October 2005

Final Environmental 

Impact Statement

Bureau of Land Management

Vegetation Treatments Using 

Herbicides on BLM Lands in Oregon

Volume 2 - Appendices

Oregon State Office July 2010

BLM

FES 10-23 

BLM/OR/WA/AE-10/077+1792
As the Nation’s principal 

conservation agency, the 

Department of the Interior has 

responsibility for most of our 

nationally owned public lands 

and natural resources. This 

includes fostering the wisest use 

of our land and water resources, 

protecting our fish and wildlife, 

preserving the environmental and 

cultural values of our national 

parks and historical places, and 

providing for the enjoyment of 

life through outdoor recreation. 

The Department assesses our 

energy and mineral resources 

and works to assure that their 

development is in the best interest 

of all our people. The Department 

also has a major responsibility 

for American Indian reservation 

communities and for people who 

live in Island Territories under U.S. 

administration. 

Cover: Southeast of Richland, Oregon along the Brownlee Reservoir 

(Snake River), a rancher views vast stands of medusahead (a noxious weed). 

The area is mixed BLM/private ownership (photographer: Matt Kniesel).

Because science cannot, in any practical sense, assure safety through any 

testing regime, pesticide use should be approached cautiously. 

(EPA scoping comment, July 28, 2008)

Our present technologies for countering invasive non-native weeds are 

rudimentary and few: control by biological agents, manual eradication, 

mechanized removal, fire, and herbicides. All have limitations; all are 

essential (Jake Sigg, California Native Plant Society 1999)
449

Final Environmental Impact Statement: Table of Contents

Table of Contents – Volume 2

Changes Between the Draft and Final EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 453

Appendix 1 – The PEIS.............................................................................455

Appendix 2 - Standard Operating Procedures and Mitigation Measures from the PEIS . . . . . . . . . . . . . . . . . . . . . . 457

Appendix 3 – Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 469

Part I - Existing Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 469

Part II - Potential Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 474

Appendix 4 – Protocol for Identifying, Evaluating, and Using New Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 477

Identification and Approval of New herbicide Products and Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 477

Determining the Need for New Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 478

Assessment of Hazards and Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 479

NEPA Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 480

Appendix 5 – Federally Listed and other Special Status Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 483

Summary of the Action Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 484

Summary of Applicable Standard Operating Procedures and PEIS Mitigation Measures . . . . . . . . . . . . . . . . . 484

Consultation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 485

Biological Assessment Conservation Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 486

Endangered and Threatened Species in Oregon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 486

Birds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 486

Fish. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 493

Invertebrates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 510

Mammals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 514

Vascular Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 519

State Directors Special Status Species List – Federally Listed or Proposed . . . . . . . . . . . . . . . . . . . . . . . . . . . . 540

State Directors Special Status Species List – Bureau Sensitive . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 542

Appendix 6 – Summary of Existing District Resource Management Plan Direction for Noxious Weeds . . . . . . . . . 555

Appendix 7 – Additional Information about Noxious Weeds and Other Invasive Plants . . . . . . . . . . . . . . . . . . . . . . . 585

Oregon State Noxious Weed List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 586

Common and Scientific Plant Names . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 589

Noxious Weed Spread Rate References and Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 594

Additional Information about the Ecological Damage Caused by Invasive Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . 598

Appendix 8 – Human Health and Ecological Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 605

Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 605

Appendix 9 – Additional Information About the 18 Herbicides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 609

Herbicide Formulations Approved for BLM Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 609

Target Species and Recommended Herbicide Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 617

Adjuvants Approved for Use on BLM Lands Nationally . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 624

Individual Herbicide Summaries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 627

Appendix 10 - Response to Public Comments on the September 2009 Draft EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 649

Appendix 11 - Comment Letters from Federal, State, and Local Government Agencies on the 2009 Draft EIS . . . . . . 765
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Appendix 12 - 2,4-D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 783

Uses and Importance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 783

Acres and Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 785

Worker and Public Health . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 785

Environmental Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 786

DEIS Public Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 786

Appendix 13 - EPA Pesticide Registration and Reregistration and BLM/FS Risk Assessment Processes . . . . . . . . . 799

Data Requirements for EPA Pesticide Registration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 800

EPA Reregistration Eligibility Decision (RED) Documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 803

BLM Ecological Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 804

BLM Human Health Risk Assessments (HHRA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 805

Forest Service Human Health and Environmental Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 808

Uncertainty Analysis in Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 817
451

Final Environmental Impact Statement: Table of Contents

Tables

Table A2-1. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of BLM-Evaluated Herbicides . . . . . . . . . 466

Table A2-2. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of Forest Service-Evaluated Herbicides 466

Table A2-3. Buffer Distances to Minimize Risk to Non-Special Status Fish and Aquatic Invertebrates from OffSite Drift of BLM-Evaluated Herbicides from Broadcast and Aerial Treatments . . . . . . . . . . . . . . . . . . . . . . . . 467

Table A2-4. Buffer Distances to Minimize Risk to Special Status Fish and Aquatic Organisms from Off-Site 

Drift of BLM-Evaluated Herbicides from Broadcast and Aerial Treatments . . . . . . . . . . . . . . . . . . . . . . . . . . . 467

Table A5-1. State Director’s Special Status Species List – Federally Threatened, Endangered, or Proposed, 

Oregon January 2008 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 540

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM . . . . . . . . . . . . 542

Table A7-1. Oregon State Noxious Weed List: Abundance and Alternative Where Effective Control Becomes 

Available - June 2010. This list includes most of the noxious weeds actively managed by the 

BLM in Oregon, but additional plants may be designated on Federal or County lists. . . . . . . . . . . . . . . . . . 586

Table A7-2. Common and Scientific Plant Names of Plants Potentially Requiring Management . . . . . . . . . . . . . . . . . . . . 589

Table A7-3. Annual Acres of Effective Noxious Weed Control by Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 596

Table A7-4. Weed Spread of 12% Reduced by 10 Times 18,860 Acres of Effective Annual Control (Difference 

Between Alts 2 and 3), Distributed Over 15 Decades at 10, 5, 5, 5, 5, 5, 5, 5, 5, 5, 5, 10, 10, 10 

and 10% ea Decade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 596

Table A7-5. Weed Spread of 12% Increased by 10 Times the 14,670 Acres Less Effective Annual Control 

(Difference Between Alt 2 and the Reference Analysis, Shown as a Negative Number), 

Distributed over 15 Decades at 10, 5, 5, 5, 5, 5, 5, 5, 5, 5, 5, 10, 10, 10 and 10% ea Decade . . . . . . . . . . . . 597

Table A7-6. Weed Spread of 12% Reduced by 10 Times 21,210 Acres of Effective Annual Control (Difference 

Between Alts 2 and 4), Distributed Over 15 Decades at 10, 5, 5, 5, 5, 5, 5, 5, 5, 5, 5, 10, 10, 10 

and 10% ea Decade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 597

Table A8-1. Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 607

Table A8-2: Additional Risk Assessment Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 607

Table A9-1. Herbicide Formulations Approved for Use on BLM Lands Nationally as of November 2009 . . . . . . . . . . . . 609

Table A9-3. Adjuvants Approved for Use on BLM Lands Nationally as of November 2009 . . . . . . . . . . . . . . . . . . . . . . . 624

Figures

Figure A6-1. Resource Management Plan Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 583
 452

Vegetation Treatments Using Herbicides on BLM Lands in Oregon
453

Final Environmental Impact Statement: Changes

Appendices

Changes Between Draft and Final EIS

The following changes were made to the Appendices between the draft and final EIS. Minor corrections, 

explanations, and edits are not included in this list.

Changes were made in:

•	 Appendix 3 - Monitoring, to better describe existing monitoring under the Northwest Forest Plan, 

PACFISH/INFISH, and the National Invasive Species Monitoring Systems, and to add information about 

State monitoring efforts;

•	 Appendix 5 – Endangered, Threatened, and other Special Status Species, to update it for expanded bull 

trout critical habitat, the listing of Pacific Eulachon, 12-month findings for petitions to list the greater sage 

grouse, and to add the Conservation Measures from the PEIS Consultation and Conferencing;

•	 Appendix 8 – Risk Assessments, to add newer risk assessments for hexazinone and clopyralid; and, 

•	 Appendix 9 – Additional Information About the 18 Herbicides, to add individual information summary 

pages for each of the 18 herbicides, to add a list of BLM’s currently approved adjuvants, and to clarify 

how the Alternative where recommended herbicide available determinations on Table A9-2 were made.

In addition, the following Appendices were added:

•	 Appendix 10 – Response to Public Comments on the September 2009 Draft EIS;

•	 Appendix 11 – Comment Letters from Federal, State, and local Government Agencies on the 2009 Draft 

EIS;

•	 Appendix 12 – 2,4-D provides additional information about 2,4-D, and specifically documents additional 

considerations of 2,4-D as a management tool; and, 

•	 Appendix 13 – EPA Pesticide Registration and BLM/FS Risk Assessment Process describes the process 

and information considered during herbicide registration, and during the Agencies’ Risk Assessment 

process. This Appendix includes additional information about incomplete and unavailable information 

about inerts and adjuvants to supplement the discussions in Chapter 3 and in the Incomplete and 

Unavailable information section early in Chapter 4.
 454

Vegetation Treatments Using Herbicides on BLM Lands in Oregon
455

Final Environmental Impact Statement: Appendix 1

Appendix 1 – 

The PEIS

This appendix consists of the Final Vegetation Treatments Using Herbicides on Bureau of Land Management Lands 

in 17 Western States Programmatic Environmental Impact Statement (PEIS) published in June 2007. The Oregon 

EIS is tiered to this 2007 analysis, and the PEIS is incorporated in its entirety into the Oregon EIS as Appendix 1. 

The PEIS is available at http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. A CD or hard copy version can be 

obtained by emailing, writing, or calling the BLM at the contact points included in the front of this EIS.

The PEIS consists of three volumes and a separately published Biological Assessment. The volumes and sections 

within each are arranged on the website as follows:

Final Vegetation Treatments Using Herbicides Programmatic Environmental Impact Statement 

Programmatic EIS Vol. 1 

a. Dear Reader Letter

b. Title Page - Abstract

c. Executive Summary

d. Table of Contents

e. Chapters 1 - 8 

i. Chapter 1 - Proposed Action and Purpose and Need

ii. Chapter 2 - Alternatives

iii. Chapter 3 – Affected Environment

iv. Chapter 4 – Environmental Consequences

v. Chapter 5 – Consultation and Coordination

vi. Chapter 6 - References

vii. Chapter 7 - Glossary

viii. Chapter 8 - Index

f. Final Programmatic EIS Maps 

i. Map 1-1 – Public Lands Administered by the BLM

ii. Map 3-1 – Ecoregion Divisions

iii. Map 3-2 – Class I Areas

iv. Map 3-3 – Oil and Gas Wells on Public Lands

v. Map 3-4 – Soil Orders on Public Lands

vi. Map 3-5 – Hydrologic Regions

vii. Map 3-6 – Watershed Surface Water Quality on Public Lands

viii. Map 3-7 – General Groundwater Quality on Public Lands

ix. Map 3-8 – Vegetation Types and Ecoregions on Public Lands in Alaska

x. Map 3-9 – Vegetation Types and Ecoregions on Public Lands in the Western U.S.

xi. Map 3-10 – Fire Regime Condition Classes on Public Lands

xii. Map 3-11 – Native Areas of Western North America

xiii. Map 3-12 – National Landscape Conservation System Areas

g. List of Acronyms 
 456

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

h. Programmatic Report Covers 

Programmatic EIS Vol. 2 

a. Programmatic EIS Cover Pages and Table of Contents (TOC) 

i. Vol. 2 Title Page

ii. Vol. 2 TOC

b. Programmatic EIS Appendixes 

i. Appendix A - Scientific Names

ii. Appendix B - Human Health Risk Assessment

iii. Appendix C - Ecological Risk Assessment

iv. Appendix D - Degradates

v. Appendix E - Risk Assessment Protocol

vi. Appendix F - BLM Manual

vii. Appendix G - Consultation Agreements

viii. Appendix H - ANILCA 810 Analysis

ix. Appendix I - Restore Native Ecosystems Alternative and BLM Policy Analysis

x. Appendix J - Special Status Species

c. Final Programmatic EIS Vol. 2 Report Covers 

Programmatic EIS Vol. 3 

a. Title Page 

b. Response to Comments

c. Public Comment Letters

i. Email Comments

ii. Fax Comments

iii. Form Letter Comments

iv. Letter Comments

v. Public Hearing Comments

vi. Public Hearing Transcripts

vii. Vol. 3 Programmatic EIS Report Covers

Final Biological Assessment 

a. Biological Assessment

b. Final BA Report Cover

c. Map
457

Final Environmental Impact Statement: Appendix 2

Appendix 2 - 

Standard Operating Procedures and 

Mitigation Measures from the PEIS

Introduction

The following Standard Operating Procedures and Mitigation Measures have been adopted from the Record 

of Decision for the PEIS. Minor edits have been made to some Standard Operating Procedures and Mitigation 

Measures to clarify intent.

Standard Operating Procedures (identified below with SOP) have been identified to reduce adverse effects to 

environmental and human resources from vegetation treatment activities based on guidance in BLM manuals 

and handbooks, regulations, and standard BLM and industry practices.1 The list is not all encompassing, 

but is designed to give an overview of practices that would be considered when designing and implementing 

a vegetation treatment project on public lands (PER:2-29)2. Effects described in the EIS are predicated on 

application of the Standard Operating Procedures, that a site-specific determination is made that their application 

is unnecessary to achieve their intended purpose or protection, or that if the parent handbook or policy direction 

evolves, the new direction would continue to provide the appropriate environmental protections.

For example, the Standard Operating Procedure to “complete vegetation treatments seasonally before pollinator 

foraging plants bloom” would not be applied to treatments not likely to have a significant effect on pollinators. 

PEIS Mitigation Measures (identified below with MM) were identified for all potential adverse effects identified 

in the PEIS. They are included in, and adopted by, the Record of Decision for the PEIS. Like the SOPs, 

application of the mitigation measures is assumed in this EIS. However, for PEIS Mitigation Measures, sitespecific analysis and/or the use of Individual Risk Assessments Tools (see Chapter 3), or evolution of the PEIS 

Mitigation Measures into handbook direction at the national level, would be permitted to identify alternative ways 

to achieve the expected protections (PEIS:4-4).

Although not displayed here, Standard Operating Procedures for non-herbicide treatments (from regulation, BLM 

policy, and BLM Handbook direction) also apply (PER:2-31 to 44).

Standard Operating Procedures and Mitigation Measures for Applying Herbicides

Guidance Documents

BLM Handbook H-9011-1 (Chemical Pest Control); and manuals 1112 (Safety), 9011 (Chemical Pest Control), 

9012 (Expenditure of Rangeland Insect Pest Control Funds), 9015 (Integrated Weed Management), and 9220 

(Integrated Pest Management).

1 Manual-directed standard operating procedures and other standing direction may be referred to as best management 

practices in resource management and other plans, particularly when they apply to water.

2 The PER includes Standard Operating Procedures for the full range of vegetation treatment methods. Only those 

applicable to herbicide application are included in this appendix.
 458

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

General

•	 Prepare an operational and spill contingency plan in advance of treatment. (SOP)

•	 Conduct a pretreatment survey before applying herbicides. (SOP)

•	 Select the herbicide that is least damaging to the environment while providing the desired results. (SOP)

•	 Select herbicide products carefully to minimize additional impacts from degradates, adjuvants, other 

ingredients, and tank mixtures. (SOP)

•	 Apply the least amount of herbicide needed to achieve the desired result. (SOP)

•	 Follow herbicide product label for use and storage. (SOP)

•	 Have licensed or certified applicators or State-licensed “trainees” apply herbicides, or they can be applied by 

BLM employees under the direct supervision of a BLM-certified applicator. (SOP)

•	 Use only USEPA-approved herbicides and follow product label directions and “advisory” statements. (SOP)

•	 Review, understand, and conform to the “Environmental Hazards” section on the herbicide product label. 

This section warns of known herbicide risks to the environment and provides practical ways to avoid harm to 

organisms or to the environment. (SOP)

•	 Consider surrounding land use before assigning aerial spraying as a treatment method and avoid aerial 

spraying near agricultural or densely populated areas. (SOP)

•	 Minimize the size of application area, when feasible. (SOP)

•	 Comply with herbicide-free buffer zones to ensure that drift will not affect crops or nearby residents/

landowners. (SOP)

•	 Post treated areas and specify reentry or rest times, if appropriate. (SOP)

•	 Notify adjacent landowners prior to treatment, if appropriate. (SOP)

•	 Keep a copy of Material Safety Data Sheets (MSDSs) at work sites. MSDSs are available for review at http://

www.cdms.net/. (SOP)

•	 Keep records of each application, including the active ingredient, formulation, application rate, date, time, and 

location. (SOP)

•	 Avoid accidental direct spray and spill conditions to minimize risks to resources. (SOP)

•	 Avoid aerial spraying during periods of adverse weather conditions (snow or rain imminent, fog, or air 

turbulence). (SOP)

•	 Make helicopter applications at a target airspeed of 40 to 50 miles per hour (mph), and at about 30 to 45 feet 

above ground. (SOP)

•	 Take precautions to minimize drift by not applying herbicides when winds exceed >10 mph (>6 mph for aerial 

applications), or a serious rainfall event is imminent. (SOP)

•	 Use drift control agents and low volatile formulations. (SOP)

•	 Conduct pre-treatment surveys for sensitive habitat and Special Status species within or adjacent to proposed 

treatment areas. (SOP)

•	 Consider site characteristics, environmental conditions, and application equipment in order to minimize 

damage to non-target vegetation. (SOP)

•	 Use drift reduction agents, as appropriate, to reduce the drift hazard to non-target species. (SOP)

•	 Turn off application equipment at the completion of spray runs and during turns to start another spray run. 

(SOP)

•	 Refer to the herbicide product label when planning revegetation to ensure that subsequent vegetation would not 

be injured following application of the herbicide. (SOP)

•	 Clean OHVs to remove plant material. (SOP)

The BLM has suspended the use of the adjuvant R-11.
459

Final Environmental Impact Statement: Appendix 2

Air Quality

See Manual 7000 (Soil, Water, and Air Management)

•	 Consider the effects of wind, humidity, temperature inversions, and heavy rainfall on herbicide effectiveness 

and risks. (SOP)

•	 Apply herbicides in favorable weather conditions to minimize drift. For example, do not treat when winds 

exceed 10 mph (>6 mph for aerial applications) or rainfall is imminent. (SOP)

•	 Use drift reduction agents, as appropriate, to reduce the drift hazard. (SOP)

•	 Select proper application equipment (e.g., spray equipment that produces 200- to 800-micron diameter droplets 

[spray droplets of 100 microns and less are most prone to drift]). (SOP)

•	 Select proper application methods (e.g., set maximum spray heights, use appropriate buffer distances between 

spray sites and non-target resources). (SOP)

Soil

See Manual 7000 (Soil, Water, and Air Management)

•	 Minimize treatments in areas where herbicide runoff is likely, such as steep slopes when heavy rainfall is 

expected. (SOP)

•	 Minimize use of herbicides that have high soil mobility, particularly in areas where soil properties increase the 

potential for mobility. (SOP)

•	 Do not apply granular herbicides on slopes of more than 15% where there is the possibility of runoff carrying 

the granules into non-target areas. (SOP)

Water Resources

See Manual 7000 (Soil, Water, and Air Management)

•	 Consider climate, soil type, slope, and vegetation type when developing herbicide treatment programs. (SOP)

•	 Select herbicide products to minimize impacts to water. This is especially important for application scenarios 

that involve risk from active ingredients in a particular herbicide, as predicted by risk assessments. (SOP)

•	 Use local historical weather data to choose the month of treatment. (SOP)

•	 Considering the phenology of target aquatic species, schedule treatments based on the condition of the water 

body and existing water quality conditions. (SOP)

•	 Plan to treat between weather fronts (calms) and at appropriate time of day to avoid high winds that increase 

water movements, and to avoid potential stormwater runoff and water turbidity. (SOP)

•	 Review hydrogeologic maps of proposed treatment areas. Note depths to groundwater and areas of shallow 

groundwater and areas of surface water and groundwater interaction. Minimize treating areas with high risk 

for groundwater contamination. (SOP)

•	 Conduct mixing and loading operations in an area where an accidental spill would not contaminate an aquatic 

body. (SOP)

•	 Do not rinse spray tanks in or near water bodies. (SOP)

•	 Do not broadcast pellets where there is danger of contaminating water supplies. (SOP)

•	 Minimize the potential effects to surface water quality and quantity by stabilizing terrestrial areas as quickly as 

possible following treatment. (SOP)

•	 Establish appropriate (herbicide-specific) buffer zones for species/populations (Tables A2-1 and A2-2). (MM)

•	 Areas with potential for groundwater for domestic or municipal use shall be evaluated through the appropriate, 

validated model(s) to estimate vulnerability to potential groundwater contamination, and appropriate mitigation 

measures shall be developed if such an area requires the application of herbicides and cannot otherwise be 

treated with non-herbicide methods. (MM)

•	 Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on risk assessment 

guidance, with minimum widths from water of 100 feet for aerial, 25 feet for vehicle, and 10 feet for hand 

spray applications. (SOP)
 460

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

•	 Maintain buffers between treatment areas and water bodies. Buffer widths should be developed based on 

herbicide and site-specific conditions to minimize impacts to water bodies. (SOP)

Wetlands and Riparian Areas

•	 Use a selective herbicide and a wick or backpack sprayer. (SOP)

•	 Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on risk assessment 

guidance, with minimum widths from water of 100 feet for aerial, 25 feet for vehicle, and 10 feet for hand 

spray applications. (SOP)

•	 See mitigation for Water Resources and Vegetation. (MM)

Vegetation

See Handbook H-4410-1 (National Range Handbook), and manuals 5000 (Forest Management) and 9015 

(Integrated Weed Management)

•	 Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation would not be 

injured following application of the herbicide. (SOP)

•	 Use native or sterile plants for revegetation and restoration projects to compete with invasive plants until 

desired vegetation establishes. (SOP)

•	 Use weed-free feed for horses and pack animals. Use weed-free straw and mulch for revegetation and other 

activities. (SOP)

•	 Identify and implement any temporary domestic livestock grazing and/or supplemental feeding restrictions 

needed to enhance desirable vegetation recovery following treatment. Consider adjustments in the existing 

grazing permit, to maintain desirable vegetation on the treatment site. (SOP)

•	 Minimize the use of terrestrial herbicides (especially bromacil, diuron, and sulfometuron methyl) in watersheds 

with downgradient ponds and streams if potential impacts to aquatic plants are identified. (MM)

•	 Establish appropriate (herbicide-specific) buffer zones (Tables A2-1 and 2) around downstream water bodies, 

habitats, and species/populations of interest. Consult the ecological risk assessments (ERAs) prepared for the 

PEIS for more specific information on appropriate buffer distances under different soil, moisture, vegetation, 

and application scenarios. (MM)

•	 Limit the aerial application of chlorsulfuron and metsulfuron methyl to areas with difficult land access, where 

no other means of application are possible. (MM)

•	 Do not apply sulfometuron methyl aerially. (MM)

•	 When necessary to protect Special Status plant species, implement all conservation measures for plants 

presented in the Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Biological Assessment (see Appendix 5). (MM)

Pollinators

•	 Complete vegetation treatments seasonally before pollinator foraging plants bloom. (SOP)

•	 Time vegetation treatments to take place when foraging pollinators are least active both seasonally and 

daily. (SOP)

•	 Design vegetation treatment projects so that nectar and pollen sources for important pollinators and resources 

are treated in patches rather than in one single treatment. (SOP)

•	 Minimize herbicide application rates. Use typical rather than maximum rates where there are important 

pollinator resources. (SOP)

•	 Maintain herbicide free buffer zones around patches of important pollinator nectar and pollen sources. (SOP)

•	 Maintain herbicide free buffer zones around patches of important pollinator nesting habitat and hibernacula. (SOP)

•	 Make special note of pollinators that have single host plant species, and minimize herbicide spraying on those 

plants and in their habitats. (SOP)
461

Final Environmental Impact Statement: Appendix 2

Fish and Other Aquatic Organisms 

See manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

•	 Use appropriate buffer zones based on label and risk assessment guidance. (SOP)

•	 Minimize treatments near fish-bearing water bodies during periods when fish are in life stages most sensitive to 

the herbicide(s) used, and use spot rather than broadcast or aerial treatments. (SOP)

•	 Use appropriate application equipment/method near water bodies if the potential for off-site drift exists. (SOP)

•	 For treatment of aquatic vegetation, 1) treat only that portion of the aquatic system necessary to meet 

vegetation management objectives, 2) use the appropriate application method to minimize the potential for 

injury to desirable vegetation and aquatic organisms, and 3) follow water use restrictions presented on the 

herbicide label. (SOP)

•	 Limit the use of diquat in water bodies that have native fish and aquatic resources. (MM)

•	 Limit the use of terrestrial herbicides (especially diuron) in watersheds with characteristics suitable for 

potential surface runoff that have fish-bearing streams during periods when fish are in life stages most sensitive 

to the herbicide(s) used. (MM)

•	 To protect Special Status fish and other aquatic organisms, implement all conservation measures for aquatic 

animals presented in the Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Biological Assessment (see Appendix 5). (MM)

•	 Establish appropriate herbicide-specific buffer zones for water bodies, habitats, or fish or other aquatic species 

of interest (Tables A2-3 and A2-4, and recommendations in individual ERAs). (MM)

•	 Consider the proximity of application areas to salmonid habitat and the possible effects of herbicides on 

riparian and aquatic vegetation. Maintain appropriate buffer zones around salmonid-bearing streams. (MM)

•	 At the local level, consider effects to Special Status fish and other aquatic organisms when designing treatment 

programs. (MM)

Wildlife

See manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

•	 Use herbicides of low toxicity to wildlife, where feasible. (SOP)

•	 Use spot applications or low-boom broadcast operations where possible to limit the probability of 

contaminating non-target food and water sources, especially non-target vegetation over areas larger than the 

treatment area. (SOP)

•	 Use timing restrictions (e.g., do not treat during critical wildlife breeding or staging periods) to minimize 

impacts to wildlife. (SOP)

•	 To minimize risks to terrestrial wildlife, do not exceed the typical application rate for applications of dicamba, 

diuron, glyphosate, hexazinone, tebuthiuron, or triclopyr, where feasible. (MM)

•	 Minimize the size of application areas, where practical, when applying 2,4-D, bromacil, diuron, and 

Overdrive® to limit impacts to wildlife, particularly through contamination of food items. (MM)

•	 Where practical, limit glyphosate and hexazinone to spot applications in grazing land and wildlife habitat areas 

to avoid contamination of wildlife food items. (MM)

•	 Do not use the adjuvant R-11 (MM)

•	 Either avoid using glyphosate formulations containing POEA, or seek to use formulations with the least 

amount of POEA, to reduce risks to amphibians. (MM)

•	 Do not apply bromacil or diuron in rangelands, and use appropriate buffer zones (Tables A2-1 and 2) to limit 

contamination of off-site vegetation, which may serve as forage for wildlife. (MM)

•	 Do not aerially apply diquat directly to wetlands or riparian areas. (MM)

•	 To protect Special Status wildlife species, implement conservation measures for terrestrial animals presented 

in the Vegetation Treatments on Bureau of Land Management Lands in 17 Western States Programmatic 

Biological Assessment (See Appendix 5) (MM)
 462

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Threatened, Endangered, and Sensitive Species

See Manual 6840 (Special Status Species)

•	 Provide clearances for Special Status species before treating an area as required by Special Status Species 

Program policy. Consider effects to Special Status species when designing herbicide treatment programs. 

(SOP)

•	 Use a selective herbicide and a wick or backpack sprayer to minimize risks to Special Status plants. (SOP)

•	 Avoid treating vegetation during time-sensitive periods (e.g., nesting and migration, sensitive life stages) for 

Special Status species in area to be treated. (SOP)

Livestock

See Handbook H-4120-1 (Grazing Management)

•	 Whenever possible and whenever needed, schedule treatments when livestock are not present in the treatment 

area. Design treatments to take advantage of normal livestock grazing rest periods, when possible. (SOP)

•	 As directed by the herbicide product label, remove livestock from treatment sites prior to herbicide application, 

where applicable. (SOP)

•	 Use herbicides of low toxicity to livestock, where feasible. (SOP)

•	 Take into account the different types of application equipment and methods, where possible, to reduce the 

probability of contamination of non-target food and water sources. (SOP)

•	 Avoid use of diquat in riparian pasture while pasture is being used by livestock. (SOP)

•	 Notify permittees of the herbicide treatment project to improve coordination and avoid potential conflicts and 

safety concerns during implementation of the treatment. (SOP)

•	 Notify permittees of livestock grazing, feeding, or slaughter restrictions, if necessary. (SOP)

•	 Provide alternative forage sites for livestock, if possible. (SOP)

•	 Minimize potential risks to livestock by applying diuron, glyphosate, hexazinone, tebuthiuron, or triclopyr at 

the typical application rate where feasible. (MM)

•	 Do not apply 2,4-D, bromacil, dicamba, diuron, Overdrive®, picloram, or triclopyr across large application 

areas, where feasible, to limit impacts to livestock, particularly through contamination of food items. (MM)

•	 Where feasible, limit glyphosate and hexazinone to spot applications in rangeland. (MM)

•	 Do not apply bromacil or diuron in rangelands, and use appropriate buffer zones (Tables A2-1 and 2) to limit 

contamination of off-site vegetation, which may serve as forage for wildlife. (MM)

Wild Horses and Burros

•	 Minimize using herbicides in areas grazed by wild horses and burros. (SOP)

•	 Use herbicides of low toxicity to wild horses and burros, where feasible. (SOP)

•	 Remove wild horses and burros from identified treatment areas prior to herbicide application, in accordance 

with herbicide product label directions for livestock. (SOP)

•	 Take into account the different types of application equipment and methods, where possible, to reduce the 

probability of contaminating non-target food and water sources. (SOP)

•	 Minimize potential risks to wild horses and burros by applying diuron, glyphosate, hexazinone, tebuthiuron, 

and triclopyr at the typical application rate, where feasible, in areas associated with wild horse and burro use. 

(MM)

•	 Consider the size of the application area when making applications of 2,4-D, bromacil, dicamba, diuron, 

Overdrive®, picloram, and triclopyr in order to reduce potential impacts to wild horses and burros. (MM)

•	 Apply herbicide label grazing restrictions for livestock to herbicide treatment areas that support populations of 

wild horses and burros. (MM)

•	 Where practical, limit glyphosate and hexazinone to spot applications in rangeland. (MM)

•	 Do not apply bromacil or diuron in grazing lands within herd management areas (HMAs), and use appropriate 

buffer zones identified in Tables A2-1 and 2 to limit contamination of vegetation in off-site foraging areas. (MM)
463

Final Environmental Impact Statement: Appendix 2

•	 Do not apply 2,4-D, bromacil, or diuron in HMAs during the peak foaling season (March through June, and 

especially in May and June), and do not exceed the typical application rate of Overdrive® or hexazinone in 

HMAs during the peak foaling season in areas where foaling is known to take place. (MM)

Cultural Resources and Paleontological Resources

See handbooks H-8120-1 (Guidelines for Conducting Tribal Consultation) and H- 8270-1 (General Procedural

Guidance for Paleontological Resource Management), and manuals 8100 (The Foundations for Managing Cultural 

Resources), 8120 (Tribal Consultation Under Cultural Resource Authorities),and 8270 (Paleontological Resource 

Management). See also: Programmatic Agreement among the Bureau of Land Management, the Advisory Council on 

Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the Manner in 

Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act.

•	 Follow standard procedures for compliance with Section 106 of the National Historic Preservation Act as 

implemented through the Programmatic Agreement among the Bureau of Land Management, the Advisory 

Council on Historic Preservation, and the National Conference of State Historic Preservation Officers 

Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation 

Act and State protocols or 36 Code of Federal Regulations Part 800, including necessary consultations with 

State Historic Preservation Officers and interested tribes. (SOP)

•	 Follow BLM Handbook H-8270-1 (General Procedural Guidance for Paleontological Resource Management) 

to determine known Condition I and Condition 2 paleontological areas, or collect information through 

inventory to establish Condition 1 and Condition 2 areas, determine resource types at risk from the proposed 

treatment, and develop appropriate measures to minimize or mitigate adverse impacts. (SOP)

•	 Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that might be 

affected by herbicide treatments; work with tribes to minimize impacts to these resources. (SOP)

•	 Follow guidance under Human Health and Safety in the PEIS in areas that may be visited by Native peoples 

after treatments. (SOP)

•	 Do not exceed the typical application rate when applying 2,4-D, bromacil, diquat, diuron, fluridone, 

hexazinone, tebuthiuron, and triclopyr in known traditional use areas. (MM)

•	 Avoid applying bromacil or tebuthiuron aerially in known traditional use areas. (MM)

•	 Limit diquat applications to areas away from high residential and traditional use areas to reduce risks to Native 

Americans. (MM)

Visual Resources

See handbooks H-8410-1 (Visual Resource Inventory) and H-8431-1 (Visual Resource Contrast Rating), and manual 

8400 (Visual Resource Management)

•	 Minimize the use of broadcast foliar applications in sensitive watersheds to avoid creating large areas of 

browned vegetation. (SOP)

•	 Consider the surrounding land use before assigning aerial spraying as an application method. (SOP)

•	 Minimize off-site drift and mobility of herbicides (e.g., do not treat when winds exceed 10 mph; minimize 

treatment in areas where herbicide runoff is likely; establish appropriate buffer widths between treatment areas 

and residences) to contain visual changes to the intended treatment area. (SOP)

•	 If the area is a Class I or II visual resource, ensure that the change to the characteristic landscape is low and does 

not attract attention (Class I), or if seen, does not attract the attention of the casual viewer (Class II). (SOP)

•	 Lessen visual impacts by: 1) designing projects to blend in with topographic forms; 2) leaving some lowgrowing trees or planting some low-growing tree seedlings adjacent to the treatment area to screen short-term 

effects; and 3) revegetating the site following treatment. (SOP)

•	 When restoring treated areas, design activities to repeat the form, line, color, and texture of the natural 

landscape character conditions to meet established Visual Resource Management (VRM) objectives. (SOP)
 464

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Wilderness and Other Special Areas

See handbooks H-8550-1 (Management of Wilderness Study Areas (WSAs)), and H-8560-1 (Management of Designated 

Wilderness Study Areas), and Manual 8351 (Wild and Scenic Rivers)

•	 Encourage backcountry pack and saddle stock users to feed their livestock only weed-free feed for several days 

before entering a wilderness area, and to bring only weed-free hay and straw onto BLM lands. (SOP)

•	 Encourage stock users to tie and/or hold stock in such a way as to minimize soil disturbance and loss of native 

vegetation. (SOP)

•	 Revegetate disturbed sites with native species if there is no reasonable expectation of natural regeneration. 

(SOP)

•	 Provide educational materials at trailheads and other wilderness entry points to educate the public on the need 

to prevent the spread of weeds. (SOP)

•	 Use the “minimum tool” to treat noxious weeds and other invasive plants, relying primarily on the use of groundbased tools, including backpack pumps, hand sprayers, and pumps mounted on pack and saddle stock. (SOP)

•	 Use herbicides only when they are the minimum treatment method necessary to control weeds that are spreading 

within the wilderness or threaten lands outside the wilderness. (SOP)

•	 Give preference to herbicides that have the least impact on non-target species and the wilderness 

environment. (SOP)

•	 Implement herbicide treatments during periods of low human use, where feasible. (SOP)

•	 Address wilderness and special areas in management plans. (SOP)

•	 Control of weed infestations shall be carried out in a manner compatible with the intent of Wild and Scenic 

River management objectives. (SOP)

•	 Mitigation measures that may apply to wilderness and other special area resources are associated with 

human and ecological health and recreation (see mitigation measures for Vegetation, Fish and Other Aquatic 

Resources, Wildlife Resources, Recreation, and Human Health and Safety). (MM)

Recreation

See Handbook H-1601-1 (Land Use Planning Handbook, Appendix C)

•	 Schedule treatments to avoid peak recreational use times, while taking into account the optimum management 

period for the targeted species. (SOP)

•	 Notify the public of treatment methods, hazards, times, and nearby alternative recreation areas. (SOP)

•	 Adhere to entry restrictions identified on the herbicide product label for public and worker access. (SOP)

•	 Post signs noting exclusion areas and the duration of exclusion, if necessary. (SOP)

•	 Mitigation measures that may apply to recreational resources are associated with human and ecological health 

(see mitigation measures for Vegetation, Fish and Other Aquatic Resources, Wildlife Resources, and Human 

Health and Safety). (MM)

Social and Economic Values

•	 Consider surrounding land use before selecting aerial spraying as a treatment method, and avoid aerial 

spraying near agricultural or densely-populated areas. (SOP)

•	 Post treated areas and specify reentry or rest times, if appropriate. (SOP)

•	 Notify grazing permittees of livestock feeding restrictions in treated areas, if necessary, as per herbicide 

product label instructions. (SOP)

•	 Notify the public of the project to improve coordination and avoid potential conflicts and safety concerns 

during implementation of the treatment. (SOP)

•	 Control public access until potential treatment hazards no longer exist, per herbicide product label 

instructions. (SOP)

•	 Observe restricted entry intervals specified by the herbicide product label. (SOP)
465

Final Environmental Impact Statement: Appendix 2

•	 Notify local emergency personnel of proposed treatments. (SOP)

•	 Use spot applications or low-boom broadcast applications where possible to limit the probability of 

contaminating non-target food and water sources. (SOP)

•	 Consult with Native American tribes to locate any areas of vegetation that are of significance to the tribes and 

Native groups and that might be affected by herbicide treatments. (SOP)

•	 To the degree possible within the law, hire local contractors and workers to assist with herbicide application 

projects and purchase materials and supplies for herbicide treatment projects (including the herbicides) through 

local suppliers. (SOP)

•	 To minimize fears based on lack of information, provide public educational information on the need for 

vegetation treatments and the use of herbicides in an integrated vegetation management program for projects 

proposing local use of herbicides. (SOP)

Rights-of-way

•	 Coordinate vegetation treatment activities where joint or multiple use of a ROW exists. (SOP)

•	 Notify other public land users within or adjacent to the ROW proposed for treatment. (SOP)

•	 Use only herbicides that are approved for use in ROW areas. (SOP)

Human Health and Safety

•	 Establish a buffer between treatment areas and human residences based on guidance given in the HHRA, 

with a minimum buffer of 1⁄4 mile for aerial applications and 100 feet for ground applications, unless a written 

waiver is granted. (SOP)

•	 Use protective equipment as directed by the herbicide product label. (SOP)

•	 Post treated areas with appropriate signs at common public access areas. (SOP)

•	 Observe restricted entry intervals specified by the herbicide product label. (SOP)

•	 Provide public notification in newspapers or other media where the potential exists for public exposure. (SOP)

•	 Store herbicides in secure, herbicide-approved storage. (SOP)

•	 Have a copy of MSDSs at work site. (SOP)

•	 Notify local emergency personnel of proposed treatments. (SOP)

•	 Contain and clean up spills and request help as needed. (SOP)

•	 Secure containers during transport. (SOP)

•	 Follow label directions for use and storage. (SOP)

•	 Dispose of unwanted herbicides promptly and correctly. (SOP)

•	 Use the typical application rate, where feasible, when applying 2,4-D, bromacil, diquat, diuron, fluridone, 

hexazinone, tebuthiuron, and triclopyr to reduce risk to workers and the public. (MM)

•	 Avoid applying bromacil and diuron aerially. Do not apply sulfometuron methyl aerially. (MM)

•	 Limit application of chlorsulfuron via ground broadcast applications at the maximum application rate. (MM)

•	 Limit diquat application to ATV, truck spraying, and boat applications to reduce risks to workers; limit diquat 

applications to areas away from high residential and subsistence use to reduce risks to the public. (MM)

•	 Evaluate diuron applications on a site-by-site basis to avoid risks to humans. There appear to be few scenarios 

where diuron can be applied without risk to workers. (MM)

•	 Do not apply hexazinone with an over-the-shoulder broadcast applicator (backpack sprayer). (MM)
 466

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

TABLE A2-1. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of BLM-Evaluated Herbicides

Application 

Scenario BROM1 CHLR1 DIQT1 DIUR1 FLUR1 IMAZ1 OVER1 SULF1 TEBU1

Buffer Distance (feet) from Non-target Aquatic Plants

Typical Application Rate

Aerial NA 0 NE NA NE 0 NA 1,300 NE

Low Boom2 100 0 NE 900 NE 0 100 900 0

High Boom2 900 0 NE 1,000 NE 0 900 900 0

Maximum Application Rate

Aerial NA 300 NE NA NE 300 NA 1,500 NE

Low Boom2 900 0 NE 1,000 NE 0 900 900 0

High Boom2 900 0 NE 1,000 NE 0 900 900 0

Buffer Distance (feet) from Non-target Terrestrial Plants

Typical Application Rate

Aerial NA 1,350 1,200 NA NE 0 NA 0 NE

Low Boom2 950 900 100 0 NE 0 0 0 0

High Boom2 950 900 900 100 NE 0 100 0 0

Maximum Application Rate

Aerial NA 1,350 1,200 NA NE 900 NA 0 NE

Low Boom2 1,000 1,000 900 200 NE 0 100 0 50

High Boom2 1,000 1,000 900 500 NE 0 100 0 50

Buffer Distance (feet) from Threatened, Endangered, and Sensitive Plants

Typical Application Rate

Aerial NA 1,400 1,200 NA NE 0 NA 1,500 NE

Low Boom2 1,200 1,000 900 1,000 NE 0 100 1,100 0

High Boom2 1,200 1,000 900 1,000 NE 0 900 1,000 50

Maximum Application Rate

Aerial NA 1,400 1,200 NA NE 900 NA 1,500 NE

Low Boom2 1,200 1,050 1,000 1,000 NE 0 900 1,100 100

High Boom2 1,200 1,000 1,000 1,000 NE 0 900 1,000 500 1 BROM = Bromacil; CHLR = Chlorsulfuron; DIQT = Diquat; DIUR = Diuron; FLUR = Fluridone; IMAZ = Imazapic; OVER = Diflufenzopyr 

+ Dicamba (Overdrive); SULF = Sulfometuron methyl; and TEBU = Tebuthiuron.

2 High boom is 50 inches above ground and low boom is 20 inches above ground.

NE = Not evaluated and NA = not applicable.

Buffer distances are the smallest modeled distance at which no risk was predicted. In some cases, buffer distances were extrapolated if the 

largest distance modeled still resulted in risk, or interpolated if greater precision was required.

Table A2-2. Buffer Distances to Minimize Risk to Vegetation from Off-Site Drift of Forest ServiceEvaluated Herbicides

Application 

Scenario 2,4-D Dicamba Clopyralid Glyphosate Hexazinone Imazapyr Metsulfuron Methyl Picloram Triclopyr

Buffer Distance (feet) from Susceptible Plants1

Typical Application Rate

Aerial NE >900 900 300 300 900 900 >900 500

Low Boom NE 300 900 50 NE 900 900 >900 300

Maximum Application Rate

Aerial NE >900 1,000 300 900 >900 >900 >900 >900

Low Boom NE 900 1,000 300 NE >900 >900 >900 >900

Buffer Distance (feet) from Tolerant Terrestrial Plants

Typical Application Rate

Aerial NE 0 0 25 NE 100 50 25 NE

Low Boom NE 0 0 25 0 25 25 25 NE

Maximum Application Rate

Aerial NE 0 25 50 NE 300 100 50 NE

Low Boom NE 0 25 25 100 50 25 25 NE

NE = Not evaluated.

Buffer distances are the smallest modeled distance at which no risk was predicted. In some cases, buffer distances were extrapolated if the 

largest distance modeled still resulted in risk, or interpolated if greater precision was required.

1

 Mitigation measures for Bureau Sensitive or Federally Listed species use these buffer distances
467

Final Environmental Impact Statement: Appendix 2

Table A2-3. Buffer Distances to Minimize Risk to Non-Special Status Fish and Aquatic Invertebrates from OffSite Drift of BLM-Evaluated Herbicides from Broadcast and Aerial Treatments

Application 

Scenario BROM1 CHLR DIQT DIUR FLUR IMAZ OVER SULF TEBU

Minimum Buffer Distance (feet) from Fish and Aquatic Invertebrates

Typical Application Rate

Aerial NA 0 NA NA NA 0 NA 0 NA

Low boom 0 0 NA 0 NA 0 0 0 0

High boom 0 0 NA 0 NA 0 0 0 0

Maximum Application Rate

Aerial NA 0 NA NA NA 0 NA 0 NA

Low boom 0 0 NA 100 NA 0 0 0 0

High boom 0 0 NA 100 NA 0 0 0 0

1 BROM = Bromacil; CHLR = Chlorsulfuron; DIQT = Diquat; DIUR = Diuron; FLUR = Fluridone; IMAZ = Imazapic; OVER = 

Diflufenzopyr + Dicamba (Overdrive); SULFM = Sulfometuron methyl; and TEBU = Tebuthiuron.

NA = Not applicable.

Boom height = The Tier I ground application model allows selection of a low (20 inches) or a high (50 inches) boom height.

Table A2-4. Buffer Distances to Minimize Risk to Special Status Fish and Aquatic Organisms from Off-Site

Drift of BLM-Evaluated Herbicides from Broadcast and Aerial Treatments

Application 

Scenario BROM1 CHLR DIQT DIUR FLUR IMAZ OVER SULF TEBU

Minimum Buffer Distance (feet) from Fish and Aquatic Invertebrates

Typical Application Rate

Aerial NA 0 NA NA NA 0 NA 0 NA

Low boom 0 0 NA 0 NA 0 0 0 0

High boom 0 0 NA 100 NA 0 0 0 0

Maximum Application Rate

Aerial NA 0 NA NA NA 0 NA 0 NA

Low boom 0 0 NA 100 NA 0 0 0 0

High boom 0 0 NA 900 NA 0 0 0 0

1 BROM = Bromacil; CHLR = Chlorsulfuron; DIQT = Diquat; DIUR = Diuron; FLUR = Fluridone; IMAZ = Imazapic; OVER = 

Diflufenzopyr + Dicamba (Overdrive); SULFM = Sulfometuron methyl; and TEBU = Tebuthiuron.

NA = Not applicable.

Boom height = The Tier I ground application model allows selection of a low (20 inches) or a high (50 inches) boom height.
 468

Vegetation Treatments Using Herbicides on BLM Lands in Oregon
469

Final Environmental Impact Statement: Appendix 3

Appendix 3 – 

Monitoring

Introduction

Monitoring is the orderly collection, analysis, and interpretation of resource data to evaluate progress toward 

meeting management objectives. Two types of monitoring are addressed here. One type is implementation 

monitoring, which answers the question, “Did we do what we said we would do?” The second type is 

effectiveness monitoring, which answers the question, “Were treatment and restoration projects effective?” 

Implementation monitoring is usually done at the land use planning level or through annual work plan 

accomplishment reporting. Effectiveness monitoring is usually done at the local project implementation level. 

Consistent with the FLPMA’s broad mandates for resource management, and focused most specifically by 

each district’s Resource Management Plan, vegetation management and related monitoring is already being 

done on BLM lands in Oregon to meet a variety of objectives. These objectives include fuels reduction, range 

improvements, wildlife habitat improvement, watershed restoration, invasive plant control, and timber harvest. 

