United States Department of Agriculture

Draft Record of Decision

Supplemental Environmental Impact 

Statement for the Invasive Plant Control 

Project

Forest Service Santa Fe National Forest December 2017
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations 

and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering 

USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender 

identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, 

income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights 

activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). 

Remedies and complaint filing deadlines vary by program or incident. 

Persons with disabilities who require alternative means of communication for program information (e.g., 

Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or 

USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay 

Service at (800) 877-8339. Additionally, program information may be made available in languages other than 

English. 

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, 

AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or 

write a letter addressed to USDA and provide in the letter all of the information requested in the form. To 

request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: 

(1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence 

Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov. 

USDA is an equal opportunity provider, employer and lender.
Draft Record of Decision

i

Table of Contents

Decisions and Reasons for the Decisions......................................................................................................1

Decisions...................................................................................................................................................1

Invasive Plant Control Project...............................................................................................................1

Forest Plan Amendment ........................................................................................................................2

Background ...............................................................................................................................................3

Reasons for the Invasive Plant Control Project Decision .........................................................................4

Purpose of the amendment (36 CFR 219.13(b)(1))...................................................................................8

Responsiveness to the Issues and Resources Analyzed for the Forest Plan Amendment.........................8

Other Alternatives Considered..................................................................................................................9

Alternative A – No Action ..................................................................................................................10

Alternative C – No Herbicides............................................................................................................10

Alternative D – Herbicides Only.........................................................................................................11

Public Involvement .................................................................................................................................11

Collaboration and Scoping ..................................................................................................................11

Public Comment on the Draft Environmental Impact Statement ........................................................12

Appeal of the Record of Decision .......................................................................................................12

Draft Supplemental Environmental Impact Statement........................................................................12

Findings Required by Other Laws and Regulations................................................................................13

Implementation .......................................................................................................................................16

Administrative Review or Objection Opportunities................................................................................17

Objection opportunity Forest Plan Amendment (36 CFR 219.50 through 219.62) ............................17

Effective date (§ 219.17(a)(2):................................................................................................................18

Contact Person ........................................................................................................................................18

Appendix 1. Invasive Plant Control Project Selected Alternative...............................................................19

Design Features and Monitoring Requirements..................................................................................26

Draft Record of Decision

1

Decisions and Reasons for the Decisions

Decisions

I am making two decisions: one for the non-native plant control project and one for the forest 

plan amendment. Based upon my review of all alternatives, information in the 2005 FEIS and the 

Supplemental FEIS, and public input, I have decided to implement Alternative B to control nonnative plants on the Santa Fe National Forest and the forest plan amendment to allow the use of 

herbicides in places currently prohibited by forest plan standards and guidelines. 

Invasive Plant Control Project

Alternative B is an integrated set of management actions considered necessary to control weeds 

on the Santa Fe National Forest with the goal of completely eliminating some and preventing the 

spread of others. 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. The Santa Fe National Forest does not intend 

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

(Glycyrrhiza lepidota).

During approximately the next 10 years, the Santa Fe 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 1,500 acres. The implementation period could extend beyond 10 

years if monitoring shows treatment results are within expected outcomes. 

The following treatment methods are included to treat weeds on the State’s noxious weed list:

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). 
Santa Fe National Forest Invasive Plant Control Project

2

The scope of this decision 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 the 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.

Appendix 1 provides details of the selected alternative, including treatment criteria and 

limitations, design features, and monitoring requirements.

Forest Plan Amendment

This ROD also documents my decision to amend the 1987 Santa Fe Forest Plan concurrently with 

my decision on the Invasive Plant Control Project. Determining whether the proposed project 

would be consistent with the forest plan is a component of the purpose and need for the Invasive 

Plant Control Project (FEIS pages 13-26). A review indicated that the proposed action or any of 

the action alternatives that would use herbicides to control invasive plants would result in 

conditions that are inconsistent with management direction in the 1987 forest plan. The no action 

alternative and alternative C are the only alternatives among those considered in the FEIS that are 

consistent with the management direction in the 1987 forest plan. However, the no action 

alternative does not meet the purpose and need for the project. A programmatic forest plan 

amendment must be approved for any of the action alternatives to allow for herbicide in places 

currently prohibited in the 1987 forest plan. The amendment will ensure the project’s consistency 

with the 1987 forest plan. 

Table 1. Proposed Amendment to the Santa Fe National Forest Plan for forest-wide watershed 

management standard and guides (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.1

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.

 

1

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].” With this decision, use of picloram 

will be prohibited in municipal watersheds. The design features listed in Table S-11 (Such as rows 1, 4, and 

46 to 49) of the FSEIS and the requirement to obtain the concurrence of the municipality ensure the safety 

of the application method for other herbicides. 
Draft Record of Decision

3

Existing Forest Plan Direction

Proposed Forest Plan Direction

(bold text shows new language) 

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.

Background

In northern New Mexico’s Santa Fe National Forest, more than 10,406 acres of invasive 

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

represents less than one percent of the 1.5 million acres managed by the national forest, 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. 

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

National Forest is to maintain or improve the diversity, function, and sustainability of desired 

native plant communities on the Santa Fe National Forest. 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 national forest. Weeds typically outcompete native plants for 

space, water, and nutrients because they have characteristics that give them a competitive 

advantage over native plant species and they do not have natural biological mechanisms to keep 

them in check. 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 Santa Fe 

National Forest 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 national forest. 

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 

Santa Fe National Forest. 
Santa Fe National Forest Invasive Plant Control Project

4

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 on the two national forests (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. The 

supplemental environmental impact statement (SEIS) documents the analysis of 4 alternatives to 

meet this need. 

Reasons for the Invasive Plant Control Project Decision

I have determined that alternative B would do more to minimize the establishment of invasive 

weeds than any of the other alternatives, and it will protect and improve native plant communities 

with positive effects on soil and water conditions, wildlife, and aquatic habitats (FSEIS p. 8). 

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

and of short duration (FSEIS pp. 8-11, 40-42; table S-3, S-13)

When compared to the other alternatives this alternative will provide an integrated approach and 

an effective set of methods for achieving the project purpose and need while protecting human 

health and natural resources. All practical means to avoid or, minimize environmental harm from 

the decision have been adopted while still moving toward our desired conditions. In making this 

decision, I reviewed the FSEIS and other supporting information, including the Forest Service 

risk assessments available for the herbicides proposed for use. I also reviewed herbicide 

information provided by commenters on the DSEIS. 

The integrated set of management actions, including an adaptive strategy, can be used in concert 

with other efforts on National Forest system lands which restore forest and watershed health. By 

protecting the abundance and diversity of native plant communities, the selected alternative 

would enhance our efforts to improve the overall sustainability of forest ecosystems and 

resiliency to natural disturbances such as drought, climatic variability, insects, disease, and fire.

