown to increase the nitrate content of plants and the palatability of the plants, increasing the potential 

for poisoning. Mitigation measures that defer the use of pastures treated with herbicides would avoid 

this impact." Deferring pastures may protect livestock but does not prevent exposure to animals. 

Herbicides are nonspecific, so the argument that endangered species (such as American Pika, p 81) 

will not be affected because they do not consume weeds is not a valid argument. The USFS itself 

acknowledges that short-term mortality of natives is expected. Because of this, all wildlife, including 

endangered species, will be exposed to pastures which have been treated with herbicides, and all plants 

in that area have the potential for increased levels of herbicides (toxicity) as well as nitrates with could 

result in methemoglobinemia. Therefore we consider the mitigation proposed by the USFS to be 

inadequate and request further efforts. While some species are listed (p. 78, 80, exc.) under the affects 

table s-41, There is no discussion regarding risk to these animals, i.e., Spotted bat lives in caves and no 

treatments would occur in caves- so it was determined there would be no effect on bats from any 

treatments. If these plants are sprayed with herbicides how would this effect bats and their 

reproductions etc.?

Concern: The mitigation of having a biologist in the field when herbicides are being applied for protecting 

Mexican spotted owls needs to be mandatory, not optional.

Response: The final supplemental environmental impact statement, Table S-11, design feature #37

(p. 36) states: “No prescribed burns will be done within Mexican spotted owl protected activity 

centers. Treatments will be done by hand pulling, grubbing, or herbicide application during part of the 

breading season (early June to mid-July) to be effective. Treatments will be short duration, lowdisturbance activities that would occur once or twice in a season (depending on size of the treatment 

area). A biologist can accompany applicators to monitor any owl activity that might occur. A year 

after treatment, monitoring would be done for any reoccurrence of the weed.”

Analysis presented in Table S-35 (p. 81) of the final supplemental environmental impact statement 

provides the determination of effects for the Mexican spotted owl and rationale for the statement. It 

states the proposed action “may effect, but not likely to adversely affect with an overall beneficial 

effect because treatments would improve the habitat of the prey the owl feeds on. Negligible negative 

effects would be expected given the design features that avoid disturbing owls during the breeding 
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226

season.” It is the agency’s assessment that the proposed action with design features are sufficient to 

provide protections for the Mexican spotted owl.

The phrase “or other qualified person” as referenced by the commenter occurs in design feature #38, 

to evaluate when the ground surface within Jemez Mountain salamander habitat is sufficiently dry 

enough to permit treatments after receiving 5 consecutive days of rain. There are many types of fieldgoing staff who could be qualified to assess suitable soil moisture conditions, which is why it is not 

limited to a Forest Service biologist.

Associated Comments

We wish to draw attention to page 24 DSEIS where the plan allows that a biologist "can accompany 

applicators into the field to monitor for any potential owl activity that may occur." Why is the 

attendance of a biologist not mandated in this section? How will this biologist be funded, and is 

this...We seek clarification as well on the exact definition of an "other qualified person" who is allowed 

to substitute for the biologist required to monitor other endangered species. Are they at the training 

level of a biologist?

Concern: The Forest Service cannot assert that the use of pesticides registered with the EPA will not harm 

listed species because the EPA has not consulted on the effects of individual pesticide registrations under 

Section 7 of the Endangered Species Act.

Response: The registration process by the Environmental Protection Agency is outside the scope of 

this analysis. As background, however, the Environmental Protection Agency provides documents 

that describe the scientific basis for review and risk analysis of each substance they register. The 

Environmental Protection Agency is required by law to review based on the science. The 

Environmental Protection Agency is required to evaluate based on the best evidence available. 

Environmental Protection Agency registration includes an assessment of risk, given the toxicity of a 

substance and expected use/exposure. The Environmental Protection Agency regulates the use of 

registered products so the more likely a dose is to exceed the level of concern (reference dose), the 

more heavily regulated the use. This provides an overall level of assurance no harm will come to 

people or animals from use of the products. 

Scientific review of the information provided occurs by the Environmental Protection Agency and it 

is evaluated for particular herbicide formulations in the risk assessments. Where the conclusions of a 

study have come into question, the risk assessments note these cases, which is generally when a study 

proposes a conclusion that is not supported by the data not a case where data is falsified. The 

Environmental Protection Agency does not make the claim that use of herbicides is risk free or "safe." 

Associated Comments

ESA consultations on herbicide use are flawed given that the FWS has never consulted over the 

registration and re-registration of pesticides. In this case, the FWS has de-facto unilaterally permitted 

the use of toxic pesticides without first ensuring, through the ESA consultation process, that those uses 

will not jeopardize endangered species’ survival or destroy their critical habitat. This procedural and 

substantive 12 flaw is a fatal one to the use of any herbicide in the habitat of listed species. Moreover, 

the limited, cursory analysis provided in the Biological Assessment is not an adequate substitute, even 

if procedurally the agency chose to substitute it for the required and missing consultation on the 

registration and general use of each individual herbicide....Herbicide use does not comply with the 

Endangered Species Act because the EPA has never examined the effects of new and pre-existing 

herbicide registrations on newly listed species. Only the EPA’s use and registration of picloram has 

undergone formal ESA consultation. However, as is detailed below, the mandatory directions that were 

the outcome of that consultation are not being followed and the EPA has never re-consulted to address 

the effects of picloram on newly listed species....Section 7(a)(2) mandates the EPA to ensure that its 

actions will not jeopardize the continued existence of listed species. In this particular case, the EPA has 
Final Supplemental Environmental Impact Statement

227

not adequately discharged its Section 7 obligations because it has not consulted on the effects of 

individual pesticide registrations on the ESA listed Southwestern willow flycatcher, Mexican spotted 

owl, Mexican spotted owl critical habitat, Rio Grande silvery minnow, Bald eagle, and the Holy Ghost 

Ipomopsis. The failure to initiate consultation on pesticide registration is relevant because the EPA 

pesticide approval and registration process is so heavily politicized that the process often does not even 

provide the FWS with adequate information upon which to formulate a biological opinion. 

We believe that because the current Forest Service action and ESA consultation must necessarily be 

tiered to, and rest upon the foundation of an adequate consultation on the pesticide registration itself, 

that the current Forest Service consultation is arbitrary and capricious....What is fundamentally 

different about the factual circumstances surrounding the proposed application of herbicides on the 

Carson and Santa Fe national forests that are most relevant to the adequacy of the ESA consultation on 

the proposed action is that the EPA does not even have partial information on the effects of many of 

these pesticides on listed species. The EPA simply has never engaged in a formal ESA consultation on 

these species. Thus, conclusions by the FWS and Forest Service that the proposed use of the various 

toxic pesticides will not be harmful to listed species are not based on the best available science. In this 

case, the best available science has never been applied because the ESA Section 7 consultation on the 

pesticide registration never occurred.