Implementation monitoring of these treatments is usually done at the plan level through annual work plan 

accomplishment reporting, and by a variety of formal or semi-formal post-project reviews done by staff, district 

management teams, or next-level reviews. Effectiveness monitoring takes place both formally and informally 

within two to three years. Examples include seedling survival exams and follow-up monitoring of invasive plant 

populations. Evaluations of the appropriateness and effectiveness of the overall Resource Management Plan 

direction are done periodically, usually every five years, to determine if Resource Management Plan direction is 

meeting overall goals. 

Herbicides are one of the tools currently being used to meet the noxious weed control objectives identified in the 

Resource Management Plans. Herbicides are currently being applied to more than 12,000 acres annually, mostly 

as spot spraying of individual weeds. Herbicides can be uniquely hazardous and adverse effects can be difficult 

to observe directly, so specialized controls and monitoring requirements are applied. Management objectives for 

herbicide use include protection of the public, environmental safety, and efficient control of target vegetation. 

Existing monitoring would apply to the selected alternative and continue to provide the primary controls for 

assuring treatments adhere to established standards for herbicide use. Existing monitoring is described (in part) 

below, as it is being applied not only across Oregon but in other states as well.

Part I - Existing Monitoring

Policy Requirements

Monitoring ensures that vegetation management is an adaptive process that continually builds upon past 

successes and learns from past mistakes. The adaptive management framework employed by the State Office 

includes developing stated management objectives to guide decisions about what actions to take and identifying 

explicit assumptions about expected outcomes that are then compared against actual outcomes. This framework 

acknowledges uncertainty about how natural resources systems function and how they would respond to 

management actions, and it makes use of management intervention and monitoring to improve subsequent 

decision-making (USDI 2008). The regulations of 43 C.F.R 1610.4-9 require that land use plans establish 
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intervals and standards for monitoring and evaluating land management actions. Within BLM district Resource 

Management Plans, integrated vegetation management objectives and actions are outlined and the effectiveness of 

those actions are evaluated as part of the overall effectiveness monitoring of the Resource Management Plans. The 

1601 Land Use Planning Manual requires that monitoring and evaluation of Resource Management Plans take place 

at prescribed intervals (typically every five years) and in accordance with standards identified in those plans. 

BLM Manual Section 9011, Chemical Pest Control, institutes implementation monitoring requirements for 

pesticide applications as part of an integrated vegetation management strategy. Manual Section 9011 requires 

that a Pesticide Use Proposal be prepared for each chemical application. This Pesticide Use Proposal must be 

reviewed and approved by the BLM State Office prior to the pesticide application. Once the application of 

the pesticide is completed, a Pesticide Application Record is completed. This record documents the pesticide 

application that occurred and is then kept on file for ten years. These records are used by the BLM to track 

pesticide use, which is reported to the EPA annually.

Numerous other BLM Manuals and Handbooks describe applicable monitoring policy and practices, including:

• BLM Technical Reference 1730-1 Measuring and Monitoring Plant Populations (1998). Provides 

technical guidance on how to develop and implement effective monitoring plans for vegetation and use 

monitoring in adaptive management. 

• Manual Section 9011 Chemical Pest Control (1992). Establishes requirements for monitoring pesticide 

applications. 

• Manual Section 9014 Use of Biological Control Agents of Pests on Public Lands (1990). Establishes 

requirements to monitor success or failure in survival, control, and spread of biological agents. 

• Manual Section BLM Manual 9015, Integrated Weed Management. Outlines the BLM’s integrated 

weed management policy and within that sets out requirements related to monitoring in those areas where 

management actions have a potential to introduce or spread noxious weeds or when the action is taking place in 

an area where known noxious weeds already exist. 

• Guidelines for Coordinated Management of Noxious Weeds (1990). Provides guidance on establishing 

monitoring plans for noxious weeds and their control. 

• NEPA Handbook H-1790-1 Chapter VI – Monitoring (1988). All actions and mitigation measures, including 

monitoring and enforcement programs, adopted in a decision document are legally enforceable commitments. 

The purposes of monitoring in a NEPA context are to 1) ensure compliance with decisions, 2) measure 

effectiveness of decisions, and 3) evaluate validity of decisions. 

• Manual Section 1734 Monitoring and Inventory Coordination (1983). Provides the BLM with technical 

guidance on how to develop and implement effective monitoring plans for vegetation. 

Other technical references for inventory, monitoring, and assessment of the cross section of BLM-managed 

resources are found at http://www.blm.gov/nstc/library/techref.htm. 

Implementation Monitoring

Implementation monitoring answers the question, “Did we do what we said we would do?” 

During preparation of implementation plans, treatment objectives, standards, and guidelines are stated in 

measurable terms, where feasible, so that treatment outcomes can be measured, evaluated, and used to guide 

future treatment actions. This approach ensures that vegetation treatment processes are effective, adaptive, and 

based on prior experience (Record of Decision for the PEIS:2-6).

According to BLM Manual Section 9011 and noted above, implementation monitoring specified in the local 

Resource Management Plans, project-specific NEPA documents, and/or the Biological Assessment or Opinions 
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associated with the project may be accomplished by reviewing the Pesticide Application Records (PAR) 

completed at the time of treatment and comparing them with the Pesticide Use Proposal, Standard Operating 

Procedures, and specific mitigation measures prescribed in the project NEPA decision. The PAR documents the 

actual rate, date, time, and location of herbicide application. It also documents the species treated and climatic 

characteristics such as wind speed and air temperature. The Pesticide Application Record, which must be 

completed within 24 hours of the application, documents the actual rate of application and that all the PUP and 

NEPA Standard Operating Procedures and mitigation measures were taken into account. Review of the PARs 

can determine whether actual application was consistent with plans and requirements documented in the sitespecific NEPA decision or Pesticide Use Proposal. Pesticide Application Records are used to develop annual 

state summaries of herbicide use for the BLM (Record of Decision for the PEIS:App. D). Pesticide Application 

Records are used for site-specific implementation monitoring. For example, the time of application recorded in 

the PAR can be compared with the prescribed mitigations to determine whether the application was made at the 

correct time, or if mitigation for sensitive wildlife concerns identified were observed during treatment. 

Invasive plant implementation monitoring for non-herbicide treatments is accomplished through site revisits 

performed during the growing season of the target species to determine if treatments were implemented correctly 

and decide the best time for follow-up treatments (Record of Decision for the PEIS:App. D). 

Adaptive management strategies require implementation monitoring to determine whether the plan was followed 

and obtained the expected results. Monitoring also ensures that vegetation treatment Standard Operating 

Procedures and mitigation measures are adopted and implemented appropriately and determined to be effective 

(Record of Decision for the PEIS:2-6).

Effectiveness Monitoring

Effectiveness monitoring answers the question, “Were treatment and restoration projects effective?” The 

BLM 9011 Handbook provides technical guidance on post-treatment evaluations for pesticide applications. 

Effectiveness monitoring can be formal or informal and typically compares vegetation characteristics of a site 

before and after treatment. Effectiveness monitoring typically occurs within two years of treatment, and results in 

recommendations for additional monitoring and weed or other vegetation management actions.

A purpose of effectiveness monitoring is to demonstrate the effects of pest control and the cost effectiveness of 

various treatment methods or combination of methods (USDI 1992c:Chapter 2. IV. A. Post-Treatment Evaluation 

Procedures). However, the objective of weed control is not just to kill weeds, but to protect, maintain, and 

enhance native plant communities and the ecosystems that depend on them. 

Thorough effectiveness monitoring determines if the actions taken had the intended outcome or effect. 

Monitoring of invasive plant treatment effectiveness (regardless of the treatment method) can range from site 

visits to compare the targeted population size against pre-treatment inventory data, to comparing pre-treatment 

and post-treatment photo points, to more elaborate transect work, depending on the species and site-specific 

variables. The goals of monitoring should be to answer questions such as the following:

• What changes in the distribution, amount, and proportion of invasive plant infestations have resulted due 

to treatments? 

• Has infestation size been reduced at the project level or larger scale (such as a watershed)? 

• Which treatment methods, separate or in combination, are most successful for a particular species? 

(Record of Decision for the PEIS:App D) 
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A long-term adaptive management approach is based on changing conditions. The invasive plant infestation 

conditions need to be monitored in order to know when it is appropriate for action to be taken, and whether that 

action is effective. If treatment was not effective, the decision maker would review the strategy (USDA 2005:2-15)

Water quality monitoring is conducted at the discretion of the district. Typically water quality monitoring would 

be conducted to check the effectiveness of buffer strips and administrative controls on protecting water quality 

and aquatic environments (USDI 1992:Chapter 2. IV. B). BLM’s Chemical Pest Control Handbook notes that 

the need for and type of monitoring are dictated by the nature of the critical components of the environment in 

the treatment area. Thus, a toxic chemical proposed for use in a sensitive area, such as near a residential area, or 

domestic water supply must be monitored intensively. Chemical residues in air, vegetation, soil, and water may 

need to be determined. A less toxic chemical used on other areas may require only limited stream monitoring to 

ensure that significant quantities of the chemical do not enter the stream. An innocuous chemical used on a small 

remote area may require no monitoring (USDI 1992).

There might also be a need to determine if the Conservation Measures were effective at reducing potential effects 

to Federally Listed species and/or designated critical habitat. 

Monitoring Biological Control Agent Releases

BLM Manual Section 9014 requires that a Biological Control Agent Release Proposal be prepared when a district 

is considering the use of a biological control agent as part of an integrated vegetation management strategy. The 

Proposal is reviewed and approved by the BLM State Office. Upon completion of the biological control release, 

a Biological Control Agent Release Record is prepared and the State Office maintains a permanent record of all 

releases and locations. In addition to this implementation monitoring, Manual Section 9014 also requires that BLM 

conduct effectiveness monitoring of the release, and document the success or failure in terms of species survival, 

control, and spread. All biological control agents must be approved by the State Department of Agriculture.

Monitoring BLM Management Activities for Weed Spread

BLM Manual 9015, Integrated Weed Management outlines the BLM’s integrated weed management policy and 

within that, sets out requirements related to monitoring in those areas where BLM management actions have a 

potential to introduce or spread noxious weeds or when the action is taking place in an area where known noxious 

weeds already exist. If, through a risk assessment process, it is determined that a proposed management activity 

(such as a timber sale or road construction) has a moderate or high risk for establishing noxious weeds, BLM is 

required to prescribe follow-up monitoring as well as identify project actions that need to be taken in order to 

reduce or prevent the spread of noxious weeds. 

Northwest Forest Plan Aquatic and Riparian Effectiveness Monitoring Program (AREMP)

The purpose of AREMP is to assess the status and trend of watershed attributes to determine if the Forest 

Service and BLM’s Northwest Forest Plan Aquatic Conservation Strategy1 is achieving its goals of maintaining 

and restoring watersheds. Monitoring determines watershed condition every five years for every 6th-field 

watershed (with > 25% federal ownership along the stream length) based on upslope and riparian data derived 

from GIS layers and satellite imagery. In-channel attributes are also measured each year in a subset of 

1 The Northwest Forest Plan Aquatic Conservation Strategy is a common set of watershed management standards and 

guidelines added to BLM district and National Forest Land and Resource Management Plans within the range of the 

northern spotted owl in 1994. A joint-agency common monitoring strategy is used.
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Final Environmental Impact Statement: Appendix 2

watersheds to supplement the watershed condition assessments and validate the models used to assess stream 

condition. Watershed condition assessments are done using decision-support models. AREMP also tracks 

changes in watershed condition over time, and reports on the Forest Plan's effectiveness across the region. 

Although the program was not designed to monitoring pesticides or track invasive plants, invasive plants are 

recorded when found.

The program’s 2008 Annual Technical Report noted AREMP staff “participated in the second year of a pilot 

regional survey effort to locate aquatic invasive species on federal lands. Protocols developed by Oregon State 

University Sea Grant College Program personnel were used to survey for 11 aquatic plants and animals identified 

as primary threats to northwest watersheds. Among the key species included were; ...yellow flag iris, knotweed, 

hydrilla, Chinese mitten crabs, and four species of nonnative crayfish. Included also were fifteen species of 

secondary concern” (USDA, USDI 2008). 

PACFISH/INFISH Biological Opinion (PIBO) Effectiveness Monitoring Program

Similar to the AREMP, the goal of the PACFISH/INFISH Biological Opinion Effectiveness Monitoring Program 

(PIBO) is to determine whether the aquatic conservation strategies within PACFISH and INFISH, or revised land 

management plans, are effective in maintaining or restoring the structure and function of riparian and aquatic 

systems. This affects Oregon BLM streams with anadromous fish and bull trout outside of the Northwest Forest 

Plan area. Like AREMP, the program is not designed to monitor pesticides. PIBO monitoring does establish 

transects on each stream reach and are records vegetation down to species. This data could be used to track the 

spread or occurrence of invasive plants if we choose to query them.

National Invasive Species Information Management System (NISIMS)

In 2007, the BLM began field-testing a new data management system for documentation, mapping, treating, and 

monitoring of invasive species. When fully operational, the system will provide tools for data collection and the 

generation of BLM-wide analysis and statistics for invasive species infestations and treatments. The objective of 

this project is to develop a BLM-wide invasive species geodatabase that is web-enabled.

The deployment of a BLM-wide database supports the BLM strategies of the delivery of information directly to 

the program specialists/decision makers; establish accountability, responsibility, and standardized, comprehensive 

management of BLM information. 

Primary functions of the system are:

•	 Track invasive species infestation areas and treatments of infestation areas.

•	 Generate yearly reports and other reports as required by various constituents of the weed program.

•	 Provide standardized data for analysis of invasive species infestations/inventories.

•	 Provide bi-directional synchronization between system and field collection devices.

•	 Serve tabular and spatial BLM-wide invasive species data and analysis to internal and external customers. 

Geospatial components facilitate weed control effectiveness monitoring.

•	 Provide capability to share corporate data set with other national applications.

•	 Provide components that could be utilized in the development of other national datasets.
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Part II – Potential Monitoring

Introduction

In addition to existing monitoring, the selection of one of the action alternatives could create a changed 

circumstance or condition (e.g. a concern over a potential environmental effect) that would suggest a need for 

additional monitoring. Those circumstances might include the use of different herbicides with different ecological 

risks, more acres being treated, more acres being treated in proximity to people or sensitive environmental 

resources, more use of broadcast spraying with its potential for drift, or simply increasing the use of “new” 

herbicides as weed specialists become more familiar with their advantages. This section describes changes that 

might suggest additional, EIS-specific monitoring and describes some options as to what form that monitoring 

might take. These descriptions should be viewed the same as Potential Mitigation, they do not apply unless the 

decision maker specifically selects them in the Record of Decision. Potential monitoring could also be adopted 

during site-specific NEPA.

Implementation Monitoring

Monitoring for Concerns Identified in the EIS - For each of the first five years of EIS implementation, a subset 

of the year’s herbicide application projects could be identified using parameters identified in the EIS as having 

the potential for adverse effects. A list of what constitutes qualifying parameters may be compiled after the 

Final EIS is issued. For example, parameters might include aerial spray within a certain distance of population 

centers or Federally Listed species, treatments exceeding some number of acres with herbicides having a high 

risk of environmental damage to non-target species (other than non-special status plants), treatments where PEIS 

Mitigation Measure buffers around sensitive species were reduced by more than 50 percent, aquatic treatments, 

riparian treatments for streams with Federally Listed fish, use of known ground-water contaminants on the west 

side, projects that required formal consultation, sprays within riparian management zones, broadcast sprays of 

over 100 contiguous acres, roadside boom sprays on native plants, use of diuron, bromacil, tebuthiuron, or 2,4-D 

at higher than 50% of the typical rate for over 100 net acres in any one thousand acre area, and so forth. 

From this “higher risk” subset, a representative sample (at least three) of State Office randomly selected projects 

could be identified. Both the east and west side would be represented by at least one selection assuming there are 

projects that qualify. For selected projects, the full set of planning and reporting documents would be reviewed, 

as well as field implementation records, monitoring, applicator licenses, adherence to Standard Operating 

Procedures and appropriate mitigations measures, and all other project requirements. A questionnaire listing these 

review elements would be prepared by the State Office. The review could be conducted by a team that includes, 

at minimum, at least one non-BLM person from a Resource Advisory Committee, County Weed Board, County 

Board of Supervisors, or Oregon Department of Agriculture Invasive Plant or Pesticide Enforcement Division, 

and; a line officer, District Weed Coordinator, or State Office Restoration Program lead from a different district or 

the State Office. 

Implementation Monitoring on the Avoidance and Mitigation of Adverse Impacts to Non-target Resources - 

The above project monitoring would not preclude the need to identify specific, or narrow, concerns with specific 

herbicides regarding certain parameters. Pre-emergent herbicides with long soil half-lives may suggest soil 

monitoring. Water monitoring should be conducted, particularly where there are Federally Listed fish species, when 

there is a possibility herbicides toxic to fish could drift onto, or be washed into, streams. This type of monitoring 

is already described in the BLM’s Chemical Pest Control Handbook (USDI 1992), in Chapter 1. I. E, Chemical 

Residue Monitoring, for when toxic materials are introduced near sensitive areas such as residences or domestic 
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water supplies. Suggested monitoring points include air, vegetation, soil, and water. Although this represents 

existing monitoring, it is included here to suggest using the EIS analysis to help identify monitoring points.

Effectiveness Monitoring

Five-year Examination of Weed Spread - The action alternatives are expected to have a significant effect on, 

but not stop, noxious weed spread on BLM lands in Oregon. Assuming an action alternative is selected and 

a more complete set of tools are available for weed control and are being utilized; a more careful estimate of 

noxious weed spread rate should be made to determine if a change in the control strategy is warranted. Setting 

up a statewide series of randomly selected (but unmarked) plots soon, and then rechecking them in five years or 

other selected interval, could provide a statistically valid estimate of weed spread rate. This effort might be done 

cooperatively with other agencies. 

Restoration Monitoring – The action alternatives would make imazapic available, and districts estimate its 

primary use would follow wildfire or prescribed burns in, or threatened by, medusahead or other invasive 

annual grasses. Imazapic was desired because it would leave more native forbs than glyphosate. Because large 

applications will be expensive and may not occur annually at least on any one district, a detailed examination 

of the first two or three large-scale uses could help ensure this new tool achieves maximum effectiveness while 

protecting non-target vegetation and other resources. 

State of Oregon Information Sharing

The Oregon Department of Environmental Quality has requested that the BLM coordinate with them when 

sending data electronically for potential entry into the Oregon Department of Environmental Quality’s Laboratory 

Analytical Storage and retrieval Database (LASAR). In addition, the Oregon Department of Environmental 

Quality has requested copies of any monitoring reports of herbicide effectiveness and impacts on water quality 

and ecological conditions.

Similarly, the state of Oregon encourages the BLM to share any water quality effectiveness monitoring data 

collected in support of this EIS with the State of Oregon’s Water Quality Pesticide Management Team (WQMPT). 

The multi-agency WQMPT acts to review and respond to pesticide detections in Oregon's ground and surface 

water in support of Oregon’s Pesticide Management Plan for Water Quality Protection (see http://egov.oregon.

gov/ODA/PEST/docs/pdf/wqpmtPMP.pdf). 

References

USDA Forest Service. 2005. Pacific Northwest Region Invasive Plant Program: Preventing and Managing 

Invasive Plants. Final Environmental Impact Statement. Available at http://www.fs.fed.us/r6/invasiveplant-eis/

USDA Forest Service, USDI Bureau of Land Management. 2008. Aquatic and Riparian Effectiveness 

Monitoring Program, 2008 Annual Technical Report. Available at http://www.reo.gov/monitoring/reports/

watershed/2008-AREMP-Tech-Report.pdf

USDI Bureau of Land Management. 1992c. Chemical Pest Control Handbook (BLM Manual 9011)

USDI Bureau of Land Management.. 2008d. 522 Department Manual 1; Adaptive Management. Washington 

D.C. 3 pp.
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477

Final Environmental Impact Statement: Appendix 4

Appendix 4 – 

Protocol for Identifying, Evaluating, 

and Using New Herbicides

The Oregon EIS evaluates a proposal and alternatives that would make up to 18 herbicides available to the BLM 

districts in Oregon for use in their existing noxious weed, invasive plants, and other vegetation management 

programs (except for projects specifically designed to improve livestock forage or timber production). These 

herbicides were analyzed in the 2007 PEIS and approved for use in the 17 western states by the 2007 Record 

of Decision. This EIS does not propose or assume the use of any herbicides other than these 18. Should other 

herbicide active ingredients be desired for use in the future, Appendix A of the 2007 Record of Decision for the 

PEIS entitled, Protocol for Identifying, Evaluating, and Using New Herbicides outlines a protocol that is to be 

followed. This protocol applies to BLM nationally; individual State BLM offices do not implement the process 

independently. However, the BLM in Oregon may help identify future herbicide active ingredients needed, and 

propose them to the National Office under this protocol. 

The PEIS protocol (summarized below) addresses the identification and approval of new herbicide products and 

technologies, requires that there be a determination of the need for the herbicide, involves a formal request for use 

of the herbicide be made to the BLM National Office, requires that the herbicide active ingredient have completed 

EPA Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) registration and be labeled for use on the site 

type proposed, and requires National Environmental Policy Act (NEPA) compliance. The BLM National Office 

would take the lead on conducting the NEPA analysis for new herbicide active ingredients. 

Summary of 2007 Record of Decision Appendix A – Protocol for 

Identifying, Evaluating, and Using New Herbicides

The BLM may become aware of new herbicide active ingredients, products, and technologies that are developed 

and marketed in the future, and may consider application of these products or technologies to vegetation treatment 

projects. 

Identification and Approval of New Herbicide Products and Technologies

The means by which the BLM could learn of new products and their applications include, but are not limited to, 

professional networking, technical research and publications, and vendor marketing.

Networking

The BLM participation in professional networks is an important method for learning or staying current about the 

technical, regulatory, efficacy, and environmental aspects of herbicide products in the development phase and 

those currently on the market. These networks include other state and Federal agencies such as the U.S. EPA 

and Oregon Department of Agriculture, as well as county weed districts, university extension services, the Weed 
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Science Society of America, and numerous others. For the most part, networking occurs at the local level, with 

BLM professional staff and managers working with local representatives of the organizations mentioned above. 

BLM State Office weed coordinators and vegetation management professionals often represent the BLM at annual 

meetings and workshops. 

Occasionally, members of the public who are interested in various approaches to vegetation treatment send 

relevant information to the BLM. As with vegetation treatment methods identified through other avenues, if 

the BLM determines that the approach may have some utility for meeting its needs, a product demonstration or 

additional information may be requested. 

Research and Demonstration 

Demonstration areas for current and emerging technologies play an important role in facilitating research and 

evaluating efficacy of treatment applications. Current BLM practice allows for limited and controlled use of new 

herbicides on demonstration plots up to 5 acres in size, with a maximum of 15 acres per field office. Approval to 

adopt a new herbicide for research and demonstration use is provided by the BLM National Office after an initial 

evaluation of FIFRA registration materials and risk assessments. If research and demonstration results appear 

favorable, the BLM then considers the herbicide for further human health and ecological risk assessments, and 

those results are evaluated through the NEPA process. 

Technical Research and Publications, and Vendor Marketing 

The BLM also obtains information on vegetation management and herbicide treatments from professional 

journals associated with vegetation management societies and associations, working though a wide variety of 

publication compilation services. The general public and non-governmental organizations also provide the BLM 

with information through the NEPA process and other participatory processes. For example, scoping comments 

received for this EIS suggested that aminopyralid (e.g. Milestone®) should be the next herbicide adopted for 

use by the BLM. Also, vendors of invasive plant control technologies, including agrochemical company 

representatives, contact the BLM to introduce new active ingredients and new formulations, and to provide 

updates on existing products. 

Determining the Need for New Herbicides 

In order for the BLM to consider and approve a new active ingredient or formulation, the BLM must first consider 

whether there is a need for an available product. Factors that would be considered when assessing the need 

for adopting an available product include, but are not limited to: spectrum of application, efficacy, factors that 

could limit efficacy, extent or scope of use, cost, availability, availability of substitute or alternative products or 

technologies, expected effectiveness compared to any currently used methods, previous use reports at other sites 

and their outcomes, results from research and demonstration use, training and personnel requirements, and any 

other relevant factors including hazards and risks. Once a need is determined, the BLM would then integrate the 

approval process with its annual budget cycle. In general, the approval/budget process should take approximately 

two fiscal years to complete once a need for an available product is identified. 

The determination for the need is a primarily a “bottom up” process that would typically start with a BLM field 

or state office collecting information regarding the need. To assess the potential for site-specific effectiveness, 

the BLM field office manager will investigate its use through professional networks, technical publications, and 

research reports, such as those described in the previous section. Requests are forwarded to the BLM National 

Office with annual statewide pesticide use reports. Proposed herbicide active ingredients must already have a 
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Final Environmental Impact Statement: Appendix 4

completed FIFRA registration in place, and be labeled for use on the site proposed (e.g. rangeland, pasture, noncropland, aquatic habitat). The BLM will not consider any active ingredients in its review and approval process, 

including research and demonstration, if it does not have a completed FIFRA registration. The BLM will comply 

with label directions and with state registration requirements. Thus, if current state requirements do not allow the 

application of an herbicide being considered for use by the BLM, the BLM will not apply that herbicide in that 

state. 

Weed specialists and others in the BLM National Office will determine whether the new active ingredient being 

proposed will benefit the BLM and whether the cost of analysis is likely to be justified. If approved, funds will be 

requested in the following fiscal year’s budget process to conduct a risk assessment. 

Assessment of Hazards and Risks 

FIFRA registration already requires product performance data relating to each product’s effectiveness. This 

requirement was designed “to ensure that pesticide products will control the pests listed on the label and that 

unnecessary pesticide exposure to the environment will not occur as a result of the use of ineffective products” 

(40 C.F.R. 158.202[i]). Therefore, any new pesticide registered under FIFRA is expected to be generally effective 

for the labeled uses. 

For an herbicide to be considered for use on public lands, the EPA-reviewed toxicological, environmental fate, 

and ecotoxicity data submitted by the pesticide manufacturer to support its registration application will be 

available for review. These data could then be used to conduct an assessment of the potential human health and 

ecological risks from the herbicide’s use, including, but not limited to, the following components: 

• Identification of potential use patterns, including target plants, formulation, application methods, locations to 

be treated, application rate, and anticipated frequency of use; 

• Review of herbicide hazards relevant to the human health risk assessment, including systemic and reproductive effects, skin and eye irritation, allergic hypersensitivity, carcinogenicity, dermal absorption, eurotoxicity, 

immunotoxicity, and endocrine disruption; 

• Estimation of exposure to workers applying the herbicide or reentering a treated area; 

• Environmental fate and transport, including drift, leaching to groundwater, and runoff to surface streams 

and ponds; 

• Estimation of exposure to members of the public; 

• Review of available ecotoxicity data, including hazards to mammals, birds, reptiles, amphibians, fish, and 

aquatic invertebrates; 

• Estimation of exposure to terrestrial and aquatic wildlife species; and, 

• Characterization of risk to human health and wildlife. 

If the available toxicity or ecotoxicity data were inconclusive, or if substantial disagreement occurs among the 

results of technical studies that could affect the potential risk conclusions for the herbicide, the BLM will conduct 

a formal peer review of the available scientific information to develop a consensus about the endpoint(s) in 

question. The peer review process is based largely on EPA’s peer review process (EPA 2000). 

If review of the registration information supports use, the next step is to confirm or redesign the human health and 

ecological risk assessment protocols and complete the assessment(s). The risk assessment protocols used by the 

BLM must reflect the best science available and ensure current standards for environmental review are utilized 

while the risk assessments are conducted. 
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NEPA Documentation 

The potential use of new herbicide active ingredients will require compliance with NEPA. That requirement 

might be met all or in part by tiering to an existing document, supplementing an existing document, and/or 

incorporating or adopting another analysis as appropriate under NEPA. If existing NEPA documentation is 

determined to be inadequate, a new NEPA document will be prepared. 

In any event, the process for complying with NEPA for proposals to use new herbicide active ingredients on 

BLM lands differs from the standard NEPA screening process for other Federal actions. For example, neither the 

USDI, nor the BLM have categorical exclusions1 that address the use of herbicides; therefore, this step does not 

apply. The BLM, through this and previous EISs, has already determined that approval of herbicides for future 

use on public lands is a controversial Federal action significantly affecting the human environment. It is therefore 

inappropriate to use an Environmental Assessment and Finding of No Significant Impact for such approval. This 

is not to say a particular project involving the use of herbicides could not be assessed with an Environmental 

Assessment level analysis, properly tiered to a land use plan EIS or other NEPA document, such as this 

Programmatic EIS. This determination of significance only applies to the approval of a new active ingredient for 

use by BLM overall. Site-specific impacts for any project using herbicides will be assessed at a level appropriate 

for the project, using the standards for “significantly” found under 40 C.F.R. 1508.27. 

Initially, the BLM expects to use the PEIS as its basis for conducting future risk assessments and approvals. 

Following the guidance under 40 C.F.R. 1502.9 (4) Environmental Impact Statement, Draft, Final and 

Supplemental Statements, the BLM will conduct risk assessments on new active ingredients and build on the 

analysis contained in the PEIS through the issuance of a Supplemental Environmental Impact Statement (SEIS). 

A final decision on whether an active ingredient is approved would be recorded in a Record of Decision. SEISs 

would be utilized for approvals of new active ingredients until such time as the need for a new programmatic EIS 

was warranted and such a document was prepared. For cost efficiency, BLM would likely assess several active 

ingredients together in one SEIS. 

Special Status Species 

As part of any NEPA analysis of new herbicides, the BLM would consult with the FWS and NMFS as required 

under Section 7 of the Endangered Species Act. As part of this process, the BLM would prepare a consultation 

package that could include a description of the program; species listed as threatened or endangered, species 

proposed for listing, and critical habitats that could be affected by the program, and; a Biological Assessment that 

evaluates the likely impacts to listed species, species proposed for listing, and critical habitats from the proposed 

vegetation treatment program. The BLM will also provide guidance on actions that will be taken by the BLM to 

avoid adversely impacting species or destroying critical habitat. 

References

ENSR. 2004. Vegetation Treatments Programmatic EIS Ecological Risk Assessment Protocol. Report Prepared for 

the Bureau of Land Management, Reno, Nevada. Westford, Massachusetts. 

1 Categorical exclusions are “a category of [federal] actions that does not individually or cumulatively have a significant 

effect on the human environment...for which, therefore, neither an Environmental Assessment (EA) nor an EIS is 

required” (40 C.F.R. 1508.4).
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Final Environmental Impact Statement: Appendix 4

ENSR. 2005. Human Health Risk Assessment Final Report. Report Prepared for the Bureau of Land Management, 

Reno, Nevada. Westford, Massachusetts. 

U.S. Department of the Interior Bureau of Land Management (USDI BLM). 1988. National Environmental Policy 

Act Handbook. Bureau of Land Management Handbook H-1790-1 Washington, D.C. 

U.S. Environmental Protection Agency (USEPA). 2000. Peer Review Handbook 2nd Edition. Washington, D.C. 

Available at: http://www.epa.gov/osp/spc/prhandbk.pdf.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon
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Final Environmental Impact Statement: Appendix 5

Appendix 5 – 

Federally Listed and other Special 

Status Species 

This appendix addresses species Federally Listed or proposed as threatened or endangered, and Bureau Sensitive 

species (collectively referred to as Special Status Species), and proposed or designated critical habitat. Since this 

EIS is programmatic, tiered to the PEIS, and all of its action alternatives are wholly consistent with the selected 

alternative in the Record of Decision for the PEIS, the Biological Assessment for the PEIS1 is incorporated by 

reference in accordance with 50 CFR 402.12 (g). That statute says:

If a proposed action requiring the preparation of a biological assessment is identical, or very similar, to 

a previous action for which a biological assessment was prepared, the Federal agency may fulfill the 

biological assessment requirement for the proposed action by incorporating by reference the earlier biological 

assessment, plus any supporting data from other documents that are pertinent to the consultation, into a 

written certification that: 

(1) The proposed action involves similar impacts to the same species in the same geographic area; 

(2) No new species have been listed or proposed or no new critical habitat designated or proposed for 

the action area; and 

(3) The biological assessment has been supplemented with any relevant changes in information. 

This Appendix serves as that supplement. Updated information is provided for bull trout Critical Habitat, Pacific 

Eulachon, and greater sage grouse. Oregon-specific information about the effects of the alternatives is presented 

in Chapter 4.

Table of Contents

Summary of the Action Alternatives........................................................................................................ 484

Summary of Applicable Standard Operating Procedures and PEIS Mitigation Measures...................... 484

Consultation ............................................................................................................................................. 485

Biological Assessment Conservation Measures....................................................................................... 486

Endangered and Threatened Species in Oregon ...................................................................................... 486

Birds............................................................................................................................................ 486

Fish.............................................................................................................................................. 493

Invertebrates................................................................................................................................ 510

Mammals .................................................................................................................................... 514

Vascular Plants............................................................................................................................ 519

Table A5-1. State Director’s Special Status Species List – Federally Threatened, 

 Endangered, or Proposed, Oregon January 2008................................................................ 540

Table A5-2. State Director’s Special Status Species List - Bureau Sensitive, 

 January 2008, Oregon BLM ............................................................................................... 542

1 The PEIS is the Final Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western 

States Programmatic Environmental Impact Statement, June 2007. The Biological Assessment is available on the PEIS 

website at http://www.blm.gov/wo/st/en/prog/more/veg_eis.html
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Summary of the Action Alternatives

The selected alternative in the Record of Decision for the PEIS and to which the PEIS Biological Opinion applied, 

would make 18 herbicides available to the BLM in the 17 western states for use in their vegetation management 

program. The action alternatives in the Oregon EIS are subsets of that alternative, using fewer herbicides and/or 

restricting their use to particular plants or management objectives as described below.

As with the PEIS, an estimate has been made of the acres to be sprayed with each herbicide (Table 3-3 in Chapter 

3). This estimate is for analysis purposes, and the estimated acres are not part of the alternative descriptions 

themselves. The estimates are comparable to the estimates made for the PEIS.

An important overriding assumption of the Biological Assessment (BA) is that each site-specific action that 

could occur under the Proposed Action will be analyzed as required by NEPA and the Endangered Species Act, 

and that there will be compliance with all Federal laws during implementation of the project. Since this EIS is 

programmatic in nature, it does not authorize a specific commitment of resources. Therefore, any proposed sitespecific activity will require a site-specific NEPA analysis and consultation, if necessary, between the local BLM 

field office and the Services. 

The Action Alternatives

Alternative 3 would add 8 and 9 herbicides on the west and east side of the Cascades respectively, to the 4 

herbicides already being used on BLM lands in Oregon for noxious weeds. They could be used on noxious weeds 

and other invasive plants, and on native plants as needed to control plant pests and diseases in State-identified 

control areas. 

Alternative 4, the proposed action, would add 9 herbicides west of the Cascades, and 12 herbicides east of 

the Cascades, to the four already in use, and to expand their use from noxious weeds to all invasive plants, 

the control of pests and diseases, the control of native vegetation in rights-of-way, administrative sites, and 

recreation sites, and to improve wildlife habitat where specified in interagency Recovery/Delisting Plans or 

Conservation Strategies.

Alternative 5 would add 14 herbicides to the 4 already being used, and permit them to be used to achieve any 

management objective except livestock forage or timber production. Except for the inability to use herbicides for 

livestock forage or timber production, this alternative corresponds to the selected alternative from the PEIS.

The complete description of these alternatives, as well as the No Action Alternative (Alternative 2) and the 

Reference Analysis, which would cease the use of herbicides completely, is in Chapter 2.

Summary of Applicable Standard Operating Procedures and PEIS Mitigation Measures

Standard Operating Procedures were identified in the PEIS and adopted by the Record of Decision for the 

PEIS. They are included in this EIS, Appendix 2, with minor edits for clarity. Standard Operating Procedures 

reduce adverse effects to environmental and human resources from vegetation treatment activities, and are based 

on guidance in BLM manuals and handbooks, regulations, and standard agency and industry practices. The 

list is not all encompassing, but is designed to give an overview of practices that would be considered when 

designing and implementing a vegetation treatment project on public lands (PER:2-29). Effects described in 

the EIS are predicated on application of the Standard Operating Procedures or that a site-specific determination 

is made that their application is unnecessary to achieve their intended purpose or protection. As with the 
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Final Environmental Impact Statement: Appendix 5

corresponding protective measures listed in the Biological Opinion, BLM field offices would tailor these national 

Standard Operating Procedures based on local conditions and the habitat needs of the particular threatened and 

endangered species that could be affected by the treatments (PEIS Biological Opinion [Record of Decision for the 

PEIS:Appendix C-22]).

Mitigation Measures were identified for all potential adverse effects identified in the PEIS, and they were adopted 

by the Record of Decision for the PEIS. They are included in this EIS with minor edits for clarity, in Appendix 2 

with the Standard Operating Procedures. Like the Standard Operating Procedures, application of the mitigation 

measures is assumed in the analysis. However, for PEIS mitigation measures, site-specific analysis, the use of 

Individual Risk Assessment Tools, or the evolution of these measures into similar handbook direction is permitted 

to identify alternative ways to achieve the expected protections.

Consultation

For the PEIS, the BLM consulted with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries 

Service (NMFS) as required under Section 7 of the Endangered Species Act (PEIS:Chapter 5 and Appendix G). 

The BLM prepared a formal initiation package that included: 1) a description of the program, listed threatened 

and endangered species, species proposed for listing, and critical habitats that may be affected by the program; 

and, 2) a Biological Assessment for Vegetation Treatments on Bureau of Land Management Lands in 17 Western 

States (BA). That BA evaluated the likely impacts to listed species, species proposed for listing, and critical 

habitats from the proposed use of herbicides and other treatment methods in its vegetation treatment program, and 

also identified management practices to minimize impacts to these species and habitats.

The FWS issued a Letter of Concurrence on September 1, 2006, which concurred that the proposed action as 

described in the PEIS and Biological Assessment, with all PEIS Mitigation Measures and Standard Operating 

Procedures and the Biological Assessment’s Conservation Measures, would not likely adversely affect any 

threatened or endangered species under the jurisdiction of the FWS. In addition, the FWS recognized that any 

future site-specific2 actions carried out under the PEIS would undergo additional consultation as appropriate. 

 

The Biological Opinion issued by the NMFS on June 26, 2007 concluded that the proposed action as described in 

the PEIS and Biological Assessment, in addition to Biological Assessment-identified Conservation Measures for 

Aquatic Species (referred to in the Biological Opinion as Protective Measures), was not likely to jeopardize the 

continued existence of endangered and threatened salmon and trout, threatened green sturgeon, and threatened 

southern resident killer whales. Since the PEIS does not authorize any site-specific actions, subsequent Section 

7 review on proposed site-specific vegetation treatments will be required. There is no incidental take3 identified 

or exempted by the Biological Opinion for the PEIS. If take is anticipated for site-specific treatments, then the 

amount or extent of take will be identified during consultation for those treatments. 

Like the PEIS, this programmatic EIS does not authorize site-specific actions or amend RMPs. In addition, the 

three action alternatives in this EIS are subsets of the selected alternative in the PEIS. Therefore this EIS is 

incorporating the PEIS Biological Assessment by reference (50 CFR 402.12(g)). A discussion of the Federally 

Listed (and proposed) species in Oregon, proposed and designated critical habitat, and a list of the Bureau 

Sensitive species in Oregon are included in this appendix. Informal consultation with the FWS (50 CFR 

2 Site, area, or project-specific level

3 ‘‘take’’ means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any 

such conduct.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

402.13), and formal consultation with NMFS (50 CFR 402.14), are expected to confirm and apply the PEIS 

consultation results to this EIS. Specific treatment projects that tier to this EIS will be subject to site–specific 

consultation as appropriate. 

Biological Assessment Conservation Measures 

The BLM will incorporate mitigation and conservation measures identified in the Ecological Risk Assessments 

and Biological Assessment, and from analysis of exposure levels based on modeling, to eliminate or reduce 

risks to Threatened, Endangered and Proposed species. It is possible that conservation measures would be less 

restrictive than those listed in subsequent sections of this appendix if local site conditions were evaluated using 

the Ecological Risk Assessments when developing project-level conservation measures. Conservation measures 

specifically listed in the Biological Assessment for the PEIS are included in this appendix for all of the species to 

which they apply.

Endangered and Threatened Species in Oregon

Birds

Endangered

California Brown Pelican 

The primary reference for this section is: USFWS. No Date. Brown Pelican, (Pelicanus occidentalis). Available 

at: http://species.fws.gov. 

The brown pelican (Pelicanus occidentalis), also called the American brown pelican or common pelican, inhabits 

the Atlantic, Pacific, and Gulf coasts of North and South America. On the Atlantic Coast, pelicans can be found 

from Virginia south to the mouth of the Amazon River in Brazil; on the Pacific, they range from central California 

to south-central Chile and the Galapagos Islands; and on the Gulf of Mexico, they are found in Alabama, 

Louisiana, and Texas. Brown pelicans are rarely seen either inland or far out at sea. 

Pelicans are primarily fish eaters, and require up to 4 pounds of fish a day. Their diet consists mainly of “rough” 

fish, species considered unimportant commercially. Examples of rough fish species are menhaden, herring, 

sheepshead, pigfish, mullet, grass minnows, topminnows, and silversides. Brown pelicans have also been known 

to eat some crustaceans, usually prawns. Brown pelicans have extremely keen eyesight. As they fly over the 

ocean, sometimes at heights of 60 to 70 feet, they can spot a school of small fish, or even a single fish. Diving 

steeply into the water, they may submerge completely or only partly, depending on the height of the dive, and 

come up with a mouthful of fish. Air sacs beneath the pelican’s skin cushion the impact and help it surface. 

Pelicans are social and gregarious. Males and females, juveniles and adults, congregate in large flocks for 

much of the year. The only breeding area in the western U.S. is in Channel Islands National Park in California. 

Pelicans nest in large colonies on the ground, in bushes, or in the tops of trees. On the ground, a nest may be a 

shallow depression lined with a few feathers and a rim of soil built up 4 to 10 inches above ground, or it may be a 

large mound of soil and debris with a cavity in the top. A treetop nest is built of reeds, grass, and straw heaped on 

a mound of sticks interwoven with the supporting tree branches. In most of the pelican’s U.S. nesting range, peak 

egg-laying occurs in March and April. Two or three chalky white eggs hatch in approximately 1 month. Like 

many birds, newly hatched pelicans are blind, featherless, and completely dependent upon their parents. Average 

age at first flight is 75 days. 
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Final Environmental Impact Statement: Appendix 5

The brown pelican was Federally Listed as endangered on June 2, 1970. Critical habitat has not been designated. 

On February 4, 1985, brown pelican populations on the Atlantic Coast of the U.S. (including all of Florida and 

Alabama), had recovered to the point that the species could be removed from the Endangered Species List in that 

part of its range. The U.S. Gulf Coast population, which is still considered endangered, was recently estimated at 

nearly 6,000 breeding pairs. The brown pelican is also endangered in the Pacific Coast portion of its range, and in 

Central and South America. The southern California population of brown pelicans today is estimated at 4,500 to 

5,000 breeding pairs. Brown pelicans have few natural enemies. Although ground nests are sometimes destroyed 

by hurricanes, flooding, or other natural disasters, the biggest threat to pelican survival comes from human 

activities. Pelican populations have been heavily affected by past hunting to protect commercial fishery resources, 

as well as the use of DDT and other pesticides. Current threats to the species include human development along 

the coast, abandoned fishing lines and tackle, and potential future oil spills.

Conservation Measures for the California Brown Pelican

Although treatment activities are unlikely to negatively affect the brown pelican or its habitat, extra steps could be 

taken by the BLM to ensure that herbicide treatments conducted in brown pelican wintering habitat did not result 

in negative effects to the species: 

• If feasible, conduct vegetation treatments in brown pelican wintering habitat outside the period when 

pelicans are likely to be present. 

• If herbicide treatments in brown pelican habitats must be conducted during the wintering period: 

• Do not use 2,4-D in pelican wintering habitat. 

• Prior to conducting herbicide treatments on pelican wintering habitat, survey the area for pelicans. Wait 

for pelicans to leave the area before spraying. 

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in pelican wintering 

habitats. 

• If broadcast spraying imazapyr or metsulfuron methyl in pelican wintering habitats, use the typical rather 

than the maximum application rate. 

• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in brown 

pelican wintering habitat, utilize the typical, rather than the maximum, application rate.

Threatened

Marbled Murrelet 

The primary references for this section are: USFWS. 1992j. Determination of Threatened Status for the Washington, 

Oregon, and California Population of the Marbled Murrelet. Federal Register 57(191):45328-45337; and National 

Audubon Society. 2002a. Marbled murrelet (Brachyramphus marmoratus). Available at: http://audubon2.org/

webapp/watchlist/. References cited in this section are internal to the above-referenced USFWS document. A 

complete list of these references is available from the USFWS Portland Field Office, Portland, Oregon. 

The North American subspecies of marbled murrelet (Brachyramphus marmoratus marmoratus) is a small 

seabird found on the Pacific Coast of North America. Marbled murrelets are generally found in nearshore waters 

(within about 3 miles of shore) near their nesting sites. They nest in a narrow range along the Pacific, from the 

Aleutian Islands of Alaska south through British Columbia, Washington, and Oregon, to central California. The 

species generally occupies nesting areas on a year-round basis, although in certain places in Alaska and British 

Columbia, birds move to more protected waters during the winter. This species can also be found wintering 

south of its breeding range, along the coast of southern California to extreme northwestern Baja California. The 

states of California, Oregon, and Washington encompass roughly one-third of the geographic area occupied by 

this subspecies, comprising an important portion of its range. The amount of nesting habitat has undergone a 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

tremendous decline since the late 1800s (most of which has taken place during the last 30 to 40 years), especially 

in the coastal areas of all three states. Therefore, the marbled murrelet is listed only in these three states, which 

together constitute a distinct population segment of the eastern Pacific subspecies. 

Marbled murrelets feed primarily on fish and invertebrates in nearshore marine waters. During the summer, major 

food items include Pacific sand lance, northern anchovy, Pacific herring, and other small schooling fish, while 

during the winter, krill, amphipods, and herring are major prey items. Marbled murrelets usually forage alone, or 

in pairs, and are active in search of food both day and night. Although the majority of birds are found within or 

adjacent to the marine environment, there have been detections of marbled murrelets on rivers and inland lakes 

(Carter and Sealy 1986). Marbled murrelets spend the majority of their lives on the ocean, and come inland to 

nest, although they visit some inland stands during all months of the year. There are records of marbled murrelets 

up to 50 miles inland in Washington (Hamer and Cummins 1991), 35 miles inland in Oregon (Nelson 1990), 22 

miles inland in northern California (Carter and Erickson 1988, Paton and Ralph 1990), and 11 miles inland in 

central California (Paton and Ralph 1990). However, the majority of detections were recorded closer to the coast. 

Marbled murrelets are semi-colonial in their nesting habits, and simultaneous detections of more than one bird are 

frequently made at inland sites. Nesting birds are often aggregated, with separate nests located close together. 

Marbled murrelets do not reach sexual maturity until their second year, and adults have a variable reproductive 

rate (i.e., not all adults may nest every year). They produce one egg per nest, which the female lays on the limb of 

an old-growth conifer tree. Nesting occurs over an extended period from mid-April to late September (Carter and 

Sealy 1987). Incubation lasts about 30 days, and fledging takes another 28 days (Simons 1980; Hirsch et al. 1981). 