The selected alternative would allow the Forest Service to more fully cooperate with other 

agencies and jurisdictions with an integrated approach for weed control and allow us to do a 

better job of partnering and sharing resources to be more effective together in our efforts to 

control invasive plants. It will allow the Forest Service to be a better neighbor by controlling the 

spread of weeds across boundaries where National Forest System lands are adjacent to lands 

owned or managed by others. 
Draft Record of Decision

5

In reviewing the FSEIS, the greatest difference in consequences are between no action and the 

action alternatives. No action would lead to many unwanted changes to the Forest. Weed 

treatment under Alternatives B, C, and D provide long-term, beneficial improvements to native 

ground vegetation such as grasses, forbs and shrubs. Riparian vegetation—particularly rushes, 

sedges, willows and cottonwoods—would benefit from this project as well. Protecting and 

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

well as wildlife and aquatic habitats (as a consequence of enhancing riparian vegetation).

In all action alternatives, negative effects to native vegetation, soil, water and aquatic organisms 

would be minor and of short duration (FSEIS pages 40-42). 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. Other than the effectiveness of treatments and cost, there are few 

other key differences among the action alternatives.

Differences between action 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 associated with the action alternatives, although generally within background 

levels. 

With an integrated approach for controlling the spread of weeds and protecting native plant 

communities, habitats and watershed conditions on the Forest, alternative B would maintain or 

enhance social or economic conditions, particularly for local rural communities in northern New 

Mexico who typically rely on the Forest’s natural resources for their livelihood, traditional culture 

and quality of life. Examples of enhancing social or economic conditions include: improved 

forage availability for livestock grazing on the forest and restoration of native vegetation that may 

be used for medicinal or religious purposes. 

In reviewing the information available in the FSEIS, as well as the risk assessments and 

supporting information, I have determined the risk of harm to people, animals or non-target plants 

is small when considered in the context of their use. Although it is certainly true herbicides pose a 

potential danger because of toxic effects at high doses, the likelihood of exposure occurring at 

these high levels is very small, as explained in more detail below. Non-target plants are most at 

risk of being affected when using nonselective herbicides (e.g. glyphosate, imazapic, imazapyr, 

and others as described in the (FSEIS, Appendix 3). The advantage of the nonselective herbicides 

is that they tend to have the lowest risk of harm to people and wildlife. Thus, for a given situation, 

more risk would be accepted for non-target plants in order to avoid a higher risk to people. I 

conclude herbicide use poses a very low risk of harm to people or animals, when used properly at 

the application rates proposed.

The analysis found in the risk assessments includes a number of plausible exposure scenarios that 

assume spills, human consumption of sprayed vegetation soon after application, and other 

occurrences that I do not believe are likely. In a few accidental exposure scenarios, the level of 

concern is exceeded for some of the herbicides proposed for use. Although the possibility of a 

single spill occurring is slight, the chance of repeated spills in the same place is even less likely. 

In other words, if these exposure levels were to occur regularly, they would raise the risk of 

harmful effect. However, these exposures would only occur during scenarios where herbicides 

were improperly used, or spilled, or where someone travels through a sprayed before the re-entry 

period specified on the herbicide label. Although included in the analysis to disclose these 
Santa Fe National Forest Invasive Plant Control Project

6

possibilities, I believe the more likely outcomes rely on proper application and safety measures 

included in the FEIS mitigation measures, which reduces these possibilities to a very small level.

During the public comment period, some comments noted that because the adaptive strategy 

places priority on treating areas of high human use, the risk to people from herbicides is greater. 

We have evaluated the risk and do not come to that conclusion. Herbicides, when used with the 

required application methods and following directions for use, can be used without causing harm. 

In the FSEIS, special attention has been given to the differences among the herbicides so that we 

can more clearly disclose which herbicides would be most likely to be used in locations that 

people frequent, and which herbicides are more likely to be used in other areas where the extra 

protection is not necessary (FSEIS Appendix 3).

Given a large enough workforce (paid or volunteer), some non-herbicidal methods can be 

effective in small areas for some invasive plant species. Two towns in the project area (Taos and 

Santa Fe) have had some success after restricting the use of herbicides, but they have also seen 

weed populations grown as well. One city (Boulder, Colorado) has established a program of 

invasive plant control that uses herbicides to increase control effectiveness of its program. The 

Santa Fe National Forest has similar locations to the urban landscape, such as campgrounds, dayuse areas and other places readily accessible and where getting the large number of personnel to 

control invasive plants presents a realistic possibility, and Alternative B would allow nonherbicidal treatments in those areas. However, the Santa Fe National Forest also has more remote 

locations, where the resources are simply not available to send regular patrols for repeated nonherbicidal treatment methods. Moreover, experience with volunteers has shown us that this 

approach works better in some circumstances (close to towns, small areas, on invasive plant 

species that lend themselves to hand pulling). I consider the use of volunteers as a key part of 

Alternative B in those circumstances where it can be effective.

Similar to suggestions to increase volunteer efforts, comments on the DSEIS mentioned a number 

of alternative methods, such as covering weeds with rubber mats, and using vinegar and other 

methods found effective with organic gardening methods. Replacing weed populations with more 

vigorous plants has also been suggested. Selection of Alternative B does not preclude use of these 

methods as long as they fall within the effects and mitigation measures described in the FSEIS. 

Alternative B provides for herbicide use where it is the most effective method, which may often 

be in combination with other treatment methods.

Commenters expressed a concern that Alternative B should not be selected simply because it is 

the least costly. The FSEIS does not support that conclusion, showing that Alternative D is the 

least costly to implement (FEIS pages 173-179, FSEIS p. 170). I chose Alternative B because it is 

an integrated approach and it is the most effective, not because it costs the least to implement. As 

noted in the FEIS, the use of “herbicides only” as proposed in Alternative D would result in more 

repeated treatments where the herbicides had not achieved the desired level of control. Although 

the cost of treatments in this alternative is the lowest of the three action alternatives, we do not 

believe that cost alone should be the determining factor in selection. Over time, the less effective 

treatments would require closer monitoring and possibly more return visits than Alternative B, the 

integrated approach.

I acknowledge a certain level of uncertainty exists with respect to the effects of herbicides. I have 

relied on the U.S. Environmental Protection Agency’s methodology to determine this risk and 

account for this uncertainty. This methodology determines a lower level of exposure with no 

adverse effect if this dose were given every day over a 70-year lifespan (known as a Reference 

Dose or RfD). The Reference Dose accounts for uncertainty by taking the lowest level of no 

observable adverse effect (NOAEL) and reducing it by factors of 10 based on uncertainty. For 
Draft Record of Decision

7

instance, most tests on the toxicity are conducted on laboratory animals, and so a safety factor of 

10 would apply based on species to species extrapolation.

Comments on the DSEIS noted a number of epidemiological studies showing a connection 

between herbicide use and some forms of cancer. I acknowledge these studies and their claims, 

but find the totality of information in the risk assessments more persuasive for each particular 

herbicides because they provide a broader context, which includes an evaluation of many of the 

studies and other literature cited by the DSEIS comments. For instance, the impurity 

hexachlorobenzene is found in two of the herbicides proposed for use. As noted in the risk 

assessments and public comment, this substance has been linked to cancer. However, similar tests 

on the two herbicides (picloram and clopyralid) indicate no such link. Nonetheless, the risk 

assessments evaluated the risks associated with the use of these herbicides and found them to be 

less than one in a million because of the small amount of hexachlorobenzene (below background 

levels). Although commenters argue that any risk is too much, this no-risk approach does not 

represent a standard that can be attained, even if these herbicides are not used in this project. The 

presence of hexachlorobenzene in the background environment results in some risk of exposure.