Concern: The Forest Service fails to address the effects of herbicide use to non-listed species such as the 

American goldfinch, barred owl, and hummingbirds.

Response: In accordance with Presidential Executive Order 13186 (January 2011) multiple migratory 

birds and their habitat types are discussed and analyzed addressing the effects of herbicide 

application. The final supplemental environmental impact statement addresses effects of herbicides

on non-listed bird species (migratory birds) and their habitats on pages 90-94. American goldfinch, 

barred owl, and hummingbirds are not listed specifically. 

Associated Comments

Also bird species often dig truffles, burry pinecones, etc. In addition to eating thousands of small 

insects (ants, spiders, etc.). What about herbicide treatments upon humming birds, songbirds especially 

blue birds and flycatchers that visit invasive plants to clean insects? If such plants are sprayed with a 

toxic herbicide, how will this affect these birds? Also of concern are birds of prey such as the 

Mexican spotted owl, goshawk, bared owl and other species. Many birds' burry pinecones dig truffles 

and get insects from soil under plants. If invasive are treated with herbicide, how will it affect birds or 

nomads that dig under these plants? There is no way to keep wildlife away from sprayed areas 

especially birds and insects as well as small nomads. So even if they may not be directly affected by an 

herbicide treatment, they are likely to ne indirectly affected by toxic sprays. The indicator species 

policy seems inadequate to protect the American goldfinch, a beautiful little bird whose survival is 

dependent on the Bull thistle. If these thistles are invasive, then the American Goldfinch is also 

invasive and what proof do you have that there were none here before Columbus? What will be the fate 

of the American Goldfinch if you target Bull Thistles?... Bull thistles are easy to pull, or mow. While 

Canadian Thistles have crab grass lie root systems and takes years to get out with manual methods. 

Canadian thistles are more invasive and Bull thistles are usually incidental. Using the same treatment 

methods on these two species will endanger the American Goldfinch. The issue is not whether 

herbicides are toxic to the birds and insects, but that certain plant species (which cattle do not like to 

eat) are vital to the food, nesting and other habitat needs many methods devastate symbiotic life forms. 

Concern: Before approving a site-specific project, the Forest Service must gather population data for MIS 

and analyze MIS population within the project area. This duty to monitor is non-discretionary.

Response: Population monitoring data for management indicator species is gathered at the forest 

level. In the final supplemental environmental impact statement, Table S-32 (pp. 69-70) displays the 

two national forests’ management indicator species, the estimated acres of existing habitat, the habitat 

trend, the population trend, and the acres and percent of weed infestations within those habitats.
Invasive Plant Control Project

228

Associated Comment

Before approving a site-specific project the Forest Service must gather population data for MIS and 

analyze MIS population within the project area....Further, the Forest Service cannot rely on habitat 

availability and habitat trends as a substitute for actual quantitative data....Both the Carson and Santa 

Fe Forest Plans obligate the Forest Service to monitor the populations1. A viable population is defined 

as one that has the estimated numbers and distribution of reproductive individuals to ensure its 

continued existence is well distributed in the planning area. Management indicator species are 

surrogates for a broad range of other species that have similar needs. 2 This duty to monitor is nondiscretionary. “Population trends of management indicator species will be monitored.” 36 C.F.R. 

219.19(a)(6) (emphasis added).

Concern: The Forest Service plans on applying herbicides when certain species are hibernating. Hibernation 

periods, however, are changing due to the effects of climate change. The Forest Service has not accounted for 

these changes, and thus could apply herbicides at a time when they are harmful to species.

Response: Depending on the level of protection required by law, regulation, and policy, design 

features and mitigation measures require surveys and/or avoidance and use of seasonal restrictions to 

reduce impacts to wildlife species. Design features incorporated into the proposed action (final 

supplemental environmental impact statement Table S-11, p. 33-38) provide for consideration of 

species whose activity patterns may change, whether as a result of the effects of climate change or 

other factors, by focusing on when habitat is known or presumed to be occupied by wildlife (design 

features #33-36, 38, 40, 41) rather than specific dates or time periods. 

The adaptive management component of the project further ensures the effects will not extend beyond 

the scope of the predicted effects at any given location with any given treatment. The Forest Service 

must monitor the effects of treatments and adjust future treatments to remain within the scope of this 

environmental impact statement or do additional National Environmental Policy Act analysis (final 

supplemental environmental impact statement p. 38, design feature #61).

The potential for effects to wildlife species from the proposed action includes consideration of the 

possibility of exposure to the herbicides proposed for use as discussed under the wildlife risk 

assessment section of appendix 3 (final environmental impact statement pp. 244-248 and final 

supplemental environmental impact statement pp. 188-189).

Associated Comments

In the DSEIS, the NM meadow jumping mouse “hibernates below ground for nearly 9 months and 

emerges in July” (DSEIS, p. 82). The FS is counting on this as fact, and will apply herbicides 

according to this schedule. But this schedule no longer applies due to the effects of climate change. 

Hibernation periods become shorter and shorter, and there has been no consideration for this or other 

climate change factors in this DSEIS. This is a significant flaw that must be addressed. “Termination 

of hibernation is highly sensitive to temperature change. In fact, current global upward trends in 

ambient temperature are having a measurable effect in shortening the hibernation seasons of a number 

of species...” 

(http://labspace.open.ac.uk/file.php/5850/!via/oucontent/course/338/s324_4_bk2_ch4.pdf) 

(http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3894896/)

Concern: The Forest Service should integrate the information related to specific pesticides with the 

discussions of the potential impacts to plant and wildlife species, focusing on how specific species’ viability 

and populations may be affected due to the unique characteristics of the various herbicides. Without 

concurrence on its BA from the US Fish and Wildlife Service, the Forest Service cannot provide updated or 

accurate information as to the likely impact on threatened and endangered species from this project.

Response: The wildlife risk assessment section of appendix 3 in the final environmental impact 

statement (pp. 244-248) describes the effects of herbicides to terrestrial organisms. The final 
Final Supplemental Environmental Impact Statement

229

environmental impact statement also describes the effects of herbicides to aquatic organisms in the 

aquatic risk assessment section (pp. 249-250). The final environmental impact statement (pp. 251-

285) and final supplemental environmental impact statement (pp. 191-192) discuss specific herbicides 

characteristics and environmental effects. The environmental effects include specific herbicide effects 

to terrestrial and aquatic organisms. Biological assessment concurrence on threatened and endangered 

species effect determinations was obtained from the U. S. Fish and Wildlife Service on January 9, 

2015.