Both sexes incubate the egg in alternating 24-hour shifts (Simons 1980; Singer et al. 1991). Flights from ocean 

feeding areas to inland nest sites occur most often at dusk and dawn (Hamer and Cummins 1991). The adults feed 

the chick at least once per day, carrying one fish at a time (Carter and Sealy 1987; Hamer and Cummins 1991; 

Nelson 1992; Singer et al. 1992). Before leaving the nest, the young molt into a distinctive juvenile plumage. 

Fledglings appear to fly directly from the nest to the sea, rather than exploring the forest environment first (Hamer 

and Cummins 1991). 

In California, Oregon, and Washington, marbled murrelets use older forest stands near the coastline for nesting. 

These forests are generally characterized by large trees (32 inches diameter at breast height or larger), a multistoried stand, and a moderate to high canopy closure. In certain parts of the range, marbled murrelets are also 

known to use mature forests with an old-growth component. In order to provide suitable nest platforms, trees must 

have large branches or deformities (Binford et al. 1975; Carter and Sealy 1987; Hamer and Cummins 1990, 1991; 

Singer et al. 1991, 1992). Marbled murrelets tend to nest in the oldest trees in the stand. Observations of nests 

indicate that they tend to be located high above ground, usually with good overhead protection, in locations that 

allow easy access to the exterior of the forest. In Oregon and Washington, nests are located in stands dominated 

by Douglas-fir, and in California they are located in old-growth redwood stands. 

In California, the species is restricted to old-growth redwood forests in Del Norte, Humboldt, San Mateo, and 

Santa Cruz Counties (Paton and Ralph 1988). In northwest Washington, marbled murrelets are mostly found at 

old-growth/mature sites (Hamer and Cummins 1990), and in Oregon, they occupy stands dominated by larger 

trees more often than those dominated by smaller trees (Nelson 1990). Large geographic gaps in offshore marbled 

murrelet numbers occur between central and northern California (a distance of 300 miles), and between Tillamook 

County, Oregon, and the Olympic Peninsula (a distance of about 120 miles), where nearly all older forest has been 

removed near the coast. 

The marbled murrelet was Federally Listed as threatened in California, Oregon, and Washington on October 

1, 1992. On May 24, 1996, 32 critical habitat units in Washington, Oregon, and California, encompassing 
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Final Environmental Impact Statement: Appendix 5

approximately 3,887,800 acres of land, were designated for the species. Critical habitat areas focused on two 

primary constituent elements: individual trees with potential nesting platforms, and forested areas within 0.5 

miles of these trees with a canopy height of at least one-half the site-potential tree height. The principal factor 

affecting the marbled murrelet in the three-state area, and the main cause of population decline has been the 

loss of older forests and associated nest sites. Older forests have declined throughout the range of the marbled 

murrelet as a result of commercial timber harvest, with additional losses from natural causes such as fire and wind 

throw. Most suitable nesting habitat on private lands within the range of the subspecies in Washington, Oregon, 

and California has been eliminated by timber harvest (Green 1985; Norse 1988; Thomas et al. 1990). Remaining 

tracts of potentially suitable habitat on private lands throughout the range are subject to continuing timber harvest 

operations. Mortality associated with oil spills and gill-net fisheries (in Washington) are lesser threats. It has been 

estimated that marbled murrelets are experiencing an annual population decline throughout their range as great 

as 4 to 7% per year. Surveys from Vancouver Island conducted 10 years apart suggest that populations there may 

have decreased by 40%. Populations in the northern Gulf of Alaska, meanwhile, may have declined by 50 to 73% 

over a 17- to 20-year period of time. 

Western Snowy Plover 

The primary reference for this section is: USFWS. 1993n. Determination of Threatened Status for the Pacific 

Coast Population of the Western Snowy Plover. Federal Register 58(42):12864-12874. References cited in this 

section are internal to the above-referenced document. A complete list of these references is available from the 

USFWS Sacramento Field Office, Sacramento, California. 

There are two distinct populations of western snowy plover (Charadrius alexandrinus nivosus), only one of which 

is a Federally Listed. The Pacific coast population of the western snowy plover, which is genetically isolated from 

interior-breeding western snowy plovers, is defined as those individuals that nest adjacent to or near tidal waters, 

including all nesting colonies on the mainland coast, peninsulas, offshore islands, adjacent bays, and estuaries. It 

is the Pacific coast population that is addressed in this document. 

In the U.S., three breeding areas currently exist in southern Washington, and nesting birds have been recorded 

in nine locations in Oregon (USFWS 2001). In California, eight geographic areas support over three-quarters of 

the breeding population in that state: San Francisco Bay, Monterey Bay, Morro Bay, the Callendar-Mussel Rock 

Dunes area, the Point Sal to Point Conception area, the Oxnard lowland, Santa Rosa Island, and San Nicolas 

Island (Page et al. 1991). 

The coastal population of the western snowy plover consists of both resident and migratory birds. Some birds 

winter in the same areas used for breeding, while other birds migrate either north or south to wintering areas 

(Warriner et al. 1986), the majority of which are south of Bodega Bay, California. Pacific coast western snowy 

plovers breed primarily on coastal beaches from southern Washington to Mexico. It is estimated that, at most, 

about 2,000 snowy plovers breed along the U.S. Pacific Coast (Page et al. 1995). Nest sites occur in flat, open 

areas with sandy or saline substrates, usually in areas where vegetation and driftwood are sparse or absent (Widrig 

1980; Wilson 1980; Stenzel et al. 1981). Nesting habitat is unstable and ephemeral as a result of unconsolidated 

soil characteristics influenced by high winds, storms, wave action, and colonization by plants. Other, less 

common nesting habitats include salt pans, coastal dredged spoil disposal sites, dry salt ponds, and salt pond 

levees. Sand spits, dune-backed beaches, unvegetated beach stands, open areas around estuaries, and beaches at 

river mouths are the preferred habitats for nesting (Wilson 1980; Stenzel et al. 1981). Snowy plovers forage on 

invertebrates in the wet sand and among surf-cast kelp within the intertidal zone; in dry, sandy areas above the 

high tide; on salt pans; at spoil sites; and along the edges of salt marshes and salt ponds. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Snowy plovers breed in loose colonies that range in size from 2 to 318 adults. Based on concentrations of 

breeding birds along the coast, it is believed that the center of the plovers’ coastal distribution lies close to the 

southern boundary of California (Page and Stenzel 1981). The breeding season of coastal western snowy plovers 

extends from mid-March through mid-September. The majority of snowy plovers are site-faithful, returning to 

the same breeding site each year, and often nesting in exactly the same locations. Nest initiation and egg laying 

occurs from mid-March through mid-July (Wilson 1980; Warriner et al. 1986). Typically, the clutch size is three 

eggs, and incubation averages 27 days, with both sexes incubating the eggs (Warriner et al. 1986). 

The Pacific coast population of the snowy plover was Federally Listed as threatened on March 5, 1993. On 

December 7, 1999, the USFWS designated 28 areas along the coast of California, Oregon, and Washington 

(totaling approximately 18,000 acres and 180 miles of coastline) as critical habitat for this population segment. 

Declines in snowy plover populations have been attributed to poor reproductive success resulting from human 

disturbance, predation, and inclement weather, combined with habitat loss resulting from urban development 

and the encroachment of introduced European beachgrass. These factors continue to threaten existing coastal 

populations of this species. 

Conservation Measures for the Western Snowy Plover

The following conservation measures are the minimum steps required of the BLM to ensure that treatment 

methods would be unlikely to negatively affect TEP species. Survey for western snowy plovers, piping plovers, 

and interior least terns (and their nests) in suitable areas on proposed treatment areas, prior to developing 

treatment plans. 

• Do not treat vegetation in nesting areas during the breeding season (as determined by a qualified 

biologist). 

• Do not allow human (or domestic animal) disturbance within 1⁄4 mile of nest sites during the nesting period. 

• Ensure that nest sites are at least 1 mile from downwind smoke effects during the nesting period. 

• Conduct beachgrass treatments during the plant’s flowering stage, during periods of active growth. 

• Closely follow all application instructions and use restrictions on herbicide labels; in wetland habitats use 

only those herbicides that are approved for use in wetlands. 

• Do not use 2,4-D in western snowy plover, piping plover, or interior least tern habitats; do not broadcast 

spray 2,4-D within 1⁄4 mile of western snowy plover, piping plover, or interior least tern habitat. 

• Where feasible, avoid use of the following herbicides in western snowy plover and piping plover habitat: 

clopyralid, diquat, diuron, glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr; 

in interior least tern habitat avoid the use of clopyralid, glyphosate, hexazinone, imazapyr, metsulfuron 

methyl, picloram, and triclopyr. 

• Do not broadcast spray clopyralid, diquat, diuron, glyphosate, hexazinone, picloram, or triclopyr in western 

snowy plover or piping plover habitat; do not broadcast spray these herbicides in areas adjacent to western 

snowy plover or piping plover habitat under conditions when spray drift onto the habitat is likely. 

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in interior least tern 

habitat; do not broadcast spray these herbicides in areas adjacent least tern habitat under conditions when 

spray drift onto the habitat is likely. 

• If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to western snowy plover, piping 

plover, or interior least tern habitat, apply at the typical, rather than the maximum, application rate. 

• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in western 

snowy plover, piping plover, or interior least tern habitat, utilize the typical, rather than the maximum, 

application rate. 

Additional, project-specific conservation measures would be developed at the local level, as appropriate.
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Final Environmental Impact Statement: Appendix 5

Northern Spotted Owl 

The primary reference for this section is: USFWS. 1990g. Determination of Threatened Status for the Northern 

Spotted Owl. Federal Register 55(123):26114-26194. References cited in this section are internal to the 

above-referenced document. A complete list of references is available from the USFWS, Fish and Wildlife 

Enhancement, Portland, Oregon. 

The northern spotted owl (Strix occidentalis caurina) is one of three subspecies of the spotted owl, a nocturnal 

bird of forest habitats. The current range of the northern spotted owl is from southwestern British Columbia, 

through western Washington, western Oregon, and northern California south to San Francisco Bay. Throughout 

this present range, individuals are not evenly distributed. The majority of individuals are found in the Cascade 

Mountains of Oregon and the Klamath Mountains in southwestern Oregon and northwestern California (USDA

1989; Gould 1989). Evidently, northern spotted owls reach their highest population densities and may have their 

best reproductive success in suitable habitat in this part of their range (USDI 1987, 1989; Franklin and Gutierrez 

1988; Miller and Meslow 1988; Franklin et al. 1989; Robertson 1989). 

The northern spotted owl is known from most of the major types of coniferous forests in the Pacific Northwest 

(Gould 1974, 1975, 1979; Forsman et al. 1977, 1984; Garcia 1979; Marcot and Gardetto 1980; Solis 1983; Sisco 

and Gutierrez 1984; Gutierrez et al. 1984; Forsman and Meslow 1985). In California, northern spotted owls most 

commonly use the Douglas-fir and mixed conifer forest types (Marcot and Gardetto 1980, Soils 1983, Gutierrez 

1985). In Washington’s coastal forests, the spotted owl is found in forests dominated by Douglas-fir and western 

hemlock. At higher elevations in western Washington, Pacific silver fir is commonly used by owls, whereas on 

the east side of the Cascades, Douglas-fir and grand fir are used (Postovit 1977). Extensive studies of spotted 

owls during the last 20 years have shown the species to be strongly associated with late-successional forests 

throughout much of its range. 

Northern spotted owls have been observed over a wide range of elevations, although they seem to avoid higher 

elevation, subalpine forests (USDA 1986). The age of forests is not as important a factor in determining habitat 

suitability as are vegetational and structural components. Suitable owl habitat has moderate to high canopy 

closure (60 to 80%); a multi-layered, multi-species canopy dominated by large (> 30 inches diameter at breast 

height) overstory trees; a high incidence of large trees with various deformities (e.g., large cavities, broken tops, 

dwarf-mistletoe infections, and other evidence of decadence); numerous large snags; large accumulations of fallen 

trees and other woody debris on the ground; and sufficient open space below the canopy for owls to fly (Thomas 

et al. 1990). Usually, the features characteristic of owl habitat are most commonly associated with old-growth 

forests or mixed stands of old-growth and mature trees, which do not assimilate these attributes until 150 to 200 

years of age. 

Although a secretive and mostly nocturnal bird, the northern spotted owl is relatively unafraid of human beings 

(Bent 1938; Forsman et al. 1984; USDA 1986). The adult spotted owl maintains a territory year-round; however, 

individuals may shift their home ranges between the breeding and nonbreeding season. Northern spotted owls 

are perch-and-dive predators; over 50% of their prey items are arboreal or semi-arboreal species. They subsist 

on a variety of mammals, birds, reptiles, and insects, with small mammals (e.g., flying squirrels, red tree voles, 

and dusky-footed woodrats) making up the bulk of the food items throughout the range of the species (Solis and 

Gutierrez 1982; Forsman et al. 1984; Barrows 1985). 

Monogamous and long-lived, northern spotted owls tend to mate for life. However, specific northern spotted 

owl pairs usually do not nest every year, nor are nesting pairs successful every year. Nesting behavior begins 

in February to March, with nesting occurring from March to June. The timing of nesting and fledging varies 

with latitude and elevation (Forsman et al. 1984). The number of eggs in a clutch ranges from one to four, with 
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two eggs being most common. Fledging occurs from mid-May to late June, with parental care continuing into 

September. Females are capable of breeding in their second year, but it is likely that most do not breed until their 

third year (Barrows 1985; Miller and Meslow 1985b; Franklin et al. 1986). Males do most of the foraging during 

incubation, and assist with foraging during the fledging period. 

The northern spotted owl was Federally Listed as a threatened species on June 26, 1990. On January 15, 1992, 

critical habitat was designated for the subspecies in 190 areas, encompassing a total of nearly 6.9 million acres 

of land. Throughout its range, the northern spotted owl is threatened by the loss and modification of suitable 

habitat as a result of timber harvesting. These threats are exacerbated by risks of catastrophic events such as fire, 

volcanic eruption, and wind storms. The population of the northern spotted owl is estimated at approximately 

3,800 pairs and 1,000 individuals (National Audubon Society 2002).

Conservation Measures for the Northern Spotted Owl

The following programmatic-level conservation measures are the minimum steps required of the BLM to ensure 

that treatment methods would be unlikely to negatively affect the marbled murrelet, northern spotted owl, or 

Mexican spotted owl. 

• Survey for marbled murrelets, northern spotted owls, and Mexican spotted owls (and their nests) on 

suitable proposed treatment areas, prior to developing treatment plans. 

• Delineate a 100-acre buffer around nests prior to mechanical treatments or prescribed burns. 

• Do not allow human disturbance within 1⁄4 mile of nest sites during the nesting period (as determined by a 

local biologist). 

• Ensure that nest sites are at least 1 mile from downwind smoke effects during the nesting period. 

• Protect and retain the structural components of known or suspected nest sites during treatments; evaluate 

each nest site prior to treatment and protect it in the most appropriate manner. 

• Maintain sufficient dead and down material during treatments to support spotted owl prey species 

(minimums would depend on forest types, and should be determined by a wildlife biologist). 

• Do not conduct treatments that alter forest structure in old-growth stands. 

• Do not use 2,4-D in marbled murrelet, northern spotted owl, or Mexican spotted owl habitats; do not 

broadcast spray 2,4-D within 1⁄4 mile of marbled murrelet, northern spotted owl, or Mexican spotted owl 

habitat. 

• Where feasible, avoid use of the following herbicides in northern spotted owl and Mexican spotted owl 

habitat: bromacil, clopyralid, diquat, diuron, glyphosate, hexazinone, imazapyr, metsulfuron methyl, 

picloram, and triclopyr. 

• Where feasible, avoid use of the following herbicides in marbled murrelet habitat: clopyralid, glyphosate, 

hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr. 

• Do not broadcast spray clopyralid, glyphosate, hexazinone, picloram, or triclopyr in marbled murrelet, 

northern spotted owl, or Mexican spotted owl habitat; do not broadcast spray these herbicides in areas 

adjacent to marbled murrelet, northern spotted owl, or Mexican spotted owl habitat under conditions 

when spray drift onto the habitat is likely. 

• Do not broadcast spray diuron in Mexican or northern spotted owl habitat; do not broadcast spray these 

herbicides in areas adjacent to Mexican or northern spotted owl habitat under conditions when spray drift 

onto the habitat is likely. 

• If broadcast spraying imazapyr or metsulfuron methyl in or adjacent to marbled murrelet, northern spotted 

owl, or Mexican spotted owl habitat, apply at the typical, rather than the maximum, application rate. 

• If broadcast spraying bromacil or diquat in or adjacent to Mexican or northern spotted owl habitat, apply 

at the typical, rather than the maximum, application rate. 
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• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in marbled 

murrelet, northern spotted owl, or Mexican spotted owl habitat, utilize the typical, rather than the 

maximum, application rate. 

• Follow all instructions and Standard Operating Procedures to avoid spill and direct spray scenarios into 

aquatic habitats, particularly marine habitats where murrelets forage for prey. 

Additional conservation measures would be developed, as necessary, at the project level to fine-tune protection of 

these species.

Other

Greater Sage Grouse 

The primary references for this section are: Federal Register/Vol. 75, No. 55/Tuesday, March 23, 2010/13910-140014/

Proposed Rules, available at http://www.regulations.gov; Hagen, C. A. 2005. Greater sage-grouse conservation 

assessment and strategy for Oregon: a plan to maintain and enhance populations and habitat. Oregon Department of 

Fish and Wildlife, Salem, USA; and, Instruction Memo OR-2007-073, July 25, 2007, Sage-Grouse Guidelines.

On March 23, 2010 the Fish and Wildlife Service (Service) announced three 12-month findings on petitions to 

list three entities of the greater sage grouse (Centrocerus urophasinus) as threatened or endangered under the 

Endangered Species Act of 1973, as amended. The Service found that listing the greater sage grouse (rangewide) 

is warranted, but precluded by higher priority listing actions and will develop a proposed rule to list the greater 

sage-grouse as priorities allow (1). Therefore the greater sage-grouse remains a Bureau Sensitive species in 

Oregon and no ESA consultation is required. Oregon BLM districts will continue to implement the conservation 

guidance provided in Greater Sage-Grouse Conservation Assessment and Strategy for Oregon A Plan to Maintain 

and Enhance Populations and Habitat as per Oregon Instruction Memo OR-2007-073. 

Fish

Endangered

Modoc Sucker 

The Modoc sucker (Catostomus microps) is known from only a few widely separated tributary systems to the 

upper Pit River in northeastern California―the Rush-Ash Creek system and the Washington-Turner-Hulbert 

system (Moyle 1976, Ford 1977). This species occurs primarily in sections of stream with low or intermittent 

flow, or pools of the meadowlands (Moyle and Mariochi 1975, Moyle 1976, Ford 1977). In general, sites 

where Modoc suckers have been found are characterized by the following: low flows (intermittent in some); 

largely shallow pools; muddy bottoms; partial shade trees, shrubs, boulders, or undercut banks; abundant cover 

from riparian vegetation and undercut banks; and moderately clear water (Moyle and Mariochi 1975). Water 

temperatures (summer and fall) in Modoc sucker habitat range from 46 F (fall) to 74 F (summer; Ford 1977). 

Modoc suckers are omnivorous, feeding on detritus, diatoms, filamentous algae, chironomid larvae, crustaceans, 

and aquatic insect larvae. Adult suckers usually remain on the bottom or close to it (Martin 1972). 

Spawning usually occurs from mid-April to the last week in May or the first week in June (Boccone and 

Mills 1979). Spawning occurs over coarse fine gravel in the lower end of pools with abundant cover. Water 

temperatures range from 56 to 61 F. There is some evidence from Johnson and Washington Creeks of upstream 

migration by Modoc suckers to small intermittent tributaries, such as Higgins and Rice flats, during spawning 

season. Also, a possible spawning migration of Modoc suckers has been observed from Moon (Lake) Reservoir 

upstream into Cedar Creek. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The Modoc sucker was Federally Listed as endangered on June 11, 1985. Critical habitat has been designated 

in Modoc County, California. Designated habitat includes intermittent and permanent water and adjacent land 

areas that provide vegetation for cover and protection from soil erosion of all or portions of: Turner Creek, 

Hulbert Creek, Cedar Creek, Washington Creek, Coffee Mill Gulch, Johnson Creek, Higgins and Rice flats, 

and Rush Creek, Modoc County, California. The Modoc sucker is endangered because of its very restricted 

distribution combined with destruction of habitat. A major portion of the Rush Creek Modoc sucker habitat is on 

privately-owned land used for grazing sheep and cattle, which trample streambanks, thereby causing destruction 

of habitat through increased erosion of streambanks, removal of aquatic and riparian vegetation needed as 

cover, and siltation (Moyle 1976; Cooper et al. 1978; Mills 1980; Cooper 1983; Chesney 1985). Destruction of 

natural barriers to the Sacramento sucker by flooding areas for the creation of pastures, and by channelization, 

has resulted in losses through hybridization and backcrossing in several of the Modoc sucker streams (Ford 

1977; Cooper et al. 1978; Mills 1980; Cooper 1983; Chesney 1985). Diversions of water for irrigation reduce 

the number and sizes of pools available to the Modoc suckers (Ford 1977). In addition, introductions of brown 

trout have added to the predation pressure on the Modoc sucker (Cooper et al. 1978; Mills 1980; Cooper 1983). 

Destruction of habitat by overgrazing and limited distribution of pure populations of the Modoc sucker still 

threaten the species (Ford 1977, Chesney 1985).

Lost River and Shortnose Suckers 

The primary reference for this section is: USFWS. 1993l. Lost River (Deltistes luxatus) and Shortnose 

(Chasmistes brevirostris) Sucker Recovery Plan. Portland, Oregon. References cited in this section are internal to 

the above-referenced document. They are included in the Bibliography. 

The Lost River sucker (Deltistes luxatus) and shortnose sucker (Chasmistes brevirostris) are large, long-lived 

suckers endemic to the upper Klamath Basin of Oregon and California. Historical records indicate that the two 

species were once widespread and abundant within their range. The present distribution of the Lost River sucker 

includes Upper Klamath Lake and its tributaries, Clear Lake Reservoir and its tributaries, Tule Lake and the Lost 

River up to Anderson-Rose Dam, and the Klamath River downstream to Copco Reservoir (Beak Consultants 

Incorporated 1987; Buettner and Scoppettone 1990, 1991). The present distribution of the shortnose sucker 

includes Upper Klamath Lake and its tributaries, Klamath River downstream to Iron Gate Reservoir, Clear Lake 

Reservoir and its tributaries, Gerber Reservoir and its tributaries, the Lost River, and Tule Lake. 

Lost River and shortnose suckers are omnivores that feed primarily on zooplankton and insects. Both species 

generally spawn in rivers or streams and then return to the lake (Buettner and Scoppettone 1990). However, both 

species have separate populations that spawn near springs in upper Klamath Lake (Klamath Tribe 1993). Larval 

suckers usually spend relatively little time in tributary streams before they migrate back to the lake. Migration 

from spawning sites can begin in May or June. During the day, larvae typically move to shallow (depths of less 

than 20 inches) shoreline areas in the river, over substrates of sand, mud, and concrete (Buettner and Scoppettone 

1990). Larvae are generally found in close proximity to rooted aquatic vegetation, and appear to avoid areas 

devoid of vegetation (Coleman and McGie 1988). It is believed that the suckers once used the extensive marsh 

system of the lower river as nursery habitat. Much of this habitat has been replaced by gently sloping, sandy, 

unvegetated shorelines. Adult Lost River and shortnose suckers usually spend relatively little time in tributary 

streams and migrate back to the lake after spawning. Adults appear to prefer areas with relatively low densities 

of algae and good water quality in terms of pH and dissolved oxygen, such as areas of the lake near inflows from 

streams or springs. 

The Lost River and shortnose sucker were Federally Listed as endangered on July 18, 1988. The designation 

of critical habitat for both species was proposed in 1994, but has not occurred. The limited distribution of both 

sucker species, combined with the level of agricultural development and associated water and land use threats 
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Final Environmental Impact Statement: Appendix 5

within the drainage, make these fishes susceptible to past and present habitat loss and degradation throughout 

their distribution. Cumulative impacts of land management on public and private lands has led to the endangered 

status of the Lost River sucker and shortnose sucker, and continues to hinder their recovery. Inputs of sediment 

and nutrients, and changes in timing and duration of stream flow as a result of road building have altered lake 

habitats. Habitat has also been lost through construction of dams, diversion of water from streams, reclamation of 

wetlands, and other changes.

Borax Lake Chub 

The permanent habitat of the Borax Lake chub (Gila boraxobius) is a 10.2-acre thermal lake located in the Borax 

Lake Basin of Oregon. This lake, which is shallow and fed by hot and cool springs, is perched about 30 feet above 

the desert floor in a “pedestal” of deposited salts. The saline lake bottom is inhospitable to rooted plants, although 

some of the precipitated minerals are finely divided and silt-like. Irrigation channels have been dug from the lake 

to supply water for hay fields, and the chub may also be found in these channels. The chub is found in Lower 

Borax Lake, an artificial pond, when it has water in it. This habitat is highly alkaline, with murky water and little 

vegetation. If enough overflow water is received, marshes and temporary pools may also provide habitat for the 

chub. All of the Borax Lake chub’s known habitats in southeastern Oregon comprise approximately 640 acres. 

The Borax Lake chub is an opportunistic omnivore (Hudson et al. 2000). Spawning can occur year-round, but 

primarily occurs in the spring. Substantial spawning activity and larval chubs have been observed during autumn, 

following the cessation of unusually hot spring inflows during the preceding months. 

The Borax Lake chub was Federally Listed as endangered on October 5, 1982. Critical habitat has been designated 

in Harney County, Oregon, and includes all 640 acres of habitat in Township 37 South, Range 33 East, including 

Borax Lake, marsh areas to the south and southwest, Lower Borax Lake, and hot springs north of Borax Lake. 

Because the lake depends upon several subterranean springs for its water supply, lowering the rim of the lake or 

tapping and diverting the springs could have severe effects upon the species. Borax Lake is in a known geothermal 

resource area, and both diversion and geothermal exploration appear to constitute a threat to the species. 

Steelhead 

Along the west coast, steelhead trout (Oncorhynchus mykiss) are distributed across about 15 degrees of latitude 

from the U.S. Canada border south to the mouth of Malibu Creek, California. In some years, steelhead may be 

found as far south as the Santa Margarita River in San Diego County. There are 10 listed steelhead ESUs, 8 of 

which are found in the project area: Central California Coast, Upper Columbia River, Snake River Basin, Lower 

Columbia River, California Central Valley, Upper Willamette, Middle Columbia River, and Northern California. 

Steelhead have the greatest diversity of life history patterns of any Pacific salmonid species, including varying 

degrees of anadromy, differences in reproductive biology, and plasticity of life history between generations. 

Within the range of West Coast steelhead, spawning migrations occur throughout the year, with seasonal peaks 

of activity. In any given river basin there may be one or more peaks of migration activity; some rivers may have 

multiple runs, and fish are divided into either winter, spring, summer, or fall run steelhead. North American 

steelhead commonly spend 2 years in the ocean before entering fresh water to spawn. Summer steelhead enter 

fresh water up to a year prior to spawning. Steelhead may spawn more than once. In some cases, the separation 

between anadromous steelhead and rainbow or redband trout is obscured. 

Upper Columbia River 

The Upper Columbia River ESU was Federally Listed as endangered on August 18, 1997. This ESU 

occurs in streams in the Columbia River Basin upstream from the Yakima River, Washington, to the U.S.-

Canada border. Wells Hatchery stock steelhead are also part of the listed ESU. NMFS filed final critical 
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habitat designation for this species on August 15, 2005. Approximately 1,262 stream miles and 7 square 

miles of lake habitat has been designated as critical habitat. Major river basins containing spawning and 

rearing habitat for this ESU comprise approximately 9,545 square miles in Oregon and Washington. The 

following counties lie partially or wholly within these basins (or contain migration habitat for the species): 

Oregon―Clatsop, Columbia, Gilliam, Hood River, Morrow, Multnomah, Sherman, Umatilla, and Wasco; 

and Washington―Benton, Chelan, Clark, Cowlitz, Douglas, Franklin, Gilliam, Grant, Kittitas, Klickitat, 

Okanogan, Pacific, Skamania, Wahkiakum, Walla Walla, and Yakima. Critical habitat is found in the 

following counties: Oregon―Clatsop, Columbia, Gilliam, Hood River, Morrow, Multnomah, Umatilla, 

and Wasco; and Washington―Adams, Benton, Chelan, Clark, Cowlitz, Douglas, Franklin, Grant, Kittitas, 

Klickitat, Okanogan, Skamania, Wahkiakum, Walla Walla, and Yakima. BLM-administered lands are found 

in all counties with critical habitat except Wahkiakum. 

Snake River 

The Snake River ESU of steelhead was Federally Listed as threatened on August 18, 1997. This ESU occurs 

in streams in the Snake River Basin of southeast Washington, northeast Oregon, and Idaho. NMFS filed 

final critical habitat designation for this species on August 15, 2005. Approximately 8,049 stream miles 

and 4 square miles of lake habitat has been designated as critical habitat. Major river basins containing 

spawning and rearing habitat for this ESU comprise approximately 29,282 square miles in Idaho, Oregon, 

and Washington. The following counties lie partially or wholly within these basins (or contain migration 

habitat for the species): Idaho―Adams, Blaine, Boise, Clearwater, Custer, Idaho, Latah, Lemhi, Lewis, Nez 

Perce, and Valley; Oregon―Baker, Clatsop, Columbia, Hood River, Morrow, Multnomah, Sherman, Umatilla, 

Union, Wallowa, and Wasco; and Washington―Asotin, Benton, Clark, Columbia, Cowlitz, Franklin, 

Garfield, Gilliam, Klickitat, Skamania, Wahkiakum, Walla Walla, and Whitman. Critical habitat is found in 

the following counties: Idaho―Adams, Blaine, Clearwater, Custer, Idaho, Latah, Lemhi, Lewis, Nez Perce, 

and Valley; Oregon―Clatsop, Columbia, Gilliam, Hood River, Morrow, Multnomah, Sherman, Umatilla, 

Union, Wallowa, and Wasco; and Washington―Asotin, Benton, Clark, Columbia, Cowlitz, Franklin, Garfield, 

Klickitat, Skamania, Wahkiakum, Walla Walla, and Whitman. BLM-administered lands are found in all 

counties with critical habitat except Wahkiakum. 

Lower Columbia River 

The Lower Columbia River ESU was Federally Listed as threatened on March 19, 1988. This ESU occurs in 

streams and tributaries to the Columbia River between the Cowlitz and Wind rivers, Washington (inclusive) 

and the Willamette and Hood rivers, Oregon (inclusive). Excluded are steelhead in the upper Willamette 

River Basin above Willamette Falls and steelhead from the Little and Big White Salmon rivers in Washington. 

NMFS filed final critical habitat designation for this species on August 15, 2005. Approximately 2,324 

stream miles and 27 square miles of lake habitat has been designated as critical habitat. Major river basins 

containing spawning and rearing habitat for this ESU comprise approximately 5,017 square miles in Oregon 

and Washington. The following counties lie partially or wholly within these basins (or contain migration 

habitat for the species): Oregon―Clackamas, Clatsop, Columbia, Hood River, Marion, Multnomah, 

and Washington; and Washington―Clark, Cowlitz, Lewis, Pacific, Skamania, and Wahkiakum. Critical 

habitat is found in the following counties: Oregon―Clackamas, Clatsop, Columbia, Hood River, Marion, 

and Multnomah; and Washington―Clark, Cowlitz, Klickitat, Lewis, Skamania, and Wahkiakum. BLMadministered lands are found in all counties with critical habitat except Wahkiakum. 

Upper Willamette 

The Upper Willamette ESU of steelhead was Federally Listed as threatened on March 25, 1999. This ESU 

includes all naturally-spawned populations of winter-run steelhead in the Willamette River, Oregon, and its 

tributaries upstream from Willamette Falls to the Calapooia River, inclusive. NMFS filed final critical habitat 
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Final Environmental Impact Statement: Appendix 5

designation for this species on August 15, 2005. Approximately 1,276 stream miles and 2 square miles of 

lake habitat has been designated as critical habitat. Major river basins containing spawning and rearing 

habitat for this ESU comprise approximately 4,872 square miles in Oregon and Washington. The following 

counties lie partially or wholly within these basins (or contain migration habitat for the species): Oregon―

Benton, Clackamas, Clatsop, Columbia, Lincoln, Linn, Marion, Multnomah, Polk, Tillamook, Washington, 

and Yamhill; and Washington―Clark, Cowlitz, Pacific, and Wahkiakum. Critical habitat is found in the 

following counties: Oregon―Benton, Clackamas, Clatsop, Columbia, Linn, Marion, Multnomah, Polk, 

Tillamook, Washington, and Yamhill; and Washington―Clark, Cowlitz, and Wahkiakum. BLM-administered 

lands are found in all counties with critical habitat except Wahkiakum. 

Middle Columbia River 

The Middle Columbia River ESU was Federally Listed as threatened on March 25, 1999. This ESU occurs in 

streams from above the Wind River, Washington, and the Hood River, Oregon (exclusive), upstream to, and 

including, the Yakima River, Washington. Excluded are steelhead from the Snake River Basin. NMFS filed 

final critical habitat designation for this species on August 15, 2005. Approximately 5,815 stream miles has 

been designated as critical habitat. Major river basins containing spawning and rearing habitat for this ESU 

comprise approximately 26,739 square miles in Oregon and Washington. The following counties lie partially 

or wholly within these basins (or contain migration habitat for the species): Oregon―Clatsop, Columbia, 

Crook, Gilliam, Grant, Harney, Hood River, Jefferson, Morrow, Multnomah, Sherman, Umatilla, Union, 

Wallowa, Wasco, and Wheeler; and Washington―Benton, Clark, Columbia, Cowlitz, Franklin, Kittitas, 

Klickitat, Pacific, Skamania, Wahkiakum, Walla Walla, and Yakima. Critical habitat is found in the following 

counties: Oregon―Clatsop, Columbia, Crook, Gilliam, Grant, Hood River, Jefferson, Morrow, Multnomah, 

Sherman, Umatilla, Union, Wallowa, Wasco, and Wheeler; and Washington―Benton, Clark, Columbia, 

Cowlitz, Franklin, Kittitas, Klickitat, Skamania, Wahkiakum, Walla Walla, and Yakima. BLM-administered 

lands are found in all counties with critical habitat except Wahkiakum. 

Chinook Salmon 

Chinook salmon (Oncorhynchus tshawtscha) are found from the Bering Strait south to Southern California. 

Historically, they ranged as far south as the Ventura River in California. There are 17 ESUs of chinook salmon 

along the west coast of the United States, which range from southern California to the Canadian border and east to 

the Rocky Mountains. In the project area, there are eight listed ESUs: Sacramento Winter-run; Snake River Fallrun; Snake River Spring/Summer-run; Lower Columbia River; Upper Willamette River; Upper Columbia River 

Spring-run; Central Valley Spring-run; and California Coastal. 

Chinook salmon are the largest of any salmon, with adults often exceeding 40 pounds. Like coho salmon, they 

are anadromous and spawn only once before dying. Chinook salmon stocks exhibit considerable variability in 

size and age of maturation, at least some of which is genetically determined. The relationship between size and 

length of migration may also reflect the earlier timing of river entry and the cessation of feeding for salmon stocks 

that migrate to the upper reaches of river systems. Body size, which is correlated with age, may be an important 

factor in migration and the successful construction of redds (spawning beds). 

There are different seasonal runs of chinook salmon, which correspond to the timing of migration from ocean to 

freshwater. These runs have been identified on the basis of when adults enter freshwater to begin their spawning 

migration. However, distinct runs also differ in the degree of maturation at the time of river entry, the thermal 

regime and flow characteristics of their spawning site, and their actual time of spawning. 

Adult female chinook prepare spawning beds in stream areas with suitable gravel composition, water depth, and 

velocity. The female then lays eggs, which she guards for a brief period before dying. Eggs hatch between 90 and 
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150 days after deposition, depending on water temperatures. The following spring, young salmon fry emerge, and 

may spend from 3 months to 2 years in freshwater before migrating to estuarine areas as smolts, and then into the 

ocean to feed and mature. Chinook salmon remain at sea for 1 to 6 years, with the exception of a small number of 

yearling males that mature in freshwater, or return after 2 to 3 months in salt water. 

There are two distinct races of chinook salmon: stream-type and ocean-type. Stream-type chinook have a longer 

freshwater residency and perform extensive offshore migrations before returning to their natal streams in the spring 

and summer months. Ocean-type chinook, which are commonly found in coastal streams, typically migrate to sea 

within the first 3 months of emergence, but may spend up to a year in fresh water prior to emigration. They also 

spend their ocean life in coastal waters, utilizing estuaries and coastal areas more extensively for juvenile rearing. 

Snake River Fall Run 

The Snake River Fall-run ESU was Federally Listed as a threatened species on April 22, 1992. This ESU 

includes all natural populations occurring in the mainstem Snake River and any of the following subbasins: 

Tucannon River, Grande Ronde River, Imnaha River, Salmon River, and Clearwater River. 

Critical habitat (designated on December 28, 1993) includes all river reaches presently or historically 

accessible (except reaches above impassable natural falls, and Dworshak and Hells Canyon dams) in the 

Columbia River, from a straight line connecting the west end of the Clatsop jetty (south jetty, Oregon 

side) and the west end of the Peacock jetty (north jetty, Washington side). Critical habitat also includes all 

Columbia River estuarine areas and river reaches proceeding upstream to the confluence of the Columbia 

and Snake rivers. On the Snake River, all reaches from the confluence of the Columbia River, upstream to 

Hells Canyon Dam are included. Also included are the Palouse River from its confluence with the Snake 

River upstream to Palouse Falls; the Clearwater River from its confluence with the Snake River upstream to 

its confluence with Lolo Creek; and the North Fork Clearwater River from its confluence with the Clearwater 

River upstream to Dworshak Dam. Major river basins containing spawning and rearing habitat for this ESU 

comprise approximately 13,679 square miles in Idaho, Oregon, and Washington. The following counties 

lie partially or wholly within these basins: Idaho―Adams, Benewah, Clearwater, Idaho, Latah, Lewis, 

Nez Perce, and Shoshone Valley; Oregon―Baker, Union, and Wallowa; and Washington―Adams, Asotin, 

Columbia, Franklin, Garfield, Walla Walla, and Whitman. Counties with critical habitat are: Idaho―Adams, 

Clearwater, Idaho, Latah, Lemhi, Lewis, and Nez Perce; Oregon―Baker, Clatsop, Columbia, Gilliam, Hood 

River, Morrow, Multnomah, Sherman, Umatilla, Wallowa, and Wasco; and Washington―Adams, Asotin, 

Benton, Clark, Columbia, Cowlitz, Franklin, Garfield, Klickitat, Lincoln, Pacific, Skamania, Spokane, 

Wahkiakum, Walla Walla, and Whitman. BLM-administered lands are found in all counties with critical 

habitat except Wahkiakum County. 

Snake River Spring/Summer Run 

The Snake River Spring/Summer-run ESU was Federally Listed as a threatened species on April 22, 1992. 

Included in this ESU are all natural populations occurring in the mainstem Snake River and in the subbasins 

of the Tucannon River, Grande Ronde River, Imnaha River, and Salmon River. 

Critical habitat (designated on December 28, 1993) is similar to that for the Snake Fall-run ESU, except that 

stretches of the Palouse River, Clearwater River, and the North Fork Clearwater are not included. There are 

a total of 22,390 square miles of major river basins containing spawning and rearing habitat for this ESU in 

Idaho, Oregon, and Washington. The following counties lie partially or wholly within these basins: Idaho―

Adams, Blaine, Custer, Idaho, Lemhi, Lewis, Nez Perce, and Valley; Oregon―Baker, Umatilla, Union, 

and Wallowa; and Washington―Adams, Asotin, Columbia, Franklin, Garfield, Walla Walla, and Whitman. 

Counties with critical habitat are: Idaho―Adams, Blaine, Custer, Idaho, Lemhi, Lewis, Nez Perce, and 
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Valley; Oregon―Baker, Clatsop, Columbia, Gillium, Hood River, Morrow, Multnomah, Sherman, Umatilla, 

Union, Wallowa, and Wasco; and Washington―Asotin, Benton, Clark, Columbia, Cowlitz, Franklin, Garfield, 

Klickitat, Pacific, Skamania, Wahkiakum, Walla Walla, and Whitman. BLM-administered lands are found in 

all counties with critical habitat except Wahkiakum County. 

Lower Columbia River 

The Lower Columbia River ESU was Federally Listed as threatened on March 24, 1999. Included in this 

ESU are all naturally-spawned populations occurring in the Columbia River and its tributaries, from its mouth 

at the Pacific Ocean upstream to a transitional point between Washington and Oregon east of the Hood River 

and the White Salmon River This ESU also includes populations in the Willamette River to Willamette Falls, 

Oregon, exclusive of spring-run chinook salmon in the Clackamas River. 

On August 15, 2005, NMFS filed the final critical habitat designation for this species in Clackamas, Clatsop, 

Columbia, Hood River, Multnomah, Wasco counties in Oregon; and Clark, Cowlitz, Klickitat, Lewis, 

Pacific, Pierce, Skamania, Wahkiakum, and Yakima counties in Washington. Major river basins that contain 

spawning and rearing habitat for this ESU comprise approximately 6,338 square miles in Oregon and 

Washington. There are approximately 1,311 stream miles and 33 square miles of lake habitat within this 

ESU that is designated as critical habitat. The following counties lie partially or wholly within these basins, 

or contain migration habitat for the ESU: Oregon―Clackamas, Clatsop, Columbia, Hood River, Marion, 

Multnomah, Wasco, and Washington; and Washington―Clark, Cowlitz, Klickitat, Lewis, Pacific, Pierce, 

Skamania, Wahkiakum, and Yakima. Critical habitat is found in the following counties: Oregon―Clackamas, 

Clatsop, Columbia, Hood River, and Multnomah; and Washington―Clark, Cowlitz, Klickitat, Lewis, Pacific, 

Skamania, and Wahkiakum. BLM-administered lands are found in all counties with critical habitat except 

Pierce and Wahkiakum counties. 

Upper Willamette River 

The Upper Willamette River chinook salmon ESU was Federally Listed as threatened on March 24, 1999. 

This ESU includes all naturally-spawned populations occurring in the Clackamas River and in the Willamette 

River, and its tributaries, above Willamette Falls, Oregon. 

NMFS filed final critical habitat designation for this species on August 15, 2005. Approximately 1,472 stream 

miles and 18 square mile of lake habitat has been designated as critical habitat in this ESU. Major river 

basins containing spawning and rearing habitat for this ESU comprise approximately 8,575 square miles. The 

following counties lie partially or wholly within these basins (or contain migration habitat for the species): 

Oregon―Benton, Clackamas, Clatsop, Columbia, Douglas, Lane, Lincoln, Linn, Marion, Multnomah, Polk, 

Tillamook, Washington, and Yamhill; and Washington―Clark, Cowlitz, Pacific, and Wahkiakum. Critical 

habitat has been designated in the following counties: Oregon―Benton, Clackamas, Clatsop, Columbia, 

Lane, Linn, Marion, Multnomah, Polk, and Yamhill; and Washington―Clark, Cowlitz, and Wahkiakum. 

BLM-administered lands are found in all counties with critical habitat except Wahkiakum County. 

Upper Columbia River Spring Run 

The Upper Columbia River Spring-run ESU was Federally Listed as threatened on March 24, 1999. Included 

in this ESU are all naturally-spawned populations occurring in all accessible river reaches in Columbia River 

tributaries upstream of the Rock Island Dam and downstream of Chief Joseph Dam in Washington, excluding 

the Okanogan River. Chinook salmon (and their progeny) from the following hatchery stocks are considered 

part of the listed ESU: Chiwawa River (spring run); Methow River (spring run); Twisp River (spring run); 

Chewuch River (spring run); White River (spring run); and Nason Creek (spring run). 
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NMFS filed final critical habitat designation for this species on August 15, 2005. Approximately 974 stream 

miles and 4 square miles of lake habitat has been designated as critical habitat in this ESU. Major river basins 

containing spawning and rearing habitat for this ESU comprise approximately 7,003 square miles in Oregon 

and Washington. The following counties lie partially or wholly within these basins (or contain migration 

corridors for the species): Oregon―Clatsop, Columbia, Hood River, Gilliam, Morrow, Multnomah, Sherman, 

Umatilla, and Wasco; and Washington―Benton, Chelan, Clark, Cowlitiz, Douglas, Franklin, Grant, Klickitat, 

Kittitas, Okanogan, Pacific, Skamania, Wahkiakum, Walla Walla, and Yakima. Critical habitat for this ESU 

is found in the following counties: Oregon―Clatsop, Columbia, Gilliam, Hood River, Morrow, Multnomah, 

Sherman, Umatilla, and Wasco; and Washington―Benton, Chelan, Clark, Cowlitiz, Douglas, Franklin, Grant, 

Kittitas, Klickitat, Okanogan, Pacific, Skamania, Wahkiakum, Walla Walla, and Yakima. BLM-administered 

lands are found in all counties with critical habitat except Wahkiakum County. 

Threatened

Warner Sucker 

The primary reference for this section is: USFWS. 1998l. Recovery Plan for the Native Fishes of the Warner 

Basin and Alkali Subbasin. Portland, Oregon. References cited in this section are internal to the abovereferenced document. They are included in the Bibliography. 

The Warner sucker (Catostomus warnerensis) is endemic to the Warner Basin of southeastern Oregon. The 

probable historic range of this species includes the main Warner Lakes (Pelican, Crump, and Hart), and other 

accessible standing or flowing water in the Warner Valley, as well as the low-to-moderate gradient reaches of the 

tributaries that drain into the valley. Studies conducted between 1977 and 1991 indicate that when adequate water 

is present, Warner suckers may inhabit all the lakes, sloughs, and potholes in the Warner Valley. Stream resident 

populations are found in Honey Creek, Snyder Creek, Twentymile Creek, and Twelvemile Creek. 

There are two phenotypic variations, or morphs of the Warner sucker, which correspond to the two generally 

continuous aquatic habitat types provided by the Warner Basin. Stream morphs occur in the temporally stable 

stream environments, and lake morphs occur in the temporally less stable lake environments. Individual fish can 

opportunistically change from one morph to another based on the types of habitat that are available. The exact 

nature of the relationship between lake and stream morphs is not well studied, and remains poorly understood. 

The feeding habitats of the Warner sucker depend to a large degree on habitat and life history stage, with adult 

suckers becoming more generalized than juveniles and young-of-year. Larvae have terminal mouths and short 

digestive tracts, enabling them to feed selectively in midwater or at the surface. Invertebrates, particularly 

planktonic crustaceans, make up most of their diet. As the suckers grow, they develop subterminal mouths and 

longer digestive tracts, and gradually become benthic feeders, eating diatoms, filamentous algae, and detritus. 

Adult stream morph suckers forage nocturnally over a wide variety of substrates, such as boulders, gravel, and 

silt. Adult lake morph suckers are thought to have a similar diet, though they feed over predominantly muddy 

substrates (Tait and Mulkey 1993a, b). 