The FSEIS and risk assessments also consider the cumulative effects of using herbicides in 

conjunction with known other herbicide uses, but also must acknowledge a boundary of what can 

be known considering the variety of other chemicals in use throughout the communities and on 

private land that may be adjacent to the National Forest System lands being treated. I do not find 

a substantially greater risk arises because of the potential for other herbicide applications on 

nearby lands. The greatest risk may be in the non-regulated use by private landowners, which 

cannot be quantified with any certainty. However, logic and experience tells us coordinated 

control with landowners in conjunction with advice from local extension services promises to be 

the best way to assure invasive plants are controlled with the least amount of herbicide used in the 

most effective and proper way possible.

I recognize the concerns expressed by many commenters regarding the threat of herbicides to 

people who suffer from the medical condition known as multiple chemical sensitivity (MCS). The 

potential for harm to come to this segment of the population as a result of herbicide use was given 

careful consideration in our decision. Many comments suggested we avoid herbicides in order to 

take the most conservative possible approach, especially when considering the low level of 

herbicides (noted as far below the Reference Dose) that may have an effect to people with this 

condition. As discussed previously, Alternative C would eliminate any risk posed by herbicide 

use—no matter how small the risk—but would shift to risks associated with other methods, which 

are also small. 

I have reviewed the information provided by DSEIS commenters, as well as the risk assessments, 

which review the effects of Forest Service herbicide use to sensitive populations (which in some 

risk assessments specifically include the MCS condition). When considering the low levels of 

potential effect described by these comments, I cannot single out herbicide use as a cause separate 

from many other factors in the environment, including such common substances as those found in 

automobile exhaust, commonly used household products, and other sources of chemicals. I

recognize the difficulty of proving a link between MCS and the use of herbicides as proposed 

with this project, and although we do not find clear evidence of this link, we do not want to 

ignore the concern either. I believe we can best respond by including notification provisions in 

the mitigation measures (FSEIS page 33-34) that will allow people suffering from this condition 

to avoid areas where herbicides are applied by the Forest. I do not believe a complete ban on the 

use of herbicides would provide the extra level of protection sought out by these commenters.

We developed, and this decision requires, the implementation of fourteen measures to ensure the 

public and employees are not exposed to unacceptable levels of herbicides (FSEIS pp. 33-34).
Santa Fe National Forest Invasive Plant Control Project

8

I have adopted notification procedures to alert the public about where herbicides would be used, 

and under the adaptive strategy, these procedures are subject to modification for increasing their 

effectiveness. This strategy will result in treated places being unavailable for some people to use 

for a period of time after treatment. I acknowledge this potential result, but at the same time do 

not see this as unique to the use of herbicides. Such temporary use restrictions are common for 

other activities, such as thinning, prescribed burning, or road paving. As in those cases, we must 

weigh such short-term restrictions against the results of inaction, which will restrict use in a more 

subtle way as the resources people value and use become compromised.

The selected alternative includes necessary herbicide application licenses as required by Federal 

and State statutes. Training and certification programs are used to assure anyone applying and 

supervising the application of herbicides has the knowledge to assure proper use.

In summary, Alternative B includes mitigation measures and notification procedures as outlined 

in the FSEIS to assure the risk of adverse effects caused by herbicides is negligible. Given the 

low risk to people, animals, or sensitive non-target plants, this alternative provides the most 

effective way to deal with invasive plants on the national forest. 

Purpose of the amendment (36 CFR 219.13(b)(1))

The current forest plan forest-wide standards for watershed management prohibit herbicide use 

within municipal watersheds, in areas of human habitation, on soils with low regeneration 

potential or less than moderate cation exchange capacity (USDA FS 1987). The amendment 

allows herbicides to be used where necessary in those situations. The current Santa Fe National 

Forest Plan also prohibits herbicide use if an environmental analysis shows that it is not 

“environmentally, economically or socially acceptable,” which is an ambiguous and nonquantifiable standard, subject to variable interpretations. The amendment will slightly modify that 

standard while continuing to focus on using the analysis of environmental, economic and social 

impacts to determine the appropriateness of herbicide application. 

In order to achieve the desired ecological conditions described in the Santa Fe National Forest 

Plan, including maintaining native vegetation and wildlife habitat quality, along with sustainable 

soil, water and riparian conditions that will otherwise be threatened by ineffective treatments and 

the continued spread of weeds, it is necessary to have the flexibility to apply herbicides to weed 

populations that cannot be effectively treated with other methods. This could, in some instances,

include herbicide applications within municipal watersheds, on National Forest System lands 

adjacent to human residences, and on some soils with a low revegetation potential or less than 

moderate cation exchange capacity. The amendment is made within the context of the mitigation 

measures and label instructions that apply to herbicide use, as well as the 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 

FS 1993). This will ensure that long-term soil productivity will be maintained. In addition, the 

Forest Plan standard and guideline regarding cation exchange capacity is proposed for deletion 

because it is outdated. That particular soil measurement is not used by the Forest Service in the 

Southwestern Region. 

Responsiveness to the Issues and Resources Analyzed for 

the Forest Plan Amendment 

Public notification of the need to amend the Santa Fe National Forest’s forest plan was made in 

the notice of intent to prepare a supplemental environmental impact statement and draft record of 

decision. Details regarding public notices and public participation are outlined in the Public 
Draft Record of Decision

9

Involvement section of this document. The Forest Service has followed the applicable regulations 

regarding public participation and notices in place at the time of applicable processes. 

A number of public comments disagreed with the proposed amendment to the Santa Fe National 

Forest Plan. Although the amendment modifies several standards, the one that received the focus 

was allowing use of herbicides in areas of human habitation and within developed recreation 

sites. I understand the concern, based on the assumption that any amount of herbicide poses a 

potential threat. As with use of herbicides elsewhere, the hazard exists, but the risk of people 

being exposed to levels that express a harmful effect is very low. We developed and will require 

the implementation of fourteen measures to ensure neither the public, nor employees, are exposed 

to unacceptable levels of herbicides (FSEIS pp. 33-34).

An additional treatment method limitation for weed treatments in the Santa Fe and Gallinas 

municipal watersheds was added to the FSEIS (Table S-10) and is included as part of this 

decision. Methods must be 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.

Aminopyralid, glyphosate, imazapyr, imazapic, metsulfuron methyl, and clopyralid products 

would be available for use per risk assessment results found in appendix 3 of the FSEIS. Also 

treatments will adhere to other design features to protect human health and safety (for example, 

notification of treatments). Methods 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.

Using the 1982 planning provisions, as allowed by 36 CFR 219.17(b)(3), I have determined that 

this amendment is not significant, according to Forest Service Manual 1926.51 and 1926.52, for 

the following reasons. The amendment: 

 will not alter the multiple-use goals and objectives for long-term land and resource 

management; 

 will not have an important effect on the entire land management plan or affect land and 

resources throughout a large portion of the planning area; 

 involves a minor change in the Forest-wide standards for watershed management; and 

 will contribute to achieving the desired ecological conditions described in the rest of 

Santa Fe National Forest Plan including maintaining native vegetation along with 

sustainable soil, water and riparian conditions that will otherwise be threatened by 

ineffective treatments and the continued spread of weeds.