Associated Comments

Within the DSEIS the Forest Service repeatedly emphasizes that the action alternatives are not likely to 

adversely affect threatened or endangered plant or animal species. See DSEIS at 56 (“Not likely to 

adversely affect the Holy Ghost ipomopsis”), 72 (“may affect but is not likely to adversely affect, and 

may be beneficial to the Mexican spotted owl” and “may affect but not likely to adversely affect the 

Southwestern willow flycatcher”); see Table S-35. However, the Forest Service has not yet completed 

formal consultation with the FWS for this project. The most recent Biological Assessment (“BA”) 

completed by the Forest Service has not been reviewed by the FWS, so the information provided in the 

DSEIS concerning impacts to threatened and endangered species does not represent the most current 

findings of the FWS. Until such time as the FWS concurs with the Forest Service’s biological 

assessment or issues a biological opinion, the Forest Service cannot provide updated or accurate 

information as to the likely impact on threatened and endangered species from this project. The Forest 

Service needs to supplement this DSEIS once formal consultation with FWS has been completed in 

order to meet the requirements of the ESA and NEPA. The BAs from 2005 (present in the project 

record) and the current Forest Service assessment of wildlife impacts, (presented in the DSEIS) fail to 

include specific information as to the potential impacts of the specific herbicides proposed for use on 

the specific types of plants and animals present within the project area. While the DSEIS provides 

“Specific Herbicide Characteristics and Environmental Effects” analysis for all the propose herbicides 

within Appendix 3 of the DSEIS, these assessments are general in nature and do not address the 

potential impacts to viability and populations of the wildlife or plant species on the Carson and Santa 

Fe National Forests that are discussed within other sections of the DSEIS. The Forest Service should 

integrate the information related to specific pesticides with the discussions of the potential impacts to 

plant and wildlife species, focusing on how specific species’ viability and populations may be affected 

due to the unique characteristics of the various herbicides. As currently written, both the DSEIS and 

the BAs lack adequate information to fully understand the relevant impact of the specific herbicides 

proposed for use in this project. Merely stating that mitigation measures should prevent negative 

impacts is insufficient to meet NEPA requirements that all direct and indirect impacts are disclosed 

and discussed.

Water Resources

Concern: The Forest Service will purposely or inadvertently cause herbicides to enter waterways, which will 

contaminate drinking water used by people.

Response: Water quality protection measures are included in the analysis by alternative and treatment 

criteria, limitations, design criteria and monitoring measures for all alternatives under which herbicide 

use is proposed. For use of herbicides near water under the proposed action, these are described in the 

final supplemental environmental impact statement in Table S-10 (pp. 31-32) and Table S-11 (pp. 33-

39). As proposed, no aerial broadcast spray of herbicides is going to occur as part of this project. 

The model used in this analysis simulates the potential concentrations of herbicide in a stream 

draining a watershed subject to weed treatment. The model calculates dilution of herbicide in primary 

streams of representative watersheds for two time periods – May and September, representing typical 

time periods when discharge is near the peak (May) and near the minimum (September). Picloram 

was selected because of its “high risk quotient” for fisheries and aquatic life, and a worst-case 
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230

scenario was developed that represented the treatment of all weed acres at one time under alternative 

B. 

Modeling assumptions were clearly articulated and disclosed (final environmental impact statement 

pg. 292). Modeling results are illustrated in Table 66 (final environmental impact statement pp. 293-

294), and two watershed were found to potentially exceed the recommended threshold indicating that 

some effect to soil and water resources would be expected (loss of fish or aquatic insects). The 

interdisciplinary team considered these potential risks and developed design features to limit or avoid 

treatment scenarios in which the impacts would be likely to occur (final supplemental environmental 

impact statement pp. 33-38). Mitigation measures include limitations on herbicide treatment near 

streams and water bodies, use of only hand application onto individual weed plants in riparian areas, 

choice of herbicide method of application documented to be of low risk to aquatic species, prohibiting 

mixing and loading of herbicides near live water, etc. 

While the commenter(s) may feel the model is inadequate, it meets the requirements of the National 

Environmental Policy Act to disclose the effects of a proposed action to the public and develop 

mitigation to address those impacts.

The potential for effects to human health and safety was identified as an issue to analyze in detail 

(final supplemental environmental impact statement pp. 33-34 and final supplemental environmental 

impact statement pp. 149-150). Analysis is provided in chapter 3 of the final supplemental 

environmental impact statement (pp. 149-161).

Associated Comments

The Forest Service now explicitly plans to discharge pesticides into waterways. It intends to obtain 

three types of permits to do this: (a) a permit under the Clean Water Act for a discharge of pesticides 

into "Surface Waters of the United States"; (b) a "Pesticide General Permit" under the Clean Water 

Act; and (c) a permit from the New Mexico Environment Department allowing "short-term 

degradation to the chemical, physical or biological integrity" of surface waters. If chemical herbicides 

are applied near the watershed, it cannot be guaranteed that these herbicides will not end up in our 

water supply. We need to protect our water supply for now and for future generations. 

Concerns: Herbicides need to be applied farther from waterways than is currently proposed in order to 

prevent the chemicals from entering water. 

Response: Water quality protection measures are included in the analysis by alternative and treatment 

criteria, limitations, design criteria and monitoring measures for all alternatives under which herbicide 

use is proposed. For use of herbicides near water under the proposed action, these are described in the 

final supplemental environmental impact statement in Table S-10 (pp. 31-32) and Table S-11 (pp. 33-

39). As proposed, no aerial broadcast spray of herbicides is going to occur as part of this project. 

The model used in this analysis simulates the potential concentrations of herbicide in a stream 

draining a watershed subject to weed treatment. The model calculates dilution of herbicide in primary 

streams of representative watersheds for two time periods – May and September, representing typical 

time periods when discharge is near the peak (May) and near the minimum (September). Picloram 

was selected because of its “high risk quotient” for fisheries and aquatic life, and a worst-case 

scenario was developed that represented the treatment of all weed acres at one time under alternative 

B. 

Modeling assumptions were clearly articulated and disclosed (final environmental impact statement 

pg. 292). Modeling results are illustrated in Table 66 (final environmental impact statement pp. 293-

294), and two watershed were found to potentially exceed the recommended threshold indicating that 

some effect to soil and water resources would be expected (loss of fish or aquatic insects). The 
Final Supplemental Environmental Impact Statement

231

interdisciplinary team considered these potential risks and developed design features to limit or avoid 

treatment scenarios in which the impacts would be likely to occur (final supplemental environmental 

impact statement pp. 33-38). Mitigation measures include limitations on herbicide treatment near 

streams and water bodies, use of only hand application onto individual weed plants in riparian areas, 

choice of herbicide method of application documented to be of low risk to aquatic species, prohibiting 

mixing and loading of herbicides near live water, etc. 