Spawning usually occurs in April and May in streams, although variations in water temperature and stream flows 

may result in either earlier or later spawning. Temperature and flow cues appear to trigger spawning, with most 

taking place at 57 to 68 °F when stream flows are relatively high. Suckers spawn in sand or gravel beds in slow 

pools (White et al. 1990, 1991; Kennedy and North 1993). In years when access to stream spawning areas is 

limited by low flow or by physical in-stream blockages, suckers may attempt to spawn on gravel beds along the 

lake shorelines. 
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Larvae are found in shallow backwater pools or on stream margins where there is no current, often among or near 

macrophytes. Young-of-year are often found over still, deep water from midwater to the surface, but also move 

into faster flowing water near the heads of pools (Coombs et al. 1979). Juveniles (1 to 2 years old) are usually 

found at the bottom of deep pools or in other habitats that are relatively cool or permanent, such as near springs. 

In general, adults use stretches of streams where the gradient is sufficiently low to allow the formation of long 

(167 feet or longer) pools. These pools tend to have undercut banks, large beds of aquatic macrophytes, root wads 

or boulders, a surface to bottom temperature differential of at least 36 °F, a maximum depth greater than 5 feet, 

and overhanging vegetation. 

The Warner sucker was Federally Listed as threatened on September 27, 1985, with critical habitat designated at 

the time of listing. Critical habitat for this species includes the following areas: 1) Twentymile Creek from the 

confluence of Twelvemile and Twentymile Creeks upstream for about 4 miles; 2) Twentymile Creek starting about 

9 miles upstream of the confluence of Twelvemile and Twentymile Creeks and extending downstream for about 

18 miles; 3) Spillway Canal north of Hart Lake and continuing about 2 miles downstream; 4) Snyder Creek from 

the confluence of Snyder and Honey Creeks upstream for about 3 miles; and 5) Honey Creek from the confluence 

of Hart Lake upstream 16 miles. 

The Warner sucker is threatened by human-induced stream channel and watershed degradation; irrigation 

diversion practices that block its spawning migration routes and reduce stream flows below the points of 

diversion; and predation by and competition with non-native game fish such as crappie, bullhead catfish, and bass 

that were previously stocked in Warner Basin lakes. 

Hutton Tui Chub 

The following information, taken from Moyle (1976), refers to tui chubs in general. Tui chubs occur in a wide 

variety of habitats, most commonly in the weedy shallows of lakes and quiet waters in sluggish rivers. They do 

well in a wide variety of water conditions from warm to cold, and clear to eutrophic. In the fall, they seek out 

deeper water and may spend winters in a semi-dormant state on the bottom of lakes. Tui chubs are opportunistic 

omnivores concentrating on invertebrates associated with bottom or aquatic plants (i.e., clams, insect larvae, 

insects, crayfish), as well as algae and plant material. 

Tui chub usually spawn from late April to late June; eggs adhere to plants or the bottom and hatch in 9 days. In 

large deep lakes, they tend to form large schools in shallow water frequently associated with beds of aquatic 

vegetation. In shallow lakes, with heavy aquatic growth, schooling is less noticeable. Tui chubs tend to disperse 

amongst the vegetation, presumably as protection from predators. They also appear to be able to adapt to the 

severe long- and short-term climatic fluctuations characteristic of the interior basins where they are most common. 

The minnow family in general has been successful because they have a well-developed sense of hearing, release a 

fear scent when injured (a warning signal to others), have a broad diet, and exhibit high fecundity. Despite these 

advantages, many native minnows are declining in numbers as their environment deteriorates beyond their ability 

to cope with the changes or they are displaced by more aggressive introduced species. 

The Hutton tui chub (Gila bicolor ssp.) is endemic to Hutton Spring and a nearby unnamed spring in Lake County, 

south-central Oregon (NatureServe Explorer 2001). These springs are located in a grassy rangeland bordered to the 

north and west by shrubby rangeland and to the east and south by the lake bed of pluvial Alkali Lake. 

The Hutton tui chub was Federally Listed as threatened on March 28, 1985. Critical habitat has not been 

designated. The current isolation of the Hutton tui chub was caused by the desiccation of pluvial Alkali Lake 

(Snyder 1908a, Hubbs and Miller 1942). Present status is in part a result of past access by cattle to the springs 

in which the Hutton tui chub occurs (Franzreb 1985). Threats include pumping of water from the springs, which 
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occurred in the past but is no longer occurring (Bond 1974, Franzreb 1985), and contamination of groundwater by 

dispersal of chemicals from a nearby herbicide-manufacturing residue disposal site (Franzreb 1985). Modification 

of the springs by heavy equipment (causing siltation, erosion, vegetation cover loss, water diversion and 

drawdown) has also had detrimental effects on the chub population.

Lahontan Cutthroat Trout 

The primary reference for this section is: Hudson, B., J. Augsburger, M. Hillis, and P. Boehne. 2000. 

Draft Biological Assessment for the Interior Columbia River Basin Ecosystem Management Project Final 

Environmental Impact Statement. USDI BLM and USDA Forest Service. Boise, Idaho. References cited in this 

section are internal to the above-referenced document. Full citations have been included in the Bibliography. 

The Lahontan cutthroat trout (Oncorhyncus clarki henshawi) in the only trout native to the Lahontan subbasin of 

the American Great Basin, west-central Nevada. Historically, the subspecies was found in the Carson, Humboldt, 

Truckee, and Walker rivers, and in their tributary lakes and streams. Since the late 19th century, fluvial (stream) 

and lacustrine (lake) populations of the Lahontan cutthroat trout have been reduced to approximately 10.7% and 

0.4% of their original habitat, respectively. 

Lahontan cutthroat trout occupy a great variety of habitats, from large rivers and lakes to small tributary streams. 

They are unusually tolerant of both high temperatures (> 81 °F) and large daily fluctuations in temperature (up 

to 68 °F). In addition, they are tolerant of high alkalinity (>3,000 ppm) and dissolved solids (>10,000 ppm). 

However, they are intolerant of competition or predation by non-native salmonids (LaRivers 1962, Trotter 1987, 

Behnke 1992). 

Lahontan cutthroat trout are obligate but opportunistic stream spawners. Typically, they spawn from April 

through July, depending on water temperature and flow characteristics, though autumn spawning runs have also 

been reported for some populations. Fish may spawn more than once, although post-spawning mortality rates of 

60 to 90% have been reported. Lake residents migrate into streams to spawn, typically on well-washed gravels in 

riffles. Adults court, pair, and deposit and fertilize eggs in a spawning bed dug by the female, which may then be 

defended for some period of time. 

The Lahontan cutthroat trout was Federally Listed as threatened on July 16, 1975. Critical habitat has not been 

designated. The observed major decline in this species has been attributed to habitat loss, introgression with 

introduced rainbow trout, and competition with other introduced species of trout, such as brown and brook trout. 

Habitat loss and the negative impacts of non-native fishes continue to be the primary threats to the Lahontan 

cutthroat trout (Coffin and Cowan 1995, Gerstrung 1998).

Coho Salmon 

Historically, coho salmon (Oncorhyncus kisutch) were distributed throughout the North Pacific Ocean, from 

Central California to Point Hope, Alaska, through the Aleutian Islands, and from the Anadyr River, Russia south 

to Hokkaido, Japan. The species probably once inhabited most coastal streams in Washington, Oregon, and 

northern California. Some populations, now considered extinct, are believed to have migrated hundreds of miles 

inland to spawn in tributaries of the upper Columbia River in Washington and the Snake River in Idaho. There are 

six distinct ESUs of coho salmon along the West Coast of the United States, three of which are listed and occur in 

the project area: Central California, Southern Oregon/Northern California Coast, and Oregon Coast. 

Coho salmon are anadromous; adults migrate from a marine environment into the freshwater streams and rivers of 

the birth. The species spawns only once, and then dies. Coho spend approximately the first half of their life cycle 

rearing in streams and small freshwater tributaries. The remainder of their life cycle is spent foraging in estuarine 
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Final Environmental Impact Statement: Appendix 5

and marine waters of the Pacific Ocean, prior to returning to their stream of origin to spawn and die. Most fish 

return to spawn at 3 years old, although some precocious males may do so at 2 years of age. 

Southern Oregon/Northern California Coasts 

The Southern Oregon/Northern California Coasts ESU was Federally Listed as threatened on May 6, 1997. 

This ESU includes all naturally spawned populations occurring in coastal streams between Cape Blanco, 

Oregon, and Punta Gorda, California. Critical habitat (designated on May 5, 1999) includes all accessible 

reaches within this range, with the exception of areas above specific dams or above longstanding, naturally 

impassable barriers. Major river basins containing spawning and rearing habitat for this ESU comprise 

approximately 18,090 square miles in California and Oregon. Counties that lie partially or wholly within 

watersheds inhabited by this ESU include Del Norte, Glenn, Humboldt, Lake, Mendocino, Siskiyou, and 

Trinity counties in California, and Coos, Curry, Douglas, Jackson, Josephine, and Klamath counties in 

Oregon. Counties with critical habitat are Del Norte, Glenn, Humboldt, Lake, Mendocino, Siskiyou, and 

Trinity counties in California, and Curry, Douglas, Jackson, Josephine, and Klamath counties in Oregon; 

BLM-administered lands are also found in these counties. 

Lower Columbia River 

The Lower Columbia River ESU was Federally Listed as threatened on June 28, 2005. This ESU includes all 

naturally spawned populations occurring in the Columbia River and its tributaries in Washington and Oregon, 

from the mouth of the Columbia River up to and including the Big White Salmon and Hood Rivers. This ESU 

also includes the Willamette River to Willamette Falls, Oregon, as well as 25 artificial propagation programs. 

Critical habitat for this ESU is currently under development, and has not yet been proposed for designation.

Foskett Speckled Dace 

The Foskett speckled dace (Rhinichthys osculus ssp.) is endemic to Foskett Spring in south-central Oregon, a 

small spring system in the Coleman Basin on the west side of Warner Valley. Habitat is a small springhole and 

overflow rivulets that occur in what appears to be mixed rangeland at the edge of an alkali playa. The wet areas 

at the spring, along the course of the rivulets, and at the sump on the edge of the playa supports grasses and some 

aquatic vegetation, including cattails. The main population is in the springhole, which is about 6 feet in diameter 

and mostly 6 to 12 inches deep. Individuals also live in tiny outflow rivulets that are at times only a few inches 

wide and deep. Some are found in cattle tracks into which water seeps continuously (Bond 1974). Cover utilized 

includes overhanging bank edges, grass, exposed grass roots, and filamentous algae. Water in the spring is clear, 

and the current is slow. The bottom is primarily mud. The dace has also been introduced into Dace Spring, an 

excavated area at a spring source located on public land about 1 mile south of Foskett Spring. This artificial 

habitat is muddy and well-vegetated (Armantrout 1985). Although individuals have been collected from shallow 

water habitats associated with filamentous algae, exposed grass roots, and emergent aquatic vegetation, this 

habitat is not believed to be optimal. Based on conditions under which other speckled dace live, it is likely that 

deeper water with moderate vegetative cover would be better habitat. 

The Foskett speckled dace appears to feed primarily on invertebrates. Extensive migration is not known, but 

larval and early juvenile dace have been observed only in the marsh at the edge of the lake bed (Hayes 1980), so 

there is either a migration of adults downstream to spawn, or a migration of the hatched larvae from the spring 

hole or rivulets to the marsh (a distance of about 6 to 12 feet). Reproduction apparently occurs in the second year 

of age, and spawning is believed to occur between late May and early July (Hayes 1980). 

The Foskett speckled dace was Federally Listed as threatened on March 28, 1985. Critical habitat has not been 

designated. The subspecies apparently became isolated in Foskett Spring about 9,000 to 10,000 years ago, 

when Lake Warner went dry (Hubbs and Miller 1948a). Its main natural habitat has been overrun by vegetation 

or heavily trampled by cattle. Future perceived threats are essentially the same as the past reasons for decline, 
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although the dace population seems to have stabilized to a point compatible with present use of the area by cattle. 

A spring to which the dace was transplanted by the BLM is fenced to exclude cattle (Armantrout and Bond 1981), 

and the main threat at this site is the encroachment of vegetation (cattails and possible rushes), and the resulting 

decrease in dissolved oxygen. Pumping of groundwater or channelization (via heavy equipment, such as a 

backhoe) at either site could impact the habitat as well (USFWS 1985i). Both springs that contain the dace are in 

a known geothermal area, so there is also a potential future threat of energy development. 

Bull Trout 

The primary references for this section are: USFWS. 1999h. Determination of Threatened Status for Bull Trout 

in the Coterminous United States Final Rule. Federal Register 64(210):58909-58933; Federal Register/Vol. 

75, No. 9/Thursday, January 14, 2010/2270-2431/Proposed Rules; and, USFWS Biological Opinion and Letter 

of Concurrence USDA Forest Service, USDI Bureau of Land Management and the Coquille Indian Tribe for 

Programmatic Aquatic Habitat Restoration Activities in Oregon and Washington That Affect ESA-listed Fish, 

Wildlife, and Plant Species and their Critical Habitats, June 14, 2007. References cited in this section are internal 

to these documents. 

Bull trout (Salvelinus confluentus) are native to the Pacific Northwest and western Canada. They historically 

occurred in major river drainages in the Pacific Northwest, from the southern limits in the McCloud River in 

northern California and the Jarbidge River in Nevada, north to the headwaters of the Yukon River in Northwest 

Territories, Canada (Cavender 1978, Bond 1992). To the west, the range of the bull trout includes the Puget Sound, 

and various coastal rivers of Washington, British Columbia, Canada, and southeast Alaska (Bond 1992, Leary and 

Allendorf 1997). Bull trout are relatively dispersed throughout tributaries of the Columbia River Basin, including its 

headwaters in Montana and Canada. Bull trout also occur in the Klamath River Basin of south-central Oregon. East 

of the Continental Divide, they are found in the headwaters of the Saskatchewan River in Alberta and the MacKenzie 

River system in Alberta and British Columbia (Cavender 1978, Brewin and Brewin 1997). 

Bull trout exhibit both resident and migratory life-history strategies through much of their current range (Rieman 

and McIntyre 1993). Resident bull trout complete their life cycles in the tributary streams in which they spawn 

and rear. Migratory bull trout spawn in tributary streams, and juvenile fish rear from 1 to 4 years before migrating 

to either a lake (adfluvial), river (fluvial), or in certain coastal areas, saltwater (anadromous), to mature (Fraley 

and Shepard 1989, Goetz 1989). Anadromy is the least studied life-history stage in bull trout, and some biologists 

believe the existence of true anadromy in bull trout is still uncertain (McPhail and Baxter 1996). Resident 

and migratory forms may be found together, and bull trout may produce offspring exhibiting either resident or 

migratory behavior (Rieman and McIntyre 1993). 

Compared to other salmonids, bull trout have more specific habitat requirements (Rieman and McIntyre 1993) 

that appear to influence their distribution and abundance. Critical parameters include water temperature, cover, 

channel form and stability, valley form, spawning and rearing substrates, and migratory corridors (Oliver 

1979; Pratt 1984, 1992; Fraley and Shepard 1989; Goetz 1989; Hoelscher and Bjornn 1989; Sedell and Everest 

1991; Howell and Buchanan 1992; Rieman and McIntyre 1993, 1995; Rich 1996; Watson and Hillman 1997). 

Watersheds must have specific physical characteristics to provide the necessary habitat requirements for bull trout 

spawning and rearing, although these characteristics are not necessarily ubiquitous throughout watersheds in 

which bull trout occur. Because bull trout exhibit a patchy distribution, even in undisturbed habitats (Rieman and 

McIntyre 1993), fish would not likely occupy all available habitats simultaneously (Rieman et al. 1997). 

Bull trout are typically associated with the colder streams in a river system, although fish can occur throughout 

larger river systems (Fraley and Shepard 1989; Rieman and McIntyre 1993, 1995; Buchanan and Gregory 1997; 

Rieman et al. 1997). Spawning areas are often associated with cold-water springs, groundwater infiltration, and 
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Final Environmental Impact Statement: Appendix 5

the coldest streams in a given watershed (Pratt 1992; Rieman and McIntyre 1993; Rieman et al. 1997). All life 

history stages of bull trout are associated with complex forms of cover, including large woody debris, undercut 

banks, boulders, and pools (Oliver 1979, Fraley and Shepard 1989, Goetz 1989, Hoelscher and Bjornn 1989, 

Sedell and Everest 1991, Pratt 1992, Thomas 1992, Rich 1996, Sexauer and James 1997, Watson and Hillman 

1997). Maintaining bull trout populations requires stream channel and flow stability (Rieman and McIntyre 

1993). Juvenile and adult bull trout frequently inhabit side channels, stream margins, and pools with suitable 

cover (Sexauer and James 1997). These areas are sensitive to activities that directly or indirectly affect stream 

channel stability and alter natural flow patterns. 

Preferred spawning habitat generally consists of low gradient stream reaches, which are often found in high 

gradient streams that have loose, clean gravel (Fraley and Shepard 1989) and water temperatures of 41 to 48 °F 

in late summer to early fall (Goetz 1989). The size and age of maturity for bull trout is variable depending upon 

life-history strategy. Growth of resident fish is generally slower than that of migratory fish; resident fish tend to 

be smaller at maturity and less fecund (productive; Fraley and Shepard 1989, Goetz 1989). Bull trout normally 

reach sexual maturity in 4 to 7 years, and can live 12 or more years. Biologists report repeat and alternate year 

spawning, although repeat spawning frequency and post-spawning mortality are not well known (Leathe and 

Graham 1982, Fraley and Shepard 1989, Pratt 1992, Rieman and McIntyre 1996). Bull trout typically spawn from 

August to November during periods of decreasing water temperatures. However, migratory bull trout may begin 

spawning migrations as early as April, and move upstream as far as 155 miles to spawning grounds in some areas 

of their range (Fraley and Shepard 1989, Swanberg 1997). Depending on the water temperature, egg incubation is 

normally 100 to 145 days (Pratt 1992), and juveniles remain in the substrate after hatching. Fry normally emerge 

from early April through May, depending on water temperatures and increasing stream flows (Pratt 1992, Ratliff 

and Howell 1992). 

Bull trout are opportunistic feeders, with food habits primarily a function of size and life-history strategy. 

Resident and juvenile bull trout prey on terrestrial and aquatic insects, macro-zooplankton, amphipods, mysids, 

crayfish, and small fish (Wyman 1975, Rieman and Lukens 1979 cited in Rieman and McIntyre 1993, Boag 

1987, Goetz 1989, Donald and Alger 1993). Adult migratory bull trout are primarily piscivorous, known to feed 

on various trout and salmon species, whitefish, yellow perch and sculpin (Fraley and Shepard 1989, Donald and 

Alger 1993). 

The bull trout was Federally Listed as threatened throughout its entire range in the coterminous United States 

on November 1, 1999. On October 6, 2004, approximately 1,748 miles of streams and 61,235 acres of lakes 

and reservoirs in Oregon, Washington, and Idaho were designated as critical habitat for the Klamath River and 

Columbia River populations of bull trout. However, the USFWS is currently re-evaluating this designation. The 

decline of bull trout is primarily attributable to habitat degradation and fragmentation, blockage of migratory 

corridors, poor water quality, past fisheries management practices, and the introduction of non-native species. 

On January 14, 2010 the USFWS issued a proposed rule to revise the designation of critical habitat for the bull 

trout with a final decision to be submitted to the Federal Register by September 30, 2010. This proposed revision 

identifies additional streams, rivers, lakes, reservoirs, and near shore areas as critical habitat in Oregon, Idaho, 

Washington, Montana, and Nevada. In addition to implementing SOPs and mitigation measures identified in this 

EIS, and in the absence of additional site-specific analysis or consultation, the BLM in Oregon will continue to 

follow applicable project design criteria as identified in the USFWS Biological Opinion and Letter of Concurrence 

for the Programmatic Aquatic Habitat Restoration Activities in Oregon and Washington That Affect ESA-listed 

Fish, Wildlife, and Plant Species and their Critical Habitats. The BLM is Conferencing with the Service on this 

proposed rule as per section 7(a)4 of the Act with documentation to be provided as part of the Service’s letter of 

concurrence for the proposed action.
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Pacific Eulachon 

The primary references for this section area: Federal Register/Vol. 75, No. 52/Thursday, March 18, 2010/13012-

13024; and, NMFS Endangered Species Act – Section 7 Programmatic Consultation Biological Opinon and 

Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation, June 27, 2008.

On March 18, 2010 the National Marine Fisheries Service (NMFS) issued a final determination to list the southern 

Distinct Population Segment (DPS) of the Pacific eulachon (Thaleichthys pacificus) as a threatened species 

under the Endangered Species Act of 1973, as amended (6). NMFS intends to consider protective regulations 

and critical habitat for this DPS in separate rule making to occur at a later date. In the absence of finer scale 

distribution maps, it is assumed that the eulachon occurs in Oregon within the Salem District (eg. Sandy River) 

and may also occur on the Eugene and Coos Bay Districts. The most significant threat to eulachon identified by 

NMFS are changes in ocean conditions due to climate change followed by a moderate threat associated with 

climate-induced change to freshwater habitats (6). Since there are no anticipated contributions to climate change 

which would result from implementing any of the alternatives analyzed in the Oregon EIS (FEIS 162), there are 

not likely to be any adverse affects to eulachon or their ocean and freshwater habitats. In addition to Conservation 

Measures identified in the NMFS PEIS Biological Opinion for anadromous fish, and in the absence of additional 

site-specific analysis or consultation, Oregon will continue to follow applicable project design criteria as 

identified in the NMFS Endangered Species Act-Section 7 Programmatic Consultation Biological Opinion and 

Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation (7). ESA 

Consultation is ongoing with NMFS and any applicable direction concerning the eulachon will be addressed in the 

forthcoming biological opinion. 

Conservation Measures for Aquatic Animals

Many local BLM offices already have management plans in place that ensure the protection of these species, 

and have completed formal or informal consultations on similar treatment activities. These consultations have 

identified protection zones alongside aquatic habitats that support these species. The conservation measures 

discussed below are probable steps required of the BLM to ensure that vegetation treatments would minimize 

impacts to TEP species. These conservation measures are intended as broad guidance at the programmatic 

level; further analysis of treatment programs and species habitats at the local level is required to better reduce 

potential impacts from proposed vegetation treatments. Completion of consultation at the local level will fine-tune 

conservation measures associated with treatment activities and ensure consistency of the treatments with ESA

requirements. 

The aquatic TEP species considered in this programmatic BA occur in varied habitats, over a large geographic 

area. The conservation measures guidance presented below is intended to apply broadly to aquatic species and 

habitats over the entire region covered by this BA, based on the common features found in nearly all aquatic and 

riparian habitats. Some species with alternate or unusual habitat requirements may require additional conservation 

measures to ensure a Not Likely to Adversely Affect determination at the local level. Such additional conservation 

measure are outside the scope of this BA, and will be completed at the local level. 

Some local BLM plans have delineated protected riparian areas, or portions of watersheds where ripariandependent resources receive primary emphasis, and management activities are subject to specific standards and 

guidelines (USDA Forest Service 1995). These protected riparian areas include traditional riparian corridors, 

wetlands, intermittent streams, and other areas that help maintain the integrity of aquatic ecosystems by 1) 

influencing the delivery of coarse sediment, organic matter, and woody debris to streams; 2) providing root 

strength for channel stability; 3) shading the stream; and 4) protecting water quality. Examples of protected 
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Final Environmental Impact Statement: Appendix 5

riparian areas are the BLM’s Riparian Reserves of the Pacific Northwest and the Interior Columbia Basin, as 

described in the Aquatic Conservation Strategy (USDA Forest Service and USDI BLM 1994). The term “riparian 

areas,” as used in the conservation measures guidance below, refers to riparian protected areas, wherever such 

designations apply. However, since not all local BLM plans have made such designations, “riparian areas,” when 

the above-mentioned use is not applicable, generally refers to: 1) for streams, the stream channel and the extent 

of the 100-year floodplain; and 2) for wetlands, ponds, and lakes, and other aquatic habitats, the area extending 

to the edges of the riparian vegetation, provided it is no less than the minimum buffer distance for a given site 

established by local BLM biologists. 

Conservation Measures for Site Access and Fueling/Equipment Maintenance 

For treatments occurring in watersheds with TEP species or designated or undesignated critical habitat (i.e., 

unoccupied habitat critical to species recovery): 

• Where feasible, access work site only on existing roads, and limit all travel on roads when damage to the 

road surface will result or is occurring. 

• Where TEP aquatic species occur, consider ground-disturbing activities on a case by case basis, and 

implement Standard Operating Procedures to ensure minimal erosion or impact to the aquatic habitat. 

• Within riparian areas, do not use vehicle equipment off of established roads. 

• Outside of riparian areas, allow driving off of established roads only on slopes of 20% or less. 

• Except in emergencies, land helicopters outside of riparian areas. 

• Within 150 feet of wetlands or riparian areas, do not fuel/refuel equipment, store fuel, or perform 

equipment maintenance (locate all fueling and fuel storage areas, as well as service landings outside of 

protected riparian areas). 

• Prior to helicopter fueling operations prepare a transportation, storage, and emergency spill plan and 

obtain the appropriate approvals; for other heavy equipment fueling operations use a slip-tank not greater 

than 250 gallons; Prepare spill containment and cleanup provisions for maintenance operations. 

• Do not conduct biomass removal (harvest) activities that will alter the timing, magnitude, duration, and 

spatial distribution of peak, high, and low flows outside the range of natural variability. 

Conservation Measures Related to Revegetation Treatments 

• Outside riparian areas, avoid hydro-mulching within buffer zones established at the local level. This 

precaution will limit adding sediments and nutrients and increasing water turbidity. 

• Within riparian areas, engage in consultation at the local level to ensure that revegetation activities 

incorporate knowledge of site-specific conditions and project design. 

Conservation Measures Related to Herbicide Treatments 

The complexity of this action within riparian areas requires local consultation, which will be based on herbicide 

risk assessments. 

Possible Conservation Measures: 

• Maintain equipment used for transportation, storage, or application of chemicals in a leak proof condition. 

• Do not store or mix herbicides, or conduct post-application cleaning within riparian areas. 

• Ensure that trained personnel monitor weather conditions at spray times during application. 

• Strictly enforce all herbicide labels. 

• Do not broadcast spray within 100 feet of open water when wind velocity exceeds 5 mph. 

• Do not broadcast spray when wind velocity exceeds 10 mph. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

• Do not spray if precipitation is occurring or is imminent (within 24 hours). 

• Do not spray if air turbulence is sufficient to affect the normal spray pattern. 

• Do not broadcast spray herbicides in riparian areas that provide habitat for TEP aquatic species. 

Appropriate buffer distances should be determined at the local level to ensure that overhanging vegetation 

that provides habitat for TEP species is not removed from the site. Buffer distances provided as 

conservation measures in the assessment of effects to plants (Chapter 4 of this BA) and fish and aquatic 

invertebrates should be consulted as guidance (Table A2-3). (Note: the Forest Service did not determine 

appropriate buffer distances for TEP fish and aquatic invertebrates when evaluating herbicides in Forest 

Service ERAs; buffer distances were only determined for non-TEP species.) 

• Do not use diquat, fluridone, terrestrial formulations of glyphosate, or triclopyr BEE, to treat aquatic 

vegetation in habitats where aquatic TEP species occur or may potentially occur. 

• Avoid using glyphosate formulations that include R-11 in the future, and either avoid using any 

formulations with POEA, or seek to use the formulation with the lowest amount of POEA available, to 

reduce risks to aquatic organisms. 

• Follow all instructions and Standard Operating Procedures to avoid spill and direct spray scenarios 

into aquatic habitats. Special care should be followed when transporting and applying 2,4-D, bromacil, 

clopyralid, diuron, glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, tebuthiuron, and 

triclopyr. 

• Do not broadcast spray diuron, glyphosate, picloram, or triclopyr BEE in upland habitats adjacent to 

aquatic habitats that support (or may potentially support) aquatic TEP species under conditions that would 

likely result in off-site drift. 

• In watersheds that support TEP species or their habitat, do not apply bromacil, diuron, tebuthiuron, or 

triclopyr BEE in upland habitats within 1⁄2 mile upslope of aquatic habitats that support aquatic TEP 

species under conditions that would likely result in surface runoff. 

Numerous conservation measures were developed from information provided in ERAs. The measures listed 

below would apply to TEP fish and other aquatic species at the programmatic level in all 17 western states. 

However, local BLM field offices could use interactive spreadsheets and other information contained in the ERAs 

to develop more site-specific conservation measures and management plans based on local conditions (soil type, 

rainfall, vegetation type, and herbicide treatment method). It is possible that conservation measures would be less 

restrictive than those listed below if local site conditions were evaluated using the ERAs when developing projectlevel conservation measures. 

Conservation Measures Related to Non-herbicide Treatments 

Conservation Measures Related to Prescribed Fire 

Within riparian areas, in watersheds with TEP species or their habitats: 

• Conduct prescribed burning only when long-term maintenance of the riparian area is the primary 

objective, and where low intensity fires can be maintained. 

• Do not construct black lines, except by non-mechanized methods. 

• Utilize/create only the following firelines: natural barriers; hand-built lines parallel to the stream channel 

and outside of buffer zones established at the local level; or hand built lines perpendicular to the stream 

channel with waterbars and the same distance requirement. 

• Do not ignite fires using aerial methods. 

• In forested riparian areas, keep fires to low severity levels to ensure that excessive vegetation removal 

does not occur. 

• Do not camp, unless allowed by local consultation. 
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Final Environmental Impact Statement: Appendix 5

• Have a fisheries biologist determine whether pumping activity can occur in streams with TEP species. 

• During water drafting/pumping, maintain a continuous surface flow of the stream that does not alter 

original wetted stream width. 

• Do not alter dams or channels in order to pump in streams occupied by TEP species. 

• Do not allow helicopter dipping from waters occupied by TEP species, except in lakes outside of the 

spawning period. 

• Consult with a local fisheries biologist prior to helicopter dipping in order to avoid entrainment and 

harassment of TEP species. 

Conservation Measures Related to Mechanical Treatments 

Note: these measures apply only to treatments occurring in watersheds that support TEP species or in unoccupied 

habitat critical to species recovery (including but not limited to critical habitat, as designated by USFWS). 

Outside riparian areas in watersheds with TEP species or designated or undesignated critical habitat (i.e., 

unoccupied habitat critical to species recovery): 

• Conduct soil-disturbing treatments only on slopes of 20% or less, where feasible. 

• Do not conduct log hauling activities on native surface roads prone to erosion, where feasible. 

Within riparian areas in these watersheds, more protective measures will be required to avoid negatively affecting 

TEP species or their habitat: 

• Do not use vehicles or heavy equipment, except when crossing at established crossings. 

• Do not remove large woody debris or snags during mechanical treatment activities. 

• Do not conduct ground disturbing activities (e.g., disking, drilling, chaining, and plowing). 

• Ensure that all mowing follows guidance to avoid negative effects to streambanks and riparian vegetation 

and major effects to streamside shade. 

• Do not use equipment in perennial channels or in intermittent channels with water, except at crossings 

that already exist. 

• Leave suitable quantities (to be determined at the local level) of excess vegetation and slash on site. 

• Do not apply fertilizers or seed mixtures that contain chemicals by aerial methods. 

• Do not apply fertilizer within 25 feet of streams and supersaturated soils; apply fertilizer following 

labeling instructions. 

• Do not apply fertilizer in desert habitats. 

• Do not completely remove trees and shrubs. 

Conservation Measures Related to Biological Control Treatments using Livestock 

For treatments occurring in watersheds that support TEP species or in critical habitat: 

• Where terrain permits, locate stock handling facilities, camp facilities, and improvements at least 300 feet 

from lakes, streams, and springs. 

• Educate stock handlers about at-risk fish species and how to minimize negative effects to the species and 

their associated habitat. 

• Employ appropriate dispersion techniques to range management, including judicial placement of 

saltblocks, troughs, and fencing, to prevent damage to riparian areas but increase weed control. 

• Equip each watering trough with a float valve. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Within riparian areas of these watersheds, more protective measures are required. 

• Do not conduct weed treatments involving domestic animals, except where it is determined that these treatments 

will not damage the riparian system, or will provide long-term benefits to riparian and adjacent aquatic habitats. 

• Do not locate troughs, storage tanks, or guzzlers near streams with TEP species, unless their placement 

will enhance weed-control effectiveness without damaging the riparian system. 

Local BLM offices should design conservation measures for treatment plans using the above conservation 

measures as guidance, but altering it as needed based on local conditions and the habitat needs of the particular 

TEP aquatic species that could be affected by the treatments. Locally-focused conservation measures would be 

necessary to reduce or avoid potential impacts such that a Not Likely to Adversely Affect determination would 

be reached during the local-level NEPA process. BLM offices that are responsible for the protection of Northwest 

salmonids are directed to the guidance document: Criteria for At-Risk Salmonids: National Fire Plan Activities, 

Version 2.1 (National Fire Plan Technical Team 2002), which contains detailed instructions for developing 

suitable conservation measures for these TEP species in conjunction with vegetation treatment programs, and 

from which many of the above-listed conservation measures were taken.

Invertebrates

Endangered

Fender’s Blue Butterfly 

The primary reference for this section is: USFWS. 2000i. Endangered Status for Erigeron decumbens var. 

decumbens (Willamette Daisy) and Plebejus icarioides fenderi (Fender’s Blue Butterfly) and Threatened Status 

for Lupinus sulphureus ssp. kincaidii (Kincaid’s Lupine). Federal Register 65(16):3875-3890. 

The Fender’s blue butterfly (Plebejus icarioides fenderi) is endemic to upland prairies of the Willamette Valley in 

Oregon. Although the precise historic distribution of this subspecies is unknown, recent surveys have indicated 

that the insect is confined to the Willamette Valley and currently occupies 32 sites in Yamhill, Polk, Benton, 

and Lane counties (Hammond and Wilson 1993, Schultz 1996). One population is found in wet, hairgrasstype prairie, while the remaining sites are found on drier upland prairies characterized by fescue. Fender’s 

blue butterflies occupy sites located almost exclusively on the western side of the valley, within 21 miles of the 

Willamette River. 

The primary habitat requirement for the fender’s blue is its host plant, Kincaid’s lupine, which is the larval food 

source. Of the 32 sites where Fender’s blue butterfly occurs, Kincaid’s lupine co-occurs as a larval host plant 

at 27. Spurred lupine and sickle keeled lupine may be secondary food plants used by the insect (Hammond and 

Wilson 1993). 

It is thought that the life cycle of Fender’s blue is similar those of related subspecies (Hammond and Wilson 

1993, Mattoni 1997, Pratt 1997). Adult butterflies lay their eggs on the host plant, which serves as a food source 

for the caterpillars during May and June. Newly hatched larvae feed for a short time, reaching their second 

developmental stage in the early summer, at which point they enter an extended diapause (maintaining a state of 

suspended activity). Diapausing larvae remain in the leaf litter at or near the base of the host plant through the fall 

and winter, and may become active again in March or April of the following year. Some larvae may be able to 

extend diapause for more than one season depending upon the individual and environmental conditions (Mattoni 

1997). Once diapause is broken, the larvae feed and grow through three to four additional developmental stages, 

enter their pupal stage, and then emerge as adult butterflies in April and May. A Fender’s blue butterfly may 

complete its life cycle in 1 year. 
511

Final Environmental Impact Statement: Appendix 5

References cited in this section are internal to the above referenced document. A complete list of these references 

is available from the USFWS Oregon State Office, Portland, Oregon. 

The Fender’s blue was Federally Listed as endangered on January 25, 2000. The designation of critical habitat 

for this species was deemed prudent, but has been deferred. The primary threats are habitat loss from agriculture 

and urban development, the invasion of non-native plant species into prairie habitat, and the small size of the 

remaining populations. Herbicide use and collecting are also factors that can impact this subspecies.

Threatened

Vernal Pool Fairy Shrimp

The primary reference for this section is: USFWS. 1994e. Endangered and Threatened Wildlife and Plants; 

Determination of Endangered Status for the Conservancy Fairy Shrimp, Longhorn Fairy Shrimp, and the Vernal 

Pool Tadpole Shrimp; and Threatened Status for the Vernal Pool Fairy Shrimp. Final Rule. Federal Register 

59(180):48136-48153. References cited in this section are internal to the above-referenced document. A 

complete list of these references is available from the USFWS Sacramento Field Office, Sacramento, California. 

The Conservancy fairy shrimp (Branchinecta conservatio), longhorn fairy shrimp (B. longiantenna), vernal pool 

fairy shrimp (B. lynchi), and vernal pool tadpole shrimp (Lepidurus packardi) are aquatic crustaceans that are 

endemic to vernal pools in California. The vernal pools in which these species occur are found in the Central 

Valley, the Coast Range, and a limited number of sites in the Transverse Range and Santa Rosa Plateau. All four 

species are sporadic in their distribution, often inhabiting only one or a few pools in vernal pool complexes that 

are quite widespread (Eng 1990, King 1992, Simovich 1992; Brusca 1992). None are known to occur in riverine 

waters, marine waters, or other permanent bodies of water. 

The three fairy shrimp and the vernal pool tadpole shrimp are ecologically dependent on seasonal fluctuations 

in their habitat, such as absence or presence of water during specific times of the year, duration of inundation, 

and other environmental factors that include specific salinity, conductivity, dissolved solids, and pH levels. 

The Conservancy fairy shrimp inhabits vernal pools with highly turbid waters. It is known from six disjunct 

populations, occurring in large pools with low conductivity, total dissolved solids, and alkalinity (Barclay and 

Knight 1984; Eng et al. 1990). The Conservancy fairy shrimp is usually collected at cool temperatures and 

appears to be relatively long-lived (Patton 1984; Simovich et al. 1992). This species has been observed from 

November to early April. 

The longhorn fairy shrimp inhabits clear to turbid, grass-bottomed vernal pools in grasslands, and clear-water 

pools in sandstone depressions. The water in grassland pools inhabited by this species has very low conductivity, 

total dissolved solids, and alkalinity (Eng et al. 1990). This species is only known from four disjunct populations 

along the eastern margin of the central coast range. All vernal pools inhabited by this species are filled by winter 

and spring rains, and may remain inundated until June. The longhorn fairy shrimp has been observed from late 

December until late April. 

The vernal pool fairy shrimp, although it has a relatively wide range, primarily occurs in vernal pools with clear 

to tea-colored water, most commonly in grass- or mud-bottomed swales, or in basalt flow depression pools in 

unplowed grasslands. However, one population occurs in sandstone rock outcrops, and another population occurs 

in alkaline vernal pools. The water in pools inhabited by this species has low total dissolved solids, conductivity, 

alkalinity, and chloride (Collie and Lathrop 1976). Vernal pool fairy shrimp have been collected from early 

December to early May. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The vernal pool fairy shrimp has a sporadic distribution within vernal pool complexes (Patton 1984; County 

of Sacramento 1990; Jones and Stokes 1992, 1993; Stromberg 1993; Sugnet and Associates 1993b), wherein 

the majority of pools in a given complex are not inhabited by the species. The species is typically found at low 

population densities (Simovich et al. 1992), and only rarely does it co-occur with other fairy shrimp species. 

Although the vernal pool fairy shrimp can mature quickly, allowing populations to persist in shorter-lived pools, it 

also persists later into the spring where pools are longer lasting. 

The vernal pool tadpole shrimp inhabits vernal pools containing clear to highly turbid water, and ranging in size 

from 54 square feet to 89 acres. Pools have low conductivity, alkalinity, and total dissolved solids (Barclay and 

Knight 1984; Eng et al. 1990). These pools are located most commonly in grass-bottomed swales of grasslands in 

old alluvial soils underlain by hardpan, or in mud-bottomed pools containing highly turbid water. The vernal pool 

tadpole shrimp is known from 18 populations in the Central Valley, and from a single pool complex located on the 

San Francisco Bay National Wildlife Refuge in the city of Fremont, Alameda County, California. 

The life history of the vernal pool tadpole shrimp is linked to the phenology of the vernal pool habitat. After 

winter rainwater fills the pools, the populations are re-established from eggs that have been dormant in the dry 

pool sediments (Ahl 1991, Lanway 1974). Eggs hatch shortly after inundation, with sexually reproductive 

adults appearing in about 3 to 4 weeks after hatching (Ahl 1991). A female surviving to large size may lay up 

to six clutches of eggs, which are sticky, and readily adhere to plant matter and sediment particles (Simovich et 

al. 1992). A portion of the eggs hatch immediately, and the rest become dormant and remain in the soil to hatch 

during later rainy seasons (Ahl 1991). The vernal pool tadpole shrimp matures slowly and is a long-lived species 

(Alexander 1976, Ahl 1991). Adults are often present and reproductive until the pools dry up in the spring (Ahl 

1991, Simovich 1992). 

Nearly all fairy shrimp feed on algae, bacteria, protozoa, rotifers, and bits of detritus (Pennak 1989). The females 

carry eggs in an oval or elongate ventral brood sac. The eggs are either dropped to the pool bottom or remain 

in the brood sac until the female dies and sinks. The “resting” or “summer” eggs are capable of withstanding 

heat, cold, and prolonged desiccation. When the pools refill in the same or subsequent seasons some, but not all, 

of the eggs may hatch. The egg bank in the soil may be comprised of the eggs from several years of breeding 

(Donald 1983). The eggs hatch when the vernal pools fill with rainwater. The early stages of the fairy shrimp 

develop rapidly into adults. These non-dormant populations often disappear early in the season long before the 

vernal pools dry up. Tadpole shrimp are primarily benthic animals that swim with their legs down. They climb or 

scramble over objects, as well as plow along in bottom sediments, and their diet consists of organic detritus and 

living organisms, such as fairy shrimp and other invertebrates (Fryer 1987, Pennak 1989). Female tadpole shrimp 

deposit their eggs on vegetation and other objects on the bottom. Vernal pool tadpole shrimp populations pass the 

dry summer months as dormant eggs in pool sediments. Some of the eggs hatch as the vernal pools are filled with 

rainwater in the fall and winter of subsequent seasons. 

The Conservancy fairy shrimp, longhorn fairy shrimp, and vernal pool tadpole shrimp were listed as endangered 

on September 19, 1994. The vernal pool fairy shrimp was listed as threatened on the same date. On August 6, 

2003, the USFWS designated approximately 1,184,513 acres of vernal pool habitat as critical habitat for these 

and other vernal pool species. Urban, water, flood control, highway, and utility projects, as well as conversion 

to agricultural use, have eliminated vernal pools in southern California (Riverside and San Diego counties), the 

Central Valley, and the San Francisco Bay area (Jones and Stokes Associates 1987). Factors that threaten these 

species include changes in hydrologic patterns, overgrazing, OHV use, and any human activities that alter the 

watershed of the vernal pools. For some species, continued development could destroy existing habitat.

See Conservation Measures for Aquatic Animals in the Fish section of this appendix for Vernal Pool Fairy Shrimp 

Conservation Measures.
513

Final Environmental Impact Statement: Appendix 5

Oregon Silverspot Butterfly 

The primary reference for this section is: USFWS. 2001h. Oregon Silverspot Butterfly (Speyeria zerene 

hippolyta) Revised Recovery Plan. Portland, Oregon. References cited in this section are internal to the abovereferenced document. Full citations have been included in the Bibliography. 

The Oregon silverspot butterfly (Speyeria zerene hippolyta) occurs at disjunct sites near the Pacific coast, from 

Del Norte County, California, north to Long Beach Peninsula, Washington. The subspecies occupies three types 

of grassland habitat: marine terrace and coastal “salt spray” meadows, stabilized dunes, and montane grasslands. 

The first two habitats are strongly influenced by proximity to the ocean, with mild temperatures, high rainfall, 

and persistent fog. Of the two, the dune habitat tends to have lower relief, highly porous soils, and less exposure 

to winds. Conditions at the montane sites include colder temperatures, frequent cloud cover, substantial snow 

accumulations, less coastal fog, and no salt spray. 

Oregon silverspot butterfly populations currently (as of 2001) are known to occur at only six sites. One is in 

Del Norte County (Lake Earl), two are in Lane County (Rock Creek-Big Creek and Bray Point), and two are in 

Tillamook County (Cascade Head and Mount Hebo). The population at a sixth site in Clatsop County (Clatsop 

Plains) has declined in recent surveys, with only one Oregon silverspot butterfly documented in 1998 (VanBuskirk 

1993, 1998). 

Each type of habitat must provide the Oregon silverspot with host plants, nectar sources, and other suitable 

environmental conditions. Caterpillars feed primarily on early blue violets. Stands of violets that are large 

enough to provide enough food for larval butterflies on the Oregon coast occur only in relatively open and lowgrowing grasslands, where violets may be an abundant component of the plant community (Hammond and 

McCorkle 1984). Apart from early blue violets, Oregon silverspot caterpillars are also known to feed on a few 

other violet species, such as yellow stream violets and Aleutian violets. Nectar plants most frequently used by 

Oregon silverspot butterflies are members of the aster family, including the following native species: Canada 

goldenrod, dune goldenrod, California aster, pearly everlasting, dune thistle, and yarrow. They are also known 

to nectar on two common introduced species: tansy ragwort and false dandelion. The flowering seasons of these 

species overlap, providing an array of nectar choices for adult butterflies throughout the flight season. 

The Oregon silverspot butterfly goes through six larval instars and a pupal stage before metamorphosing into an 

adult. Newly hatched first-instar larvae immediately enter diapause after eating the lining of the eggshell. They 

remain in diapause until host plants send up new growth in spring, and feed until pupation in the summer. Very little 

is known about the biology of the caterpillar or pupae. Adult emergence starts in July and extends into September, 

with many males appearing several weeks before females appear. Mating usually takes place in relatively sheltered 

areas. Adults will often move long distances for nectar or to escape windy and foggy conditions. 

The Oregon silverspot butterfly was Federally Listed as threatened on July 2, 1980, and critical habitat was 

designated at the same time. Lands included in the critical habitat designation are those that were known to be 

occupied by the butterfly at the time: portions of Section 15 and the south half of Section 10 that are west of a 

line parallel to and about 1,500 feet west of the eastern section boundaries of Sections 10 and 15, Township 16 

South, Range 12 West, Lane County, Oregon. Invasion by exotic species, natural succession, fire suppression, 

and land development have resulted in the loss and modification of the species’ habitat. Land use practices have 

altered disturbance regimes needed to maintain existing habitats and create new habitats for species expansion. 

Other threats to the subspecies include OHVs, grazing, erosion, road kill, and pesticides. The Oregon silverspot 

butterfly is also sought by collectors.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Conservation Measures for Butterflies

Many local BLM offices already have management plans in place that ensure the protection of these species 

during activities on public lands. The following conservation measures are the minimum steps required of the 

BLM to ensure that treatment methods would be unlikely to negatively affect TEP species. 

Each local BLM office is required to draw up management plans related to treatment activities that identify any 

TEP butterfly or moth species or their critical habitat that are present in the proposed treatment areas, as well as 

the measures that will be taken to protect these species. 

Management plans should, at a minimum, follow this general guidance: 

• Use an integrated pest management approach when designing programs for managing pest outbreaks. 

• Survey treatment areas for TEP butterflies/moths and their host/nectar plants (suitable habitat) at the 

appropriate times of year. 

• Minimize the disturbance area with a pre-treatment survey to determine the best access routes. Areas with 

butterfly/moth host plants and/or nectar plants should be avoided. 

• Minimize mechanical treatments and OHV activities on sites that support host and/or nectar plants. 

• Carry out vegetation removal in small areas, creating openings of 5 acres or less in size. 

• Avoid burning all of a species’ habitat in any 1 year. Limit area burned in butterfly/moth habitat in such 

a manner that the unburned units are of sufficient size to provide a refuge for the population until the 

burned unit is suitable for recolonization. Burn only a small portion of the habitat at any one time, and 

stagger timing so that there is a minimum 2-year recovery period before an adjacent parcel is burned. 