The effects of the plan amendment are documented in Chapter 3 of the Supplemental 

Environmental Impact Statement for the Invasive Plant Control Project following Forest Service 

NEPA procedures at 36 CFR Part 220 (FSEIS pp. 43-172).

Other Alternatives Considered

In addition to the selected alternative, I considered 3 other alternatives, which are discussed 

below. Alternative B is the environmentally preferred alternative. A more detailed comparison of 

these alternatives can be found in the FSEIS on pages 27-42, with full analysis found in Chapter 3 

of the FSEIS.
Santa Fe National Forest Invasive Plant Control Project

10

Alternative A – No Action

Under the no-action alternative, current management plans would continue to guide management 

of the project area. This is the baseline for comparing the other alternatives and is the alternative 

where proposed weed control actions would not occur on the national forest. 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 A 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, particularly on 

and near, currently infested areas. 

Alternative C – No Herbicides

This alternative does not include herbicide use and was developed in response to public concerns 

raised about potential effects of herbicides on human health, fish, wildlife, and non-target native 

vegetation. Weed inventories and prevention activities would continue to occur.

The main reason I did not choose alternative C is that it would limit our options for dealing with 

weed populations in situations where herbicides could be safely and effectively used to better 

control weed populations. Under alternative C, it is likely the rate of weed spread would exceed 

the rate of weed control, and we would not be able to get ahead of the weed problem (FSEIS p. 

60).

Not using herbicides means that the invasive plant control efforts would not be as effective across 

the Forest. With a given amount of funding and human resources available to fight the problem, 

fewer invasive populations could be controlled. I would be more inclined to reduce the level of 

effectiveness in order to protect public health and safety if I had found clear and convincing 

evidence that herbicide use, as proposed with this project, was likely to cause harm. On review of 

both the Forest Service risk assessments and information provided by DSEIS commenters, I have 

not found this evidence.

Given a large enough workforce (paid or volunteer), some non-herbicidal methods can be 

effective in small areas for some invasive plant species. Taos has had some success after 

restricting the use of herbicides, but weed populations have grown as well. Experience with 

volunteers has shown us that this approach works better close to towns, in small areas, and on 

invasive plant species that lend themselves to hand pulling. The Forest has weed population 

locations, such as campgrounds, day-use areas and other places readily accessible, where getting 

the large number of personnel to control invasive plants without herbicide use presents a realistic 

possibility. However, the Forest also has more remote locations, where the resources are simply 

not available to send regular patrols for repeated non-herbicidal treatment methods. 

Alternative C would limit the Forest Service’s ability to fully cooperate with other agencies and 

jurisdictions with an integrated approach for weed control. It would hamper our efforts to partner 

and share resources in our efforts to control invasive plants by not allowing us to effectively 

control the spread of weeds across boundaries where National Forest System lands are adjacent to 

lands owned or managed by others. 
Draft Record of Decision

11

Alternative C would eliminate the risks associated with herbicide use on the national forest, but it

would increase other risks, such as those associated with smoke because of the greater amount of 

burning included in this alternative. Other treatments, such as hand pulling or mowing have small 

risks associated with them as well. These risks range from injury due to repetitive motion and 

back and knee pain, skin irritations, to physical injuries due to accidents with mechanical 

equipment (FSEIS pp. 160-168). I do not believe that the risks of other methods are substantially 

different from those of herbicide use. Although these risks are considered minor, increasing their 

use simply shifts the risk without eliminating it.

The potential increases in sediment would be more with alternative C, but there would be no 

measurable, long-term consequences, and long-term soil productivity would be protected (FSEIS 

pp. 42, 102, 112, 121). So, even though this a consideration, I did not give this much weight in 

deciding not to select it.

Alternative D – Herbicides Only 

This alternative would exclusively rely on herbicides and was developed in response to the cost 

effectiveness issue associated with proposed non-herbicide treatments. Weed inventories and 

prevention activities would continue to occur.

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

watershed conditions on the Forest, alternative D would maintain or enhance social or economic 

conditions; however, it would limit options for treatment where herbicide use is not the best 

method for a given situation because it is not an integrated approach.

Although alternative D would be the most cost-effective alternative (FSEIS p. 170) give up those 

many instances where integrated management actions could be used. Studies show herbicides 

alone are not as effective as when they are combined with other methods (FSEIS p. 60-61, 69).

One important example is the treatment of saltcedar. Saltcedar has been successfully treated with 

a combination of herbicides and mechanical treatments which proved more effective at 

controlling or eradicating saltcedar than using herbicides alone (FSEIS p. 61).

As noted in the FSEIS, the use of “herbicides only” would result in more repeated treatments 

where the herbicides had not achieved the desired level of control, and continuous use of 

herbicides alone can lead to other problems (FSEIS p. 61). Although the cost of treatments in this 

alternative is the lowest of the three action alternatives, I do not believe that cost alone should be 

the determining factor in selection. Over time, this alternative would require closer monitoring 

and possibly more return visits than alternative B, the integrated approach. 

Public Involvement

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 forest-wide 

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

the efforts of the Santa Fe and the Carson National Forests and document the analysis in an 

environmental impact statement. In December 2000, the Forest Service sent a new letter to the 
Santa Fe National Forest Invasive Plant Control Project

12

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 Santa Fe 

National Forest 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 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 non-herbicidal methods would be less effective and weeds 

would spread faster than they could be controlled. In response to these concerns, two action 

alternatives (Alternatives C and D) were developed. Alternative C is a no herbicide alternative 

developed in response to public concerns raised about potential effects of herbicides on human 

health, fish, wildlife, and non-target native vegetation. Alternative D relies exclusively on 

herbicides and was developed in response to the cost effectiveness issue associated with proposed 

non-herbicide treatments. 

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 (FEIS) 

clarified and expanded its discussion of the risks associated with the use of herbicides (see 

appendix 3 of the FEIS and FSEIS). Appendix 9 of the FEIS responds to comments received on 

the DEIS.

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. On February 23, 2006, the Deputy Regional Forester remanded the decision for further 

analysis and documentation. 

Draft Supplemental Environmental Impact Statement 

The Forest Service prepared a draft supplemental environmental impact statement (SEIS) to 

address concerns identified by the Deputy Regional Forester and to update the analysis 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 
Draft Record of Decision

13

was not re-scoped, but the public had the opportunity to comment before this draft decision was 

made available.

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

the draft SEIS 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 SEIS 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 SEIS.

The Forest Service’s interdisciplinary team identified approximately 75 distinct 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 SEIS responds to comments received on the draft SEIS. 

Findings Required by Other Laws and Regulations

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 is included in this decision; otherwise, this 

project is consistent with the Santa Fe Nation Forest Plan.

Endangered Species Act

This decision is consistent with the Endangered Species Act of 1973. Informal consultation with 

the U.S. Fish and Wildlife Service (USFWS) was undertaken. The USFWS concurred with the 

biological finding that the project “may affect, is not likely to adversely affect” the Mexican 

spotted owl, southwestern willow flycatcher, Jemez Mountain salamander, New Mexico meadow 

jumping mouse, Western yellow-billed cuckoo, and Holy Ghost ipomopsis (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)) . This finding also applies to the designated habitats of the species, 

respectively. Treatment criteria and limitations, design criteria, and monitoring requirements 

included in the FSEIS provide protection for these species (FSEIS pp. 31-39).