While the commenter(s) may feel the model is inadequate, it meets the requirements of the National 

Environmental Policy Act to disclose the effects of a proposed action to the public and develop 

mitigation to address those impacts.

The potential for effects to human health and safety was identified as an issue to analyze in detail 

(final supplemental environmental impact statement pp. 33-34 and final supplemental environmental 

impact statement pp. 149-150). Analysis is provided in chapter 3 of the final supplemental 

environmental impact statement (pp. 149-161).

Associated Comments

We recommend larger facilities near riparian areas. Wind, soil movements, rain, snowfall all wash 

herbicides a good distance from where they are sprayed. Any treatments need to be much farther from 

all riparian areas and springs / wet meadows.

Concern: The Forest Service fails to adequately address the New Mexico Environment Department's 

concerns about using picloram in municipal watersheds.

Response: In response to the concern of the New Mexico Environment Department to the use of 

picloram in municipal watersheds (watersheds that supply drinking water to municipalities),

additional treatment criteria, limitations of treatment methods, and design features were developed. 

These are described in the final supplemental environmental impact statement in Table S-10 (pp. 31-

32), Table S-11 (pp. 33-38), and Table S-12 (pp. 38-39). 

Table S-10 of the final supplemental environmental impact statement (pp. 31-32) outlines criteria for 

several weed site conditions applicable to this comment: 

• Area where there is a shallow water table (no more than 6 feet deep) and soil with a high 

permeability rate, where there may be a risk of an herbicide leaching through the soil to the 

groundwater (final supplemental environmental impact statement p. 31), and 

• Santa Fe and Gallinas municipal watersheds in the Santa Fe National Forest (final supplemental 

environmental impact statement p. 32). 

Table S-10 also indicates herbicide formulations and application methods with the lowest risk of 

harmful effects to humans would be used and methods of treatment used must be approved by 

appropriate officials of the cities of Santa Fe and Las Vegas, NM. This also includes non-herbicide 

methods of treatments in these areas. 

Table S-11 design feature #46 (p. 36) restricts the use of herbicides containing picloram as their 

active ingredient within “25 feet of a waterbody...or within the municipal watersheds of the Gallinas 

and Santa Fe Rivers.” Design feature #58 (p. 37) states “Weed treatments within the Santa Fe and 

Gallinas municipal watersheds will be agreed to and coordinated with the appropriate officials for the 

cities of Santa Fe and Las Vegas, respectively. Proposed use of herbicides within these municipal 

watersheds would occur only upon agreement from officials of these cities.”
Invasive Plant Control Project

232

Table S-12 (p. 38) displays the proposed amendment to the Santa Fe National Forest Plan, which 

would read, in part “Chemical treatments may be applied:...(b) within municipal watersheds only 

when the municipality concurs with the proposed treatment and design features.”

The specific design features for the Gallinas and Santa Fe municipal watersheds discussed above in 

addition to those developed for human health and safety (Table S-11, pp. 33-34) address these 

concerns. 

Associated Comments

The New Mexico Environment Department's concern about the use of picloram in watersheds is 

explicitly rejected. The DSEIS, announcing its intention to ignore the Department, states without 

further analysis that "[t]he agency believes that retaining flexibility in weed treatments is crucial to the 

success of this project." The concerns of the NM Environment Department about applying picloram 

in the municipal watersheds are summarily dismissed in the DSEIS, even though picloram is well 

known to leach in soil and contaminate water. It strains credulity to understand how anyone could 

propose putting any herbicides in a watershed (which serves as a drinking water source), but picloram 

is one of the poorest choices.

Health and Safety

Concern: The Forest Service has not quantified the risk of herbicide use proposed in this project to people 

with multiple chemical sensitivities.

Response: For people who have been diagnosed or identified themselves as being sensitive to 

multiple chemicals, there is no measurable level they find acceptable. Therefore, the design features

for human health and safety located in Table S-11 (pp. 33-34) of the final supplemental 

environmental impact statement provide a notification procedure to let anyone who wishes to avoid 

all exposure the opportunity to do so. 

The review of literature regarding health effects is documented in the risk assessment for each 

herbicide proposed for use. Appendix 3 of the final environmental impact statement (pp. 223-285) 

and final supplemental environmental impact statement (pp. 185-192) provides a summary of the risk 

assessments. The risk assessments include population segments regarded as most vulnerable, such as 

children. In the risk assessments, the effects to children are evaluated using extreme exposure 

scenarios (for example, directly spraying them or children drinking water immediately after a spill). 

These scenarios are not likely to occur in the course of this project. 

Associated Comments

The Forest Service has not quantified the risk to people with multiple chemical sensitivities. No one 

with expertise about MCS was consulted in preparing the FEIS, the ROD, or the DSEIS. The so-called 

"design features" are ineffective in preventing exposure to herbicides to people at risk of injury or 

death from such exposure. The Forest Service's documents are fatally biased, because the list of 

sources of information about herbicides identified by the Forest Service reads like a Who's Who of the 

petrochemical industry. As in the FEIS, the DSEIS makes no mention of range of human 

vulnerability to herbicides, and no mention of chemically sensitive individuals, many of whom 

frequent the forests to escape urban and agricultural pollution. The DSEIS makes broad sweeping 

statements about how the herbicides to be used by the Forests will not hurt anyone. This is just wishful 

thinking. This project as proposed presents a threat to my life. This threat to me extends into my own 

home. Moreover, approval of this plan would result in denial of access by me to the Carson and Santa 

Fe National Forests. Please do not use chemical herbicides in Carson and Santa Fe National Forests. I 

am disabled with Environmental Illness/Multiple Chemical Sensitivity. Myself and others with this 

illness are profoundly physically affected by chemical herbicides such as the one being proposed to use 

in Carson and Santa Fe National Forests. A quick note to state that I'm very concerned about the 

spraying of herbicides in the National Forest. My wife is extremely chemically sensitive and one of 
Final Supplemental Environmental Impact Statement

233

her few joys in life is to be able to hike in the Santa Fe National Forest. Please do not approve of any 

spraying in these forests under review. Both the proposed action and alternative 2, using only 

herbicides, would be literally life-threatening to me and to others living in these regions. We are ones 

who have already been so seriously chemically poisoned that usage of herbicides in our areas could 

seriously injure or even kill us. We are the so-called "chemically sensitive" people. We should be 

called "previously chemically poisoned" people! I tested in the highest percentiles for pesticide 

residues, especially DDT, DDE, and so-called inert chemicals mixed with these applications which are 

not listed in the product literature. Dr. Root informed me that these "inert chemicals" were as 

dangerous or more so than the pesticides. I learned that such chemical residues remain in our bodies. 

Our bodies have no natural way to discharge them. 

Concern: The proposed action will expose the public to unacceptable levels of herbicides.