• Where feasible, mow or wet around patches of larval host plants within the burn unit to reduce impacts to 

larvae. 

• In TEP butterfly/moth habitat, burn while butterflies and/or moths of concern are in the larval stage, when 

the organisms would receive some thermal protection. 

• Wash equipment before it is brought into the treatment area. 

• Use a seed mix that contains host and/or nectar plant seeds for road/site reclamation. 

• To protect host and nectar plants from herbicide treatments, follow recommended buffer zones and other 

conservation measures for TEP plants species when conducting herbicide treatments in areas where 

populations of host and nectar plants occur. 

• Do not broadcast spray herbicides in habitats occupied by TEP butterflies or moths; do not broadcast 

spray herbicides in areas adjacent to TEP butterfly/moth habitat under conditions when spray drift onto 

the habitat is likely. 

• Do not use 2,4-D in TEP butterfly/moth habitat. 

• When conducting herbicide treatments in or near habitat used by TEP butterflies or moths, avoid use of 

the following herbicides, where feasible: bromacil, clopyralid, diquat, diuron, glyphosate, hexazinone, 

imazapyr, picloram, tebuthiuron, and triclopyr. 

• If conducting manual spot applications of diquat, diuron, glyphosate, hexazinone, tebuthiuron, or triclopyr to 

vegetation in TEP butterfly or moth habitat, utilize the typical, rather than the maximum, application rate.

Mammals

Endangered

Gray Wolf 

The primary reference for this section is: USFWS. 2000p. Proposal to Reclassify and Remove the Gray Wolf 

From the List of Endangered and Threatened Wildlife in Portions of the Coterminous United States; Proposal 

To Establish Three Special Regulations for Threatened Gray Wolves; Proposed Rule. Federal Register Volume 
515

Final Environmental Impact Statement: Appendix 5

65(135):43449-43496. References cited in this section are internal to the above-referenced document. A 

complete list of these references is available from the USFWS Region 3 Office, Fort Snelling, Minnesota. 

Gray wolves (Canis lupus) are the largest wild members of the dog family. The species historically occurred 

across most of North America, Europe, and Asia. In North America, wolves occurred from the northern reaches 

of Alaska, Canada, and Greenland to the central mountains and the high interior plateau of southern Mexico. The 

only areas of the contiguous U.S. that apparently lacked gray wolves are much of California and the Gulf and 

Atlantic coastal plain south of Virginia. In addition, wolves were generally absent from the extremely arid deserts 

and the mountaintops of the western United States (Goldman 1944, Hall 1959, Mech 1974). The cultural attitudes 

of European settlers, coupled with perceived and real conflicts between wolves and human activities along the 

frontier, led to widespread persecution of wolves. Poisons, trapping, and shooting―spurred by federal, state, 

and local government bounties―resulted in extirpation of the species from more than 95% of its range in the 48 

coterminous states. 

Wolves are predators of large animals. Wild prey species in North America include white-tailed deer, mule deer, 

moose, elk, woodland caribou, barren ground caribou, bison, muskox, bighorn sheep, Dall sheep, mountain goat, 

beaver, and snowshoe hare, with small mammals, birds and large invertebrates sometimes being taken (Mech 

1974, Stebler 1944, Wisconsin Department of Natural Resources 1999a). Wolves may also feed on domestic 

animals (Paul 1999). Wolves are social animals, normally living in packs of 2 to 10 members. Packs are 

primarily family groups consisting of a breeding pair, their pups from the current year, offspring from the previous 

year, and occasionally an unrelated wolf. Packs occupy, and defend from other packs and individual wolves, a 

territory of 20 to 214 square miles (though typically larger in the Rocky Mountains). Normally, only the topranking male and female in each pack breed and produce pups. Litters are born from early April into May; 

they can range from 1 to 11 pups, but generally contain 4 to 6 pups (USFWS 1992a, Michigan Department of 

Natural Resources 1997). Yearling wolves frequently disperse from their natal packs, although some remain with 

their pack. Dispersers may become nomadic and cover large areas as lone animals, or they may locate suitable 

unoccupied habitat and a member of the opposite sex and begin their own territorial pack. Dispersal movements 

of over 500 miles have been documented (Fritts 1983). 

As many as 24 distinct subspecies of gray wolf have been recognized, and federal listings were originally at the 

subspecies level. On March 9, 1978, the gray wolf was relisted as endangered throughout the conterminous 48 

States and Mexico. In Minnesota, however, the gray wolf was reclassified to threatened. In addition, critical 

habitat was designated in Isle Royale National Park, Michigan, and Minnesota. On November 22, 1994, areas 

in Idaho, Montana, and Wyoming were designated as nonessential experimental populations in order to initiate 

gray wolf reintroduction projects in central Idaho and the Greater Yellowstone area. On January 12, 1998, a 

nonessential experimental population was established for the Mexican gray wolf in portions of Arizona, New 

Mexico, and Texas. 

On July 13, 2000, the USFWS proposed the establishment of four distinct population segments (DPSs) for the 

gray wolf in the United States and Mexico. Under this proposal, gray wolves in the Western Great Lakes DPS 

(North Dakota, South Dakota, Minnesota, Wisconsin, and Michigan), the Western DPS (Washington, Oregon, 

Idaho, Montana, Wyoming, Utah, Colorado, and parts of Arizona and New Mexico), and the Northeastern DPS 

(New York, Vermont, New Hampshire, and Maine) would be reclassified from endangered to threatened, except 

where already classified as an experimental population or as threatened. Gray wolves in the Southwestern 

(Mexican) DPS (portions of Arizona and New Mexico) would retain their endangered status. All three existing 

gray wolf experimental population designations would be retained. In all other areas of the 48 conterminous 

states, gray wolves would be removed from the protections of the ESA. Gray wolf populations in all DPSs, 

except the Southwestern DPS, have shown steady increases from the late 1970s to the present. As of the 

1998/1999 census, there were a total of 22 gray wolves in the Southwestern DPS. Gray wolves are still threatened 

by direct human-caused mortality, and potentially by habitat loss.
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Conservation Measures for the Gray Wolf

Although the proposed vegetation treatments would not be likely to have negative effects on wolves or their 

habitat, the following programmatic-level conservation measures are recommended to ensure protection of the 

species. Additional or more specific guidance would also be provided at the project level, as appropriate. 

• Avoid human disturbance and/or associated activities within 1 mile of a den site during the breeding 

period (as determined by a qualified biologist). 

• Avoid human disturbance and/or associated activities within 1 mile of a rendezvous site during the 

breeding period (as determined by a qualified biologist). 

• Do not use 2,4-D in areas where gray wolves are known to occur; do not broadcast spray within 1⁄4 mile of 

areas where gray wolves are known to occur. 

• Where feasible, avoid use of the following herbicides in gray wolf habitat: bromacil, clopyralid, diquat, 

diuron, glyphosate, hexazinone, imazapyr, metsulfuron methyl, picloram, and triclopyr. 

• Do not broadcast spray clopyralid, diuron, glyphosate, hexazinone, picloram, or triclopyr in gray wolf 

habitat; do not broadcast spray these herbicides in areas adjacent to gray wolf habitat under conditions 

when spray drift onto the habitat is likely. 

◦ If broadcast spraying bromacil, diquat, imazapyr, or metsulfuron methyl in or near gray wolf habitat, 

apply at the typical, rather than the maximum, application rate. 

• If conducting manual spot applications of glyphosate, hexazinone, or triclopyr to vegetation in gray wolf 

habitat, utilize the typical, rather than the maximum, application rate.

Columbian White-tailed Deer 

The primary reference for this section is: USFWS. 2002m. Supplemental Proposed Rule to Remove the Douglas 

County Population of Columbian White-tailed Deer From the Federal List of Endangered and Threatened 

Wildlife. Federal Register 67(120):42217-42229. References cited in this section are internal to the abovereferenced document. A complete list of these references is available from the USFWS, Oregon Fish and Wildlife 

Office, Portland, Oregon. 

The Columbian white-tailed deer (Odocoileus virginianus leucurus) is the westernmost representative of 30 

subspecies of white-tailed deer in North and Central America. The subspecies was formerly distributed throughout 

the bottomlands and prairie woodlands of the lower Columbia, Willamette, and Umpqua River basins in Oregon and 

southern Washington (Bailey 1936, Verts and Carraway 1998). It is believed that this deer was locally common, 

particularly in riparian areas along major rivers (Gavin 1978). With the arrival and settlement of pioneers in 

the fertile river valleys, the decline in Columbian white-tailed deer numbers was rapid (Gavin 1978). By 1940, 

a population of 500 to 700 animals along the lower Columbia River in Oregon and Washington, and a disjunct 

population of 200 to 300 in Douglas County survived (Crews 1939, Gavin 1984, Verts and Carraway 1998). 

Columbian white-tailed deer in Douglas County are most often associated with riparian habitats, though the deer 

also uses a variety of lower elevation habitat types (e.g., grassland, grass shrub, oak savanna, oak-hardwood 

woodland, oak-hardwood savanna shrub, oak-hardwood conifer, conifer, and urban/suburban yards; Ricca 

1999). Open areas are used for feeding between dusk and dawn. The Columbia River population occurs in wet 

bottomlands and dense forest swamps where there is little elevational relief, and which receive a large amount of 

precipitation. The diet of Columbian white-tailed deer consists of forbs, shrubs, grasses, and a variety of other 

foods, such as lichens, mosses, ferns, seeds, and nuts (Whitney 2001). 

Like other types of deer, Columbian white-tailed deer breed in the winter, primarily in November and December. 

Most fawns are born between mid-May and mid-June. Columbian white-tailed deer first breed as yearlings (18 

months), and young females typically give birth to a single fawn. After 2 years of age, twins are more common. 
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The Columbian white-tailed deer was Federally Listed as endangered on March 11, 1967. Protection under the 

Endangered Species Act has resulted in acquisition, protection, and improvement of habitat, which has allowed the 

two populations to increase in size. A recovery plan was developed for the two populations of Columbian whitetailed deer in 1983. Many of the tasks identified in the Recovery Plan have been implemented. In 1972, the Julia 

Butler Hansen Refuge for the Columbian White-tailed Deer was established in Wahkiakum County, Washington.

In Douglas County, the Bureau of Land Management acquired a large parcel of habitat, known as the North 

Bank Habitat Management Area (NBHMA), through a land exchange specifically to benefit the Columbian 

white-tailed deer. This parcel alone provides over 6,000 acres of good habitat for the deer. The USFWS has 

coordinated with the BLM and the Oregon Department of Fish and Wildlife at the NBHMA to accomplish 

recovery of the Columbian white-tailed deer. The acquisition and management of the NBHMA was instrumental 

in the delisting of the Douglas County subpopulation in 2003 (http://www.fws.gov/oregonfwo/species/data/

columbianwhitetaileddeer/). 

Numbers of white-tailed deer have more than doubled since the species was first listed. The Douglas County 

subpopulation is now estimated at over 5,000 animals, and the Columbia River subpopulation is estimated at 

approximately 1,000 animals. This species is primarily threatened by a lack of suitable habitat. Logging has 

degraded forest habitat in some areas. In addition, periodic flooding of the Columbia River, and residential 

development along the North Umpqua River are also threats to the subspecies. 

Conservation Measures for the Columbian white-tailed deer

The projected short-term negative effects of vegetation treatments on the Columbian white-tailed deer could be 

avoided by implementing the following programmatic-level conservation measures. 

• Prior to treatments, survey for evidence of white-tailed deer use of areas in which treatments are proposed 

to occur. 

• Address the protection of Columbian white-tailed deer in local management plans developed in 

association with treatment programs. 

• In areas that are likely to support Columbian white-tailed deer, protect riparian areas from degradation by 

avoiding them altogether, or utilizing Standard Operating Procedures. Consult Chapter 5 for appropriate 

conservation measures to be used in protected riparian areas. 

• In habitats used by deer, conduct treatments that use domestic animals during the plant growing season, 

and remove the animals after clearing has been achieved. 

• Do not use domestic animals to control weeds in woodland habitats utilized by Columbian white-tailed deer. 

• In areas where Columbian white-tailed deer occur, or may possibly occur, avoid the use of fences to keep 

domestic animals out of sensitive habitats or to otherwise restrict their movement (fence accidents are 

associated with deer mortality). 

• Avoid burning in deer habitats during the fawning season. 

• Closely follow all application instructions and use restrictions on herbicide labels; in riparian habitats use 

only those herbicides that are approved for use in riparian areas. 

• Avoid broadcast spray treatments in areas where Columbian white-tailed deer are known to forage. 

• Do not use 2,4-D in Columbian white-tailed deer habitats; do not broadcast spray 2,4-D within 1⁄4 mile of 

Columbian white-tailed deer habitat. 

• Where feasible, avoid use of the following herbicides in Columbian white-tailed deer habitat: bromacil, 

clopyralid, diquat, diuron, glyphosate, hexazinone, imazapyr, metsulfuron methyl, Overdrive®, picloram, 

tebuthiuron, and triclopyr. 

• Do not broadcast spray bromacil, clopyralid, diquat, diuron, glyphosate, hexazinone, Overdrive®, picloram, 

or triclopyr in Columbian white-tailed deer habitat; do not broadcast spray these herbicides in areas adjacent 

to Columbian white-tailed deer habitat under conditions when spray drift onto the habitat is likely.
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• If broadcast spraying imazapyr, metsulfuron methyl, or tebuthiuron in or near Columbian white-tailed 

deer habitat, apply at the typical, rather than the maximum, application rate. 

• If conducting manual spot applications of glyphosate, hexazinone, imazapyr, metsulfuron methyl, 

tebuthiuron, or triclopyr to vegetation in Columbian white-tailed deer habitat, utilize the typical, rather 

than the maximum, application rate. 

In addition, site-specific and project specific conservation measures would need to be developed by local BLM 

offices to ensure complete protection of the Columbian white-tailed deer.

Threatened

Canada Lynx 

The primary reference for this section is: USFWS. 2000m. Determination of Threatened Status for the 

Contiguous U.S. Distinct Population Segment of the Canada Lynx and Related Rule. Federal Register 

65(58):16051-16086. References cited in this section are internal to the above-referenced document. A complete 

list of these references is available from the USFWS Montana Field Office, Helena, Montana. 

Lynx occur in moist coniferous forests that provide a prey base of snowshoe hare (Quinn and Parker 1987; 

Koehler 1990; Koehler and Brittell 1990; Mowat et al. 1999). In the contiguous United States, the Canada lynx 

(Lynx canadensis) historically occurred in the Cascades Range of Washington and Oregon; the Rocky Mountain 

Range in Montana, Wyoming, Idaho, eastern Washington, eastern Oregon, northern Utah, and Colorado; the 

western Great Lakes Region; and the northeastern United States region from Maine southwest to New York 

(McCord and Cardoza 1982, Quinn and Parker 1987). This distribution associated with the southern boreal forest, 

comprising of subalpine coniferous forest in the West and primarily mixed coniferous/deciduous forest in the East 

(Aubry et al. 1999). In Canada and Alaska, however, lynx inhabit the classic boreal forest ecosystem known as 

the taiga (McCord and Cardoza 1982; Quinn and Parker 1987; Agee 1999; McKelvey et al. 1999b). Within these 

general forest types, lynx are most likely to persist in areas that receive deep snow, for which the lynx is highly 

adapted (Ruggiero et al. 1999b). 

The lynx population in the contiguous U.S. is considered by the USFWS to be part of a larger metapopulation 

whose core is located in the northern boreal forest of central Canada (Buskirk et al. 1999b; McKelvey et al. 

1999a, 1999b). The boreal forest extends south into the contiguous United States along the Cascade and Rocky 

Mountain ranges in the West, the western Great Lakes Region, and along the Appalachian Mountain Range of the 

northeastern United States. At its southern margins, the boreal forest becomes naturally fragmented into patches 

of varying size as it transitions into other vegetation types. These southern boreal forest habitat patches are 

small relative to the extensive northern boreal forest of Canada and Alaska, which constitutes the majority of the 

lynx range. Many of these southern boreal forest habitat patches within the contiguous U.S. are able to support 

resident populations of lynx and snowshoe hare. It is likely that some of the habitat patches act as sources of lynx 

(recruitment is greater than mortality) that are able to disperse and potentially colonize other patches (McKelvey 

et al. 1999a). Other habitat patches act as “sinks” where lynx mortality is greater than recruitment and lynx are 

lost from the overall population. The ability of naturally dynamic habitat to support lynx populations may change 

as the habitat undergoes natural succession following natural or manmade disturbances (i.e., fire, clearcutting). 

In addition, fluctuations in the prey populations may cause some habitat patches to change from being sinks to 

sources and vice versa. 

It is believed that historic and current lynx densities in the contiguous U.S. are naturally low relative to lynx 

densities in the northern boreal forest. At present, in the western states, resident populations currently exist only 

in Montana and Washington, and populations that are no longer self-sustaining occur in Oregon, Idaho, Wyoming, 

Utah, and Colorado. Because the lynx is a secretive animal, there are no reliable population estimates for this 

species. However, sightings of lynx throughout the U.S. have continued to decrease over the years. 
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Lynx are highly specialized predators whose primary prey is the snowshoe hare, a species that has evolved to 

survive in areas that receive deep snow (Bittner and Rongstad 1982). Snowshoe hares use forests with dense 

understories that provide forage, cover to escape from predators, and protection during extreme weather (Wolfe 

et al. 1982; Monthey 1986; Hodges 1999a, 1999b). Generally, earlier successional forest stages have greater 

understory structure than do mature forests and therefore support higher hare densities (Hodges 1999a, 1999b). 

However, mature forests can also provide snowshoe hare habitat as openings develop in the canopy of mature 

forests when trees succumb to disease, fire, wind, ice, or insects, and the understory grows (Buskirk et al. 1999b). 

Lynx concentrate their hunting activities in areas where hare activity is relatively high (Koehler et al. 1979; Parker 

1981; Ward and Krebs 1985; Major 1989; Murray et al. 1994; O’Donoghue et al. 1997, 1998a). Lynx also prey 

opportunistically on other small mammals and birds, particularly when hare populations decline (Nellis et al. 

1972; O’Donoghue 1997, 1998a). Red squirrels are an important alternate prey (Apps 1999; Aubry et al. 1999). 

However, a shift to alternate food sources may not compensate for the decrease in hares consumed (Koehler and 

Aubry 1994). In northern regions, when hare densities decline, the lower quality diet causes sudden decreases in 

the productivity of adult female lynx and decreased survival of kittens, which causes the numbers of breeding lynx 

to level off or decrease (Nellis et al. 1972; Brand et al. 1976; Slough and Mowat 1996; O’Donoghue et al. 1997). 

The breeding period for Canada lynx is late winter to early spring, with adult females producing one litter every 1 

to 2 years. The gestation period typically lasts from 62 to 74 days, and the litter size is 3 to 4 kittens, on average. 

Females may reach reproductive maturity by as early as 1 year (Brainerd 1985). 

Lynx use large woody debris, such as downed logs and windfalls, to provide denning sites with security and 

thermal cover for kittens (McCord and Cardoza 1982, Koehler 1990, Koehler and Brittell 1990, Squires and 

Laurion 1999, Organ 1999). For lynx den sites, the age of the forest stand does not seem as important as the 

amount of downed, woody debris available (Mowat et al. 1999). The size of lynx home ranges varies by the 

animal’s gender, abundance of prey, season, and the density of lynx populations (Hatler 1988; Koehler 1990; 

Poole 1994; Slough and Mowat 1996; Aubry et al. 1999; Mowat et al. 1999). Documented home ranges vary 

from 3 to 300 square miles (Saunders 1963; Brand et al. 1976; Mech 1980; Parker et al. 1983; Koehler and Aubry 

1994; Apps 1999; Mowat et al. 1999; Squires and Laurion 1999). 

The population of the Canada lynx occurring in the contiguous U.S. was Federally Listed as threatened on March 

24, 2000. The designation of critical habitat for the species was deemed prudent, but has not yet occurred. 

According to the USFWS, the primary factor affecting lynx in the contiguous U.S. is the lack of guidance for 

conservation of lynx in federal land management plans. People change forests through timber harvest, fire 

suppression, and conversion of forest lands to agriculture. Forest fragmentation may eventually become severe 

enough to isolate habitat into small patches, thereby reducing the viability of lynx populations, which are 

dependent on larger areas of forest habitat (Litvaitis and Harrison 1989). In addition, human alteration of forests 

may facilitate competition by creating habitats that are more suitable to potential lynx competitors (McCord 

and Cardoza 1982, Quinn and Parker 1987, Buskirk et al. 1999a). Finally, lynx movements may be negatively 

influenced by high traffic volume on roads that bisect suitable lynx habitat, such as in the Southern Rockies and in 

some parts of the Northern Rockies/ Cascades Region.

Vascular Plants

Endangered

McDonald’s Rock-cress 

McDonald’s rock-cress (Arabis mcdonaldiana) appears to be restricted to serpentine soils in northern California 

and immediately adjacent southwestern Oregon. The species occurs at Red Mountain, a dome of red colored 

rock forming an island of peculiar vegetation protruding through the carpet of mixed evergreen forest indigenous 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

to the Coast Ranges of northern California. The majority of rock-cress populations occupy conspicuously open 

habitats, scree slopes, rocky ridges, and barren rocky outcrops devoid of competing vegetation and exposed to 

full sun. This species appears to show long-term stability in open rocky habitats devoid of competition from 

other plant species. The densest populations occur in areas of north and east exposures or in sheltered saddles, 

which probably have the most persistent accumulations of snow. Rock-cress roots penetrate rock crevices, and 

areas of substantial sheet erosion appear to be poor areas of establishment. Temporarily successful at this site, 

McDonald’s rock-cress is likely a transitional member of this rapidly changing chaparral community (Baad 1985). 

The vegetation covering the crest of Red Mountain is notably sparse, consisting of an open forest of sugar pine, 

ponderosa pine, Jeffrey pine, and incense-cedar. An understory of chaparral species forms a patchy mosaic 

of dense cover alternating with extensive park-like expanses of open forest. Frequent herbaceous associates 

include Red Mountain buckwheat and Red Mountain stonecrop (Baad 1985). McDonald’s rock-cress is found at 

elevations of 3,200 to 4,100 feet. 

McDonald’s rock-cress is a perennial herb whose aboveground parts remain alive year-round (Rollins 1941, 1973; 

Baad 1985). Germination commences with fall rains. Flowering occurs from April through June, and fruiting 

occurs from July through August, with dispersal from August through mid-September (Baad 1985). A number 

of insect visitors appear to be potential pollinators of rock-cress, including Syrphid flies, solitary bees, and 

bumblebees. Individual plants produce a variable number of fruits, which split open in August. 

McDonald’s rock-cress was Federally Listed as endangered on September 28, 1978. Critical habitat has not been 

designated. Although approximately two-thirds of the plants occur on public land, all populations are potentially 

endangered by plans to mine exploitable nickel and chromium deposits occurring within this area. A large-scale 

surface mining operation immediately adjacent to the total distribution of the species represents a serious threat to 

the survival of McDonald’s rock-cress.

Marsh Sandwort 

The primary reference for this species is: USFWS. 1998k. Recovery Plan for Marsh Sandwort (Arenaria 

paludicola) and Gambel’s Watercress (Rorippa gambelii). Portland, Oregon. References cited in this section are 

internal to the above-referenced document. Full citations have been included in the Bibliography. 

The Marsh sandwort (Arenaria paludicola) was historically found in scattered locations near the Pacific coast in 

southern and central California and Washington. The species occurs in freshwater marshes at elevations from sea 

level to 1,480 feet. Soils in these habitats are saturated, acidic bog soils that are predominantly sandy and have a 

high organic content. Presently, there are only two known populations of this species in the United States, both 

in San Luis Obispo County, California: one of fewer than 10 individuals in Black Lake Canyon, and one of more 

than 85 individuals at Oso Flaco Lake. The Marsh sandwort has been listed by the Washington Natural Heritage 

Program as “possibly extirpated” in Washington State. Nonetheless, it is thought that suitable habitat for the 

species remains in Washington State, and that populations could exist there now or in the future. As this species 

occurs on the BLM’s Washington/Oregon special status species list, but not on the California list, it is unlikely 

that this species presently occurs on public lands. 

Because there are so few individuals of the Marsh sandwort remaining, studying the life history of this species 

has been difficult. Although plants have been observed flowering and fruiting minimally, and a viable seed bank 

has been identified, information about the species’ pollinators, seed germination and dispersal, and seedling 

recruitment is lacking. 

The Marsh sandwort was Federally Listed as endangered on August 3, 1993. Critical habitat has not been 

designated. Threats to the species include encroaching vegetation (both native and non-native) associated with 

lowered water tables, agricultural and residential development, and OHV use. In addition, the very low number 
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of individuals in the remaining populations puts this species at a great risk of extinction as a result of random, 

naturally occurring events.

Applegate’s Milk-vetch

The primary reference for this section is: Hudson, B., J. Augsburger, M. Hillis, and P. Boehne. 2000. 

Draft Biological Assessment for the Interior Columbia River Basin Ecosystem Management Project Final 

Environmental Impact Statement. BLM and Forest Service. Boise, Idaho. Other references used are cited in the 

text and included in the Bibliography. 

Applegate’s milk-vetch (Astragalus applegatei) is a narrow endemic, known only from the Lower Klamath Basin 

near the city of Klamath Falls in southern Oregon. It is restricted to flat-lying, seasonally moist, strongly alkaline 

soils (USFWS 1997g). Although it is currently replete with introduced grasses and other weeds, the species’ 

habitat was historically characterized by sparse, native bunchgrasses and patches of bare soil. Currently, there are 

two known populations of the species, which occur over a total area of less than 10 acres, and which form a total 

metapopulation of fewer than 20,000 individuals. Of the two populations, one is on land leased by The Nature 

Conservancy and one is on state land. There are no populations on federal lands. 

Applegate’s milk-vetch appears to be dependent on the seasonal flooding that occurs at sites where it is found, 

which may limit the dominance of other species and create favorable openings for the establishment of new plants. 

Applegate’s milk vetch hosts an unknown species of beetle larvae, and is pollinated by ground-nesting beetles. 

Applegate’s milk-vetch was federally-listed as endangered on July 28, 1993. Critical habitat has not been 

designated. The primary threats to this species include invasion of habitat by exotic species such as quackgrass 

and cheatgrass, urban development, and road construction. Low population numbers, loss of habitat, wildlife 

grazing (rabbits), and management controls that alter natural wildfire and flooding regimes all pose serious threats 

to this species.

Willamette Valley Daisy

The primary reference for this section is: USFWS. 1997f. Endangered Status for Erigeron decumbens var. 

decumbens (Willamette Daisy) and Fender’s Blue Butterfly (Plebejus icarioides fenderi) and Threatened Status 

for Lupinus sulphureus ssp. kincaidii (Kincaid’s Lupine). Federal Register 65(16):3875-3890. References cited 

in this section are internal to the above-referenced document. A complete list of these references is available from 

the USFWS Oregon State Office, Portland, Oregon. 

The Willamette Valley daisy(Erigeron decumbens var. decumbens) is restricted primarily to the Willamette Valley 

of Oregon. The valley is an alluvial floodplain that is 130 miles long and 20 to 40 miles wide, with an overall 

northward gradient (Orr et al. 1992). The valley is narrow and flat at its southern end, widening and becoming 

hilly near its northern end at the confluence of the Willamette and Columbia rivers. The alluvial soils of the 

Willamette Valley and southern Washington host a mosaic of grassland, woodland, and forest communities. The 

Willamette Valley daisyoccupies native grassland habitats within the Willamette Valley. The vast majority of 

Willamette Valley grasslands require natural or human-induced disturbance for their maintenance (Franklin and 

Dryness 1973), and would likely be forested if left undisturbed (Johannessen et al. 1971). 

The Kalapooya Indians cleared and burned lands in the Willamette Valley used for hunting and food gathering. 

Accounts by early explorers suggest a pattern of annual burning by the Kalapooya Indian tribe resulted in the 

maintenance of extensive wet and dry prairie grasslands (Johannessen et al. 1971). Although much of the woody 

vegetation was prevented from becoming established on the grasslands by this treatment, the random survival of 

young fire-resistant species such as Oregon white oak, accounted for the widely-spaced trees on the margins of the 

valley (Habeck 1961). After 1848, burning decreased sharply through the efforts of settlers to suppress large-scale 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

fires. Consequently, the open, park-like nature of the valley floor was lost, replaced by agricultural fields, dense 

oak and fir forests, and scrublands following logging. 

The primary habitat for the Willamette Valley daisy is native wetland prairie. This habitat is characterized by 

the seasonally wet tufted hairgrass community that occurs in low, flat regions of the Willamette Valley where 

flooding creates anaerobic and strongly reducing soil conditions. This wet prairie community includes rushes and 

California oatgrass as co-dominant native species, as well as the introduced species tall fescue, Japanese brome, 

and sweet vernal grass. 

The Willamette Valley daisy is a perennial herb, 0.6 to 2.4 inches tall, with erect to sometimes prostrate stems at 

the base. As with many species in the Aster family, the Willamette Valley daisy produces large quantities of winddispersed seeds. Flowering typically occurs in June and July with pollination carried out by flies and bees. Seeds 

are released in July and August. Although the seeds are wind-dispersed, the short stature of this species likely 

prevents the long-distance travel of many of these seeds. The Willamette Valley daisy is capable of vegetative 

spreading and is commonly found in large clumps scattered throughout a site (Clark et al. 1993). 

The Willamette Valley daisy was Federally Listed as endangered on January 25, 2000. At the time of listing, the 

USFWS indicated that designation of critical habitat was prudent, but that it would be deferred until resources 

became available to do so. The Willamette Valley daisy likely once occurred over a large distribution throughout 

the historic native prairie. However, native prairie vegetation in the Willamette Valley was decimated by the 

rapid expansion of agriculture from the 1850s to the present. In addition, fire suppression allowed shrub and tree 

species to overtake grasslands, while agricultural practices hastened the decline of native prairie species through 

habitat loss and increased grazing (Johannessen et al. 1971; Franklin and Dyrness 1973). Currently, the species is 

threatened by commercial and/or residential development, agriculture, silvicultural practices, road improvement, 

collection, herbicide use, and naturally occurring demographic and random environmental events.

Gentner’s Fritillary

The primary reference for this section is: BLM. 2008. Biological Assessment FY 2009-2013 Programmatic 

Assessment For Activities that May Affect the Listed Endangered Plant Species Gentner’s Fritillary, Cook’s 

Lomatium, McDonald’s Rockcress, and Large-flowered Wooly Meadowfoam. USFWS concurred with this 

assessment on 9/25/08. References cited in this section are internal to the above-referenced document. 

Gentner’s fritillary (Fritillaria gentneri), a perennial herb of the lily family, is restricted to southwestern Oregon 

and northern California where it is known from scattered localities in the Rogue and Klamath River basins 

in Josephine, Jackson and Siskiyou counties. The species is known from a wide variety of habitats and soil 

types across its range. The recovery plan (USDI 2003) identifies over 25 soil types and about 16 different plant 

communities that this species can occupy. Elevations of known occurrences range from 600 feet near the Rogue 

River to nearly 5,000 feet near Soda Mountain and can occur on nearly all aspects. Gentner’s fritillary is most 

often found in forest ecotones or transitional areas, especially along ridgelines or aspect changes. No estimates 

of suitable habitat have been done because of the wide range of habitats in which it has been found. There are 

194 known occurrences on all ownerships; 146 sites (75%) occur on federal lands, 16 sites (8%) occur on State, 

County or City owned public lands and 32 sites (16%) on private lands (Medford BLM, 2008; USDI FWS 2002; 

USDI FWS, 2003). 

Gentner’s fritillary is found in four general habitat types: ecotones between (and inclusions within) forested sites 

and more open habitat (oak woodlands/grasslands/chaparral);open canopied woodlands and mixed evergreen 

forests of madrone and Douglas-fir; permanent openings and edges of openings in forest and woodlands; riparian 

zone edges with canopy gaps and or deciduous tree canopies.
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Final Environmental Impact Statement: Appendix 5

The primary means of reproduction of Gentner’s fritillary is asexual. Small plants arise from near the base of 

larger flowering plants, presumably from underground bulblets coming off the parent bulb. The flowering season 

for this species is April-June. Few plants set fruit containing viable seed and most occurrences of this species 

contain few flowering plants. Plants may remain dormant for several years without producing above-ground 

stems and flowers. Hummingbirds (McFarlane 1980), and andrinid and halictid bees (Donham 2002) are the 

likely pollinators. About 3,000 flowering plants are documented on federal lands, and it is estimated that about 

140,000 vegetative plants exist, although since the amount of genetic diversity within patches is very low, the 

number of distinct genotypes may be fewer than a few hundred. Three populations on private lands are believed 

to be extirpated.

Gentner’s fritillary was Federally Listed as endangered on December 10, 1999. Critical habitat has not been 

designated. The species is threatened by residential development, agricultural activities, browsing by deer and 

livestock, logging, road and trail improvement, OHV use, collection for gardens, and problems associated with small 

population size. The recovery plan calls for intensive augmentation of populations with nursery-grown plants.

Western Lily

The primary reference for this section is: USFWS. 1998e. Recovery Plan for the Endangered Western Lily 

(Lilium occidentale). Portland, Oregon. 

The western lily (Lilium occidentale) occurs in early successional bogs or coastal scrub on poorly drained soils, 

usually those underlain by a hard, poorly permeable layer. Currently, the species occurs in widely scattered 

locations near the Pacific Ocean. Populations occur along a 200-mile stretch of the Pacific Coast, from near Coos 

Bay in Oregon, south to Humboldt Bay in California. The plants grow at low elevations, from almost sea level to 

about 300 feet, and from ocean-facing bluffs to about 4 miles inland. Common plant associates include the shrubs 

salal, western wax myrtle, western spiraea, huckleberry, blackberry, black twinberry, and glandular Labrador tea. 

Common tree associates include shore pine, Sitka spruce, red alder, Port Orford cedar, and willow. Common 

herbaceous associates include Pacific reed-grass, slough sedge, bunchberry, staff gentian, bracken fern, peat moss, 

and western tofieldia. 

The western lily appears to require a habitat that maintains a delicate balance between having some shrubbery and 

having too much. Vegetation less than 3 feet tall can be beneficial to the lily by sheltering juvenile plants from 

browsing by large mammals, and by providing shelter from the heat in July and August. This protection is most 

critical during spring and early summer, because seedlings appear to tolerate dieback of aboveground parts later 

in the growing season. Dense, tall shrub growth reduces reproduction and survivorship, and closure of the forest 

canopy will eventually eliminate a population entirely. 

The western lily is an herbaceous perennial that grows from an unbranched, scaly, bulblike rhizome. The species 

reproduces primarily by seed, but asexual reproduction is possible from detached bulb scales growing into new 

plants. Shoots emerge primarily in March and April, although they can emerge as early as January in some 

locations. Flowers bloom in May to July. Rhizomes may produce one or more flowering shoots per year, each 

typically with one to three, but up to 25, pendant flowers. Flowers often emerge above the surrounding shrubs, 

where they are available to pollinators such as hummingbirds. Capsular fruits become erect and may produce 

over 100 seeds when mature. Seeds are dispersed primarily by wind and gravity, generally within a radius of 

about 13 feet. Each year the aboveground portion of the plants die back and individuals overwinter underground 

as rhizomes/bulbs. 

The western lily was Federally Listed as endangered on August 17, 1994. Critical habitat has not been 

designated. The species is known or assumed to be extirpated in at least nine historical sites, as a result of forest 
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succession, cranberry farm development, livestock grazing, deer and mammal herbivory, highway construction, 

and other development. These factors continue to threaten the western lily, with development taking a primary 

role. Populations of the western lily appear to have been maintained in the past by occasional fires, at least at 

some sites in Oregon, and by grazing. Among the most serious threats to this species is loss of habitat as a result 

of ecological succession facilitated by aggressive fire suppression.

Large-flowered Woolly Meadowfoam

The primary reference for this species is: USFWS. 2002c. Determination of Endangered Status for Lomatium 

cookii (Cook’s Lomatium) and Limnanthes floccosa ssp. grandiflora (Large-flowered Woolly Meadowfoam) from 

Southern Oregon. Federal Register 67(216):68003-68015. 

References cited in this section are internal to the above-referenced document. A complete list of these references 

is available from the State Supervisor, USFWS, Oregon Fish and Wildlife Office, Portland, Oregon. 

Large-flowered woolly meadowfoam (Limnanthes floccosa ssp. grandiflora), like Cook’s Lomatium discussed 

in the previous species account, occurs in vernal pool habitats in a small area of Jackson County, southwestern 

Oregon. The species is known to occur at about 15 sites in Jackson County (M. Jones, USDI BLM 2002; Oregon 

Natural Heritage Information Center Database 2002). 

The large-flowered woolly meadowfoam occurs within the Agate Desert, a landform that was described in the 

previous species account. This landform is characterized by shallow soils, a relative lack of trees, sparse prairie 

vegetation, and agates commonly found on the soil surface (Oregon Natural Heritage Program 1997). Vernal 

pools in the Agate Desert vary in size from 3 to 100 feet across, and attain a maximum depth of about 12 inches. 

Common associated native species in these vernal pools include popcorn flower, a rush, navarretia, common 

woolly meadowfoam, and annual hairgrass. 

The large-flowered woolly meadowfoam is a delicate annual of the meadowfoam family that is covered with short, 

fuzzy hairs. Like Cook’s Lomatium, plants are adapted to grow, flower, and set seed during the short time that water 

is available in the spring, finishing their life cycle before the dry hot summers. Each year, plant populations exhibit 

some natural variation in numbers, related primarily to temperature and rainfall conditions for that year. 

The large-flowered woolly meadowfoam was Federally Listed as endangered on November 7, 2002. Designation 

of critical habitat has been deferred. The primary threat to the large-flowered woolly meadowfoam is the 

destruction of vernal pool habitat by industrial and residential development, including road and powerline 

construction and maintenance. Agricultural conversion, certain grazing practices, and OHV use also contribute 

to population declines and local extirpations. Recent evidence also indicates that non-native annual grasses, 

particularly medusahead, are a greater problem than previously believed, as discussed in the species account for 

Cook’s Lomatium.

Bradshaw’s Desertparsley

The primary reference for this section is: USFWS. 1993g. Lomatium bradshawii (Bradshaw’s desertparsley ) 

Recovery Plan. Portland, Oregon. References cited in this section are internal to the above-referenced document. 

They are included in the Bibliography. 

Bradshaw’s desertparsley , or Bradshaw’s desert-parsley (Lomatium bradshawii) is endemic to the central and 

southern portions of the Willamette Valley, in western Oregon. It is known from Marion, Linn, Benton, and Lane 

counties. The majority of the sites and plants occur in and adjacent to the Eugene metropolitan area, with the 

greatest concentration found in West Eugene. Bradshaw’s desertparsley occurs in two very distinct habitats. The 
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Final Environmental Impact Statement: Appendix 5

rarest are the shallow, stream-covered basalt areas found in Marion and Linn counties neat the Santiam River. 

At these sites, the plants occur in areas with almost no soil, usually in vernal wetlands or along stream channels. 

The majority of the species’ populations occur on seasonally saturated or flooded prairies, which are common by 

creeks and small rivers in the southern Willamette Valley. They occur in areas with deep, pluvial clays, usually in 

a matrix with alluvial silts. The slowly permeable clay layer results in a perched water table in winter and spring, 

so soils are generally saturated to the surface or slightly inundated during the wet season. This relic wetland 

prairie has been described as the tufted hairgrass valley prairie, which ranges from fairly wet areas with high 

sedge and rush cover, to drier bunchgrass prairie. In the wet areas, Bradshaw’s desertparsley occurs on the edges 

of tufted-hairgrass or sedge bunches, in patches of bare or open soil. In the drier areas, it is found in low areas, 

such as small depressions, trails, or seasonal channels, also with open, exposed soils. 

Bradshaw’s desertparsley reproduces entirely by seeds, which are produced on umbels. Flowers are visited by 

numerous pollinators, and require insects for pollination. The species blooms fairly early in the spring, usually 

in April or early May. In the Willamette Valley, these are often wet, rainy weeks, when large bees and butterflies 

are largely absent. The very general nature of the insect pollinators probably buffers the species from population 

swings of any one pollinator (Kaye 1992). A typical population of Bradshaw’s desertparsley is composed of 

many more vegetative plants than reproductive plants. In general, populations that have experienced prescribed 

fire have a higher probability of survival. 

Bradshaw’s desertparsley was Federally Listed as endangered on September 30, 1988. Critical habitat has not 

been designated. The species’ habitat is presently being destroyed or modified by a number of factors: invasion 

of prairie vegetation by trees and shrubs; changes in flooding patterns and water movement (which may be critical 

to seedling establishment); urban development; and agricultural or rural development. In addition, disease caused 

by a fungal parasite, and insect predation of plants and fruit may threaten smaller populations. Finally, natural 

factors such as inbreeding or limited pollinator availability may reduce fecundity, and therefore reproductive 

capacity of the species.

Cook’s Lomatium

The primary reference for this species is: USFWS. 2002c. Determination of Endangered Status for Lomatium 

cookii (Cook’s Lomatium) and Limnanthes floccosa ssp. grandiflora (Large-flowered Woolly Meadowfoam) from 

Southern Oregon. Federal Register 67(216):68003-68015. References cited in this section are internal to the 

above-referenced document. A complete list of these references is available from the State Supervisor, USFWS, 

Oregon Fish and Wildlife Office, Portland, Oregon. 

Cook’s Lomatium (Lomatium cookii) occurs in vernal pool habitats in a small area of Jackson County, southwestern 

Oregon. It is also known to occur in seasonally wet habitats at a few sites in Josephine County, the adjacent county 

to the west. Cook’s Lomatium is known to occur at about 15 sites in Jackson County and at about 21 sites in 

Josephine County (M. Jones, USDI BLM 2002; Oregon Natural Heritage Information Center Database 2002). 

Cook’s Lomatium occurs within a 32-square-mile landform in southwestern Oregon known as the Agate Desert in 

Jackson County. This landform is characterized by shallow soils, a relative lack of trees, sparse prairie vegetation, 

and agates commonly found on the soil surface (Oregon Natural Heritage Program 1997). Vernal pools in the 

Agate Desert vary in size from 3 to 100 feet across, and attain a maximum depth of about 12 inches (Oregon 

Natural Heritage Program 1997). Common associated native species in these vernal pools include popcorn 

flower, a rush, navarretia, common woolly meadowfoam, and annual hairgrass. 

Cook’s desert parsley also occurs in another area of about 4 square miles in adjacent Josephine County. This area, 

referred to as French Flat, is located within the Illinois Valley near the Siskiyou Mountains. In this area, Cook’s 
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desert parsley grows in wet meadow areas underlain with floodplain bench deposits that contain sufficient clay to 

form a clay pan at 24 to 35 inches below the soil surface (U.S. Department of Agriculture 1983). The clay pan 

creates seasonally wet areas similar to the vernal pools of the Agate Desert, but mostly lacking in mound-swale 

topography. Common associated species include California oatgrass, popcorn flower, horkelia, mariposa lily, and 

trout lily. The surrounding forest contains ponderosa pine and Jeffrey pine. 

Cook’s Lomatium is a perennial forb in the carrot family that grows from a slender, twisted taproot. The species 

is adapted to grow, flower, and set seed during the short time that water is available in the spring, finishing its life 

cycle before the dry hot summers. 

Cook’s Lomatium was Federally Listed as endangered on November 7, 2002. Designation of critical habitat for 

this species has been deferred. The primary threat to Cook’s Lomatium is the destruction of vernal pool habitat by 

industrial and residential development, including road and powerline construction and maintenance. Agricultural 

conversion, certain grazing practices, and OHV use also contribute to population declines and local extirpations. 

Recent evidence also indicates that non-native annual grasses, particularly medusahead, are a greater problem 

than previously believed. Unlike native perennial bunchgrasses that originally occupied the area, annual grasses 

die back each year, creating a buildup of thatch from the dead leaves that interferes with the seed germination of 

native species. Current observations indicate that, without control of annual grasses through mowing, grazing, 

or prescribed burns, populations tend to decrease over time, and could be extirpated within a relatively short 

time frame as a result of competition with non-native grasses (Borgias 2002). Additionally, Cook’s Lomatium 

sites in Josephine County are threatened by habitat alteration associated with gold mining and woody species 

encroachment resulting from fire suppression.

Critical habitat designation for the listed Cook’s Lomatium and Limnanthes floccosa spp. grandiflora is out in 

draft (June 2006), and a recent settlement agreement says it will be done by July 2010.

Rough Popcorn flower 

The primary reference for this species is: USFWS. 2000f. Endangered Status for the Plant Plagiobothrys hirtus 

(Rough Popcorn flower). Federal Register 65(16):3866-3875. References cited in this section are internal to 

the above-referenced document. A complete list of these references is available from the USFWS Oregon State 

Office, Portland, Oregon. 

The rough popcorn flower (Plagiobothrys hirtus) is endemic to seasonal wetlands (e.g., wet swales and meadows) 

of the interior valley of the Umpqua River in southwestern Oregon (Amsberry and Meinke 1997b). The plant 

grows at elevations ranging from 98 to 886 feet, in open microsites within interior valley grasslands. Common 

associates include one-sided sedge, meadow barley, tufted hairgrass, American slough grass, great camas, water 

foxtail, baltic rush, wild mint, Willamette downingia, and bentgrass (Gamon and Kagan 1985). 

The rough popcorn flower is an annual herb on drier sites or a perennial herb on wetter sites (Amsberry and 

Meinke 1997a). It grows in scattered groups and reproduces largely by insect-aided cross-pollination and 

partially by self-pollination. The taxon is considered dependent on seasonal flooding and/or fire to maintain open 

habitat and to limit competition with invasive non-native plant species, such as Himalayan blackberry, teasel, 

Canada thistle and pennyroyal and native Oregon ash (Gamon and Kagan 1985, Almasi and Borgias 1996). 

Approximately 20 occurrences of this species are known, all of which are located in Douglas County, in 

the vicinity of Wilbur, Sutherlin and Yoncalla, Oregon. Fifteen populations naturally occurring and two are 

reintroduced. Of the naturally occurring populations, only 5 are legally protected. Two are on Oregon Department 

of Transportation land and 3 are on private land managed by The Nature Conservancy. The remaining populations 
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Final Environmental Impact Statement: Appendix 5

are on private, commercial, residential and agricultural land. There is an estimated 7,000 individuals, with patch 

sizes ranging from 1 to 3,000 individuals. However, since Plagiobothrys hirtus ssp. hirtus can spread vegetatively, 

it is difficult to estimate the total number of genetic individuals. Total occupied habitat is only about 45 acres 

(USFWS 2000). 

In cooperation with the Bureau of Land Management (BLM - Roseburg District) and USFWS, ODA created three 

new populations on the North Bank Habitat Management Area, a 6,000 acre ranch currently managed by the 

BLM for multi-species habitat conservation. Planted in 1998, these populations continue to thrive, and make a 

significant contribution to the recovery of this species. ODA continues to monitor these created populations and 

cooperate with BLM to ensure their long term viability (ODA 2008).

The rough popcorn flower was Federally Listed as endangered on January 25, 2000. Critical habitat has not yet 

been designated for this species. Draining of wetlands for urban and agricultural uses and road and reservoir 

construction, however, has altered the original hydrology of the valley to such an extent that the total area of 

suitable habitat for the species has been substantially reduced. In addition to the ongoing threat of direct loss of 

habitat from conversion to urban and agricultural uses, hydrological alterations, and fire suppression, other threats 

to the species include spring and summer livestock grazing, roadside mowing, spraying, competition with nonnative vegetation, and landscaping (Gamon and Kagan 1985, Kagan 1995).