Sensitive Species

Federal law and direction applicable to Forest Service sensitive species are included in the 

National Forest Management Act and Forest Service Manual (2670). The regional forester has 

developed the sensitive species list for plants and animals for which population viability is a 

concern (FSEIS pages 83-91). In reviewing the analyses and projected effects on all sensitive 

species listed as occurring or possibly occurring on the national forest, it has been demonstrated 

in the biological evaluations that there will be no trend toward Federal listing for any sensitive 

species (FSEIS pg. 86).

National Historic Preservation Act

This decision 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 
Santa Fe National Forest Invasive Plant Control Project

14

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 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 (FSEIS pp. 130-132). Cultural resource clearance for individual treatments will occur 

as individual weed treatment activities are proposed. Weed treatments include design features to 

protect cultural resources (FSEIS p. 37). Adverse effects would primarily be mitigated by 

avoidance of significant sites (FEIS p. 150). If adverse effects cannot be avoided, additional 

consultation will be required to develop a mitigation plan. 

The National Forest Management Act of 1976 (PL 94-588)

This decision, including the nonsignificant amendment to the Santa Fe National Forest Forest 

Plan, as amended, is consistent with the goals and objectives of the forest plan. This decision also 

complies with the management direction and standards and guidelines for all relevant 

management areas described in the plan.

This decision is consistent with the goals and objectives of the forest plan for the Santa Fe 

National Forest (FSEIS p. 171; FEIS PR#49). The project will help maintain ecological diversity, 

long-term soil productivity (FSEIS p. 119; FEIS p. 40), water yield and quality (FSEIS pp. 8, 42, 

113-115), air quality (FSEIS p. 129), habitat for rare plant and animal species (FSEIS pp. 8-9, 40-

42, 65-69, 78, 81-83, 86-91), visual quality (FSEIS pp. 143-146), and high quality forage 

availability (FSEIS pp. 52-62 and 146-153) which are all threatened by continued weed 

infestation and spread (FSEIS pp. 1-2, 13-14).

The desired condition of the Forest is to have minimal establishment or spread of weed 

infestations. It would be virtually impossible to eradicate all weeds within the forest boundaries. 

However, to meet Forest Plan goals for resource protection, it is important to control the 

establishment and spread of invasive weeds, particularly in special plant and wildlife habitats, 

riparian areas, wilderness areas and roads leading to them, livestock grazing allotments, 

recreation sites, and administrative sites. 

National Environmental Policy Act (NEPA)

The NEPA requires Federal agencies to consider and disclose the effects of proposed actions that

significantly affect the quality of the human environment. The Invasive Plant Control Project 

FSEIS analyzes the alternatives and displays the effects in conformance with NEPA (40 CFR 

1500 to 1508 and FSH 1909.15).

The Clean Water Act

The Clean Water Act of 1948, as amended, establishes as Federal policy the control of point and 

nonpoint pollution and assigns the States the primary responsibility for control of water pollution. 

Compliance with the Clean Water Act by national forests in New Mexico is achieved under State 

law. Alternative B will result in long-term, protection of water quality (FSEIS pages 104-115). 

With the use of the site-specific design features, mitigation measures, and best management

practices, this alternative meets the laws and associated regulations designed to protect water 

quality. Based on this analysis, I find that alternative B is consistent with the Clean Water Act.
Draft Record of Decision

15

The Clean Air Act

The basic framework for controlling air pollutants in the United States is the 1970 Clean Air Act 

as amended in 1990 and 1999 (42 USC 7401 et seq.). The primary concern with this project in 

regards to air quality is with ground application of herbicides. Since impacts will be distributed 

across the Carson and the Santa Fe National Forests and over time, concentrations of air 

contaminants will not accumulate to the point of violating air quality standards for any area 

(FSEIS pages 123-130).

The Migratory Bird Treaty Act

Alternative B—with treatment criteria and limitations, design criteria, and monitoring 

requirements described in the FSEIS—provides for adequate conservation measures for migratory 

birds. Overall impacts on land birds and waterfowl are expected to be minimal (FSEIS pp. 92-96).

Executive Order 12898-Environmental Justice

Executive Order 12898 governs Federal actions to address environmental justice in minority and 

low-income populations. The provisions also apply to programs involving Native Americans.

There would not be a disproportionately high and adverse effect on minority or low-income 

populations under these alternatives. With the treatment criteria and limitations, design criteria, 

and monitoring requirements described in the FSEIS, 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, however an actual exposure to hazardous chemicals is highly 

unlikely because of the design features described (FSEIS pages 31-39, 153-156).

36 CFR Subpart A, Section 222.8

This regulation directs the Chief of the Forest Service to cooperate with county or other local 

weed control districts in analyzing noxious farm weed problems and developing control programs 

in areas which the national forests and grasslands are a part. Alternative B complies with this 

direction and would allow the Forest to more fully cooperate with other agencies and jurisdictions 

with an integrated approach for weed control. It includes an implementation plan that will be 

coordinated with other agencies as discussed in this record of decision. The Forest met with other 

county, state, and other federal land management agencies to discuss the threat of noxious weeds 

and coordinate treatments (ROD p. 11). Coordination with other agencies is included as part of 

the design features (Appendix 1, design features 13, and 16). 

Federal Noxious Weed Act of 1974 (Section 9)

Alternative B complies with this authorization for the Secretary of Agriculture to cooperate with 

other Federal and State agencies or political subdivisions thereof, and individuals in carrying out 

measures to eradicate, suppress, control, or prevent the spread of noxious weeds. 

The Plant Protection Act of 2000, PL 106-224, 

The 1990 Farm Bill, PL 101-624

These acts and laws direct the Forest Service to develop and coordinate management programs 

for controlling undesirable plants. Alternative B complies with this direction.
Santa Fe National Forest Invasive Plant Control Project

16

USDA Policy 9500-10

Under this directive the Agency is to integrate noxious weed management into all programs and 

activities and to develop, demonstrate, and apply the essential science, technology, and 

stewardship to effectively manage and prevent the spread of these plants. Alternative B complies 

with this direction.

In addition, Alternative B also complies with and compliments 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. 

“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.

Implementation

If no objection is filed, implementation for the invasive plant control project may begin on, but no 

sooner than the fifth business day following the end of the 45-day objection filing period (36 CFR 

218.12). If an objection is filed, implementation may begin immediately following the date of the 

final decision. 

The Forest Plan Amendment for the Invasive Plant Control on the Santa Fe National Forest will

become effective 30 days after publication of the legal notice of my amendment approval in the 
Draft Record of Decision

17

Santa Fe National Forest newspaper of record, Albuquerque Journal (§219.17(a)(1). The timing 

will depend on whether an objection is filed (§219.58).

Administrative Review or Objection Opportunities

The invasive plant control project decision is subject to objection pursuant to 36 CFR Part 218. 