Response: The Forest Service has developed and will require the implementation of 14 measures to 

ensure neither the public, nor its workers, are exposed to unacceptable levels of herbicides (final

supplemental environmental impact statement, pp. 33-34, Table S-11, #1 - 14). These measures

include not using herbicides in high-use developed recreation areas on the weekends when the public 

is most likely to be present, posting signs about the use of herbicides, using the appropriate herbicide 

under the conditions listed on the label, and requiring training and personal protective equipment by 

applicators.

The commenters present no scientific evidence herbicides will remain in the environment at toxic 

levels. The risk assessments, on the contrary, take into account the exposure that would occur if 

someone walked through an area immediately after it was sprayed (which would mean they ignored 

the signs) when vegetation would still be wet. The risk assessments show that, after the herbicide is 

dry, exposure is greatly reduced.

The Forest Service acknowledges the use of herbicides presents risks. Based on the risk assessments

summarized in appendix 3 of the final environmental impact statement (pp. 223-285) and final 

supplemental impact statement (pp. 185-192), the Forest Service believes the risk of harmful 

exposure to the public and workers is exceedingly low. The Environmental Protection Agency's 

system of assessing risk denotes a reference dose, and then after evaluating plausible exposure 

scenarios, compares likely exposure with the reference dose. The Environmental Protection Agency 

then assigns a hazard quotient, which is the dose received under the exposure scenario divided by the 

reference dose. The smaller the hazard quotient, the less hazard. Any hazard quotient greater than one 

is an exposure that exceeds the level of concern. 

Associated Comments

The Forest Plan Amendment has a new provision allowing herbicides to be applied "in areas of human 

habitation." The use of herbicides "in highly used developed recreation areas" is now specifically 

planned (during weekdays only!). The claim in the DSEIS that “since the public will not be applying 

herbicides, their risk of exposure by any application method proposed in this project is zero” is 

unsubstantiated and wrong. After an herbicide is applied to the environment it does not “go away” 

even after it is dry or after it is “absorbed by the plant”. Residues remain on the plant, the soil, and 

target and non-target vegetation. Pets and humans can absorb herbicides through the skin after 

touching contaminated areas, despite claims in the DSEIS that states, “The likelihood of a member of 

the public absorbing an herbicide through their skin is virtually zero.” To the contrary, 2,4-D especially 

is known for its high rate of absorption through the skin....And the expanded plan to use herbicides in 

“areas of human habitation” and “in highly used developed recreation areas” increases the risk of 

human exposure to herbicides significantly. Although areas may be restricted or warnings signs 

placed before herbicide applications, no specific information is given in DSEIS indicating how long 

these would be in place. In another Santa Fe Forest project, signs would only be left in place a few 

days, which is not nearly long enough to protect those that are more vulnerable to low levels of 

herbicides. Another statement in the DSEIS is false at worst and misleading at best. “Studies show 

that the risk of dermal exposure is higher than the risk of inhalation. Since the risk of dermal exposure 
Invasive Plant Control Project

234

is below the LD50, the risk of inhalation would be as well.” But inhaling levels “below the LD50” is 

hardly a safeguard. This just means that half of the test animals that received a particular dose did not 

die! It does not address other adverse affects that can occur from inhaling lower doses. Whether low 

doses of EDCs influence certain human disorders is no longer conjecture, because epidemiological 

studies show that environmental exposures to EDCs are associated with human diseases and 

disabilities. We conclude that when nonmonotonic dose-response curves occur, the effects of low 

doses cannot be predicted by the effects observed at high doses. Thus, fundamental changes in 

chemical testing and safety determination are needed to protect human health. The FEIS admits that 

some of the impurities could cause cancer at a rate of one in a million, as if that was acceptable. There 

are, in fact, no safe levels for chemicals that are carcinogenic, mutagenic, or cause reproductive or 

developmental harm. Some of the proposed herbicides contain such chemicals.

Concern: The Forest Service needs to evaluate the safety of AMPA, a glyphosate byproduct, before using 

herbicides with this ingredient.

Response: The citation provided by the commenter is not peer-reviewed, scientific literature. It 

presents no discussion of toxicity, and, as such, does not support the commenter's concern about 

herbicides disrupting the endocrine system or causing cell death. The only mention of concentrations 

is the following: "The highest measured concentration of glyphosate was 8.7 micrograms per liter, 

well below the MCL (700 micrograms per liter). The highest AMPA concentration was 3.6 

micrograms per liter (there is no MCL for AMPA)." No conclusions are drawn in the article. The 

commenter falsely attributes claims to this paper. For example, the paper makes no claim about the 

length of time AMPA stays in water (forever, according to commenter) or the cost of treatment by 

municipalities (prohibitive, according to commenters).

The glyphosate risk assessment describes the toxicity, the likely means of exposure, the dose at which 

harm occurs, and the risk that use at application rates proposed would reach such a level. Glyphosate 

and its formulations have very low toxicity. No definitive link to cancer was established in doseresponse tests.

Associated Comments

There are no established standards on glyphosate byproducts when they break down in water, 

specifically the byproduct aminomethylphosphonic acid (AMPA). AMPA never leaves the water 

supply except via carbon filtration which is beyond the...ability of many municipalities (see USGS 

(Dec 2013). "Glyphosate Herbicide Found in Many Midwestern Streams. "USGS Environmental 

Health - Toxic Substances. http://toxics.usgs.gov/highlights/glyphosate02.html 

<http://toxics.usgs.gov/highlights/glyphosate02.html> ) We request that the impact and safety of 

AMPA be evaluated before herbicides are used.

Concern: The Forest Service should not conduct any prescribed burning because smoke releases fine 

particulate matter that is harmful to human health.

Response: Use of prescribed fire exclusively to treat weeds is expected to be minimal, about 900 

acres (6.8 percent) of the treatment area. For comparison, the Santa Fe National Forest conducted 

prescribed burning on about 13,000 acres in 2014, which is approximately the footprint of known 

existing weeds on the Santa Fe and the Carson combined.

All prescribed burning must comply with the New Mexico smoke management requirements 

(permitting, monitoring, and so forth) to maintain levels of these emissions within State and Federal 

air quality standards (final supplemental environmental impact statement, p. 36, design feature #43). 

Use of prescribed fire must adhere to restrictions in the forest plan and Forest Service directives, such 

as those for using fire within wilderness (Forest Service Manuals 2324.2 and 2324.04(b)), 

requirements for detailed burn prescriptions, and other requirements intended to avoid unexpected 

consequences (final supplemental environmental impact statement, p. 34, design feature #24).
Final Supplemental Environmental Impact Statement

235

The potential effects of prescribed burning on air quality is provided in the final supplemental 

environmental impact statement (pp. 120-128). Under the proposed action, “a large amount of 

emissions is not expected and would fall well below standards (p. 127).