Malheur Wire-lettuce

The primary reference for this section is: Hudson, B., J. Augsburger, M. Hillis, and P. Boehne. 2000. 

Draft Biological Assessment for the Interior Columbia River Basin Ecosystem Management Project Final 

Environmental Impact Statement. BLM and Forest Service. Boise, Idaho. 

Malheur wire-lettuce (Stephanomeria malheurensis) is an annual plant that is found at only one 70-acre location 

near Malheur National Wildlife Refuge in Harney County, Oregon. This population is found within the high 

desert environment typical of the northern portion of the Great Basin, on top of a dry, broad hill. The substrate at 

this location is an azonal soil derived from the volcanic tuff layered with thin crusts of limestone. By contrast, the 

surrounding soils are derived from basalt. The top of the hill is about 500 feet above the surrounding flats, which 

consist of sagebrush-rabbitbrush desert. The immediate site itself is dominated by big sagebrush, common or gray 

rabbitbrush, and cheatgrass. Malheur wire-lettuce appears to be one of the few species that is able to survive on 

and around the otherwise barren harvester ant hills at the site. The area has been fenced to protect the population. 

Because the species is an annual, the numbers of plants vary greatly from year to year, and depend largely on the 

amount of precipitation received prior to and during the spring growing season. Seeds germinate in the fall after a 

late summer / early fall rain. 

The Malhuer wire-lettuce was Federally Listed as endangered on November 10, 1982, and critical habitat was 

designated to include the 160-acre Scientific Study Area on public land administered by the BLM, located 27 miles 

south of Burns in Harney County, Oregon. Because of its extremely restricted range and low numbers, this species 

is vulnerable to even small land disturbances in and around its habitat. Potential future zeolite mining in the area 

also endangers the continued existence of this species. Other threats to this species that have been identified include 

competition with cheatgrass, grazing by native herbivores, and possible foraging by beetle larvae.

Threatened

Golden Paintbrush

The primary references for this section are the listing notice (Final Rule) in the June 11, 1997 Federal Register, 

Vol.62, No. 112, 31740-31748, and Recovery Plan, August 23, 2000, in Portland OR. 
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Golden paintbrush (Castilleja levisecta) inhabits gravelly prairies at low elevations, west of the Cascades from 

Vancouver Island south through the Puget Trough of Washington. Historically, golden paintbrush was found as 

far north as British Columbia, and as far south as the Willamette Valley of Oregon. Golden paintbrush is believed 

to have been extirpated from Oregon although remnants of its Willamette Valley habitat still exists and botanists 

continue to search for this species. Many populations have been destroyed by the conversion of native prairie 

habitat to agricultural, residential, and commercial uses. The decline of golden paintbrush is also correlated with 

fire suppression. Fire disturbance is an integral component of the prairie ecosystem, maintaining grassland by 

preventing the successional encroachment of woody shrubs and trees. As a direct consequence of these land-use 

changes, golden paintbrush has not been seen in Oregon for over 40 years. It is found in openings damp in the 

winter but not from standing water, and it is typically associated with Idaho or red fescue, meadow checkerbloom, 

camas, cinquefoil, peacock larkspur, Hall’s aster, and hairgrass. 

Golden paintbrush is a multi-stemmed perennial with covered with soft, somewhat sticky hairs. Flower bracts are 

about the same width as the upper leaves and are a brilliant golden to yellow color. Plants emerge in early March 

and flower from April to early September. Bumblebees are most frequently observed foraging on the flowers, and 

are suspected of being a primary pollinator. Seed production is rather prolific, and cold stratification is required 

for germination. Like many species within the family Scrophulariaceae, and particularly within the genus 

Castilleja, golden paintbrush is considered to be a facultative root parasite. 

Golden paintbrush was federally-listed as threatened on June 11, 1997. Critical habitat has not been designated. 

Threats to the extant populations include loss of suitable habitat, the invasion of grassland habitat by native 

and non-native species, herbivory, trampling, fire suppression, and collecting by humans. The few remaining 

populations of golden paintbrush in the Pacific Northwest region are isolated, fragmented, and most are quite 

small. As such, they are vulnerable to extirpation from random, stochastic events, and are individually and 

collectively critical for the long term survival of this species. USFWS. 1997.

Water Howellia

The primary reference for this section is: Hudson, B., J. Augsburger, M. Hillis, and P. Boehne. 2000. 

Draft Biological Assessment for the Interior Columbia River Basin Ecosystem Management Project Final 

Environmental Impact Statement. BLM and Forest Service. Boise, Idaho. 

Water howellia (Howellia aquatilis) is an annual aquatic plant with a scattered distribution in the Pacific 

Northwest. The species is known to be extant in Idaho, Montana, and Washington, but is also historically known 

from California and Oregon. Sites in California and Oregon have not been recently relocated, despite intensive 

field surveys in both states. Within its current range, water howellia is known from a total of 110 occurrences. 

There are two main centers of distribution within this range: one in the Swan River Valley in Montana, and one 

in the vicinity of Spokane, Washington. Populations of water howellia in these centers range from one to 1,000 

plants, and occur mostly on publicly-owned land, and at elevations of 400 to 2,320 feet. Two occurrences are 

known in northern Idaho, in private ownership, and two others are found in western Washington. The total known 

occupied habitat for this species is less than 100 acres. 

Water howellia is restricted to small pothole ponds or the quiet water of shallow, abandoned river oxbows. These 

wetland habitats typically occur in a matrix of dense forest vegetation, and all known sites have at least some 

deciduous tree cover around a portion of the pond. Ponderosa pine forests typically surround the ponds, and redosier dogwood is usually present around the perimeters. The bottom surfaces of the wetlands consist of firm, 

consolidated clay and organic sediments. These wetlands are generally filled by snowmelt runoff and spring rains, 

but then dry out to varying degrees by late summer or early fall, depending on annual patterns of temperature and 

precipitation. The ponds are typically shallow, averaging 1 to 2 feet in depth during the middle of summer. 
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The bloom period of water howellia varies by geographic location, but typically occurs in May and June. The 

drying of the wetland habitat in late summer is critical to the species’ life cycle; the seeds will only germinate 

if they are exposed to the atmosphere. After the seedlings appear, usually in October, they overwinter under the 

snowpack. In late spring and early summer, the plants resume growth in the water that accumulates in the ponds. 

This ecological relationship has a profound influence on the size of occurrences from year to year; the summer 

climate determines the degree of pond drying, and thus the amount of seed germination in the fall. During years 

when seed germination is reduced, few plants are present the following summer. 

Water howellia was listed as threatened on July 14, 1994, but critical habitat was not designated. The highly 

specialized ecological adaptations of the species make it vulnerable to both short- and long-term natural 

environmental changes, such as succession or climate change. Land management activities and habitat destruction 

have also affected this species. Development, construction of dams, livestock grazing and trampling, timber 

harvesting, and road building are some of the human activities that alter the habitat of this species. Competition 

with introduced plant species, such as reed canarygrass and purple loosestrife, is also a threat.

Kincaid’s Lupine

The primary references for this section is: USFWS. 1997f. Endangered Status for Erigeron decumbens var. 

decumbens (Willamette Daisy) and Fender’s Blue Butterfly (Plebejus icarioides fenderi) and Threatened 

Status for Lupinus sulphureus ssp. kincaidii (Kincaid’s Lupine). Federal Register 65(16):3875-3890 and the 

Management Plan for Kincaid’s Lupine (Lupinus sulphureus ssp. kincaidii) in Douglas County, Oregon by BLM, 

USDA FS, USFWS. 2008. References cited in this section are internal to the above-referenced documents. A 

complete list of these references is available from the USFWS Oregon State Office, Portland, Oregon.

In 2008, Kincaid’s lupine was known from 76 occurrences, totaling approximately 1,150 acres (465 ha) in size, 

scattered across six counties (Yamhill, Polk, Benton, Lane, and Douglas Counties in Oregon and Lewis County, 

Washington) (USFWS 2005). In the Willamette Valley, Kincaid’s lupine is typically found in native upland 

prairie with red fescue and/or Idaho fescues, the dominant species, and Tolmie’s mariposa, Hooker’s catchfly, 

broadpetal strawberry, rose checker-mallow, and lomatium species serving as herbaceous indicator species 

(Hammond and Wilson 1993). The primary habitat for Kincaid’s lupine in Douglas County is open woodland 

and meadow edges, often near roadsides, associated with Pacific madrone (Arbutus menziesii), incense cedar

(Calocedrus decurrens), and Douglas-fir (Pseudotsuga menziesii) trees with a relatively open canopy cover. Most 

of the Douglas County populations appear to tolerate more shaded habitat conditions than the Willamette Valley 

populations with canopy cover of 50 to 80 percent (Barnes 2004). However, canopy covers between zero and 

50 percent occur at the Callahan Meadows and Callahan Ridge sites. Elevations are generally below 460 meters 

(1,500 feet) and soils are typically shallow and rocky over bedrock, or sometimes deep and very well drained 

(Chappell and Kagan 2001).

Kincaid’s lupine populations in Douglas County, represent the furthest southern extent of the current range. These 

populations are highly disjunct and isolated from the Willamette Valley populations with approximately 54 miles 

(87 km) separating Oregon’s south Willamette Valley populations from the Douglas County populations. In 

Douglas County, Kincaid’s lupine occurs at 14 sites ranging in size from 0.21 to 3.55 acres. Of these, nine sites 

occur on public lands. The Douglas County populations may be adapted to tolerate more extreme habitat and/

or other environmental conditions. (BLM, USDA FS, USFWS. 2008. Management Plan for Kincaid’s Lupine 

(Lupinus sulphureus ssp. kincaidii) in Douglas County, Oregon.) In addition to its Oregon occurrences, this species 

is known from two small sites in Lewis County, southern Washington, 40 miles north of the Willamette Valley.

Kincaid’s lupine is a long-lived perennial species, with a maximum reported age of 25 years (Wilson 1993). 

Individual plants are capable of spreading by rhizomes, producing clumps of plants exceeding 66 feet in diameter 
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(Hammond 1994). The long rhizomes do not produce adventitious roots (secondary roots growing from stem 

tissue) and apparently do not separate from the parent clump, and the clumps may be short-lived, regularly 

dying back to the crown (Kuykendall and Kaye 1993a). Kincaid’s lupine is pollinated by solitary bees and flies 

(Hammond 1994). Seed set and seed production are low, with few (but variable) numbers of flowers producing 

fruit from year to year, and each fruit containing an average of 0.3 to 1.8 seeds (Liston et al. 1994). Seeds are 

dispersed from fruits that open explosively upon drying. Kincaid’s lupine is the host plant of the federally 

endangered Fender’s blue butterfly. 

Kincaid’s lupine was Federally Listed as threatened on January 25, 2000. Critical habitat was designated in 2007 

for Willamette Valley populations, and a management plan for the species in Douglas County was developed 

in lieu of critical habitat in 2008. Kincaid’s lupine likely once occurred over a large distribution throughout the 

historic native prairie. However, native prairie vegetation in the Willamette and Umpqua Valleys. Fire was the 

primary mode of disturbance which kept grassland habitats open and free from encroaching trees and shrubs; the 

settlement of the Willamette and Umpqua Valleys by Euro-Americans resulted in the conversion of grasslands to 

urban and agriculture uses, and severely restricted the frequency of fires (Chappell and Kagan 2001). Currently, 

Kincaid’s lupine is threatened by commercial and/or residential development, agriculture, silvicultural practices, 

road improvement, collection, herbicide use, and naturally occurring demographic and random environmental 

events. Populations of Lupinus sulphureus ssp. kincaidii occur on public lands or lands that are managed by a 

conservation organization at William L. Finley National Wildlife Refuge and Baskett Slough National Wildlife 

Refuge, Fern Ridge Reservoir, Bureau of Land Management units in Lane and Douglas Counties, the Umpqua 

National Forest, Willow Creek Preserve, and at the McDonald State Forest. All of these parcels have some level 

of management for native prairie habitat values. 

McFarlane’s Four-o’clock

The primary reference for this section is: USFWS. 1996c. Reclassification of Mirabilis Macfarlanei 

(MacFarlane’s Four-o’clock) from Endangered to Threatened Status. Federal Register 61(52):10693-10697. 

References cited in this section are internal to the above-referenced document. A complete list of these references 

is available from the USFWS Snake River Basin Office, Boise, Idaho. 

MacFarlane’s four-o’clock (Mirabilis macfarlanei) is found on talus slopes in canyonland corridors where the 

climate is regionally warm and dry, and where precipitation occurs mostly during the period from winter to spring. 

It can be found in three disjunct areas in Oregon and Idaho that are associated with the Snake, Salmon, and 

Imnaha rivers. The species occurs as scattered plants on open, steep (50%) slopes of sandy soils, which generally 

have a west to southeast aspect. Talus rock underlies the soil in which the plants are rooted. Although a variety of 

soils support this plant throughout its range, the more common sandy soils are quite susceptible to displacement 

by wind and water erosion. 

The plant community in which MacFarlane’s four-o’clock occurs is a transition zone between bluebunch 

wheatgrass-Sandberg bluegrass and smooth sumac-bluebunch wheatgrass, consisting of bluebunch wheatgrass, 

cheatgrass, sand dropseed, scorpion weed, desert parsley, hackberry, smooth sumac, yarrow, and rabbit bush 

(Daubenmire 1970, Franklin and Dyrness 1973). 

One geographic unit of MacFarlane’s four-o’clock includes approximately 25 acres along 6 miles of Hells Canyon 

on the banks and canyonland slopes above the Snake River in Idaho County, Idaho, and Wallowa County, Oregon. 

The second geographic unit includes approximately 68 acres along 18 miles of banks and canyonland slopes 

above the Salmon River in Idaho County, Idaho. The third geographic unit includes about 70 acres of habitat 

along 3 miles of canyonland slopes over the Imnaha River in Wallowa County, Oregon. 
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MacFarlane’s four-o’clock is a perennial plant with a stout, deep-seated taproot. Flowering occurs from early 

May to early June, and peaks in mid-May. 

MacFarlane’s four-o’clock was Federally Listed as endangered on October 26, 1979. After additional populations 

were discovered, the plant was reclassified as threatened on March 15, 1996. Critical habitat has not been 

designated. Threats to the species include lack of plant recruitment in some areas, insect predation, invasions of 

non-native plants (often as a result of grazing practices), and the small size of some populations.

Nelson’s Checker-mallow

The primary reference for this section is: USFWS. 1998j. Recovery Plan for the Threatened Nelson’s Checkermallow (Sidalcea nelsoniana). Portland, Oregon. References cited in this section are internal to the abovereferenced document. They are included in the Bibliography. 

Nelson’s checker-mallow (Sidalcea nelsoniana) occurs as scattered populations in two distinct ecological regions: the 

northern Coast Range and the Willamette Valley of Oregon (includes two outlying populations in the Puget Trough of 

Washington). The species is not restricted to a single habitat type. Rather, it occupies a broad range of soils that vary 

in texture, drainage, and disturbance regimes (CH2M Hill 1986b). Plants appear to favor primary drainages, or those 

that receive mostly ground flow of stormwater runoff, rather than drainages fed by stream sources. 

Although occasionally occurring in the understory of woodlands or among woody shrubs, populations of Nelson’s 

checker-mallow in the Willamette Valley usually occupy open habitats that support early successional species 

(i.e., plants that colonize openings and then disappear as trees shade them out). These habitats are frequently 

represented by margins of sloughs, ditches, and streams, roadsides, fence rows, drainage swales, native prairie 

remnants, and fallow fields. Most sites have been densely colonized by invasive weeds, especially introduced 

forage grasses. Commonly associated plant species include: tall fescue, rose, common rush, Canada thistle, 

common St. Johnswort, blackberry, sedge, timothy, velvet grass, yarrow, vetch, western spiraea, bird’s-foot trefoil, 

ox-eye daisy, colonial bent-grass, meadow foxtail, reed canarygrass, Douglas’ hawthorn, wild carrot, large-leaved 

avens, geranium, and Oregon ash (Oregon Department of Agriculture 1995). 

Populations of Nelson’s checker-mallow in the Coast Range generally occur in open, wet-to-dry meadows, 

intermittent stream channels, and along the margins of coniferous forests. These areas typically support larger 

components of native vegetation than the Willamette Valley sites. Commonly associated plant species include 

tansy ragwort, spear-head senecio, strawberry, velvet grass, timothy, rush, sedge, and yarrow. 

Nelson’s checker-mallow is an herbaceous perennial plant species in the mallow family. In the Willamette Valley, 

flowering begins as early as mid-May, and continues through August to early September, depending on the 

moisture and climatic conditions of each site. Coast Range populations experience a shorter growing season and 

generally flower later and go dormant earlier. Seeds are deposited locally at or near the base of the parent plant, 

and may be shed immediately or persist into winter within the dry flower parts that remain attached to the dead 

stems. Seed dissemination could conceivably be accomplished through ingestion by deer and elk, particularly 

in the Coast Range. Aboveground portions of the plant die back in the fall, usually followed by some degree of 

re-greening at the base. It is not uncommon for some plants to continue producing flowers into the fall and early 

winter. Sexual reproduction appears to be accomplished entirely by insect pollinators. 

Nelson’s checker-mallow was Federally Listed as threatened on February 12, 1993. Critical habitat has not been 

designated. Prior to European settlement, Nelson’s checker-mallow habitats were likely maintained and kept free 

of overgrowth and woody vegetation by natural wildfires, fires set by Native Americans (Johannessen et al. 1971; 

Franklin and Dyrness 1973; Boyd 1986), and sporadic flooding. The landscape and processes such as flooding 
 532

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

and fire have been dramatically altered since the onset of European settlement. Today, no natural prairie remains 

in the Willamette Valley without evidence of livestock grazing, agriculture, and fire suppression (Moir and Mika 

1972). Urbanization and conversion of the native prairies into intensively managed croplands and pastures have 

eliminated and fragmented grasslands to the extent that Nelson’s checker-mallow is now restricted to sparsely 

distributed patches within narrow highway and country road ROW, undeveloped tracts, ditches, fence rows, 

abandoned fields, parks, and wildlife refuges. Populations in the Willamette Valley are threatened by roadside 

maintenance, herbicide application and mowing, soil cultivation, ditching, and other habitat modifications. 

Land threats are less extreme in the Coast Range, where the meadows occupied by Nelson’s checker-mallow are 

isolated from agricultural and urban development. Potential threats to these populations include a planned water 

impoundment project, herbicide application associated with timber harvest, and motorcyclists. Other threats to 

the species as a whole are competition with invasive plant species, the encroachment of trees and shrubs, limited 

seed production, and the species’ small population size and fragmentation.

Spalding’s Catchfly

The primary reference for this section is: USFWS. 2001c. Final Rule to List Silene spaldingii (Spalding’s 

catchfly) as Threatened. Federal Register 66(196):51598-51606. References cited in this section are internal to 

the above-referenced document. A complete list of these references is available from the USFWS Snake River 

Basin Office, Boise, Idaho. 

Spalding’s catchfly (Silene spaldingii) is primarily restricted to mesic grasslands that make up the Palouse region 

in southeastern Washington, northwestern Montana, adjacent portions of Idaho and Oregon, and British Columbia. 

Palouse prairie is considered a subset of the Pacific Northwest bunchgrass habitat type (Tisdale 1986). Spalding’s 

catchfly is also found in canyon grassland habitat, which is another division of the Pacific Northwest bunchgrass 

habitat type. Canyon grasslands are dominated by the same bunchgrass species as the Palouse prairie, but the two 

habitat types differ in their overall plant species composition (Hill 2000, Yuncevich 2000). In addition, canyon 

grasslands occur in steep, highly dissected canyon systems, whereas Palouse grasslands generally occur on gently 

rolling plateaus. The steep slopes in canyon grasslands result in pronounced habitat diversity (Yuncevich 2000). 

This steepness has also prevented the conversion of canyon grasslands to other uses, such as agriculture. 

Spalding’s catchfly is typically associated with grasslands dominated by native perennial bunchgrasses such 

as Idaho fescue or rough fescue. Other associated species include bluebunch wheatgrass, prairie Junegrass, 

snowberry, Nootka rose, yarrow, prairie smoke avens, sticky purple geranium, and arrowleaf balsamroot 

(Lichthardt 1997, Montana Natural Heritage Program 1998). Scattered individuals of ponderosa pine may also 

be found in or adjacent to Spalding’s catchfly habitat. Sites on which Spalding’s catchfly occurs range from 

approximately 1,500 feet to 5,100 feet in elevation (Oregon Natural Heritage Program 1998, Washington Natural 

Heritage Program 1998). 

At the time of listing in 2001, this species was known from a total of 52 populations in the United States and 

British Columbia, 51 of which were in the United States (7 in Idaho, 7 in Oregon, 9 in Montana, and 28 in 

Washington). The range of individuals in each population ranges from one to several thousand. Much of the 

remaining habitat occupied by Spalding’s catchfly is fragmented, with clusters of populations geographically 

isolated from one another. 

Spalding’s catchfly is a long-lived perennial herb that ranges from 8 to 24 inches in height (Lichthardt 1997). 

The species does not possess rhizomes or other means of vegetative reproduction, and reproduces by seed only 

(Lesica 1992). Plants are typically pollinated by bumblebees, which appear to be critical to population viability 

(Lesica 1993). 
533

Final Environmental Impact Statement: Appendix 5

Spalding’s catchfly was Federally Listed as threatened on October 10, 2001. At the time of listing, designation of 

critical habitat was deemed prudent, but was deferred until resources become available. Large-scale ecological 

changes in the Palouse region over the past century, including agricultural conversion, changes in fire frequency, 

and alterations of hydrology, have resulted in the decline of Spalding’s catchfly. More than 98% of the original 

Palouse prairie habitat has been lost or modified be agricultural conversion, grazing, invasions of non-native 

plant species, altered fire regimes, and urbanization (Noss et al. 1995). In addition, the less accessible canyon 

grasslands have been disturbed by livestock grazing and the invasion of non-native plant species. Threats to this 

species include habitat destruction and fragmentation resulting from agriculture and urban development, grazing 

and trampling by domestic livestock and native herbivores, herbicide treatment, and competition from non-native 

plant species. 

Howell’s Spectacular Thelypody

The primary reference for this section is: USFWS. 1999c. Threatened Status for the Plant Thelypodium howellii 

ssp. spectabilis (Howell’s Spectacular Thelypody). Federal Register 64(101):28393-28403. References cited in 

this section are internal to the above-referenced document. They are included in the Bibliography. 

Howell’s spectacular thelypody (Thelypodium howellii var. spectabilis) occurs in moist, alkaline meadow habitats 

at approximately 3,000 feet to 3,500 feet elevation in northeastern Oregon. The plant is currently known from 

11 sites (five populations) ranging in size from 0.03 to 41 acres in the Baker-Powder River Valley in Baker and 

Union counties. The total occupied habitat for this species is approximately 100 acres, and its range lies entirely 

within a 13-mile radius of Haines, Oregon. Howell’s spectacular thelypody usually grows in valley bottoms 

around woody shrubs that dominate the habitat on the knolls, and along the edge of wet meadow habitat between 

the knolls. Associated species include greasewood, alkali saltgrass, giant wild rye, alkali cordgrass, and alkali 

bluegrass (Kagan 1986). Soils are pluvial-deposited alkaline clays mixed with recent alluvial silts, and are 

moderately well-drained. 

Howell’s spectacular thelypody is an herbaceous biennial that reaches a height of approximately 2 feet, with 

branches arising from near the base of the stem. Flowers are purple and borne on short stalks, and fruits are long, 

slender pods (Greenleaf 1980, Kagan 1986). The taxon may be dependent on periodic flooding, since it appears 

to rapidly colonize areas adjacent to streams that have flooded (Kagan 1986). In addition, this taxon does not 

compete well with encroaching weedy vegetation such as teasel (Davis and Youtie 1995). 

Howell’s spectacular thelypody was listed as threatened on May 26, 1999. Critical habitat has not been 

designated. Factors that threaten this taxon include habitat destruction and fragmentation caused by agricultural 

and urban development, grazing by domestic livestock, competition from non-native vegetation, and alteration of 

wetland hydrology.

Conservation Measures for Vascular Plants 

As dictated in BLM Manual 6840 (Special Status Species Management), local BLM offices are required to 

develop and implement management plans and programs that will conserve listed species and their habitats. In 

addition, NEPA documentation related to treatment activities (i.e., projects) will be prepared that identify any TEP 

plant species or their critical habitat that are present in the proposed treatment areas, and that list the measures that 

will be taken to protect them. 

Many local BLM offices already have management plans in place that ensure the protection of these plant 

species during activities on public land. However, a discussion of these existing plans is outside the scope of this 

programmatic BA. The following general guidance applies to all management plans developed at the local level. 
 534

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Required steps include the following: 

• A survey of all proposed action areas within potential habitat by a botanically qualified biologist, botanist, 

or ecologist to determine the presence/absence of the species. 

• Establishment of site-specific no activity buffers by a qualified botanist, biologist, or ecologist in areas of 

occupied habitat within the proposed project area. To protect occupied habitat, treatment activities would 

not occur within these buffers. 

• Collection of baseline information on the existing condition of TEP plant species and their habitats in the 

proposed project area. 

• Establishment of pre-treatment monitoring programs to track the size and vigor of TEP populations and 

the state of their habitats. These monitoring programs would help in anticipating the future effects of 

vegetation treatments on TEP plant species. 

• Assessment of the need for site revegetation post treatment to minimize the opportunity for noxious weed 

invasion and establishment. 

At a minimum, the following must be included in all management plans: 

• Given the high risk for damage to TEP plants and their habitat from burning, mechanical treatments, and 

use of domestic animals to contain weeds, none of these treatment methods should be utilized within 

330 feet of sensitive plant populations UNLESS the treatments are specifically designed to maintain or 

improve the existing population. 

• Off-highway use of motorized vehicles associated with treatments should be avoided in suitable or 

occupied habitat. 

• Biological control agents (except for domestic animals) that affect target plants in the same genus as TEP 

species must not be used to control target species occurring within the dispersal distance of the agent. 

• Prior to use of biological control agents that affect target plants in the same family as TEP species, the 

specificity of the agent with respect to factors such as physiology and morphology should be evaluated, 

and a determination as to risks to the TEP species made. 

• Post-treatment monitoring should be conducted to determine the effectiveness of the project. 

In addition, the following guidance must be considered in all management plans in which herbicide treatments 

are proposed to minimize or avoid risks to TEP species. The exact conservation measures to be included in 

management plans would depend on the herbicide that would be used, the desired mode of application, and the 

conditions of the site. Given the potential for off-site drift and surface runoff, populations of TEP species on 

lands not administered by the BLM would need to be considered if they are located near proposed herbicide 

treatment sites. 

• Herbicide treatments should not be conducted in areas where TEP plant species may be subject to direct 

spray by herbicides during treatments. 

• Applicators should review, understand, and conform to the “Environmental Hazards” section on 

herbicide labels (this section warns of known pesticide risks and provides practical ways to avoid harm to 

organisms or the environment). 

• To avoid negative effects to TEP plant species from off-site drift, surface runoff, and/or wind erosion, 

suitable buffer zones should be established between treatment sites and populations (confirmed or 

suspected) of TEP plant species, and site-specific precautions should be taken (refer to the guidance 

provided below). 

• Follow all instructions and Standard Operating Procedures to avoid spill and direct spray scenarios into 

aquatic habitats that support TEP plant species. 

• Follow all BLM operating procedures for avoiding herbicide treatments during climatic conditions that 

would increase the likelihood of spray drift or surface runoff. 
535

Final Environmental Impact Statement: Appendix 5

The following conservation measures refer to sites where broadcast spraying of herbicides, either by ground or 

aerial methods, is desired. Manual spot treatment of undesirable vegetation can occur within the listed buffer 

zones if it is determined by local biologists that this method of herbicide application would not pose risks to TEP 

plant species in the vicinity. Additional precautions during spot treatments of vegetation within habitats where 

TEP plant species occur should be considered while planning local treatment programs, and should be included as 

conservation measures in local-level NEPA documentation. 

The buffer distances provided below are conservative estimates, based on the information provided by ERAs, 

and are designed to provide protection to TEP plants. Some ERAs used regression analysis to predict the smallest 

buffer distance to ensure no risks to TEP plants. In most cases, where regression analyses were not performed, 

suggested buffers extend out to the first modeled distance from the application site for which no risks were 

predicted. In some instances the jump between modeled distances was quite large (e.g., 100 feet to 900 feet). 

Regression analyses could be completed at the local level using the interactive spreadsheets developed for the 

ERAs, using information in ERAs and for local site conditions (e.g., soil type, annual precipitation, vegetation 

type, and treatment method), to calculate more precise, and possibly smaller buffers for some herbicides. 

2,4-D 

• Because the risks associated with this herbicide were not assessed, do not spray within 1⁄2 mile of 

terrestrial plant species or aquatic habitats where TEP aquatic plant species occur. 

• Do not use aquatic formulations in aquatic habitats where TEP aquatic plant species occur. 

• Assess local site conditions when evaluating the risks from surface water runoff to TEP plants located 

within 1⁄2 mile downgradient from the treatment area. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Bromacil 

• Do not apply within 1,200 feet of terrestrial TEP plant species. 

• If using a low boom at the typical application rate, do not apply within 100 feet of an aquatic habitat in 

which TEP plant species occur. 

• If using a low boom at the maximum application rate or a high boom, do not apply within 900 feet of an 

aquatic habitat in which TEP plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Chlorsulfuron 

• Do not apply by ground methods within 1,200 feet of terrestrial TEP species. 

• Do not apply by aerial methods within 1,500 feet of terrestrial TEP species. 

• Do not apply by ground methods within 25 feet of aquatic habitats where TEP plant species occur. 

• Do not apply by aerial methods at the maximum application rate within 300 feet of aquatic habitats where 

TEP plant species occur. 

• Do not apply by aerial methods at the typical application rate within 100 feet of aquatic habitats where 

TEP plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Clopyralid 

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which 

TEP plant species occur. 

• Do not apply by ground methods at the typical application rate within 900 of terrestrial TEP species. 

• Do not apply by ground methods at the typical application rate within 1⁄2 mile of terrestrial TEP species. 
 536

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

• Do not apply by aerial methods within 1⁄2 mile of terrestrial TEP species. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Dicamba 

• If using a low boom at the typical application rate, do not apply within 1,050 feet of terrestrial TEP plant 

species. 

• If using a low boom at the maximum application rate, do not apply within 1,050 feet of terrestrial TEP 

plant species. 

• If using a high boom, do not apply within 1,050 feet of terrestrial TEP plant species. 

• Do not apply within 25 feet of aquatic habitats where TEP plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Diflufenzopyr 

• If using a low boom at the typical application rate, do not apply within 100 feet of terrestrial TEP plant 

species. 

• If using a high boom, or a low boom at the maximum application rate, do not apply within 900 feet of 

terrestrial TEP plant species. 

• If using a high boom, do not apply within 500 feet of terrestrial TEP plant species. 

• Do not apply within 25 feet of aquatic habitats where TEP plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Diquat 

• Do not use in aquatic habitats where TEP aquatic plant species occur. 

• Do not apply by ground methods within 1,000 feet of terrestrial TEP species at the maximum application 

rate. 

• Do not apply by ground methods within 900 feet of terrestrial TEP species at the typical application rate. 

• Do not apply by aerial methods within 1,200 feet of terrestrial TEP species. 

Diuron 

• Do not apply within 1,100 feet of terrestrial TEP species. 

• If using a low boom at the typical application rate, do not apply within 900 feet of aquatic habitats where 

TEP aquatic plant species occur. 

• If using a high boom, or a low boom at the maximum application rate, do not apply within 1,1000 feet of 

aquatic habitats where TEP aquatic plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Fluridone 

• Since effects on terrestrial TEP plant species are unknown, do not apply within 1⁄2 mile of terrestrial 

TEP species. 

Glyphosate 

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species. 

• Do not apply by ground methods at the typical application rate within 50 feet of terrestrial TEP plant species. 

• Do not apply by ground methods at the maximum application rate within 300 feet of terrestrial TEP 

plant species. 

• Do not apply by aerial methods within 300 feet of terrestrial TEP plant species. 
537

Final Environmental Impact Statement: Appendix 5

Hexazinone 

• Since the risks associated with using a high boom or an aerial application are unknown, only apply this 

herbicide by ground methods using a low boom within 1⁄2 mile of terrestrial TEP plant species and aquatic 

habitats that support aquatic TEP species. 

• Do not apply by ground methods at the typical application rate within 300 feet of terrestrial TEP plant 

species or aquatic habitats that support aquatic TEP plant species. 

• Do not apply by ground methods at the maximum application rate within 900 feet of terrestrial TEP plant 

species or aquatic habitats that support aquatic TEP plant species. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Imazapic 

• Do not apply by ground methods within 25 feet of terrestrial TEP species or aquatic habitats where TEP 

plant species occur. 

• Do not apply by helicopter at the typical application rate within 25 feet of terrestrial TEP plant species. 

• Do not apply by helicopter at the maximum application rate, or by plane at the typical application rate, 

within 300 feet of terrestrial TEP plant species. 

• Do not apply by plane at the maximum application rate within 900 feet of terrestrial TEP species. 

• Do not apply by aerial methods at the maximum application rate within 300 feet of aquatic TEP species. 

• Do not apply by aerial methods at the typical application rate within 100 feet of aquatic TEP species. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Imazapyr 

• Since the risks associated with using a high boom are unknown, use only a low boom for ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which 

TEP plant species occur. 

• Do not apply at the typical application rate, by ground or aerial methods, within 900 feet of terrestrial TEP 

plant species or aquatic habitats in which aquatic TEP species occur. 

• Do not apply at the maximum application rate, by ground or aerial methods, within 1⁄2 mile of terrestrial 

TEP plant species or aquatic habitats in which aquatic TEP species occur. 

• Do not use aquatic formulations in aquatic habitats where TEP aquatic plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Metsulfuron Methyl 

• Since the risks associated with using a high boom are unknown, use only a low boom for ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which 

TEP plant species occur. 

• Do not apply at the typical application rate, by ground or aerial methods, within 900 feet of terrestrial TEP 

plant species or aquatic habitats in which aquatic TEP species occur. 

• Do not apply at the maximum application rate, by ground or aerial methods, within 1⁄2 mile of terrestrial 

TEP plant species or aquatic habitats in which aquatic TEP species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Diflufenzopyr + Dicamba

• If using a low boom at the typical application rate, do not apply within 100 feet of terrestrial TEP plant 

species. 

• If using a low boom at the maximum application rate, do not apply within 900 feet of terrestrial TEP plant 

species. 

• If using a high boom, do not apply within 900 feet of terrestrial TEP plant species. 
 538

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

• Do not apply within 25 feet of aquatic habitats where TEP plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Picloram 

• Do not apply by ground or aerial methods, at any application rate, within 1⁄2 mile of terrestrial TEP plant 

species. 

• Assess local site conditions when evaluating the risks from surface water runoff to TEP plants located 

within 1⁄2 mile downgradient from the treatment area. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Sulfometuron Methyl 

• Do not apply by ground or aerial methods within 1,500 feet of terrestrial TEP species. 

• Do not apply by ground methods within 900 feet of aquatic habitats where TEP plant species occur, or by 

aerial methods within 1,500 feet of aquatic habitats where TEP plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Tebuthiuron 

• If using a low boom at the typical application rate, do not apply within 25 feet of terrestrial TEP plant 

species. 

• If using a low boom at the maximum application rate or a high boom at the typical application rate, do not 

apply within 50 feet of terrestrial TEP plant species. 

• If using a high boom at the maximum application rate, do not apply within 900 feet of terrestrial TEP 

plant species. 

• Do not apply within 25 feet of aquatic habitats where TEP plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Triclopyr Acid 

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species. 

• Since the risks associated with using a high boom are unknown, use only a low boom during ground 

applications at the maximum application rate of this herbicide within 1⁄2 mile of aquatic habitats in which 

TEP plant species occur. 

• Do not apply by ground methods at the typical application rate within 300 feet of terrestrial TEP plant 

species. 

• Do not apply by aerial methods at the typical application rate within 500 feet of terrestrial TEP plant 

species. 

• Do not apply by ground or aerial methods at the maximum application rate within 1⁄2 mile of terrestrial 

TEP plant species or aquatic habitats in which TEP plant species occur. 

• If applying to aquatic habitats in which aquatic TEP plant species occur, do not exceed the targeted water 

concentration on the product label. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

Triclopyr BEE 

• Since the risks associated with using a high boom are unknown, use only a low boom for ground 

applications of this herbicide within 1⁄2 mile of terrestrial TEP plant species or aquatic habitats in which 

TEP plant species occur. 

• Do not apply by ground methods at the typical application rate within 300 feet of terrestrial TEP plant 

species or aquatic habitats in which TEP plant species occur. 
539

Final Environmental Impact Statement: Appendix 5

• Do not apply by aerial methods at the typical application rate within 500 feet of terrestrial TEP plant 

species or aquatic habitats in which TEP plant species occur. 

• Do not apply by ground or aerial methods at the maximum application rate within 1⁄2 mile of terrestrial 

TEP plant species or aquatic habitats in which TEP plant species occur. 

• Do not use aquatic formulations in aquatic habitats where TEP aquatic plant species occur. 

• In areas where wind erosion is likely, do not apply within 1⁄2 mile of TEP plant species. 

The information provided in Table 4-4 provides a general guideline as to the types of habitats in which treatments 

(particularly fire) may be utilized to improve growing conditions for TEP plant species. However, at the local 

level, the BLM must make a further determination as to the suitability of vegetation treatments for the populations 

of TEP species that are managed by local offices. The following information should be considered: the timing 

of the treatment in relation to the phenology of the TEP plant species; the intensity of the treatment; the duration 

of the treatment; and the tolerance of the TEP species to the particular type of treatment to be used. When 

information about species tolerance is unavailable or is inconclusive, local offices must assume a negative effect 

to plant populations, and protect those populations from direct exposure to the treatment in question. 

Treatment plans must also address the presence of and expected impacts on noxious weeds on the project site. 

These plans must be coordinated with BLM weed experts and/or appropriate county weed supervisors to minimize 

the spread of weeds. In order to prevent the spread of noxious weeds and other unwanted vegetation in occupied 

or suitable habitat, the following precautions should be taken: 

• Cleared areas that are prone to downy brome or other noxious weed invasions should be seeded with an 

appropriate seed mixture to reduce the probability of noxious weeds or other undesirable plants becoming 

established on the site. 

• Where seeding is warranted, bare sites should be seeded as soon as appropriate after treatment, and at a 

time of year when it is likely to be successful. 

• In suitable habitat for TEP species, non-native species should not be used for revegetation. 

• Certified noxious weed seed free seed must be used in suitable habitat, and preference should be given to 

seeding appropriate plant species when rehabilitation is appropriate. 

• Straw and hay bales used for erosion control in suitable habitat must be certified weed- and seed-free. 

• Vehicles and heavy equipment used during treatment activities should be washed prior to arriving at a 

new location to avoid the transfer of noxious weeds. 

When BAs are drafted at the local level for treatment programs, additional conservation measures may be added 

to this list. Where BLM plans that consider the effects of vegetation treatments on TEP plant species already exist, 

these plans should be consulted, and incorporated (e.g., any guidance or conservation measures they provide) into 

local level BAs for vegetation treatments.
 540

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table

A5-1. 

State Director’s Special

Status

Species List – 

Federally

Threatened, Endangered, or Proposed, O

regon January 2008

Scientific Name Common Name Listed Critical Habitat Recovery PlanBirdsEndangered

Pelecanus occidentalis californicus California brown pelican 1970 None Final 1983

Threatened

Brachyramphus marmoratus Marbled murrelet 1992 Designated 1996 Final 1997Charadrius alexandrinus nivosus Western snowy plover

(Pacific Coastal population)

1993 Designated 2005 Final 2007

Strix occidentalis caurina Northern spotted owl 1990 Designated 1992 Draft 2007

FishEndangered

Catostomus microps Modoc sucker 1985 Designated 1985 NoneChasmistes brevirostris Shortnose sucker 1988 Proposed 1994 Final 1993Deltistes luxatus Lost river sucker 1988 Proposed 1994 Final 1993Gila boraxobius Borax lake chub 1980 Final 1982 Final 1987Oncorhynchus mykiss Steelhead

(Upper Columbia River)

1997 Designated 2005 Final 2007

Oncorhynchus tshawytscha Chinook salmon

(Upper Columbia River Spring run)

1999 Designated 2005 Final 2007

Threatened

Catostomus warnerensis Warner sucker 1985 Designated 1985 Final 1998Gila bicolor ssp. Hutton tui chub 1985 None Final 1998Oncorhynchus clarki henshawi Lahontan cutthroat trout 1970 None Final 1995Oncorhynchus kisutch Coho salmon (Lower Columbia River) 2005 None None

(Northern CA / Southern Oregon Coast)

1997 Designated 1999 None

Oncorhynchus mykiss Steelhead (Lower Columbia River) 1998 Designated 2005 None

(Middle Columbia River) 1999 Designated 2005 None(Upper Willamette River) 1999 Designated 2005 None(Snake River Basin) 1997 Designated 2005 None

Oncorhynchus tshawytscha Chinook salmon (Lower Columbia River) 1999 Designated 2005 None

(Upper Willamette River) 1999 Designated 2005 None(Snake River – Fall/Spring/Summer runs)

1992 Designated 1993 None

Rhinichthys osculus ssp. Foskett speckled dace 1985 None Final 1998Salvelinus confluentus Bull trout (Columbia River) 1998 Final 2005 Draft 2002

(Klamath River) 1998 Final 2005 Draft 2002(Coastal / Puget Sound) 1999 Final 2005 Draft 2004
541

Final Environmental Impact Statement: Appendix 5

InvertebratesEndangered

Plebejus icarioides fenderi Fender’s blue butterfly 2000 Proposed 2005 None

Threatened

Branchinecta lynchi Vernal pool fairy shrimp 1994 Designated 2003 Final 2005Speyeria zerene hippolyta Oregon silverspot butterfly 1980 Designated 1980 Final 2001

MammalsEndangered

Canis lupus Gray wolf 2003 None in OR or WA Final 1987Odocoileus virginianus leucurus Columbian white-tailed deer

(Columbia River population)

1967 None Final 1983

Threatened

Lynx canadensis Canada lynx 2000 Designated 2006 None

Vascular PlantsEndangered

Arabis macdonaldiana Macdonald’s rock-cress 1978 None Final 1984Arenaria paludicola Marsh sandwort 1993 None Final 1998Astragalus applegatei Applegate’s milk-vetch 1993 None Final 1998Erigeron decumbens var. decumbens Willamette valley daisy 2000 Proposed 2005 NoneFritillaria gentneri Gentner’s fritillary 1999 None Final 2003Lilium occidentale Western lily 1994 None Final 1998Limnanthes floccosa ssp. grandiflora Large-flowered wooly meadowfoam 2002 None Draft 2006Lomatium bradshawii Bradshaw’s desertparsley 1988 None Final 1993Lomatium cookii Cook’s lomatium 2002 None Draft 2006Plagiobothrys hirtus Rough popcorn flower 2001 None Final 2003Stephanomeria malheurensis Malheur wire-lettuce 1982 Final 1982 Final 1991

Threatened

Castilleja levisecta Golden paintbrush 1997 None Final 2000Howellia aquatilis Water howellia 1994 None Draft 1996Lupinus sulphureus ssp. kincaidii Kincaid’s lupine 2000 Designated 2006 NoneMirabilis macfarlanei Macfarlane’s four o’clock 1979 None Final 2000Sidalcea nelsoniana Nelson’s checkermallow 1993 None Final 1998Silene spaldingii Spalding’s catchfly 2001 None Final 2007Thelypodium howellii ssp. spectabilis Howell’s spectacular thelypody 1999 None Final 2002

Table A5-1. State Director’s Special Status Species List – Federally Threatened, Endangered, or Proposed, Oregon January 2008 (continued)
 542

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM

Scientific name Common name

Amphibians

Aneides flavipunctatus Black salamander

Ascaphus montanus Inland tailed frog

Batrachoseps attenuatus California slender salamander

Batrachoseps wrightorum Oregon slender salamander

Bufo woodhousii Woodhouse’s toad

Dicamptodon copei Cope’s giant salamander

Plethodon larselli Larch mountain salamander

Plethodon stormi Siskiyou mountains salamander

Rana boylii Foothill yellow-legged frog

Rana luteiventris Columbia spotted frog

(Great Basin population)

Rana pipiens Northern leopard frog

Rana pretiosa Oregon spotted frog

Birds

Agelaius tricolor Tricolored blackbird

Ammodramus savannarum Grasshopper sparrow

Bartramia longicauda Upland sandpiper

Branta canadensis occidentalis Dusky canada goose

Branta hutchinsii leucopareia Aleutian canada goose

Bucephala albeola Bufflehead

Centrocercus urophasianus Greater sage-grouse

Charadrius alexandrinus nivosus Western snowy plover

(outside Pacific Coastal population)

Coccyzus americanus Yellow-billed cuckoo

Coturnicops noveboracensis Yellow rail

Cygnus buccinator Trumpeter swan

Cypseloides niger Black swift

Dolichonyx oryzivorus Bobolink

Egretta thula Snowy egret

Elanus leucurus White-tailed kite

Eremophila alpestris strigata Streaked horned lark

Falco peregrinus anatum American peregrine falcon

Fratercula cirrhata Tufted puffin

Haliaeetus leucocephalus Bald eagle

Histrionicus histrionicus Harlequin duck

Larus pipixcan Franklin’s gull

Leucosticte atrata Black rosy finch

Melanerpes lewis Lewis’ woodpecker

Pelecanus erythrorhynchos American white pelican

Picoides albolarvatus White-headed woodpecker

Podiceps auritus Horned grebe

Podiceps grisegena Red-necked grebe

Pooecetes gramineus affinis Oregon vesper sparrow

Progne subis Purple martin

Seiurus noveboracensis Northern waterthrush

Tympanuchus phasianellus columbianus Columbian sharp-tailed grouse
543

Final Environmental Impact Statement: Appendix 5

Fish

Catostomus tahoensis Tahoe sucker

Cottus pitensis Pit sculpin

Gila alvordensis Alvord chub

Gila bicolor eurysoma Sheldon tui chub

Gila bicolor oregonensis Oregon lakes tui chub

Gila bicolor ssp. Summer basin tui chub

Gila bicolor ssp. Catlow tui chub

Gila bicolor thalassina Goose lake tui chub

Lampetra minima Miller lake lamprey

Lampetra tridentata ssp. Goose lake lamprey

Lavinia symmetricus mitrulus Pit roach

Oncorhynchus clarki lewisi Westslope cutthroat trout

Oncorhynchus clarkii Coastal cutthroat trout

(Columbia River / SW Washington)

Oncorhynchus keta Chum salmon

(Pacific Coast)

Oncorhynchus kisutch Coho Salmon

(Oregon Coast)

Oncorhynchus mykiss Steelhead

(Klamath Mountains Province)

Oncorhynchus mykiss Steelhead

(Oregon Coast)

Oncorhynchus mykiss Inland redband trout

Oncorhynchus tshawytscha Chinook salmon

(Southern Oregon / N. California Coast)