The objection must be filed by way of regular mail, fax, e-mail, hand-delivery, or express 

delivery with the Objection Review Officer: Regional Forester, Southwest Region, USDA Forest 

Service, 333 Broadway Blvd., SE, Albuquerque, New Mexico 87102. The fax number is (505) 

842-3173.

The office business hours for those submitting hand-delivered objections are: 8:00 a.m. to 4:30 

p.m. Monday through Friday, excluding federal holidays. Electronic objections must be submitted 

in a format such as an e-mail message, plain text (.txt), rich text format (.rtf), or Word (.doc) to 

objections-southwestern-regional-office@fs.fed.us with Subject: Santa Fe NF Draft ROD for 

the Invasive Plant Control Project. In cases where no identifiable name is attached to an 

electronic message, a verification of identity will be required. A scanned signature is one way to 

provide verification.

Objections, including attachments, must be filed within 45 days from the publication date of this 

notice in the Albuquerque Journal, the newspaper of record. Attachments received after the 45-

day objection period will not be considered. The publication date in the newspaper of record is 

the exclusive means for calculating the time to file an objection. Those wishing to object this 

project should not rely upon dates or timeframe information provided by any other source. 

Individuals or organizations who submitted comments during the comment period specified at 

215.6 may file an objection to this project. The notice of objection must meet the content 

requirements at 36 CFR 218.8.

Objection opportunity Forest Plan Amendment (36 CFR 219.50 

through 219.62)

The draft decision for the forest plan amendment is subject to the pre-decisional objection process 

pursuant to 36 Code of Federal Regulation (CFR) § Part 219 Subpart B. The opportunity to object 

ends 60 days following the date of publication of the legal notice in Albuquerque Journal, the 

newspaper of record for the Santa Fe National Forest. The publication date of the legal notice in 

this newspaper is the exclusive means for calculating the time to file an objection, and those 

wishing to object should not rely upon dates or time frame information provided by any other 

source.

Objections will be accepted only from those who have previously submitted substantive formal 

comments regarding the proposed project and plan amendment during scoping or other 

designated opportunity for public comment. Issues raised in objections must be based on issues 

raised in the previously submitted substantive formal comments unless the issues are based on 

new information arising after designated comment opportunities §219.53(a).

The objection must contain the minimum content requirements specified in §219.54(c) and 

incorporation of documents by reference is permitted only as provided in §219.54(b). It is the 

objector’s responsibility to ensure timely filing of a written objection with the reviewing officer. 

All objections are available for public inspection during and after the objection process.
Santa Fe National Forest Invasive Plant Control Project

18

Written objections, including attachments, must be filed with: Objection Review Officer: 

Regional Forester, Southwest Region, USDA Forest Service, 333 Broadway Blvd., SE, 

Albuquerque, New Mexico 87102. The fax number is (505) 842-3173. The office business hours 

for those submitting hand-delivered objections are: 8:00 am to 4:30 pm Monday through Friday, 

excluding holidays. Electronic objections must be submitted in a format such as an email 

message, plain text (.txt), rich text format (.rtf), or Word (.doc, .docx) to objections-southwesternregional-office@fs.fed.us. Please state “Forest Plan Amendment for Invasive Plant Control on 

the Santa Fe National Forest” in the subject line when providing electronic objections, or on the 

envelope when replying by mail.

Effective date (§ 219.17(a)(2))

The final Record of Decision will not be signed until all concerns and instructions identified by 

the reviewing officer in the objection response have been addressed (§219.58). If no objection 

is received, the final Record of Decision cannot be signed before the fifth business day 

following the end of the objection-filing period.

The Forest Plan Amendment for the Invasive Plant Control on the Santa Fe National Forest will 

then become effective 30 days after publication of the legal notice of my amendment approval 

in the Santa Fe National Forest newspaper of record, Albuquerque Journal (§219.17(a)(1)).

Contact Person

For additional information concerning this decision or the Forest Service objection process, 

contact Sandra Imler-Jacquez, Environmental Coordinator, Santa Fe National Forest, 11 Forest 

Lane, Santa Fe, New Mexico 87508, (505) 438-5443.

---- DRAFT ----- ---- DRAFT ----

JAMES E. MELONAS DATE

Forest Supervisor

Santa Fe National Forest 
Draft Record of Decision

19

Appendix 1. Invasive Plant Control Project 

Selected Alternative

The selected alternative allows the application of one or more methods to eradicate, control, or 

contain weeds as they occur on the Forest. A common element of all treatments is to destroy the 

plant, disrupt growth, or interfere with the reproduction cycle. Treatments will occur during the 

weed’s growing season—spring, summer, or fall—depending on the weed species and treatment 

method. Based on expected funding, the forest anticipates treating 300 to 800 acres annually, with 

an annual maximum of 1,500 acres, over the next ten years. An adaptive management strategy 

will be used to apply treatments to newly discovered weed populations or to modify treatment 

prescriptions based on results of monitoring. Treatment methods will need to be within the scope 

of the treatments and effects described in the FSEIS to be implemented under the adaptive 

management strategy, and the strategy, including criteria and parameters that must be met to treat 

new weed sites or alter treatment prescriptions is described later in this appendix. 

This alternative applies a variety of methods, including manual, mechanical, biological, cultural, 

prescribed fire, grazing, and herbicides, based on the most feasible and appropriate methods for 

meeting treatment objectives, primarily based on the particular weed species and population size, 

along with considerations about specific locations and public concerns. Selection of the most 

feasible and appropriate treatment also depends on the specific objective (eradication, control, or 

containment), risk of weed expansion, weed species biology, time of year, and environmental 

setting. By allowing several methods for weed control, this approach recognizes that using only 

one management method is unlikely to be effective in all situations. 

The known weed populations have a footprint of 10,406 acres. This is a snapshot in time and does 

not necessarily encompass the full extent of acreage proposed to be treated. The selected 

alternative will 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 of the FSEIS. Figure S-2, on 

page 19, of the FSEIS shows the locations of known weed populations. Appendix 7 shows how 

each species will be treated. 

The following paragraphs describe proposed treatment methods:

Herbicides

Chemicals used to control plants are known as herbicides. Herbicides kill the existing plant but 

often allow remaining seeds to germinate. Herbicides are known through experience with similar 

Forest Service efforts to be the most effective treatment method for eradicating or controlling 

weed species that currently exist on the forest, 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 proposed for weed sites where nonherbicide 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. 

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

dicamba, glyphosate, hexazinone, imazapyr, metsulfuron methyl, sulfometuron methyl, picloram, 

and triclopyr. The herbicide aminopyralid was added as a proposed herbicide in the draft SEIS; 

the others were proposed and analyzed in the FEIS. Appendix 3 (FEIS pp.223-285 and FSEIS p. 
Santa Fe National Forest Invasive Plant Control Project

20

189-196) contains detailed information about each herbicide. Treatments using the herbicides are 

tailored to specific species and site conditions. Mixture of herbicides can be used where they 

provide more effective control, particularly for weeds that may have developed resistance to a 

particular chemical, but this is expected to be a rare case, given the weed species present and size 

of populations. Picloram will not be used in municipal watersheds.