Associated Comments

ban all burning, which releases fine particulte matter which enters human bodies and causes lung 

cancer, heart attacks, strokes, allergies pneumonia and asthma, among other illnesses and deaths. that 

fine particulate matter travels hundreds of thousands of miles killing people all along the weather path.

Concern: Some people stated that the use of herbicides would cause harmful effects to people and cited 

examples that have no relevance to this project.

Response: That glyphosate may be found in sugar, corn, soy, and wheat is not relevant because the 

Forest Service is not proposing to use herbicides on food crops.

The articles about Sri Lanka are not peer-reviewed, scientific literature, or the conditions described 

would not occur as a result of this project. The articles discuss Sri Lanka's ban of glyphosate in light 

of the death of rice paddy farmers, who use it on their crops while drinking hard water over extended 

periods of time, at least a decade.

The fact sheet states in several places that dicamba is not harmful to humans. Please refer to the 

analysis of commenters' citations found in the project record.

Associated Comments

Glyphosate, the active ingredient in Roundup®, is the most popular herbicide used worldwide. The 

industry asserts it is minimally toxic to humans, but here we argue otherwise. Residues are found in the 

main foods of the Western diet, comprised primarily of sugar, corn, soy and wheat. The Sri Lankan 

Agriculture Ministry banned the import of Roundup and the pesticides Carbaryl, Chlorophyriphos, 

Carbofuran and Propanil last year due to fears that the chronic kidney disease amongst farmers could 

be linked to them. However, this latest President’s order now bans all local sales from the stocks that 

are still available of Roundup, in reaction to the study. A new study published in the International 

Journal of Environmental Research and Public Health found a link between the weedicide known as 

Roundup and the fatal Chronic Kidney Disease of Unknown origin (CKDu) affecting mostly, the rice 

farmers in Sri Lanka and several other countries. Drift is not the only way the public could be 

exposed to airborne herbicides. Herbicides can also volatilize after application. The FEIS admits that 

dicamba can volatize, but says the amount is negligible and therefore of no concern. But dicamba is 

well known for being able to volatilize – that is, re-enter the air after it has dried – in such large 

amounts that it can cause serious damage to neighbor’s crops. Therefore, the public could inhale 

significant amounts of dicamba long after its application in the Forests. According to National 

Pesticide Information Center Technical Fact Sheet on Dicamba 

(http://npic.orst.edu/factsheets/dicamba_tech.pdf), “Dicamba has volatilized under field conditions 

and injured non-target crops. In growth chamber experiments, the acid form was most volatile, and the 

inorganic salts were least volatile. In field experiments with the less volatile forms of dicamba, potted 

soybeans showed symptoms of injury when exposed to the vapors of treated corn up to 60 meters 

away. 38”

Concern: In New Mexico's windy climate, herbicides will become airborne during application and present 

hazards to people even if they aren't in the forest.

Response: During herbicide applications, spray drift is expected to be contained near the application 

site, due to limitations restricting application under wind conditions that could result in drift. In 

addition, drift will be limited because the slow vehicle speed and low height of the spray boom would 

resulting in the herbicide falling to the ground within a few feet of the target weed population (final

supplemental environmental impact statement, p. 127). 
Invasive Plant Control Project

236

The project contains mitigations specifically designed to prevent herbicides from becoming airborne 

(final supplemental environmental impact statement, p. 33-34, Table S-11, design features #3 and 9) 

and to keep people away from treated areas (#10-12, 14).

Associated Comment

Implementation of the Project as proposed will present a hazardous threat to my life even while inside 

my own home. The unpredictable nature of our winds here along with the general high wind speeds in 

northern New Mexico render any decision which allows the release of herbicides or any other 

neurotoxins into the atmosphere completely irresponsible. If a single ember, per the Forest Service, can 

travel 4 miles here, how much further can atomized herbicides travel? Herbicides become airborne in 

New Mexico wind, and so these chemical applications to the forests cannot be properly contained.

Concern: The Forest Service fails to discuss the cumulative and synergistic effects of herbicide use, including 

the inert ingredients in formulations.

Response: The risk assessments describe the formulations that are registered for use. The 

Environmental Protection Agency has acknowledged not all of these ingredients are inert and has 

suggested (but not required) the terminology be changed on labels to describe them as "other" 

ingredients instead. The Environmental Protection Agency classifies these other ingredients into four 

levels, from those with known toxicity to those without any known adverse effects. Those with 

known toxicity that require a material safety data sheet are required to be disclosed. Others are not 

disclosed because they may be confidential business information. This information is disclosed to the 

Environmental Protection Agency and to the authors of the risk assessments, but not to the general 

public. Therefore, the determination of effects has included the products to be used (including inert 

ingredients), not simply the herbicide. 

The risk assessments also account for the most likely mixtures permitted by the label (including 

allowable surfactants and other additives). Only formulations that are considered in risk assessments 

would be used (final environmental impact statement pp. 38, final supplemental environmental 

impact statement p. 33, design feature #1). As discussed in the final environmental impact statement 

and risk assessments, every possible combination is not analyzed or accounted for and so some risk 

exists that someone would combine products that should not be mixed. Although this is considered a 

possibility, it is less probable this would happen (given supervision by certified herbicide applicators), 

than the hazardous mixing of unregistered household products, which have high proven potential for 

harm. Details about the factors affecting the hazards of herbicides is provided in appendix 3 of the 

final environmental impact statement (pp. 231-244).

For different products that would be applied on the same area in separate applications, the risk 

assessments only discuss cumulative effects, the assumption being an application of one after another 

does not add any measure of risk. This conclusion is based on the low level of active ingredient being 

left onsite by the time the second application is applied. The final supplemental environmental impact 

statement contains a mitigation measure to assure that any follow-up application of a second 

herbicide to an area is conducted after reviewing best available information on compatibility with the 

previous application (Table S-11, p. 33, design feature #4).

Associated Comments

The study found that the kidney disease did not occur without the co-presence of heavy metals, 

including arsenic, but of note is that New Mexico soil contains high levels of arsenic. This possible 

cumulative effect of simultaneous exposure to Roundup and arsenic was not analyzed in the DSEIS. 

The DSEIS also dismisses the possibility of cumulative or synergistic effects of herbicide use, 

claiming that since herbicides will have no adverse effects, then there cannot be any cumulative or 

synergistic effects. But since the assumption there cannot be any adverse human effects is incorrect, 

this dismissal of cumulative or synergistic effects is inaccurate and unacceptable. The DSEIS admits 
Final Supplemental Environmental Impact Statement

237

there is uncertainty as to what “inert” ingredients are in herbicide products and yet still claims that the 

impacts of using herbicides are known, and furthermore, are negligible. How is this possible? No one 

can assess the impact of unknown chemicals, which means the impacts of herbicides are extremely 

uncertain. In addition, no specific herbicide products (with EPA registration numbers) are listed in the 

DSEIS, nor does it analyze any specific products. Thus, the environmental and health impacts cannot 

be determined. This lack of data is a serious omission from a document whose prime objective is to do 

just that.