Oregonichthys kalawatseti Umpqua chub

Rhinichthys cataractae ssp. Millicoma dace

Richardsonius egregius Lahontan redside shiner

Mammals

Antrozous pallidus Pallid bat

Arborimus longicaudus Oregon red tree vole

(NW Oregon, North of Hwy. 20)

Brachylagus idahoensis Pygmy rabbit

(outside Columbia Basin population)

Corynorhinus townsendii Townsend’s big-eared bat

Enhydra lutris Sea otter

Euderma maculatum Spotted bat

Gulo gulo luteus California wolverine

Martes pennanti Fisher

Myotis thysanodes Fringed myotis

Odocoileus virginianus leucurus Columbian white-tailed deer

(Douglas County population)

Spermophilus washingtoni Washington ground squirrel

Vulpes macrotis Kit fox

Invertebrates

Algamorda newcombiana Newcomb’s littorine snail

Allomyia scotti Scott’s apatanian caddisfly

Boloria bellona Meadow fritillary

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Boloria selene Silver-bordered fritillary

Bombus franklini Franklin’s bumblebee

Callophrys johnsoni Johnson’s hairstreak 

Callophrys polios maritima Hoary elfin 

Chloealtis aspasma Siskiyou short-horned grasshopper

Cicindela hirticollis siuslawensis Siuslaw sand tiger beetle

Colligyrus sp. nov. 1 Columbia duskysnail

Cryptomastix devia Puget oregonian 

Cryptomastix populi Hells canyon land snail

Deroceras hesperium Evening fieldslug

Euphydryas editha taylori Taylor’s checkerspot

Fluminicola insolitus Donner und blitzen pebblesnail

Fluminicola sp. nov. 11 Nerite pebblesnail

Fluminicola sp. nov. 3 Klamath rim pebblesnail

Gliabates oregonius Salamander slug

Gonidea angulata Western ridged mussel

Helisoma newberryi newberryi Great basin ramshorn

Helminthoglypta hertleini Oregon shoulderband

Hemphillia glandulosa Warty jumping-slug

Hesperarion mariae Tillamook westernslug

Juga hemphilli dallesensis Dalles juga 

Juga hemphilli hemphilli Barren juga

Juga hemphilli maupinensis Purple-lipped juga

Lanx klamathensis Scale lanx

Lanx subrotunda Rotund lanx

Lygus oregonae Oregon plant bug

Micracanthia fennica Harney hot spring shore bug

Monadenia chaceana Chase sideband 

Monadenia fidelis beryllica Green sideband

Monadenia fidelis celeuthia Travelling sideband

Monadenia fidelis ssp. nov. Deschutes sideband

Monadenia fidelis ssp. nov. Modoc rim sideband

Ochlodes yuma Yuma skipper 

Oreohelix variabilis sp. nov. Deschutes mountainsnail

Pisidium ultramontanum Montane peaclam

Plebejus saepiolus littoralis Insular blue butterfly

Polites mardon Mardon skipper

Pomatiopsis binneyi Robust walker

Pomatiopsis californica Pacific walker

Pristiloma arcticum crateris Crater lake tightcoil

Pristiloma pilsbryi Crowned tightcoil

Prophysaon vanattae pardalis Spotted tail-dropper

Pterostichus rothi Roth’s blind ground beetle

Pyrgulopsis intermedia Crooked creek springsnail

Pyrgulopsis robusta Jackson lake springsnail

Rhyacophila chandleri A caddisfly

Rhyacophila haddocki Haddock’s rhyacophilan caddisfly

Saldula villosa Hairy shore bug

Speyeria coronis coronis Coronis fritillary

Vespericola sierranus Siskiyou hesperian

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Final Environmental Impact Statement: Appendix 5

Reptiles

Actinemys marmorata marmorata Northwestern pond turtle

Chrysemys picta Painted turtle

Vascular plants

Abronia turbinata Trans montane abronia

Abronia umbellata ssp. breviflora Pink sand-verbena

Achnatherum hendersonii Henderson’s ricegrass

Achnatherum speciosum Desert needlegrass

Achnatherum wallowaensis Wallowa ricegrass

Adiantum jordanii California maiden-hair

Agastache cusickii Cusick’s giant-hyssop

Agoseris elata Tall agoseris

Agrostis howellii Howell’s bentgrass

Allenrolfea occidentalis Iodine bush

Allium geyeri var. geyeri Geyer’s onion

Amsinckia carinata Malheur valley fiddleneck

Anemone oregana var. felix Bog anemone

Arabis koehleri var. koehleri Koehler’s rockcress

Arabis sparsiflora var. atrorubens Sickle-pod rockcress

Arctostaphylos hispidula Hairy manzanita

Argemone munita Prickly-poppy

Arnica viscosa Shasta arnica

Artemisia arbuscula ssp. longicaulis Lahontan sagebrush

Artemisia campestris ssp. borealis var. wormskioldii Northern wormwood

Artemisia papposa Owyhee sagebrush

Artemisia pycnocephala Coastal sagewort

Asplenium septentrionale Grass-fern

Asplenium trichomanes-ramosum Green spleenwort

Astragalus californicus California milk-vetch

Astragalus calycosus King’s rattleweed

Astragalus collinus var. laurentii Laurence’s milk-vetch

Astragalus cusickii var. sterilis Sterile milk-vetch

Astragalus diaphanus var. diurnus South fork john day milk-vetch

Astragalus gambelianus Gambel milk-vetch

Astragalus geyeri var. geyeri Geyer’s milk-vetch

Astragalus mulfordiae Mulford’s milk-vetch

Astragalus peckii Peck’s milk-vetch

Astragalus platytropis Broad-keeled milk-vetch

Astragalus tegetarioides Bastard kentrophyta

Astragalus tyghensis Tygh valley milk-vetch

Bensoniella oregana Bensonia

Botrychium ascendens Upward-lobed moonwort

Botrychium campestre Prairie moonwort

Botrychium crenulatum Crenulate moonwort

Botrychium lineare Slender moonwort

Botrychium lunaria Moonwort

Botrychium minganense Gray moonwort

Botrychium montanum Mountain grape-fern

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Botrychium paradoxum Twin-spiked moonwart

Botrychium pedunculosum Stalked moonwort

Botrychium pumicola Pumice grape-fern

Brodiaea terrestris Dwarf brodiaea

Bupleurum americanum Bupleurum

Calamagrostis breweri Brewer’s reedgrass

Callitriche marginata Winged water-starwort

Calochortus coxii Crinite mariposa-lily

Calochortus greenei Greene’s mariposa-lily

Calochortus howellii Howell’s mariposa-lily

Calochortus indecorus Sexton mt. Mariposa-lily

Calochortus longebarbatus var. peckii Peck’s mariposa-lily

Calochortus macrocarpus var. maculosus Green-band mariposa-lily

Calochortus monophyllus One-leaved mariposa-lily

Calochortus nitidus Broad-fruit mariposa-lily

Calochortus persistens Siskiyou mariposa-lily

Calochortus umpquaensis Umpqua mariposa-lily

Calyptridium roseum Rosy pussypaws

Camassia howellii Howell’s camas

Camissonia graciliflora Slender-flowered evening-primrose

Camissonia pygmaea Dwarf evening-primrose

Cardamine pattersonii Saddle mountain bittercress

Carex abrupta Abrupt-beaked sedge

Carex atrosquama Blackened sedge

Carex brevicaulis Short stemmed sedge

Carex capillaris Hairlike sedge

Carex capitata Capitate sedge

Carex comosa Bristly sedge

Carex constanceana Constances’s sedge

Carex cordillerana Cordilleran sedge

Carex crawfordii Crawford’s sedge

Carex diandra Lesser panicled sedge

Carex dioica var. gynocrates Yellow bog sedge

Carex gynodynama Hairy sedge

Carex idahoa Idaho sedge

Carex klamathensis sp. nov. A sedge

Carex lasiocarpa var. americana Slender sedge

Carex livida Pale sedge

Carex macrochaeta Large-awn sedge

Carex media Intermediate sedge

Carex nardina Spikenard sedge

Carex nervina Sierra nerved sedge

Carex pelocarpa New sedge

Carex pyrenaica ssp. micropoda Pyrenaean sedge

Carex retrorsa Retrorse sedge

Carex scabriuscula Siskiyou sedge

Carex scirpoidea var. stenochlaena Alaskan single-spiked sedge

Carex serratodens Saw-tooth sedge

Carex subnigricans Dark alpine sedge

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Final Environmental Impact Statement: Appendix 5

Carex vernacula Native sedge

Castilleja chlorotica Green-tinged paintbrush

Castilleja fraterna Fraternal paintbrush

Castilleja mendocinensis Mendocino coast indian paintbrush

Castilleja rubida Purple alpine paintbrush

Castilleja thompsonii Thompson’s paintbrush

Caulanthus crassicaulis var. glaber Smooth wild cabbage

Caulanthus major var. gevadensis Slender wild cabbage

Chaenactis xantiana Desert chaenactis

Chaetadelpha wheeleri Wheeler’s skeleton-weed

Cheilanthes covillei Coville’s lip-fern

Cheilanthes feei Fee’s lip-fern

Cheilanthes intertexta Coastal lipfern

Chlorogalum angustifolium Narrow-leaved amole

Cicendia quadrangularis Timwort

Cimicifuga elata var. elata Tall bugbane

Collomia mazama Mt. Mazama collomia

Coptis trifolia Three-leaf goldthread

Cordylanthus maritimus ssp. palustris Point reyes bird’s beak

Corydalis aquae-gelidae Cold-water corydalis

Cryptantha leiocarpa Seaside cryptantha

Cryptantha milo-bakeri Milo baker’s cryptantha

Cryptogramma stelleri Steller’s rockbrake

Cupressus bakeri Baker’s cypress

Cymopterus acaulis var. greeleyorum Greeley’s cymopterus

Cymopterus longipes ssp. ibapensis Ibapah wavewing

Cymopterus nivalis Snowline spring-parsley

Cymopterus purpurascens Purple cymopterus

Cyperus acuminatus Short-pointed cyperus

Cyperus lupulinus ssp. lupulinus A cyperus

Cypripedium fasciculatum Clustered lady’s-slipper

Delphinium bicolor Flathead larkspur

Delphinium leucophaeum White rock larkspur

Delphinium nudicaule Red larkspur

Delphinium nuttallii Nutall’s larkspur

Delphinium pavonaceum Peacock larkspur

Dicentra pauciflora Few-flowered bleedingheart

Dodecatheon austrofrigidum Frigid shootingstar

Dodecatheon pulchellum var. shoshonense Darkthroat shootingstar

Draba howellii Howell’s whitlow-grass

Elatine brachysperma Short seeded waterwort

Eleocharis bolanderi Bolander’s spikerush

Epilobium oreganum Oregon willow-herb

Ericameria arborescens Golden fleece

Erigeron cervinus Siskiyou daisy

Erigeron disparipilus White cushion erigeron

Erigeron engelmannii var. davisii Engelmann’s daisy

Erigeron howellii Howell’s daisy

Erigeron latus Broad fleabane

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Erigeron oreganus Oregon daisy

Eriogonum brachyanthum Short-flowered eriogonum

Eriogonum chrysops Golden buckwheat

Eriogonum crosbyae Crosby’s buckwheat

Eriogonum cusickii Cusick’s buckwheat

Eriogonum hookeri Hooker’s wild buckwheat

Eriogonum lobbii Lobb’s buckwheat

Eriogonum prociduum Prostrate buckwheat

Eriogonum salicornioides Playa buckwheat

Eriogonum umbellatum var. glaberrimum Green buckwheat

Eriophorum chamissonis Russet cotton-grass

Erythronium elegans Coast range fawn-lily

Erythronium howellii Howell’s adder’s-tongue

Eschscholzia caespitosa Gold poppy

Eucephalus gormanii Gorman’s aster

Eucephalus vialis Wayside aster

Filipendula occidentalis Queen-of-the-forest

Fritillaria camschatcensis Black lily

Galium serpenticum ssp. warnerense Warner mt. Bedstraw

Gentiana newberryi Newberry’s gentian

Gentiana plurisetosa Elegant gentian

Gentiana prostrata Moss gentian

Gentiana setigera Waldo gentian

Gentianella tenella ssp. tenella Slender gentian

Geum rossii var. turbinatum Slender-stemmed avens

Gilia millefoliata Seaside gilia

Gratiola heterosepala Boggs lake hedge-hyssop

Hackelia bella Beautiful stickseed

Hackelia cronquistii Cronquist’s stickseed

Hackelia ophiobia Three forks stickseed

Hastingsia bracteosa var. atropurpurea Purple-flowered rush-lily

Hastingsia bracteosa var. bracteosa Large-flowered rush-lily

Heliotropium curassavicum Salt heliotrope

Hieracium horridum Shaggy hawkweed

Horkelia congesta ssp. congesta Shaggy horkelia

Horkelia tridentata ssp. tridentata Three-toothed horkelia

Hydrocotyle verticillata Whorled marsh-pennywort

Hymenoxys lemmonii Cooper’s goldflower

Iliamna latibracteata California globe-mallow

Iris tenax var. gormanii Gorman’s iris

Ivesia rhypara var. shypara Grimy ivesia

Ivesia rhypara var. shellyi Shelly’s ivesia

Ivesia shockleyi Shockley’s ivesia

Juncus triglumis var. albescens Three-flowered rush

Kalmiopsis fragrans Fragrant kalmiopsis

Keckiella lemmonii Bush beardtongue

Kobresia bellardii Bellard’s kobresia

Kobresia simpliciuscula Simple kobresia

Lasthenia ornduffii Large-flowered goldfields

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Final Environmental Impact Statement: Appendix 5

Lathyrus holochlorus Thin-leaved peavine

Lepidium davisii Davis’ peppergrass

Lewisia columbiana var. columbiana Columbia lewisia

Lewisia leana Lee’s lewisia

Limnanthes floccosa ssp. bellingeriana Bellinger’s meadow-foam

Limnanthes floccosa ssp. pumila Dwarf meadow-foam

Limnanthes gracilis var. gracilis Slender meadow-foam

Limonium californicum Western marsh-rosemary

Lipocarpha aristulata Aristulate lipocarpha

Listera borealis Northern twayblade

Lobelia dortmanna Water lobelia

Lomatium engelmannii Englemann’s desert-parsley

Lomatium erythrocarpum Red-fruited lomatium

Lomatium foeniculaceum ssp. fimbriatum Fringed desert-parsley

Lomatium ochocense Ochoco lomatium

Lomatium ravenii Raven’s lomatium

Lomatium suksdorfii Suksdorf’s desert parsley

Lomatium watsonii Watson’s desert parsley

Lotus stipularis Stipuled trefoil

Luina serpentina Colonial luina

Lupinus lepidus var. cusickii Cusick’s lupine

Lupinus nevadensis Nevada lupine

Lupinus tracyi Tracy’s lupine

Lycopodiella inundata Bog club-moss

Lycopodium complanatum Ground cedar

Malacothrix sonchoides Lyrate malacothrix

Meconella oregana White fairypoppy

Mentzelia congesta United blazingstar

Mentzelia mollis Smooth mentzelia

Mentzelia packardiae Packard’s mentzelia

Microseris bigelovii Coast microseris

Microseris howellii Howell’s microseris

Mimulus bolanderi Bolander’s monkeyflower

Mimulus congdonii Congdon’s monkeyflower

Mimulus evanescens Disappearing monkeyflower

Mimulus hymenophyllus Membrane-leaved monkeyflower

Mimulus latidens Broad-toothed monkeyflower

Mimulus tricolor Three-colored monkey-flower

Muhlenbergia minutissima Annual dropseed

Navarretia leucocephala ssp. leucocephala White-flowered navarretia

Nemacladus capillaries Slender nemacladus

Oenothera wolfii Wolf’s evening-primrose

Ophioglossum pusillum Adder’s-tongue

Oxytropis sericea var. sericea White locoweed

Pellaea andromedifolia Coffee fern

Pellaea bridgesii Bridges’ cliff-brake

Pellaea mucronata ssp. mucronata Bird’s-foot fern

Penstemon barrettiae Barrett’s penstemon

Penstemon glaucinus Blue-leaved penstemon

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Penstemon peckii Peck’s penstemon

Perideridia erythrorhiza Red-rooted yampah

Phacelia argentea Silvery phacelia

Phacelia gymnoclada Naked-stemmed phacelia

Phacelia inundata Playa phacelia

Phacelia leonis Siskiyou phacelia

Phacelia lutea var. mackenzieorum Mackenzie’s phacelia

Phacelia minutissima Dwarf phacelia

Phlox hendersonii Henderson’s phlox

Phlox multiflora Many-flowered phlox

Physaria chambersii Chambers’ twinpod

Pilularia americana American pillwort

Plagiobothrys austiniae Austin’s plagiobothrys

Plagiobothrys figuratus ssp. corallicarpus Coral seeded allocarya

Plagiobothrys greenei Greene’s popcorn flower

Plagiobothrys lamprocarpus Shiny-fruited popcorn flower

Plagiobothrys salsus Desert allocarya

Platanthera obtusata Small northern bog-orchid

Pleuropogon oregonus Oregon semaphoregrass

Poa rhizomata Timber bluegrass

Poa unilateralis San francisco bluegrass

Pogogyne floribunda Profuse-flowereed mesa mint

Polystichum californicum California sword-fern

Potamogeton diversifolius Rafinesque’s pondweed

Pyrrocoma racemosa var. racemosa Racemose pyrrocoma

Pyrrocoma radiata Snake river goldenweed

Rafinesquia californica California chicory

Ranunculus austrooreganus Southern oregon buttercup

Ranunculus triternatus Dalles mt. Buttercup

Rhamnus ilicifolia Redberry

Rhynchospora alba White beakrush

Ribes divaricatum var. pubiflorum Straggly gooseberry

Romanzoffia thompsonii Thompson’s mistmaiden

Rorippa columbiae Columbia cress

Rotala ramosior Lowland toothcup

Rubus bartonianus Bartonberry

Salix farriae Farr’s willow

Salix wolfii Wolf’s willow

Saxifraga adscendens ssp. oregonensis Wedge-leaf saxifrage

Saxifragopsis fragarioides Joint-leaved saxifrage

Scheuchzeria palustris var. americana Scheuchzeria

Schoenoplectus subterminalis Water clubrush

Scirpus pendulus Drooping bulrush

Sedum moranii Rogue river stonecrop

Senecio ertterae Ertter’s senecio

Sericocarpus rigidus White-topped aster

Sesuvium verrucosum Verrucose sea-purslane

Sidalcea hickmanii ssp. nov. Hickman’s checkerbloom

Sidalcea hirtipes Bristly-stemmed sidalcea

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Final Environmental Impact Statement: Appendix 5

Sidalcea malviflora ssp. patula Coast checker bloom

Silene hookeri ssp. bolanderi Bolander’s catchfly

Sisyrinchium hitchcockii Hitchcock’s blue-eyed grass

Sisyrinchium sarmentosum Pale blue-eyed grass

Solanum parishii Parish’s horse-nettle

Sophora leachiana Western sophora

Stanleya confertiflora Biennial stanleya

Stellaria humifusa Creeping chickweed

Streptanthus glandulosus Common jewel flower

Streptanthus howellii Howell’s streptanthus

Streptopus streptopoides Kruhsea

Suksdorfia violacea Violet suksdorfia

Sullivantia oregana Oregon sullivantia

Symphoricarpos longiflorus Long-flowered snowberry

Talinum spinescens Spinescent fameflower

Thalictrum alpinum Alpine meadowrue

Thelypodium brachycarpum Short-podded thelypody

Thelypodium eucosmum Arrow-leaf thelypody

Townsendia montana Mountain townsendia

Townsendia parryi Parry’s townsendia

Trifolium douglasii Douglas’ clover

Trifolium leibergii Leiberg’s clover

Trifolium owyheense Owyhee clover

Trillium kurabayashii Siskiyou trillium

Trollius laxus var. albiflorus American globeflower

Utricularia gibba Humped bladderwort

Utricularia minor Lesser bladderwort

Utricularia ochroleuca Northern bladderwort

Viola primulifolia ssp. occidentalis Western bog violet

Wolffia borealis Dotted water-meal

Wolffia columbiana Columbia water-meal

Zigadenus fontanus Small-flowered death camas

Bryophytes

Andreaea schofieldiana Moss

Barbilophozia lycopodioides Liverwort

Bryum calobryoides Moss

Calypogeia sphagnicola Liverwort

Campylopus schmidii Moss

Chiloscyphus gemmiparus Liverwort

Codriophorus depressus Moss

Cryptomitrium tenerum Liverwort

Diplophyllum plicatum Liverwort

Encalypta brevicollis Moss

Encalypta brevipes Moss

Encalypta intermedia Moss

Entosthodon fascicularis Moss

Ephemerum crassinervium Moss

Gymnomitrion concinnatum Liverwort

Helodium blandowii Moss

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Herbertus aduncus Liverwort

Iwatsukiella leucotricha Moss

Jungermannia polaris Liverwort

Kurzia makinoana Liverwort

Limbella fryei Moss

Lophozia laxa Liverwort

Meesia uliginosa Moss

Metzgeria violacea Liverwort

Orthodontium pellucens Moss

Peltolepis quadrata Liverwort

Polytrichum sphaerothecium Moss

Porella bolanderi Liverwort

Pseudocalliergon trifarium Moss

Ptilidium pulcherrimum Liverwort

Rhizomnium nudum Moss

Rhytidium rugosum Moss

Schistidium cinclidodonteum Moss

Schistostega pennata Moss

Splachnum ampullaceum Moss

Tayloria serrata Moss

Tetraphis geniculata Moss

Tetraplodon mnioides Moss

Tomentypnum nitens Moss

Tortula mucronifolia Moss

Trematodon boasii Moss

Tritomaria exsectiformis Liverwort

Fungi

Albatrellus avellaneus

Alpova alexsmithii

Arcangeliella camphorata

Boletus pulcherrimus

Bridgeoporus nobilissimus

Chamonixia caespitosa

Choiromyces venosus

Cortinarius barlowensis

Cudonia monticola

Cystangium idahoensis

Dermocybe humboldtensis

Destuntzia rubra

Gastroboletus imbellus

Gastroboletus vividus

Gomphus kauffmanii

Gymnomyces fragrans

Gymnomyces nondistincta

Helvella crassitunicata

Leucogaster citrinus

Mythicomyces corneipes

Octaviania macrospora

Otidea smithii

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Phaeocollybia californica

Phaeocollybia dissiliens

Phaeocollybia gregaria

Phaeocollybia olivacea

Phaeocollybia oregonensis

Phaeocollybia pseudofestiva

Phaeocollybia scatesiae

Phaeocollybia sipei

Phaeocollybia spadicea

Pseudorhizina californica

Ramaria amyloidea

Ramaria gelatiniaurantia

Ramaria largentii

Ramaria rubella var. blanda

Ramaria spinulosa var. diminutiva 

Rhizopogon chamaleontinus

Rhizopogon ellipsosporus

Rhizopogon exiguus

Rhizopogon inquinatus

Sowerbyella rhenana

Stagnicola perplexa

Thaxterogaster pavelekii

Lichens

Bryoria pseudocapillaris

Bryoria spiralifera

Bryoria subcana

Calicium adspersum

Chaenotheca subroscida

Dermatocarpon meiophyllizum

Erioderma sorediatum

Heterodermia leucomela

Heterodermia sitchensis

Hypogymnia duplicata

Hypotrachyna revoluta

Leioderma sorediatum

Leptogium burnetiae

Leptogium cyanescens

Lobaria linita

Microcalicium arenarium

Niebla cephalota

Pannaria rubiginosa

Pilophorus nigricaulis

Pseudocyphellaria mallota

Ramalina pollinaria

Stereocaulon spathuliferum

Teloschistes flavicans

Texosporium sancti-jacobi 

Tholurna dissimilis

Usnea nidulans

Table A5-2. State Director’s Special Status Species List – Bureau Sensitive, January 2008, Oregon BLM (cont.)
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon
555

Final Environmental Impact Statement: Appendix 6

Appendix 6 – 

Summary of Existing District Resource 

Management Plan Direction for Noxious Weeds

The public lands within the nine BLM Districts in Oregon are covered by 18 Resource Management Plans 

(RMPs) and accompanying environmental impact statements (Figure A6-1). The RMPs contain direction for 

allocated uses, protection for resource values, and objectives for vegetation management. All of the RMPs 

acknowledge the problem of noxious weeds and contain objectives for their control. However, like other 

objectives identified in RMPs, they are not prescriptive with regards to control methods, tools, seasons, or other 

treatment parameters. Following are the sections within each of the 18 RMPs that address noxious weeds and 

their treatment. 

Acronyms specific to this Appendix 

(Acronyms for the entire EIS be found in Volume I, page i of this EIS)

ACS Aquatic Conservation Strategy

AMR Appropriate Management Response

CMPA Cooperative Management and Protection Area

CSNM Cascade Siskiyou National Monument

DEA Diversity Emphasis Area

FONSI Finding of No Significant Impact

GIS Geographic Information System

KFRA Klamath Falls Resource Area

PNC Potential Natural Communities

PRIA Public Rangelands Improvement Act

RA Resource Area

ROD Record of Decision

SMA Special Management Area

T&E Threatened & Endangered

USFWS U.S. Fish and Wildlife Service

References cited in this Appendix are internal to the RMP that the reference is cited in. 

Salem Resource Management Plan, Salem District, 1995, Page 64

Noxious Weeds

Objectives

Contain and/or reduce noxious weed infestations on BLM-administered lands using an integrated pest 

management approach. Some noxious weeds expected to be subject to control are tansy ragwort, Canadian thistle, 

scotch broom, and knapweed.
 556

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Avoid introducing or spreading noxious weed infestations in any areas.

Land Use Allocations

No allocations are made for noxious weeds in the planning process.

Management Actions/Direction

Late-Successional Reserves

Evaluate impacts of nonnative plants (weeds) growing in Late-Successional Reserves.

Develop plans and recommendations for eliminating or controlling nonnative plants (weeds) which adversely 

effect Late-Successional Reserve objectives. Include an analysis of effects of implementing such programs on 

other species or habitats within reserves.

All Land Use Allocations

Continue to survey BLM-administered lands for noxious weed infestations, report infestations to the Oregon 

Department of Agriculture, and work with them to reduce infestations.

Use control methods which do not retard or prevent attainment of Aquatic Conservation Strategy objectives.

Apply integrated pest management methods (e.g., chemical, mechanical, manual and/or biological) in accordance 

with BLM's multistate environmental impact statement for noxious weed control and the related record of decision.

Eugene Resource Management Plan, Eugene District, 1995, Page 102

Noxious Weeds

Objectives

Contain and/or reduce noxious weed infestations on BLM administered land using an integrated pest management 

approach. Some noxious weeds expected to be subject to control are:

Common Name Scientific Name

meadow knapweed

tansy ragwort

Canada thistle

St.-Johns-wort 

Scotch broom

French broom

gorse

diffuse knapweed

spotted knapweed

purple loosestrite

puncture vine

bull thistle

distaff thistle

Centaurea jacea x nigra

Senecio jacobaeae

Cirsium arvense 

Hypericum perforatum

Cytisus scoparius

Cytisus monspessulanus

Ulex europaeus

Centaurea diffusa

Centaurea maculosa

Lythrum salicaria

Tribulus terrestris

Cirsium vulgare

Carthamus lanatus

Avoid introducing or spreading noxious weed infestations in any areas.
557

Final Environmental Impact Statement: Appendix 6

Land Use Allocations

No allocations are made for noxious weeds in the planning process.

Management Actions/Direction

Implement an integrated noxious weed control program. Develop a Prevention Plan and identification of Weed 

Free Areas. Site-specific plans will be prepared for 5-year periods. Control methods or combinations of methods 

proposed are dependent upon size, location, species, and type of weed infestation.

Evaluate impacts of nonnative plants (weeds) growing in all land use allocations.

Develop plans and recommendations for eliminating or controlling nonnative plants (weeds) that adversely affect 

Late-Successional Reserve objectives. Include an analysis of effects of implementing such programs on other 

species or habitats within reserves.

Continue to survey BLM administered land for noxious weed infestations, report infestations to the Oregon 

Department of Agriculture (ODA) and work with ODA to reduce infestations.

Use control methods that do not retard or prevent attainment of Aquatic Conservation Strategy objectives.

Apply integrated pest management methods (chemical, mechanical, manual and/or biological) in accordance with 

BLM's multistate Environmental Impact Statement, Northwest Area Noxious Weed Control Program, 1985, as 

supplemented in 1987, and the related ROD.

Roseburg Resource Management Plan, Roseburg District, 1995, Page 74

Noxious Weeds

Objectives

Contain and/or reduce noxious weed infestations on BLM-administered land using an integrated pest 

management approach.

Avoid introducing or spreading noxious weed infestations in any areas.

Land Use Allocations

No allocations are made for noxious weeds in the planning process.

Management Actions/Direction

Late-Successional Reserves

Evaluate impacts of nonnative plants (weeds) growing in Late-Successional Reserves.

Develop plans and recommendations for eliminating or controlling nonnative plants (weeds) which adversely 

affect Late-Successional Reserve objectives. Include an analysis of effects of implementing such programs on 

other species or habitats within reserves.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

All Land Use Allocations

Continue to survey BLM-administered land for noxious weed infestations, report infestations to the Oregon 

Department of Agriculture, and work with the department to control infestations.

Use control methods which do not retard or prevent attainment of Aquatic Conservation Strategy Objectives.

Apply integrated pest management methods (e.g., chemical, mechanical, manual, and biological) in accordance 

with BLM's 1985 Northwest Area Noxious Weed Control Program Environmental Impact Statement, 1987 

Supplement and respective Records of Decision.

Medford Resource Management Plan, Medford District, 1995, Page 92

Noxious Weeds

Objectives

Contain and/or reduce noxious weed infestations on BLM-administered land using an integrated pest management 

approach. Some noxious weeds expected to be subject to control are:

Common Name

Rush skeleton weed

Tansy ragwort

Yellow star thistle

Scotch broom

Puncturevine

Canada thistle

Leafy spurge

Diffuse knapweed

Purple loosestrife

Scientific Name

Chondrilla juncea

Senecio jacobaea

Centaurea solstitialis

Cytisus scoparius

Tribulus terrestiris

Cirsium arvense

Euphorbia esula

Centaurea diffusa

Lythrum salicaria

Avoid introducing or spreading noxious weed infestations in any areas. Reduce infestations where possible.

Land Use Allocations

None

Management Actions/Direction

Late-Successional Reserves

Evaluate impacts of nonnative plants (weeds) growing in late-successional reserves.

Develop plans and recommendations for eliminating or controlling nonnative plants (weeds) which adversely 

affect late-successional reserve objectives. Include an analysis of effects of implementing such programs on other 

species or habitats within late-successional reserves.
559

Final Environmental Impact Statement: Appendix 6

All Land Use Allocations

Continue to survey BLM-administered land for noxious weed infestations, report infestations to the Oregon 

Department of Agriculture (the department), and work with the department to reduce infestations.

Use control methods that do not retard or prevent attainment of Aquatic Conservation Strategy and riparian 

reserve objectives.

Apply integrated pest management methods (e.g., chemical, mechanical, manual and/or biological) in accordance 

with BLM's multistate environmental impact statement, Northwest Area Noxious Weed Control Program, 1986, as 

supplemented in 1987, and the related ROD.

Place priority on elimination or reduction of noxious weeds occurring within special areas.

Coos Bay Resource Management Plan, Coos Bay District, 1995, Page 72

Noxious Weeds

Objectives

Contain and/or reduce noxious weed infestations on BLM-administered land using an integrated pest management 

approach and avoid introducing or spreading noxious weed infestations in any areas. Some noxious weeds 

expected to be subject to control are:

Common Name

Purple loosestrife

Gorse

Scotch broom

French broom

Yellow starthistle

Tansy ragwort

Maltgrass

Thistles

Scientific Name

Lythrum salicaria

Ulex europaeus

Cytisus scoparius

Genista monospessulana

Centaurea solstitalis

Senecio jacobaea

Nardus stricta

Cirsium spp.

Land Use Allocations

No allocations are made for noxious weeds in the planning process.

Management Actions/Direction - Late-Successional Reserves

Evaluate impacts of non-native plants (weeds) growing in Late-Successional Reserves.

Develop plans and recommendations for eliminating or controlling non-native plants (weeds) that adversely affect 

Late-Successional Reserve objectives. Include an analysis of effects of implementing such programs on other 

species or habitats within reserves.
 560

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Management Actions/Direction - All Land Use Allocations

Continue to survey BLM-administered land for noxious weed infestations, report infestations to the Oregon 

Department of Agriculture, and coordinate with them to reduce infestations.

Use control methods that do not retard or prevent attainment of Aquatic Conservation Strategy Objectives.

Apply integrated pest management methods (e.g., chemical, mechanical, manual, and/or biological) in accordance 

with BLM's multi-state environmental impact statement, Northwest Area Noxious Weed Control Program, as 

supplemented, and the related ROD.

Klamath Falls Resource Management Plan, Lakeview District, 1995, Page 73 

Noxious Weeds 

Objectives 

Avoid introducing or spreading noxious weed infestations in any areas. 

Contain and/or reduce noxious weed infestations on BLM-administered land using an integrated pest management 

approach. Some noxious weeds expected to be subject to control are listed in Table 18. 

Land Use Allocations 

No allocations are made for noxious weeds in the planning process. 

Management Actions/Direction 

All Land Use Allocations 

Continue to survey BLM-administered land for noxious weed infestations, report infestations to the Oregon 

Department of Agriculture, and work with the Department of Agriculture to reduce infestations. 

Use control methods which do not retard or prevent attainment of Aquatic Conservation Strategy Objectives. 

Apply integrated pest management methods (for example, chemical, mechanical, manual, and/or biological) in 

accordance with the BLM's multi-state environmental impact statement, Northwest Area Noxious Weed Control 

Program, 1985, as supplemented in 1987, and the related Record of Decision, and as described in the Noxious 

Weed Strategy for Oregon/Washington (July 1994). Local direction for the planning area is from an integrated 

weed control plan and environmental assessment decision record of July 1993. 

Design management actions to minimize the potential for noxious weed invasion and/or dominance of the affected area. 

Late-Successional/District Designated Reserves

Evaluate impacts of non-native plants (weeds) growing in Late-Successional/District Designated Reserves. 

Develop plans and recommendations for eliminating or controlling non-native plants (weeds) which adversely 

affect Late-Successional/District Designated Reserve objectives. Include an analysis of effects of implementing 

such programs on other species or habitats within reserves. 
561

Final Environmental Impact Statement: Appendix 6

Cascade Siskiyou National Monument Record of Decision and Resource 

Management Plan, Medford District, August 2008, Pages 28, 31, 33, 45, 48, 49, 50, 

56, 58, 67, 81, 83 and 

Appendix F 

Page 28 

Noxious Weeds/Invasive Plants 

Noxious weeds and other non-native species are also a management concern. Canada thistle, yellow starthistle, 

and medusahead are the most common noxious weeds in the OGEA. Bulbous bluegrass, a non-native species, has 

established a strong foothold in all plant communities throughout the monument. Knapweeds show potential for 

spreading within the OGEA, but have so far been restricted to a few roadside populations that have been treated 

with herbicides.

Page 31 

2) Protect or enhance existing habitat for species associated with late-successional forests.

•	 Reduce the threat of high-severity wildland fire or other major disturbance events (stand replacement) to 

areas currently functioning as late-successional habitat. 

•	 Reduce mortality rates of large trees, especially pines, in mid- and late-successional stands with high tree 

densities.

•	 Maintain intact, healthy old-growth structure in forests. Focus treatments on stands where previous 

interventions or events have adversely impacted stand structure.

•	 Reintroduce fire to the landscape through the careful use of prescribed fire.

•	 Reduce the presence and spread of noxious weeds and undesirable non-native species.

Page 33 

Noxious Weed Treatments

Noxious weed treatments are an important component of OGEA management. The tools that can be used to treat 

noxious weeds are described in Appendix F.

Page 45 

Noxious Weeds/Invasive Plants

One of the primary management concerns in the DEA is the proliferation of weeds across the landscape (Map 

15). Spatial analysis in GIS indicates that weeds are associated with roads, sites of acute disturbance (past timber 

harvest, power line corridors, pastures and other tilled areas), and areas of high livestock utilization. Disturbance 

associated with management activities may favor noxious weed invasion; therefore, limiting disturbance appears 

critical to controlling weeds. Some of the major ecological problems associated with grass/shrub/woodlands 

involve annual grasses, and noxious weeds like yellow starthistle and Canada thistle.

Page 48 

1) Control the spread of noxious weeds and other invasive grasses.

•	 Maintain healthy herbaceous plant communities as a barrier to weed invasions. 

•	 Improve conditions of stands that have a mixture of weeds and remnant native herbaceous species.

•	 Eradicate and restore small isolated weed patches to native herbaceous plant domination.

•	 Survey and treat primary travel corridors that serve as vectors for weed spread. 

•	 Isolate and treat large extensive weed areas. 

•	 Develop a long-term restoration plan for weedy areas greater than one acre.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Page 49 

4) Protect monument resources from fires originating on adjacent private lands. Reduce the risk of 

wildland fires spreading to residential properties in the wildland-urban interface.

•	 Manage DEA lands in the WUI in a way that complements the management of adjacent lands in the 

OGEA.

•	 Where possible, reinforce fire hazard reduction activities on private lands by reducing fire hazard on 

adjoining monument lands.

The control of noxious weeds and the improvement of riparian habitats are management objectives that extend 

beyond the boundaries of the DEA. Although these objectives are of particular concern in the DEA, this section 

references rather than repeats the monument’s landscape-wide noxious weed strategy (Appendix F) and the 

Riparian Areas and Aquatic Resources section of this chapter.

Page 50

Weed Abatement

DEA-1 The comprehensive strategy for treating noxious weeds across the monument described in Appendix 

F is adopted. The treatments described in this strategy will not be limited by the pilot studies described below. 

Noxious weed treatments can include manual weeding, biological control, herbicides, prescribed fire or prescribed 

grazing. Focal areas identified for immediate treatments are identified in the weed strategy. Noxious weeds 

will be treated aggressively, contingent on funding. Current funding has allowed a mixture of hand-pulling 

and herbicide treatments on approximately 1,000 to 2,000 acres each year for the past several years. The only 

herbicide currently used in the monument is RODEO® (glyphosate).

Page 56

Noxious Weeds/Invasive Plants

Noxious weeds and other invasive species are present in riparian areas and can displace the native vegetation 

used by aquatic and terrestrial wildlife. Some aquatic noxious weeds, such as purple loosestrife, are present in the 

region and could infest the monument’s riparian ecosystems in the near future.

Page 58

2) Maintain and improve wetland and riparian plant communities and structure (ACS Objective 8).

•	 Promote herbaceous and woody-plant development.

•	 Protect existing late-successional structure in riparian areas.

•	 Promote the development of late-successional structure where appropriate.

•	 Reduce the presence and spread of noxious weeds and other non-native species.

•	 Restore floodplain plant communities and add large wood to floodplains.

•	 Where possible, improve, reconstruct or decommission constructed water sources to allow recovery of the 

former native plant communities.

Page 67

Noxious Weeds

The spread of noxious weeds is a problem throughout the monument, particularly in the Diversity Emphasis Area 

(DEA). Livestock are one vector associated with the spread of noxious weeds: livestock disturbance may increase 

site receptiveness to noxious weed invasions; and livestock movement through areas may also contribute to weed 

spread. To what extent do livestock, as compared to other historic or current disturbance factors, contribute to the 

introduction and/or spread of noxious weeds and undesirable non-native species in the monument?
563

Final Environmental Impact Statement: Appendix 6

Page 81 

Disturbance associated with road construction and subsequent travel over roads provides corridors for the 

spread of noxious weeds and other invasive species. An analysis of the spatial relationship of individual weed 

populations relative to disturbance factors throughout the monument indicate that higher than expected counts of 

weed populations occur within 100 meters (328 feet) of roads. Most of the recorded weed populations within the 

monument are found in close proximity to roads (Map 15).

Page 83 

Road Closures

Seasonal, temporary, and long-term road closures will be used to reduce the open road density in order to protect 

monument resources. Gates and road barriers regulate vehicle access in order to reduce maintenance costs, road 

damage, soil erosion, water quality degradation, the spread of noxious weeds, wildland fire risk, and wildlife 

disturbance. Road closures restrict unauthorized motorized access while allowing access for administrative 

purposes, ROW grants, reciprocal agreements, fire suppression, or other authorized uses. Roads that are closed 

but not decommissioned may be maintained. Seasonal closure of roads with natural surfaces may prevent damage 

during the wet season. Roads may also be closed on a seasonal basis to provide various species with protection 

from motorized traffic during the breeding season or other sensitive times.

APPENDIX F- STRATEGY FOR CONTROLLING THE SPREAD OF NOXIOUS WEEDS AND OTHER 

INVASIVE GRASSES IN THE CASCADE-SISKIYOU NATIONAL MONUMENT

WEED ABATEMENT MANAGEMENT STRATEGY

This appendix describes the strategy and objectives for weed management and provides a framework to control 

the spread of noxious weeds and other invasive grasses in the monument. Although this strategy is specific to the 

Cascade-Siskiyou National Monument (CSNM), it incorporates decisions and guidance provided in the following 

documents:

• The Decision Record, signed June 5, 1998, for the Integrated Weed Management Plan with the associated 

FONSI and Medford District Integrated Weed Management Plan. 

• Instruction Memo OR 91-302 Approved Herbicides for Noxious Weed Control states: “A copy of this 

memorandum should be made a permanent part of your reference copy of the Record of Decision for the 

Northwest Area Noxious Weed Control Program., BLM offices in Oregon and Washington are authorized to 

use these herbicides for noxious weed control in accordance with BLM Manual H-9011-1.”

• The Supplemental Record of Decision, signed May 5, 1987 for the Northwest Area Noxious Weed Control 

Program and the associated Final Environmental Impact Statement (March 1987).

The primary goal of monument management is to maintain, protect, and restore habitat and ecological processes 

critical to richness and abundance of the objects of biological interest for which the monument was proclaimed. 

The proliferation of weeds across the landscape is an obstacle to this goal, and is a management concern 

throughout the monument, especially in the Diversity Emphasis Area. Current objectives for weed management 

have been developed and are described below. Additional weed abatement objectives could be developed through 

research and pilot studies following the adaptive management strategy in Chapter 3 of this RMP.

Spatial analysis in GIS indicates that weeds are associated with roads, sites of acute disturbance (past timber 

harvest, pastures and other tilled areas), and areas of high livestock utilization. Some of the major ecological 

problems associated with grass/shrub/woodlands involve annual grasses, yellow starthistle, and Canada thistle 

displacing the native bunchgrasses found in the monument. Limiting disturbance, therefore, is critical to 

controlling weeds; reduction of soil surface disturbance and increased shading of the soil can help favor the 

growth of native bunchgrasses over noxious weeds and other invasive grasses. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The literature supports the following formulation of a general management strategy incorporating aspects of 

vegetation management and weed control: 

Maintain healthy herbaceous plant communities as a barrier to weed invasions.

• Limit ground-disturbing activities.

• Collect and maintain sources of native grass and forb seed for emergency restoration.

• Sow with native seed where natural or ground-disturbing management activities take place.

Improve condition of stands that have a mixture of weeds and remnant native herbaceous species. 

• Apply manual or spot herbicide treatments. 

• Utilize prescribed burning where appropriate. 

• Restore native species by seeding and/or planting.

• Utilize different grazing strategies to reduce disturbance.

Eradicate and restore small isolated weed patches to native herbaceous plant domination.

• Apply manual or spot herbicide treatment.

• Protect sensitive resources (e.g., wetlands, riparian, and rare plants). If herbicide treatments occur in riparian 

areas, use appropriate herbicides labeled for use in these communities. 

• Seed areas with native grass and forbs.

Survey and treat primary travel corridors that serve as vectors for weed spread.

• Inventory roads and power line corridors. 

• Apply manual or spot herbicide treatments in a systematic manner.

• Work with power companies, the county, and adjacent land owners to reduce periodic disturbance and treat 

weeds on adjacent non-federal land. 

• Re-vegetate treated areas with native grass and forbs.

Isolate and treat large extensive weed areas.

• Minimize soil disturbance and activities that could spread weeds, especially during the wet season.

• Manually or spot spray large patches working from the “outside” in toward the center of the infestation.

• Seed or plant treated locations with native vegetation.

Implement a long-term restoration/management plan for extensive weedy areas (>1 acre) 

• Work with local groups and land owners on noxious weed education and management.

• Identify high-priority treatment areas. 

• Avoid disturbance in large patches.

• Monitor efficacy of treatment(s).

• Apply adaptive management strategy. 

POTENTIAL MANAGEMENT TOOLS 

Education and cooperative partnerships with adjacent landowners and local groups

Educating private land owners within the greater monument boundary on weed issues and treatment strategies is 

paramount to succeeding in controlling and eradicating weeds in the monument. Partnerships and cost-sharing 

projects, moreover, are an efficient way to treat larger landscape areas. Working with adjacent land owners, 

including companies under BLM-permitted activities (e.g., power companies), to prevent the spread of weeds 

across ownership boundaries, and addressing noxious weeds in all land management activities is critical to 

success for the landscape as a whole. Identification booklets, preventive strategies, and recommended treatment 

methods could be a valuable tool for educating and developing partnerships with the monument public. 
565

Final Environmental Impact Statement: Appendix 6

Weed inventories

The use of surveys and inventories contribute to the understanding of the pattern and distribution of weeds within 

the monument, informing ongoing creation of adaptive strategies to control and eliminate such weeds from the 

monument. Surveys identify new species and patches becoming established, such that they become a treatment 

priority before they spread. Focused inventories along identified primary travel corridors and areas of primary 

concern will help target specific weed populations for containment and eradication. 

Weed prevention and treatments

Weed prevention is an important tool to stop the introduction and spread of weeds. Prevention activities can 

reduce the spread and introduction of weeds. These activities include the use of “weed-free” hay, mulch, and 

seed for restoration activities; routinely washing the under-carriage of equipment and vehicles; and keeping 

vehicles and livestock out of heavily infested areas (i.e., reduce disturbance). All available means to effectively 

and efficiently prevent and treat weeds could be used in the monument, including manual weeding, hot foam 

treatments, cultural control, biological control, herbicides, prescribed fire, or grazing. Various treatments are 

discussed below in more detail. 

Manual weeding can effectively remove target species over small- to medium-sized areas. Extensive manual 

weeding can also cause severe damage to micro-topography and microphytic crust through trampling, potentially 

leading to soil surface instability. 

Hot foam treatment is a manual method that utilizes hot steam with foam (formulated from sugar extracts from 

corn and coconut). This treatment is used along roadways and other accessible areas to treat weeds. The steam and 

foam is delivered through a hose with a wand. The foam holds the temperature of the steam for several minutes, 

killing the unwanted vegetation. 

The hot foam method is used on individual weed plants, usually in the rosette stage. The hot steam (212 degrees) 

can kill individual special status plants if treated, but pre-disturbance surveys for special status plants will identify 

plants to be protected. 

Cultural treatments, such as disking or plowing, consist of entire plant removal from a specific site, but do have 

some negative side effects. For example, these treatments require precise timing to control the desired species; the 

acute ground disturbance resulting from these treatments can destroy the remnant native vegetation and promote 

additional weed invasion; and these treatments are difficult to apply in rough or rocky terrain, and will not occur 

in the monument with perhaps the exception of road-beds during decommissioning. Mowing or clipping removes 

the above-ground parts of all plants which is harmless to native bunchgrasses. Mowing can result in light to 

moderate damage to the soil surface, depending on the technique used. Mowing and manual seed head clipping 

can be effective in reducing a single year seed crop, although it does not kill the plants. However, some weeds, 

like starthistle or knapweeds, adapt quickly and will flower closer to the ground following mowing. Mowing 

may require multiple applications and can lead to soil surface instability. Mowing is not likely to be used in the 

monument except perhaps along road edges. 