No aerial application of herbicides will be used for this project. Herbicides will be applied using 

ground-based methods such as: hand applications using a glove, rag, or wick to wipe the chemical 

onto the weed while preventing it from getting on non-target vegetation or other resources; spray 

using a backpack containing the herbicide attached to a flexible sprayer, wand, or other hand 

application device that directs the chemical onto the target weed. Vehicles may be used with a 

mounted herbicide tank and boom or wand spray device to direct the spray, provided that the 

conditions described in the mitigation measures can be met for each respective herbicide used. 

Booms or wands may be articulated or fixed. All these methods have turnoff capabilities in or 

near the operator’s hand. Herbicides (such as hexazinone) may also be applied in granular or 

pellet form.

Where objectives for a given population is eradication and the target weed species has developed 

a large seedbed, herbicide applications usually require follow-up treatment, either as additional

herbicide applications or using another method. Because the herbicides proposed for use do not 

persist in the soil at effective levels for more than a few months (at the maximum), in many 

invasive plant populations with seedbeds established, the follow-up treatments are needed to 

eliminate new sprouts that were seeds during the initial treatment. 

Biological Methods 

Biological control methods include release of insects or plant pathogens that are proven natural 

control agents of specific weed species. The insect or plant pathogen will attack, weaken, and kill 

a targeted weed species and reduce its competitive or reproductive capacity. Biological controls 

will be used for reducing population densities and rates of spread (when the objective is 

containment), as they are not effective for eradicating or substantially controlling weeds. This 

treatment is most effective on dense infestations of a weed species covering large areas. 

Host-specific insects are proposed for use on some of the larger populations of riparian weeds 

like saltcedar, along with spotted knapweed (insects such as seed gall fly, root or seed head moth, 

flower or root boring weevil), and leafy spurge (e.g. flea beetles). In general, biological agents 

require an infestation large enough (more than 20 acres) to allow for the establishment of the 

controls to occur. Weed infestations on adjacent lands could be added to the populations on 

National Forest System lands in order to make this treatment effective.

Manual Methods

Manual control methods involve hand pulling or digging with hand tools like shovels or hoes, or 

hand-operated power tools. It may also involve clipping or cutting off the tops of plants. If 

enough root mass is removed, the plant may be destroyed. Cutting plants reduces reproduction of 

plants by seeds. Cutting also depletes the carbohydrate reserves in roots, thereby weakening a 

plant’s competitive advantage on a site. This method will be most often applied to small 

populations (less than an acre) of herbaceous weeds that spread primarily by seeds rather than 

through root sprouts.
Draft Record of Decision

21

Controlled Grazing

Grazing with goats or sheep has been shown to suppress weeds in some prolonged applications. 

Goats have a digestive system that can handle most vegetation including weeds. Goats have been 

used on a limited basis in efforts to control weeds, using hay, water, or minerals to attract them to 

the weed patch. Other grazing methods include herding and fencing to confine the goats/sheep 

within a specific area. For example, sheep can be induced to eat leafy spurge, which is toxic to 

cattle but not to sheep or goats. Sheep are known to suppress leafy spurge populations, but 

usually do not eradicate this weed. 

This method may be used to reduce the vigor of some weeds where numerous, repeat treatments 

can be applied at the appropriate times. The availability of herds managed for this type of control 

may be limiting. This method is primarily proposed as a minor, incidental treatment method, and 

will be evaluated for effectiveness. Where appropriate, grazing will be integrated with other 

treatment methods to achieve more effective weed control. 

This weed control method will be conducted in accordance with Forest Service grazing 

regulations and regional policy. A site-specific project operation plan will be developed for the 

treatment area that will consider factors such as target weed species, type of livestock to be used, 

forage preference, planned grazing intensity, herding characteristics, topography, water 

availability, season of use, and a monitoring program. Forest Service regulations, policies, and the 

appropriate mitigation measures will be followed.

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 roots. Girdling is a method 

that may be used for invasive trees, such as Siberian elm. 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 Forest due to steep slopes and other terrain 

features such as trees, boulders, or logs. Thus, this method is only proposed for minor, incidental 

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

mechanical treatment is proposed in combination with other methods. 

Prescribed Burning 

Burning is similar to plowing or cutting the tops of weeds. It removes the seed heads and for 

some plants can reduce the seedbank in the soil. Broadcast burning weeds on the soil surface may 

be employed if there are sufficient fuels to carry a fire, or propone torches may be used on weeds 

where a surface fire will not carry through the weed population. Generally burning is not highly 

effective when used alone to eradicate or control most weed populations. Thus, it will typically be 

used in combination with other methods. 

Cultural Methods

Cultural methods are actions such as planting or seeding with desirable native plants immediately 

following a weed control treatment or other methods that allow desirable plants to out-compete 

the weed species. These methods are not proposed to be used alone to eradicate or control weed 

populations, but will be used where needed on treated sites as a follow-up method to favor native 

species and minimize subsequent weed infestation. This method will also be used where 
Santa Fe National Forest Invasive Plant Control Project

22

necessary to minimize soil erosion or stream sedimentation where needed following removal of 

weed species and exposure of bare soil.

Adaptive Strategy

The selected alternative will employ an adaptive strategy that has been determined to be 

necessary for the success of weed control projects and consistent with Forest Service policy

(USDA-FS 2001b). As part of this adaptive strategy, weed treatments must be monitored, 

evaluated and modified as necessary to improve effectiveness of future treatments while reducing 

the potential for adverse effects to people and natural resources. This strategy allows for adopting 

findings from research studies on different practices or impacts, or changes in land or resource 

conditions. This strategy is key to finding and treating infestations that are not currently 

identified.

The adaptive strategy provides for flexibility to use the appropriate treatment method, based on 

the results of monitoring and evaluation. For the selected alternative, the adaptive strategy will 

allow for any of the integrated weed control methods to be used on a given site. The adaptive 

strategy will cover weeds found in additional locations as well as new species found on the 

Forest. The Forest proposes an adaptive strategy with the following actions: 

Annually inventory portions of the Forest that are likely to have new infestations (e.g. 

areas burned by wildfires) and map any new weed infestations. Budget 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 later in this section.

Monitor the effectiveness and effects of weed treatment activities and associated 

mitigation measures.

Evaluate and disclose monitoring results, and use those results to determine appropriate 

modifications in treatment prescriptions, mitigation measures, or implementation 

practices.

New information (as described in Table 1) would 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.

Implement modifications or other feasible and appropriate treatment methods based on 

monitoring results, as long as the new or modified 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 this FSEIS (and in accordance with Forest 

Service Handbook FSH 1909.15 §18). 

Treatment Objectives, Priorities and Decision Criteria

Treatment objectives for a given weed species fall into one of the following three categories:

Eradication (elimination)

Control (reducing the population over time) 

Containment (preventing the population from spreading) 

Eradicating or controlling every weed infestation at the same time is beyond the budget and 

personnel resources of the Forest. Eradication will be the objective applied to first priority species 

or situations, followed by control for second priority situations, and containment for third priority. 
Draft Record of Decision

23

Therefore, a system for setting priorities is proposed so that treatment concentrates on species that 

have the greatest impact on the resource base, and those that become more difficult to control if 

action is delayed. Most weeds become much more difficult to control once they have spread.