Concern: ...you cite your outdated information as the basis for your conclusion that herbicides containing 

glysophate are safe if used according to label directions. 

Response: The final supplemental environmental impact statement has been updated to include the 

most recent risk assessment available for glyphosate (p. 185). 

The Forest Service has undertaken careful measures to avoid, wherever practicable, harm to people, 

wildlife, and other natural resources when using herbicides. The 58 design features listed on pages 33

through 38 of the final supplemental environmental impact statement ensure that the risk of herbicide 

use is at a minimum. For instance, areas would be closed during application. Further, Environmental 

Protection Agency registration includes an assessment of risk given the toxicity of a substance and 

expected use and exposure. The Environmental Protection Agency regulates the use of registered 

products so the more likely a dose is to exceed the level of concern, the more heavily regulated the

use. This provides an overall level of assurance no harm will come to people or animals from the use 

of the products. 

When viewed against the extremely low risk of exposure, the environmental damage posed by not 

controlling or eradicating weeds is much greater. As described in the final environmental impact 

statement and final supplemental environmental impact statement, weed invasion and spread results 

in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water 

quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental 

impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13 -

14). The potential impacts of weeds known to exist on the Santa Fe and Carson National Forests are 

provided in appendix 2 (final environmental impact statement pp. 213-221 and final supplemental 

environmental impact statement pp. 181-183).

Concern: Rewrite the “Affected Environment for Human Health and Safety” section Chapter 3 beginning on 

page 156. This would include rewriting Table 64 to remove the lies.

Response: Information provided in Table S-64 (final supplemental environmental impact statement 

pp. 156-157) is based on the most recent risk assessments available (final supplemental impact 

statement p. 186).

The Forest Service has undertaken careful measures to avoid, wherever practicable, harm to people, 

wildlife, and other natural resources when using herbicides. The 58 design features listed on pages 33 

through 38 of the final supplemental environmental impact statement ensure that the risk of herbicide 

use is at a minimum. For instance, areas would be closed during application. Further, Environmental 

Protection Agency registration includes an assessment of risk given the toxicity of a substance and 

expected use and exposure. The Environmental Protection Agency regulates the use of registered 

products so the more likely a dose is to exceed the level of concern, the more heavily regulated the 

use. This provides an overall level of assurance no harm will come to people or animals from the use 

of the products. 

When viewed against the extremely low risk of exposure, the environmental damage posed by not 

controlling or eradicating weeds is much greater. As described in the final environmental impact 
Invasive Plant Control Project

238

statement and final supplemental environmental impact statement, weed invasion and spread results 

in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water 

quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental 

impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13 -

14). The potential impacts of weeds known to exist on the Santa Fe and Carson National Forests are 

provided in appendix 2 (final environmental impact statement pp. 213-221 and final supplemental 

environmental impact statement pp. 181-183).

Concern: While natural vegetation will be harmed if non-native invasive plants are not eradicated, 

alternatives to herbicides should be implemented because of the potential harm to the public and the 

environment from their use.

Response: The precautionary principle has another aspect, which is a lack of scientific evidence does 

not preclude action if damage would otherwise be serious and irreversible. If there are threats of 

serious or irreversible environmental damage from not acting, a lack of full scientific certainty should 

not be used as rationale for postponing measures to prevent environmental degradation. 

The wildlife risk assessment section of appendix 3 in the final environmental impact statement (pp. 

244-248) describes the effects of herbicides to terrestrial organisms. The final environmental impact 

statement also describes the effects of herbicides to aquatic organisms in the aquatic risk assessment 

section (pp. 249-250). The final environmental impact statement (pp. 251-285) and final supplemental 

environmental impact statement (pp. 191-192) discuss specific herbicides characteristics and 

environmental effects. The environmental effects include specific herbicide effects to terrestrial and 

aquatic organisms. Biological assessment concurrence on threatened and endangered species effect 

determinations was obtained from the U. S. Fish and Wildlife Service on January 9, 2015.

The Forest Service has undertaken careful measures to avoid, wherever practicable, harm to people, 

wildlife, and other natural resources when using herbicides. The 58 design features listed on pages 33

through 38 of the final supplemental environmental impact statement ensure that the risk of herbicide 

use is at a minimum. For instance, areas would be closed during application. Further, Environmental 

Protection Agency registration includes an assessment of risk given the toxicity of a substance and 

expected use and exposure. The Environmental Protection Agency regulates the use of registered 

products so the more likely a dose is to exceed the level of concern, the more heavily regulated the 

use. This provides an overall level of assurance no harm will come to people or animals from the use 

of the products. 

When viewed against the extremely low risk of exposure, the environmental damage posed by not 

controlling or eradicating weeds is much greater. As described in the final environmental impact 

statement and final supplemental environmental impact statement, weed invasion and spread results 

in a loss of natural diversity and reductions in the quality of wildlife habitat, soil stability, and water 

quality. The harmful effects of weeds to ecosystems are described in detail in the final environmental 

impact statement (pp. 13 - 16) and the final supplemental environmental impact statement (pp. 13 -

14).

Associated Comments

... as a retired USFS employee I understand that natural vegetation and the resources that depend on 

the health of the natural vegetation will be significantly harmed if the non-native invasive plants are 

not eradicated. I also know there are effective (although more costly) alternatives to killing these plants 

other than herbicides. If most Americans knew of the tragic results stemming from contact with some 

herbicides they would insist that the USFS spend the extra money on these safer alternatives. 

Competent public servants apply the Precautionary Principle to any risky proposed actions see below: 

The precautionary principle or precautionary approach states that if an action or policy has a suspected 

risk of causing harm to the public or to the environment, in the absence of scientific consensus that the 

action or policy is harmful, the burden of proof that it is not harmful falls on those taking an action.
Final Supplemental Environmental Impact Statement

239

Index

adaptive strategy, 5, 31, 38

air quality, i, 40, 51, 123, 130, 159, 179

effects to, 129

emissions, 123

national ambient air quality standards 

(NAAQS), 123, 124

alternatives

alternative A (no action), 5, 27, 56, 67, 112, 

113, 129, 139, 141, 143, 144, 151, 152, 156, 

160, 169

alternative B (proposed action), 5

alternative C (no herbicides), 5

alternative D (herbicides only), 5

comparison of, i, 8, 9, 40, 164

appeal of 2005 record of decision, 3, 25

aquatic macroinvertebrates, 74

assumptions of analysis, i, 51, 154, 157, 169, 208

Clean Air Act, 123

Clean Water Act, 40, 109, 179, 221, 230

culturally important forest products, 56, 155, 219

cumulative effects, i, 43

fish and aquatic resources, 103

human health and safety, iii, 166

low-income and minority populations, 156

past and present actions, 43

reasonably foreseeable actions, 44

recreation and wilderness, 141

sensitive wildlife species, 91

soil, 122

summary, ii, 49

threatened and endangered wildlife, 83

water resources, 113

design features, 33

economics

cost-benefit analysis, 169

present net value, iii, 169, 170

environmental justice, 170

Environmental Protection Agency, 7, 8, 10, 31, 33, 

36, 40, 41, 49, 103, 114, 123, 157, 158, 160, 

161, 162, 164, 166, 167, 171, 172, 174, 183, 

189, 190, 191, 192, 195, 196, 208, 218, 226, 

233, 236, 237, 238

fish and aquatic resources, i, 97, 99, 104

effects to, iii, 100

sensitive species, 98

forest plan amendment, i, 7, 23, 38, 66, 96, 104, 

114, 122, 130, 132, 142, 146, 153, 170, 210, 

212, 233

hairy woodpecker, 73

herbicides, 28

aminopyralid, 195

characteristics with soil, iii, 121

dermal (skin) absorption, 159, 162

effects, 102, 104

endocrine disruption, 159, 164

ingestion, 159

inhalation, 159, 162, 167

leaching into soil, 102

length of exposure, 158, 162

potential for exposure, 191

risk assessments, ii, 189, 195

risk of overland flow, 103

synergistic interactions, 163

toxicity, 159, 162

worse-case effects to fish and aquatic resources, 

102

heritage resources, i, 7, 37, 130, 132

effects to, 132

Hispanic populations, 154

Holy Ghost ipomopsis, 63

human health and safety, 6, 8, 33, 39, 49, 50, 140, 

155, 156, 159, 170, 237

incomplete or unavailable information, 171

invasive plants

definition, i, 13

issues, i, 2, 10, 25, 26, 41, 153, 158

juniper (plain) titmouse, 72

livestock grazing, i, 146, 151, 153, 173

effects of weeds, 146, 151, 152

low income and minority populations, iii, 153, 

154, 155

management indicator species, 66

effects to, iii, 75

Mexican spotted owl, 74, 78, 81

monitoring, ii, 6, 7, 33, 38, 52, 103, 133, 134, 139, 

203

mourning dove, 73

Native Americans, 132, 154, 155, 173

native plants, 6, 34, 37, 49, 61

New Mexico Department of Agriculture, 4, 15, 22, 

27, 30, 34, 40, 171, 211

New Mexico Environment Department Surface 

Water Quality Bureau, 37, 40

New Mexico Pesticide Control Act, 40

New Mexico State Historic Preservation Officer, 

39
Invasive Plant Control Project

240

Nokomis fritillary butterfly, 98

Outstanding National Resource Waters, 113

pea-clams, 98

permits and authorizations, i, 39

piñon jay, 72

plants

endangered, 63

sensitive plants, 7, 35, 37, 63, 65, 66

special status, 63, 65, 66

proposed action, i, ii, 4, 5, 22, 27, 56, 67, 120, 129, 

139, 170, 210, 225

public involvement, i, ii, 2, 24, 209

purpose and need, i, 1, 13

recreation, 132, 139, 140, 141

effects to, 138

red squirrel, 74

resident trout, 74

Rio Grande cutthroat trout, 74, 99

Rio Grande sucker, 99

Rocky Mountain bighorn sheep, 73

Rocky Mountain elk, 73

social and economic resources, i, 153

local economy, 155

soil, 115

effects to, 119

erosion, iii, 116

southwestern willow flycatcher, 80, 81

threatened and endangered wildlife species, iii, 79, 

81

threatened, endangered and sensitive species, 35

traditional cultural properties, 131

treatment

annual amounts, 22, 52

treatment methods

alternative B, 29

alternative C, ii, 30

alternative D, ii, 31

biological methods, 4, 160

controlled grazing, 4

herbicides, 4

limitations, 31

manual methods, 4, 161

mechanical, 28, 161

prescribed burning, 4

summary of treatments proposed for alternatives 

B, C, and D, iv, 200

treatment objectives, 5

U.S. Fish and Wildlife Service, 35, 39, 78, 81, 

182, 183

USDA Animal and Plant Health Inspection 

Service, 40

visual quality, i, 143, 145, 146

effects to, 143

visual quality objectives, 143, 144, 145

water resources, i, ii, 97, 104, 112, 151, 229

effects to surface and groundwater quality, 112

surface and groundwater quality, 109, 114

weed effects

erosion, 1

native plants, 1

recreation, 2, 14

water quality, 14

wilderness, 14

wildlife habitat, 2, 14

weed locations, iv, 19

by vegetation types, 52, 53

grasslands, 53

grazing allotments, iii, 147, 148

piñon-juniper, 54, 71

ponderosa pine, 54

recreation sites, iv, 136

riparian areas and valley bottoms, iv, 54, 105

sagebrush-shrub, 53

spruce-fir, 53, 54, 93

wilderness areas, iv, 137

weed species

characteristics and impacts, ii, 16

cheatgrass, 16, 185

knapweed, 14, 16, 20, 52, 53, 54, 56, 60, 62, 67, 

69, 115, 116, 138, 139, 159, 161, 178, 185, 

198, 211

leafy spurge, 2, 14, 20, 21, 53, 54, 161, 198

Russian olive, 2, 20, 46, 48, 53, 54, 115, 133, 

135, 198

saltcedar (tamarisk), 2, 14, 20, 21, 44, 46, 48, 

53, 54, 60, 61, 80, 96, 115, 133, 135, 139, 

150, 185, 198, 213, 221

Siberian elm, 2, 20, 28, 46, 48, 53, 54, 115, 133, 

198

St. John’s Wort, 4, 22

tree of heaven, 16, 186

yellow starthistle, 2, 53, 61, 175, 190, 195

weed spread, 51, 62

effects from livestock grazing, 147, 151, 152

white-tailed ptarmigan, 73

wilderness

effects to, 140, 141

wildfires, 44, 62, 146

Dome Fire, 56

Las Conchas Fire, 74, 126, 146, 149

Wallow Fire, 126

wildlife, i, 66, 139, 174
Final Supplemental Environmental Impact Statement

241

amphibian sensitive species, 86, 224

birds, 87, 194

cumulative effects, 69

effects of proposed treatments, 67, 68

effects to migratory birds, iii, 94

mammal sensitive species, 89, 194

migratory birds, 92, 93, 96

sensitive species, 83, 86