Thus, the highest priority is to eradicate new species occurrences on the Forest, and then to keep 

existing populations from spreading or increasing in size. 

Weed species of limited extent are eradicated or controlled. Because the size threshold varies by 

weed species, this determination will need to be made based on site-specific conditions. 

Extremely widespread and common weeds are much more difficult to control, and so they are 

generally scheduled to “contain” as a Priority 3 species.

Treatment objectives and priorities are interconnected, and will be based on the following criteria, 

which is consistent with New Mexico’s weed control laws and procedures. 

Priority 1—Eradicate New Populations of High-Threat Species. 

This priority immediately eradicates new populations of species that pose a high threat to 

resources. Eliminating these populations while they are small creates the best opportunity to 

avoid impacts from these species. Eradication includes all viable seeds and vegetative propagules. 

High-threat species are those that can rapidly expand into native habitats and displace native 

vegetation throughout the national forest in a relatively short period of time. Eradicate all 

infestations of Class A weeds, which are those species exotic to New Mexico, but threatening to 

invade the State. Examples include black henbane, leafy spurge, and toadflax. They have limited 

distribution on the national forest (e.g. yellow toadflax), but if they become widespread, they pose 

a threat to agriculture crops, rangelands, plants listed as endangered, threatened or sensitive, and 

other resources in the State.

Priority 2—Control Existing Populations of High-Threat Species. 

This priority gradually reduces existing populations of high-threat species. Control is 

accomplished by preventing seed production throughout the target area, decreasing the area 

coverage of the weed over time, and preventing the weed from dominating the area’s vegetation. 

This priority strives to achieve low levels of the weed populations if eradication is not feasible. 

For Class B weeds, this priority will decrease the population size and eventually eliminate this 

class of weeds, which are exotic (NMDA 1999) and of limited distribution in the national forest 

but are common in other parts of the State and so likely to appear. As a general rule, the objective 

will be to substantially reduce Class B weed infestations. For populations of 5 to 25 acres in size 

this means reducing the size by about 75 to 100 percent. For Class B weed infestations greater 

than 25 acres in size, this means reducing the size by 50 percent. Examples of Class B weeds 

include bull thistle and musk thistle. 

Priority 3—Contain Existing Populations of High-Threat Species. 

This priority holds existing populations of aggressive weeds in check, so that they do not increase 

from their current size. Containing populations is accomplished by preventing weeds from 

expanding beyond the perimeter of the infestation, perhaps providing only limited treatment 

within the infestation, and treating to eradicate or control the weed outside the perimeter of the 

infestation. This priority will contain the spread of Class B weeds that are of limited distribution 

on the Santa Fe National Forest (e.g. poison hemlock). For Class C weeds, which are widespread 

throughout the State and national forest, contain them to their present population size, or for 

populations greater than 5 acres in size, strive to reduce by 50 percent. Examples include 

saltcedar, Russian olive, and Siberian elm.
Santa Fe National Forest Invasive Plant Control Project

24

Priority 4—Eradicate New Populations of Moderate-Threat Species. 

This priory eradicates new populations of less aggressive weeds. This priority immediately treats 

these new populations to eradicate them early, although they are not as high a priority as Priority 

1 weeds. These populations expand into native habitats more slowly and/or are less successful 

than Priority 1 weeds in displacing native plants.

Priority 5—Control Existing Populations of Moderate-Threat Species.

This priority gradually reduces existing populations of less aggressive weeds.

Priority 6—Contain Existing Populations of Moderate-Threat Species. 

This priority holds in place existing populations of less aggressive weeds.

Additional Criteria for Prioritizing and 

Determining Objectives and Methods 

In addition, weed infestations found in the following locations will likely be given 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 semiprimitive, nonmotorized, including 

the road corridors and trails that lead to those areas;

Areas that are now relatively weed free that 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 Forest with weed populations adjacent to other land ownerships where land 

managers have active weed control programs; and

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 will be based first on the priorities just described, 

and spread out over time based on levels of funding and staffing on the Forest.

Selection of treatment method is based to a large extent on the priority of the weed species and 

associated objective, along with site-specific factors such as proximity to water or roads (which 

increases chance of spread), and the size of the weed infestation (small sizes are easier to 

eradicate).

For example, a Priority 1 weed species (spotted knapweed) is found in a site that suggests 

eradication is the objective (it lays along a major highway). The size of the infestation is more 

than can be hand pulled (more than 2 acres). Therefore, an herbicide will be selected because that 

is the only method known to be highly effective and economically feasible for this weed 

population.

In addition to using treatment objectives, priority rankings, and infestation size, additional criteria 

that will be used in selecting the most appropriate treatment method under the adaptive strategy is 

shown in Table 1.
Draft Record of Decision

25

Table 1. 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. 

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. 
Santa Fe National Forest Invasive Plant Control Project

26

Weed Site Conditions Treatment Method Limitations 

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.

Design Features and Monitoring Requirements

Table 2. Design Features and Monitoring Requirements

Row 

No.

Description of Design Feature and Monitoring Requirement

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.

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).

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.

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.

5 Herbicides may only be applied by a trained applicator under supervision of a licensed applicator, 

in accordance with Forest Service directives.
Draft Record of Decision

27

Row 

No.

Description of Design Feature and Monitoring Requirement

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.

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).

2

8 Workers handling herbicides will be required to wear protective clothing, including a long-sleeved 

shirt and long pants to reduce worker exposure. 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.

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.

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 National Forest websites and mailed to those who request it.

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.

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.

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.

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 ground-disturbing 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.

16 Range 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. 

17 Weed treatments will only be applied where weeds actually exist, not on areas with a potential for 

weed infestations.

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.

 

2 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”.
Santa Fe National Forest Invasive Plant Control Project

28

Row 

No.

Description of Design Feature and Monitoring Requirement

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 

weed-free 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).

20 Herbicides will not be applied if snow or ice covers the target weed plants to avoid runoff into soil 

and onto nontarget vegetation.

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.

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.

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).

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.

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.

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.

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.

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. 

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.

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.

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).

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.

Wildlife, including Threatened, Endangered and Sensitive Species
Draft Record of Decision

29

Row 

No.

Description of Design Feature and Monitoring Requirement

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. 

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.

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.

36 Applies to implementation on the Carson National Forest only. Intentionally left blank.

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.

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.

39 Only herbicides documented to have a low risk to wildlife and domestic animals (for both 

ingredients and application rates) will be used. 

40 No controlled grazing with sheep or goats will be permitted in areas occupied or frequented by 

bighorn sheep (high country/wilderness).

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.

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.

44 Heavy mechanized equipment such as tractors with tillers or mowers will not be used on slopes 

over 40 percent, to minimize erosion potential.

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.
Santa Fe National Forest Invasive Plant Control Project

30

Row 

No.

Description of Design Feature and Monitoring Requirement

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. 

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.

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. 

49 In riparian areas or next to live waterbodies containing fish, methods used must have been 

documented to have low risk to aquatic species.

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.

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 pre-implementation 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. 

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.

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.

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.

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. 

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.

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.
Draft Record of Decision

31

Row 

No.

Description of Design Feature and Monitoring Requirement

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.

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.

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.

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. 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 the 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.