Bio-control involves the use of insects to control noxious weeds. Insect releases for starthistle in the monument 

are ongoing. This method is only effective in certain locations. Currently, there are no effective bio-controls 

available for other weeds like Canada thistle, Dyer’s woad, cheatgrass or medusahead. As new bio-controls are 

developed in the future, these could be incorporated into the monument’s weed strategy.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Spot spraying with herbicides can target specific plants in specific areas. Herbicide application is the most costeffective weed treatment over large areas and has a low level of soil disturbance. Within the monument, only spot 

spraying or individual plant wicking or wiping with approved chemicals will be used so as to reduce secondary 

harm to other life forms. In riparian areas, only chemicals approved for such areas will be used in weed treatment.

Prescribed fire can be used to reduce cheatgrass, medusahead, and starthistle when the timing and intensity of 

the application is carefully controlled. Prescribed fire also reduces litter build-up and rejuvenates bunchgrasses 

over large areas. While prescribed fire can result in mortality for some woody plant species and lichens, it can also 

serve to rejuvenate others. 

Livestock grazing prescribed at the right time and intensity may allow removal of specific plants and weeds. When 

applied correctly, prescribed grazing may reduce litter and rejuvenate bunchgrasses over large areas. Changing the 

grazing system (e.g., rest-rotation) can serve to allow recovery of the native plant community in heavily utilized 

areas in combination with other treatment methods. Controlled grazing by goats could also be used to control 

starthistle. Insufficient livestock control, however, can result in degradation of adjacent biological resources from 

over-utilization (e.g., in wetlands, springs, and riparian areas). Livestock are also vector for weed spread. 

Vegetative restoration

Native seed application is best used several years following weed control treatments, or in areas of acute ground 

disturbance to prevent weeds from becoming established. Local, adapted native sources of grass and forb species 

have been established. Planting native shrubs and trees, especially along treated riparian areas will help restore 

and maintain healthy plant communities that are resistant to weed invasion. Sowing or planting appropriate native 

plants following under-story burning can re-establish the native plant community and facilitate succession. 

Monitoring

Implementation and validation monitoring of treated areas is critical to the adaptive management process. 

Multiple years are often involved in successful containment and eradication. Successful weed treatments could 

involve different or multiple treatment methods, depending on the local site conditions, the species of targeted 

weeds, and infestation levels. 

A thorough literature review on control measures for noxious weeds can be found in the CSNM Draft Resource 

Management plan, Appendix GG, pages 396-411. 

PRIORITY TREATMENT AREAS

The following list of focus areas is intended to provide a relative prioritization of areas in which to survey and 

treat noxious weeds. These focus areas are of major concern and include the primary travel corridors that can 

function to spread weeds. In general, these are the areas that contain higher densities of weed populations; 

containment and eventual eradication is the objective. The methods for containment and eradication can vary, 

depending on site-specific issues, but, in general, working from the outside into the center of the infestations is the 

model for manual or herbicide treatments. 

Given the annual fluctuations in operational funds to treat weeds, not all areas will be treated annually. New areas 

may be added over time as new populations are discovered; as monitoring shows successful treatment, areas will 

be dropped. The focus areas outlined below are a starting point for controlling noxious weeds in the monument 

and are not intended to be an exhaustive list. Numerous small populations occur that are also important to treat 

before they spread. Knapweeds, for example, are new to the monument. Because they are forming new starts, they 

are a high priority for eradication while populations are small. 
567

Final Environmental Impact Statement: Appendix 6

Infestations in areas utilized by livestock are also high on the list of treatment priorities so as to prevent further 

weed spread and to improve the range condition. Some of these infested areas targeted for weed treatment are 

around seeps, springs, and stock ponds. In some areas, pasture rotation or even rest for several years from grazing 

could be beneficial for recovery while they are treated. 

The focus areas are listed by local name, township, range, and section and/or BLM road segments. Weed 

infestations in adjacent areas on private lands may also be of concern, but are not listed. When possible, 

partnerships with adjacent land owners will be formed to treat weeds within the sub-watershed across ownerships. 

Focus areas (not in priority order):

• Soda Mountain area (T40S, R3E, sections 21, 27, 28)

• Box O ranch area (T40S, R4E, sections 21, 22, 27, 28) 

• Parsnip Lakes (T40S, 3E, section 10)

• Agate Flat, T41S, R4E, sections 6 and 7

• Hobart Lake (T40S, 3e, section 16)

• Eastern Schoheim road (Camp Creek) T41S, R3E, Sections 11, 12 including road 41-2E-10.1

• Scotch Creek RNA (T41S, R3E, section 8,9)

• Jenny Creek (below the Box O to the California Border)

• Mariposa Lily Botanical Area (T41S, R 2E, Sections 8, 9)

• Buck Rock (T40S, 2E, section 11) and roads 39-2E-34 and 40-2E-1

• Chinquapin area (T39S, R3E, sections 23, 26, 35)

As important as actual infested acres are, linear features that serve as vectors for spread also require attention. The 

major roadways coming into the monument and the large PacifiCorp power line corridor that bisect the monument 

are areas that receive some level of periodic disturbance from vehicles, maintenance, and animals. Weeds are 

spreading along these areas, mostly by seed on vehicles, equipment, and animals, including livestock. Wind and 

water also serve as vectors. The periodic disturbance in these areas provides available habitat for weed species 

to become established and then spread to adjacent areas outside the corridors. In some areas, grazing is confined 

to accessible areas along the roads. These linear features need to be continually surveyed and monitored, and as 

infestations are detected, treatment will prevent further weed spread.

Primary travel routes

• PacifiCorp power line and associated access road: (T40S, R3E, section 16, 17, 21, 27, 35; 

• T41S, R3E, sections 1, 12; T41S, R4E, sections 6, 7, 8);

• Tyler Creek Road (BLM road 40-3E-5);

• Upper Jenny Creek and Roads 39-4E-6, -7.5, -8);

• Keene Creek/Lincoln creek/Rancore Pass roads (40-3E-12-12.1);

• Soda Mountain Road (39-3E-32.3);

• Lower Keene creek road (40-3E-12.2, 40-3E-7).

MITIGATING MEASURES

RODEO® (glyphosate) would be used as the primary herbicide in efforts to control noxious weeds listed by 

Oregon Department of Agriculture in the monument. Manual and biological treatments may also occur in 

conjunction with the control efforts. Treatment operations would generally occur between March 15th and 

October 31st. 

The following mitigating measures apply to noxious weed treatments in the monument: 

• Human buffer – None of the products may be applied within 500 feet of any residence or other place of 

human occupation unless the occupant or resident gives their consent in writing.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

• Cropland buffer – Commercial products will not be applied within 100 feet of any cropland.

• 25-foot water buffer – Commercial products applied by ground vehicles equipped with boom sprayers 

will not be applied within 25 feet of any water, flowing/moist (i.e., not dry) streams, springs, and wetlands 

(saturated ground). 

• 10-foot water buffer – Spot treatments with vehicle-mounted handguns or with backpack sprayers will not 

be applied to within 10 feet of water. To add an extra measure of security, a ten-foot buffer “no spray” buffer 

will be respected along all flowing/moist (i.e., not dry) streams, springs, and wetlands. This will eliminate 

the potential for any drift entering waters (Hatterman-Valenti et al. 1995). Ground application within 10 feet 

of any flowing/moist waters will only be done by hand-wicking, wiping, or painting.

• Spraying Prohibitions – Spraying operations will be prohibited when wind velocity exceeds 5 mph; when 

temperatures exceed 80 degrees; when air turbulence would affect spray pattern; or in the event of any 

other kind of adverse weather conditions that could cause the glyphosate to impact non-target plants. These 

requirements would eliminate the potential for spray drift entering the stream channels. 

• Dry season application – The herbicide treatment would occur only during months with little rain. These 

months will almost always be June - September; however, during some years, May can be hot and dry and 

weeds will ripen and begin to set seed early. Moreover, every few years, April can be almost rainless with 

weeks of temperatures in the high 70s. In such situations, glyphosate may be applied during April or May.

• Weather Monitoring – During application, weather conditions will be monitored periodically by trained 

personnel at spray sites. Weather will be monitored frequently during the first days of a prolonged project, 

especially projects within Riparian Reserves. Additional weather monitoring will occur whenever a weather 

change may affect safe placement of the herbicide on the target area. The intent is to ensure that weather 

conditions are within the parameters of this document and/or other regulatory restrictions.

• Communication – Prior to beginning treatment each year, the District Weed Specialist and/or Resource Area 

staff will provide the Resource Area Fisheries Biologists with the following information:

• Locations to be treated

• Riparian Reserves and approximate acres to be treated

• Application method

• Herbicide to be used

• Approximate date of treatment

• “No rain” rule – Glyphosate would never be applied when weather reports predict precipitation within 24 

hours of application, before or after. This ensures that glyphosate would not be washed off by precipitation 

into small rivulets, or enter ground water. From a practical perspective, glyphosate would not be as effective 

if sprayed when rain could wash it off. 

• Mixing and Loading Restrictions – Herbicides will be mixed and loaded into tanks at least 100 feet 

from any stream channel or surface water or at a location where an accidental spill would not flow into or 

contaminate a stream or body of water.

• Tank Washing and Disposal – Spray tanks will not be washed or rinsed within 100 feet of any waters. All 

chemical containers will be disposed of at sites approved by the Oregon State Department of Environmental 

Quality.

• Application Concentrations – RODEO® and ACCORD® will be applied at or below concentrations 

allowable on the labels. 

• Quality Control – Regular testing on field calibration and calculation will take place to prevent gross 

application errors. A licensed/certified herbicide applicator will oversee all spray projects. Dye or a similar 

method will be used to ensure that chemical application occurs only in target areas. (See “Monitoring” 

below.)

• Spill Safety – The BLM contract inspector will review the BLM spill response procedures outlined in the 

BLM manual 9011-1 with each applicator before commencing herbicide application operations. All handoperated application equipment must be leak- and spill-proof.
569

Final Environmental Impact Statement: Appendix 6

• Parsimony Rule – Only the minimum area necessary for the control of noxious weeds will be treated

• Monitoring – Spray cards, dye, or other type of indicator to monitor chemical drift will be used at the 

water’s edge on a small sample (no less than five sites) of riparian treatment areas. These indicators will 

provide visual verification that the application methods are minimizing risk to listed fish species. 

Upper Klamath Basin and Wood River Wetland Resource Management Plan, 

Lakeview District, 1996, Page 18

Noxious Weed Management

Objective: Manage noxious weed species to facilitate restoration and maintenance of desirable plant communities 

and healthy ecosystems; prevent introduction, reproduction, and spread of noxious weeds into and within the 

property; and manage existing populations of noxious weeds to levels that minimize the negative impacts of 

noxious weed invasions. 

Federal agencies are directed to control noxious weeds on federal lands by the Carlson-Foley Act (Public Law 

(PL) 90-583) and the Federal Noxious Weed Act of 1974 (PL 93-629). Noxious weed management on the Wood 

River property will be part of an integrated noxious weed management program as described in the Integrated 

Weed Control Plan and Environmental Assessment (EA) for the Klamath Falls Resource Area (OR-014-93-

09). An appropriate combination of manual, mechanical, chemical, and biological methods, and water level 

manipulation will be used to control noxious weed species. Seasonal timing will be considered in any control 

program. Herbicide use will be in accordance with the program design features outlined in the KFRA Integrated 

Weed Control Plan and EA.

All chemical and some mechanical treatments for noxious weeds will be accomplished through a contract with 

Klamath County or other appropriate contractors, if populations of these species are identified for control. 

Appropriate herbicides will be used for treatment of noxious weeds in or adjacent to wetlands. Biological 

control organisms are supplied and/or distributed by the Oregon Department of Agriculture (ODA) through a 

memorandum of understanding between ODA and the BLM’s Oregon State Office.

Lakeview Resource Management Plan, Lakeview District, 2003, Page 37 

Noxious Weeds and Competing Undesirable Vegetation Management Goal—Control the introduction and 

proliferation of noxious weeds and competing undesirable plant species, and reduce the extent and density of 

established populations to acceptable levels.

Rationale

FLPMA and PRIA direct BLM to “. . . manage public lands according to the principles of multiple-use and sustained 

yield . . .” and “. . . manage the public lands to prevent unnecessary degradation . . . so they become as productive as 

feasible.” The introduction and spread of noxious weeds and undesirable plants within the planning area contributes 

to the loss of rangeland productivity, increased soil erosion, reduced species and structural diversity, loss of wildlife 

habitat, and in some instances may pose a threat to human health and welfare. The “Carlson-Foley Act” (Public Law 

90-583) and the “Federal Noxious Weed Act” (Public Law 93-629) direct weed control on public land. Protection of 

natural resource values depends on educating people about the negative impacts of weeds and what actions agencies 

and individuals can take to prevent weeds from becoming established.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Management Direction

Noxious weed prevention and control will continue to be a priority. Weeds will be controlled in an integrated 

weed management program that includes prevention education and cultural, physical, biological, and chemical 

treatments. Preventative measures such as public education and livestock and wildlife management will be 

employed to maintain or enhance desirable vegetation cover and reduce the distribution and introduction of 

noxious weed seed and plant parts. Mechanical and manual control methods and burning treatments will 

physically remove noxious weeds and unwanted vegetation; biological controls will introduce and cultivate agents 

such as insects and pathogens that naturally limit the spread of noxious weeds; and chemical treatments using 

approved herbicides will be applied where mechanical and/or biological controls are not feasible. Integrated weed 

management will be implemented in cooperation with the State of Oregon, Lake County, private interests, and 

neighboring counties and Federal jurisdictions.

Existing weed management plans for two specific geographic areas, the “Warner Basin Weed Management 

Area Plan” (USDI-BLM 1999g) and the “Abert Rim Weed Management Area Plan” (USDI-BLM 1995e), will 

continue to be implemented. A Greater Abert Weed Management Area will be proposed which will include the 

existing Abert Rim Weed Management Area and the rest of the Lake Abert Subbasin. The plan will be developed 

in consultation and cooperation with private landowners, ODFW, USFWS, U.S. Forest Service (USFS), Tribal 

governments, and other stakeholders in the Lake Abert Basin. The plan will be patterned after the “Warner Basin 

Weed Management Area Plan.”

The weed control program is designed to address the dynamic nature of noxious weeds such as increasing 

numbers of species, different plant physiology for the various species, changing conditions of infestations, and 

changing technologies. Selection of the appropriate control method will be based on such factors as the growth 

characteristics of the target species, size of the infestation, location of the infestation, accessibility of equipment, 

potential impacts to nontarget species, use of the area by people, effectiveness of the treatment on target species, 

and cost. Depending on the plant’s characteristics, these methods may be used individually or in combination and 

may be utilized over several years. Due to the length of seed viability, annual germination of seed from previous 

years, and the characteristics of certain plants, treatments could occur annually for a period of 10 or more years. 

Because weed infestations vary annually due to new introductions, spread of existing infestations, and the results 

of prior year treatments, site-specific reviews of known locations will be conducted annually prior to initiating 

weed treatment activities.

Approved weed control methods, including mechanical, biological, and chemical treatments as identified 

in “Vegetation Treatment on BLM Lands in Thirteen Western States FEIS and ROD” (USDI-BLM 1991b), 

“Supplement to the Northwest Area Noxious Weed Control Program FEIS and ROD” (USDI-BLM 1987a), and 

the “Integrated Noxious Weed Control Program Environmental Assessment” (USDA-BLM 1994d) will continue 

to be applied. Emphasis is on detection of new invaders and inventory and control in proven hot spots such as 

roads, rights-of-way, waterholes, and recreation sites, but with an expanded program to inventory areas that are less 

disturbed, remote, or previously uninventoried. Weed sites will be restored to desirable species. Control efforts will 

be expanded to include any new sites detected. Education and outreachHerbicide treatment: Herbicides that may be 

used are those approved in the “Vegetation Treatment on BLM Lands in Thirteen Western States EIS” (USDI-BLM 

1991b), or any that are approved through an amendment or other agency approval process (see Appendix G of the 

“Proposed RMP/ EIS”(USDI-BLM 2003) for the current list of approved chemicals). Application will take place 

only in accordance with the manufacturer’s label and by qualified/certified applicators.

Methods of application include wiping or wicking, backpack spraying, spraying from a vehicle with a hand gun 

or boom, aerial spraying, or other approved methods. WSAs: Noxious weeds occurring in WSA’s will be treated 

with methods that are in accordance with the provisions of the wilderness IMP (USDI-BLM 1995b).
571

Final Environmental Impact Statement: Appendix 6

Monitoring

Management Goal. Evaluation of treatments will continue in cooperation with the State of Oregon, Lake County, 

and private interests as well as, neighboring counties and Federal jurisdictions. Inventories to identify new 

introductions, distribution, and density of noxious weed populations will be carried out on an annual basis in 

cooperation with these entities. Known noxious weed sites which are identified for treatment will be visited 

each year and evaluated for effectiveness of control. Known sites not identified for treatment will be visited 

on a rotational basis over 3years. All known sites visited will be located with a global positioning system unit, 

photographed, measured, and a determination of the need for future treatment will be made.

Inventories for new noxious weeds will be conducted each year on a 3-year rotation through the resource area. 

All burned areas (natural and prescribed) will be surveyed for noxious weeds for 3 years following the burn. 

Any newly discovered sites will be located with a global positioning system unit, photographed, measured, and 

a determination of the need for future treatment will be made. Ecological trends due to changes in vegetation 

composition over time, in areas dominated by competing undesirable plant species, will be measured through 

periodic rangeland health assessments following procedures outlined in “Interpreting Indicators of Rangeland 

Health” (Shaver et al. 2000). Efforts will be expanded to include areas outside of

Lake County in an effort to “head-off” species that may spread into the resource area.

Appendix D, Best Management Practices, Page A-6

Noxious Weed Management

1) All contractors and land-use operators moving surface-disturbing equipment in or out of weed-infested areas 

should clean their equipment before and after use on public land. 

2) Control weeds annually in areas frequently disturbed such as gravel pits, recreation sites, road sides, livestock 

concentration areas.

3) Consider livestock quarantine, removal, or timing limitations in weed-infested areas.

4) All seed, hay, straw, mulch, or other vegetation material transported and used on public land weed-free zones 

for site stability, rehabilitation, or project facilitation should be certified by a qualified Federal, state or county 

officer as free of noxious weeds and noxious weed seed. All baled feed, pelletized feed, and grain transported into 

weed-free zones and used to feed livestock should also be certified as free of noxious weed seed.

5) It is recommended that all vehicles, including offroad and all-terrain, traveling in or out of weed-infested areas 

should clean their equipment before and after use on public land.

Appendix F, Watershed and Water Quality, Page A-160-161

Noxious Weeds and Competing Undesirable Vegetation Management Goal:

Control the introduction and proliferation of noxious weeds and competing undesirable plant species and reduce 

the extent and density of established populations to acceptable limits.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Three Rivers Resource Management Plan, Burns District, 1992, Page 2-53

Vegetation Program Objective and Rationale

V 1: Maintain, restore or enhance the diversity of plant communities and plant species in abundances and 

distributions, which prevent the loss of specific native plant community types or indigenous plant species within 

the RA. Rationale: FLPMA mandates that public lands be managed in a manner that will protect the quality of the 

ecological resources among others. The BLM is committed to maintaining and enhancing the vegetation of the RA 

in terms of diversity and abundance of species and diversity of plant communities. Such diversity is necessary to 

sustain the variety of uses that BLM managed lands receive.

Allocation/Management Action

V1.6:Apply approved weed control methods including manual, biological and chemical control methods as 

identified in the Weed Control EIS and Burns District Weed Control EA in an integrated pest management 

program to prevent the invasion of noxious weeds into areas presently free of such weeds and to improve the 

ecological status of sites which have been invaded by weeds. Weed control activities will be prioritized and 

funded based on the following criteria, as identified in Burns District’s Weed Control EA:

Priority I: Potential New Invaders - Emphasizes education and awareness;

Priority II: Eradication of New Invaders-Emphasizes eradication, priority funding;

Priority III: Established Infestations - Emphasizes containment and control.

Procedures to Implement/Monitoring Needs

1. Inventory.

2. Prioritize infestations.

3. Apply manual or biological control procedures if appropriate. 

4. Where chemical control is required, evaluate site for impacts, complete and submit pesticide use proposal 

(PUP) to Oregon State Office for approval.

Monitoring Needs:

- Monitoring to determine effectiveness of applied treatments will be done at least annually for the 5 years 

following treatment.

- NEPA documents compliance monitoring, if appropriate.

Andrews Management Unit Resource Management Plan, Record of Decision, Burns 

District, 2005, Page 31

Noxious Weeds

Goal - Control the introduction and proliferation of noxious weeds and reduce the extent and density of 

established populations to acceptable levels.

Objective 1. Treat noxious weeds and inventory for new infestations using the most effective means available, as 

outlined in the Burns District’s Integrated Management Program EA/Decision Record.
573

Final Environmental Impact Statement: Appendix 6

Objective 2. Create public awareness on how to utilize public land without inadvertently spreading 

noxious weeds.

Objective 3. Maintain partnerships with local groups and government agencies to combine efforts in the control 

and prevention of noxious weed infestations.

Rationale

The FLPMA and PRIA direct the BLM to “...manage public lands according to the principles of multiple-use 

and sustained yield...” and to “...manage the public lands to prevent unnecessary degradation...so they become 

as productive as feasible.” The introduction and spread of noxious weeds and undesirable plants within the AMU 

contributes to the loss of rangeland productivity, increased soil erosion, reduced species and structural diversity, 

loss of wildlife habitat, and in some instances may pose a threat to human health and welfare. The Carlson-Foley 

Act (Public Law [PL] 90-583), the Federal Noxious Weed Act (PL 93-629), and the Burns District’s Integrated 

Management Program EA direct noxious weed inventory and control on public land in the AMU. In the future, 

additional weed management direction will come from the new

National Vegetation Management EIS, which is currently being developed. Protection of natural resource values 

depends on educating people about negative impacts of weeds, and actions, which agencies and individuals can 

take to prevent introduction, establishment, and spread of invasive species.

The Burns District Noxious Weed Management Program addresses the dynamic nature of noxious weeds such as 

the increasing number of species, changing conditions of infestations, and changing technologies. Currently, 18 

noxious weed species are known to occur within the AMU, infesting 1,457 acres. Selection of appropriate control 

methods is based on such factors as growth characteristics of the target species, size and location of infestation, 

accessibility/feasibility of equipment, potential impacts to nontarget species, human use of the area, effectiveness 

of the treatment on target species, and cost. In addition, all BLM-authorized activities are evaluated for potential 

to spread or cause new infestations. If necessary, effects from proposed activities shall be mitigated so weed 

establishment is minimal.

Depending on plant characteristics, control methods may be used individually or in combination and may be 

utilized over several years. Control treatments may include cultural, mechanical, chemical, or biological methods. 

Due to the length of seed viability, annual germination of seed from previous years, and characteristics of certain 

plants, treatment could occur annually for a period of ten or more years. Since weed infestations vary annually 

due to new introductions, spread of existing infestations, and results of prior treatments, annual site-specific 

reviews of known locations will be conducted prior to initiating weed treatment activities. 

Herbicides that may be used are those approved in the Vegetation Treatment on BLM Lands in Thirteen 

Western States EIS (1991b), or any that are approved through an amendment or other agency approval process. 

Application will take place only in accordance with the manufacturer’s label and by qualified/certified applicators. 

Methods of application include wiping or wicking, backpack spraying, spraying from a vehicle with a handgun or 

boom, aerial spraying, or other approved methods. 

Noxious weeds occurring in special management areas, including areas with T&E species/habitat, will be treated 

with methods to protect resource values and in accordance with provisions of the Burns District’s Integrated 

Management Program EA directing weed management.

Management Direction

Noxious weed prevention and control will continue to be a priority. Weeds will be controlled in an integrated 

weed management program, which includes prevention, education, and cultural, physical, biological, and 
 574

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

chemical treatments. Preventive measures such as public education and livestock and wildlife management will be 

employed to maintain or promote desirable vegetation cover and reduce distribution and introduction of noxious 

weed seed and plant parts. Mechanical and manual control methods and burning treatments will physically 

remove noxious weeds and unwanted or invasive vegetation; biological controls will introduce and cultivate 

factors such as insects and pathogens that naturally limit the spread of noxious weeds; and chemical treatments 

using approved herbicides will be applied where mechanical or biological controls are not feasible. Periodic 

inventories will detect new infestations. Monitoring the extent of known infestations is key to controlling or 

eradicating noxious weeds. 

Integrated management will be implemented for control of noxious weeds. Control on disturbed areas such as 

roads, ROWs, waterholes, and recreational sites will be emphasized. Priority is given to land with high quality 

natural resource values. Emphasis is on prevention, restoration, research, and expanded efforts to inventory and 

detect new infestations. 

Public education concerning noxious weeds will be expanded to include areas outside Harney County. 

 The Harney County Weed Management partnership will continue.

Monitoring

Noxious weed infestations are a serious threat to all vegetative communities. Monitoring is focused on 

identification of new infestations, spread of existing infestations, and effectiveness of treatment activities. 

Monitoring for new infestations is accomplished through inventories, most commonly in areas previously 

disturbed by fire or other disturbance-causing activities, and also in areas with high resource values where early 

detection is critical to maintain those values. Spread of existing infestations and treatment effectiveness are often 

monitored simultaneously using stem counts, various estimation techniques, and calculations using calibrated 

herbicide application equipment. 

See the Vegetation Monitoring Section for additional monitoring information.

Steens Mountain Cooperative Management and Protection Area Resource 

Management Plan, Record of Decision, Burns District, 2005, Page 32

Noxious Weeds

Goal - Control the introduction and proliferation of noxious weeds and reduce the extent and density of 

established populations to acceptable levels.

Objective 1. Treat noxious weeds and inventory for new infestations using the most effective means available, as 

outlined in the Burns District’s Integrated Management Program EA/Decision Record.

Objective 2. Create public awareness on how to utilize public lands without inadvertently spreading noxious 

weeds.

Objective 3. Maintain partnerships with local groups and government agencies to combine efforts in the control 

and prevention of noxious weed infestations.
575

Final Environmental Impact Statement: Appendix 6

Rationale

The FLPMA and PRIA direct the BLM to “...manage public lands according to the principles of multiple-use 

and sustained yield...” and to “...manage the public lands to prevent unnecessary degradation ...so they become 

as productive as feasible.” Introduction and spread of noxious weeds and undesirable plants within the CMPA 

contributes to loss of rangeland productivity, increased soil erosion, reduced species and structural diversity, loss 

of wildlife habitat, and in some instances may pose a threat to human health and welfare. The Carlson-Foley 

Act (Public Law [PL] 90-583), the Federal Noxious Weed Act (PL 93-629), and the Burns District Integrated 

Management Program EA direct noxious weed inventory and control on public lands in the CMPA. In the future, 

additional weed management direction will come from the new National Vegetation Management EIS, which 

is currently being developed. Protection of natural resource values depends on educating people about negative 

effects of weeds, and actions which agencies and individuals can take to prevent introduction, establishment, and 

spread of invasive species.

Burns District Noxious Weed Management Program addresses the dynamic nature of noxious weeds such as 

increasing number of species, changing conditions of infestations, and changing technologies. There are currently 

17 noxious weed species known to occur within the CMPA, infesting 336 acres. Selection of appropriate control 

methods is based on such factors as growth characteristics of target species, size and location of infestation, 

accessibility/feasibility of equipment, potential impacts to nontarget species, human use of the area, effectiveness 

of treatment on target species, and cost. In addition, all BLM-authorized activities are evaluated for potential to 

spread or cause new infestations. If necessary, effects from proposed

activities shall be mitigated so weed establishment is minimal.

Depending on plant characteristics, control methods may be used individually or in combination and may be 

utilized over several years. Control treatments may include cultural, mechanical, chemical, or biological methods. 

Due to length of seed viability, annual germination of seed from previous years, and characteristics of certain 

plants, treatment could occur annually for a period of ten or more years. Since weed infestations vary annually 

due to new introductions, spread of existing infestations, and results of prior treatments, annual site-specific 

reviews of known locations will be conducted prior to initiating weed treatment activities.

Herbicides that may be used are those approved in “Vegetation Treatment on BLM Lands in Thirteen Western 

States EIS” (1991b), or any approved through an amendment or other agency approval process. Application will 

take place only in accordance with the manufacturer’s label and by qualified/certified applicators. Methods of 

application include wiping or wicking, backpack spraying, spraying from a vehicle with a handgun or boom, 

aerial spraying, or other approved methods.

Noxious weeds occurring in special management areas, including areas with T&E species/habitat, will be 

treated with methods to protect resource values and in accordance with provisions of Burns District Integrated 

Management Program EA directing weed management.

Management Direction

Noxious weed prevention and control will continue to be a priority. Weeds will be controlled in an integrated weed 

management program, which includes prevention, education, and cultural, physical, biological, and chemical 

treatments. Preventive measures such as public education and livestock and wildlife management will be employed 

to maintain or promote desirable vegetation cover and reduce distribution and introduction of noxious weed seed and 

plant parts. Mechanical and manual control methods and burning treatments will physically remove noxious weeds 

and unwanted or invasive vegetation. Biological controls will introduce and cultivate factors such as insects and 

pathogens that naturally limit spread of noxious weeds, and chemical treatments using approved herbicides will be 

applied where mechanical or biological controls are not feasible. Periodic inventories will detect new infestations. 

Monitoring the extent of known infestations is key to controlling or eradicating noxious weeds.
 576

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Integrated management will be implemented for control of noxious weeds. Control on disturbed areas such 

as roads, ROWs, waterholes, and recreational sites will be emphasized. Priority will be given to lands with 

high quality natural resource values. Emphasis is on prevention, restoration, research, and expanded efforts to 

inventory and detect new infestations.

Public education concerning noxious weeds will be expanded to include areas outside Harney County.

The Harney County Weed Management partnership will continue.

Monitoring

Noxious weed infestations are a serious threat to all vegetative communities. Monitoring is focused on 

identification of new infestations, spread of existing infestations, and effectiveness of treatment activities. 

Monitoring for new infestations is accomplished through inventories, most commonly in areas previously 

disturbed by fire or other disturbance causing activities, and also in areas with high resource values where early 

detection is critical to maintain those values. Spread of existing infestations and treatment effectiveness are often 

monitored simultaneously using stem counts, various estimation techniques, and calculations using calibrated 

herbicide application equipment.

See Vegetation Monitoring Section for additional monitoring.

Baker Resource Management Plan, Vale District, 1989, Page 50

(The Baker RMP is scheduled for revision in 2010.) 

Noxious Weed Control 

Infestations of noxious weeds are known to occur on some public lands in the planning area (refer to Figures 2 

and 3). The most common noxious weeds are diffuse, spotted and Russian knapweed, yellow starthistle, Canadian 

thistle, and yellow leafy spurge. Control methods will be proposed and subject to site specific environmental 

analyses consistent with the Record of Decision on BLM’s Northwest Area Noxious Weed Control Program EIS 

and EIS Supplement. Control methods will not be considered unless the weeds are confined to public lands or 

control efforts are coordinated with owners of adjoining infested non-public lands. Proper grazing management 

will be emphasized after control to minimize possible reinfestation. Coordination and cooperation with county 

weed control officers will continue on a regular basis.

Southeastern Oregon Resource Management Plan, Vale District, 2002

Record of Decision, Page 10

Forest and Woodland Management 

Land suitable for timber production will be managed on a sustained yield basis. All forestland and western 

juniper and quaking aspen woodlands will be managed to protect long-term productivity, biological diversity, and 

watershed values. 

The BLM will work with county, state, and Federal agencies to monitor the locations and spread of noxious 

weeds. Noxious weed control will be conducted in accordance with the integrated weed management guidelines 

and design features identified in the “Northwest Area Noxious Weed Control Program EIS” ( USDI-BLM 1985). 
577

Final Environmental Impact Statement: Appendix 6

Control of noxious weeds will occur in SMA’s, if needed, but may include certain restrictions to reduce potential 

impacts on specific values. The BLM will assess land prior to acquisition to determine whether or not noxious 

weeds are present.

Record of Decision, Page 25

Rangeland vegetation includes a mosaic of multiple-aged shrubs, forbs, and native and desirable nonnative 

perennial grasses. Shrub overstories are present in a variety of spatial arrangements and scales across the 

landscape level, including some large contiguous blocks, islands, and corridors. Shrub overstories are present 

in predominantly mature, late structural status. Plant communities not meeting DRFC’s show upward trends in 

condition and structural diversity. Desirable plants continue to improve in health and vigor. New infestations of 

noxious weeds are not common across the landscape, and existing large infestations are declining. Populations 

and habitat of rare plant species are stable or continue to improve in vigor and distribution. 

Record of Decision Page 38 - 40

Rangeland Vegetation 

Objective 1: Restore, protect, and enhance the diversity and distribution of desirable vegetation communities 

including perennial native and desirable introduced plant species. Provide for their continued existence and 

normal function in nutrient, water, and energy cycles. 

Rationale: With passage of FLPMA and the “Public Rangelands Improvement Act” (PRIA) of 1978, objectives 

and priorities for the management of public land vegetation resources were more clearly defined. Guidance 

contained in 43 CFR 4180 of the regulations directs public land management toward the maintenance or 

restoration of the physical function and biological health of rangeland ecosystems. Standards of Rangeland 

Health and Guidelines for Livestock Grazing Management (S&G’s) for public land administered by the BLM in 

Oregon and Washington were approved by the Secretary of the Interior on August 12, 1997 (USDI-BLM 1997). 

This objective will maintain and improve the condition and trend in plant communities that provide wildlife 

habitat, recreation, forage, scientific, scenic, ecological, and water and soil conservation benefits for consumptive 

and nonconsumptive uses. The long-term goal of vegetation management across the landscape is to maintain or 

improve rangeland condition to DRFC’s which meet management objectives, not specifically late-potential natural 

communities (PNC’s) ecological status. 

Management actions authorized or implemented by BLM will influence future vegetation composition. These 

actions may include season, intensity, and duration of livestock grazing within diverse vegetation communities 

(Appendix R); the influence of fire and associated suppression actions; emergency fire rehabilitation and the 

reintroduction of grazing following fire; the use of natural and management-created firebreaks to protect early 

seral communities from frequent fire intervals; rehabilitation and reclamation actions following soil-disturbing 

activities; management of noxious weeds; OHV use; wild horse management; recreational use; and mining. 

Vegetation management has been based on existing inventories delineating the ecological status of vegetation 

communities. Management objectives have been to improve early and middle seral stage vegetation communities 

to attain late seral or PNC within the limits of ecological site potential. Additionally, those vegetation 

communities in late seral stage or PNC have been managed to improve or maintain those desirable conditions. 

The basis for defining ecological status and potential is site descriptions that provide a summary of expected 

species composition and variability within climax vegetation communities, as well as anticipated responses with 

management. The delineation of ecological sites is based on soils and climatic conditions. 
 578

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Management objectives within previous land use plans to attain late-PNC seral communities were based on the 

increased productivity of late-PNC seral communities relative to low seral communities, their greater ability to 

stabilize watersheds, and their improved role in water, nutrient, and energy cycling. Vegetation communities in 

late-PNC seral stage express a mosaic of species composition and structure consistent with site potential and, 

as such, reflect a range of possible plant communities that should meet the objectives defining desired future 

conditions within this land use plan. 

Monitoring: Over the life of this plan, vegetation communities will be monitored to determine progress toward 

attaining DRFC’s. Monitoring to determine success in meeting vegetation management objectives will include 

periodic measurements of plant composition, vigor, and productivity as well as measurement of the amount 

and distribution of plant cover and litter which protects the soil surface from raindrop impact, detains overland 

flow, protects the surface from wind erosion, and retards soil moisture loss through evaporation. Additional data, 

to determine the effectiveness of established tools in meeting objectives, may include herbaceous or woody 

utilization, actual use, and climatic parameters. 

Management Actions: Upland native rangeland communities will be managed to attain a trend toward DRFC’s 

based on management objectives and site potential. Management actions will maintain the condition of those 

native communities where vegetation composition and structure will be consistent with desired conditions and 

natural values. Nonnative seedings in poor or fair condition will be managed to restore production and vigor, 

as well as to improve structural and species diversity consistent with other management objectives. Nonnative 

seedings in good or excellent condition will be managed to maintain seeding health, improve structural and 

species diversity, and ensure continued forage production. Upland shrub cover across the landscape will be 

maintained at moderate to heavy levels of potential for wildlife cover values (see Appendix F, Table F-1) and 

structural diversity in most native vegetation communities where potential exists and in nonnative seedings as 

consistent with other resource management objectives. The frequency, distribution, and ecological integrity of 

native stands of mountain shrubs will be restored and maintained where site potential will support these species. 

Management actions will be implemented to rehabilitate and/or vegetate plant communities that do not meet 

DRFC’s due to dominance by annual, weedy or woody species. Vegetation manipulation projects will be 

implemented primarily to direct trend toward desired conditions, improve structural and species diversity, and 

protect soil, water, and vegetation resources. Emphasis will be placed on the use of prescribed and wildland fire 

to regulate woody species dominance and direct vegetation composition toward desired conditions. Appropriate 

Management Response (AMR) will be implemented on wildland fires to meet vegetation management and 

other objectives. Following wildland fire, priority will be placed on the rehabilitation of rangeland vegetation 

communities held at risk due to dominance by annual and woody species. Seedings will be implemented 

with appropriate mixes of adapted perennial species. Species mixes will be determined on a site-specific basis 

dependent on the probability of successful establishment, risks associated with seeding failure, and other 

management considerations. Preference will be toward the use of native species, though nonnative species may 

be used when better adapted to out-compete established annual species. Use of competitive native species or 

desirable nonnative species will be emphasized in seedings within sites moderately and highly susceptible to 

degradation. Treatment configuration will emphasize the maintenance of natural values as consistent with other 

resource management objectives. 

Areas burned by wildland fire, including those subsequently rehabilitated, will be rested from grazing for one 

full year and through a second growing season at a minimum, or until monitoring data or professional judgment 

indicate that health and vigor of desired vegetation has recovered to levels adequate to support and protect 

upland function. Appropriate grazing use of healthy perennial vegetation communities, or areas dominated by 

annual species, prior to the two growing season limit may be allowed on a case-by-case basis, as consistent with 
579

Final Environmental Impact Statement: Appendix 6

objectives for improving or maintaining rangeland health and other objectives. Annual rangeland vegetation 

communities at risk from frequent fires will be protected through the establishment of appropriate firebreaks 

(such as greenstripping) using both desirable native and nonnative species. An emphasis will be placed on 

the establishment of effective firebreaks using seed mixes and project configurations consistent with resource 

management objectives and goals to maintain natural values.

Record of Decision, Page 40-41

Objective 3: Control the introduction and proliferation of noxious weed species and reduce the extent and density 

of established weed species to within acceptable limits. 

Rationale: FLPMA and PRIA direct BLM to “manage public lands according to the principles of multiple use 

and sustained yield” and “manage the public lands to prevent unnecessary degradation . . . so they become as 

productive as feasible.” “The Carlson-Foley Act” (Public Law 90-583) and the “Federal Noxious Weed Act” 

(Public Law 93-629) direct weed control on public land. The introduction and spread of noxious weeds within 

the planning area cause a decline in rangeland condition, expose soils to accelerated rates of erosion, reduce 

productivity, reduce dominance of individual species and communities of native plants, and reduce economic 

returns to individuals and society. 

Monitoring: In cooperation with the State of Oregon, Malheur County, adjoining counties, and private 

landowners, inventories to identify the distribution and density of identified noxious weeds will continue. 

Inventories will be repeated as necessary in subsequent years following control actions to identify effectiveness. 

Management Actions: The distribution and density of noxious weeds will be reduced through the application of 

approved control methods in an integrated program in cooperation with the State of Oregon, Malheur County, 

Harney County, and other adjoining counties, adjoining private landowners, and other affected agencies and 

interests (see Map SS-1). Control methods will include preventive management to maintain competitive 

vegetation cover and reduce the distribution and introduction of noxious weed seed; manual and mechanical 

methods to physically remove noxious weeds; biological methods to introduce and cultivate factors that naturally 

limit the spread of noxious weeds; cultural practices; and application of chemicals. Target species will include 

those identified by county, state and BLM weed priority lists.

Record of Decision, Appendix O, Page O-7

Noxious Weed Management 

1) All contractors and land-use operators moving surface-disturbing equipment in or out of weed infested areas 

should clean their equipment before and after use on public land. 

2) Control weeds annually in areas frequently disturbed such as gravel pits, recreation sites, road sides, livestock 

concentration areas. 

3) Consider livestock quarantine, removal, or timing limitations in weed infested areas. 

4) All seed, hay, straw, mulch, or other vegetation material transported and used on public land weed-free zones 

for site stability, rehabilitation or project facilitation should be certified by a qualified Federal, State, or county 

officer as free of noxious weeds and noxious weed seed. All baled feed, pelletized feed and grain transported into 

weed-free zones and used to feed livestock should also be certified as free of noxious weed seed. 
 580

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

5) It is recommended that all vehicles, including off-road and all-terrain, traveling in or out of weed infested areas 

should clean their equipment before and after use on public land. 

For additional controls on noxious weed management please refer to the “Northwest Area Noxious Weed Control 

Program” (1987), its associated “Supplemental Environmental Impact Statement” and the “Vale District Fire-Year 

Noxious Weed Control Program Environment Assessment” (1987) with extensions.

John Day Resource Management Plan, 1995, as amended in 2001 through the 

John Day River Management Plan, Two Rivers, John Day and Baker Resource 

Management Plan Amendments, Page 154

Noxious Weeds

‘Noxious’ is a legal classification rather than an ecological term. Plants that can exert substantial negative 

environmental or economic impact can be designated as noxious by various government agencies. The single 

greatest threat to the native rangeland biodiversity and recovery of less than healthy rangelands and watersheds 

is the rapidly expanding invasion of noxious weeds (Asher 1993). Both forestland and rangeland are being 

invaded by noxious weeds at an accelerated rate. Noxious weed encroachment reduces the potential of forest and 

rangeland to support grazing timber production,wildlife use, and viewing by displacing native plant species and 

reducing natural biological diversity; degrading soil integrity, nutrient cycling, and energy flow; and interfering 

with site-recovery that allow a site to recover following disturbance (Quigley and Arbelbide 1997).

The weeds of most concern in the John Day basin are diffuse, spotted and Russian knapweeds; Dalmatian 

toadflax; yellow starthistle; Scotch thistle; purple loosestrife; rush skeletonweed; leafy spurge; poison hemlock; 

and medusahead rye. Weeds of special concern are those beginning to occupy very small niches with just a 

few plants along the high water line, and small patches on islands (mainly diffuse knapweed and Dalmatian 

toadflax) that could spread very rapidly. Also, small infestations of Russian knapweed and dalmatian toadflax are 

becoming more prevalent on the upper, sheltered alluvial flats. This is especially noteworthy for riparian areas 

below the confluence of Thirtymile Canyon at RM 84. In the Clarno area, medusahead rye is prevalent in the 

burned areas on the west side of the river, north and south of Highway 219. It is also prevalent in the Murderer’s 

Creek drainage, a tributary of the South Fork of the John Day River. Diffuse knapweed is found along the road 

right-of-way, south of Clarno. Russian knapweed is prevalent in the Clarno and Bridge Creek areas, and has been 

found in numerous small patches on alluvial flats. Dalmatian toadflax has also been observed on these flats and 

up slope areas, particularly below Thirtymile Canyon. The thistles (Scotch, bull and Canada) and poison hemlock 

commonly occur at the small tributaries near and in

riparian areas. Yellow starthistle has been found in several locations in the Clarno area and is especially prevalent 

in the upper Bridge Creek area near Mitchell. It is also prevalent around the Columbia River near Biggs and the 

Horn Butte ACEC, an area north and east of the John Day/Columbia River confluence. Leafy spurge is found in 

Grant County in the upper watersheds (Fox Valley and Cottonwood Creek) of the North

Fork of the John Day. Four sites were found and treated in 1995, and 18 sites were found and treated between 

Monument and Spray in 1996. A very serious threat is noted in the recent increase of perennial pepperweed in the 

Bridge Creek drainage. Federal and state laws require certain actions be directed at managing noxious weeds. In 

large part, the ‘invasion of alien plants into natural areas’ and the crowding ‘out of native flora and fauna has been 

stealthy and silent, and thus, largely ignored’ (Cheater 1992).
581

Final Environmental Impact Statement: Appendix 6

Two Rivers Resource Management Plan District, Prineville District, 1986, Page 31

Noxious Weed Control 

Infestations of noxious weeds are known to occur on some public lands in the planning area. The most common 

noxious weeds are diffuse, spotted and Russian knapweed, yellow star thistle, tion toadflax, and poison hemlock. 

Control methods will be proposed consistant with the Record of Decision on Northwest Area Noxious Weed 

Control Program EIS. Control methods will then be subjected to site specific environmental analyses tiered to that 

EIS. Control will be considered on public iands where efforts are coordinated with owners of adjoining infested, 

non public lands. Proper grazing management will be emphasized after control to minimize possible reinfestation. 

Coordination and cooperation with county weed control officers will continue on a regular basis.

Brothers/LaPine Resource Management Plan, Record of Decision, Prineville 

District, 1989, Page 126

Noxious Weed Control

Infestations of noxious weeds are known to occur on some public lands in the planning area. Control methods 

including grazing management as well as chemical/mechanical, thermal and biological methods will be proposed 

and subject to site-specific environmental analysis. Control methods will not be considered unless weeds are 

confined to public lands or control efforts are coordinated with owners of adjoining lands. Proper grazing 

management will be emphasized to minimize new invasions of weeds and after control to minimize possible 

reinfestation.

A multi-state BLM environmental impact statement on noxious weed control has been completed for Oregon, 

Washington, Idaho, Montana and Wyoming. A district-wide environmental assessment has also been completed 

by the Prineville BLM to assess specific noxious weed control sites throughout the district. Copies of these 

documents and the related State Director decisions for Oregon and Washington are available for public review at 

the Prineville District Office during normal working hours. 

Upper Deschutes Record of Decision and Resource Management Plan, Prineville 

District, 2005, Page 37

Noxious Weeds

Objective V – 2: Maintain noxious weed-free plant communities or restore plant communities with noxious 

weed infestations through the use of broad-scale integrated weed management strategies. During planning for 

vegetation management and other ground disturbing activities, consider opportunities to manage undesirable 

non-native or invasive species.

Rationale:

The rapid expansion of noxious and other invasive species in portions of the planning area is one of the greatest 

threats to the integrity of native plant communities. Noxious weeds reduce the value of native plant communities 

in several ways.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Guidelines:

1. All land management activities and projects will assess the risk of introducing or spreading weeds. 

Integrated weed management strategies will be incorporated into the planning, design, implementation, 

monitoring, and follow-up actions of all ground-disturbing projects and activity plans.

2. Integrated weed management strategies will incorporate some or all of these objectives: detection, 

inventory, prevention, containment, control, and eradication of noxious weeds. Strategies may also target 

other undesirable plant communities as appropriate and practicable.

3. A balanced ecosystem approach for management of undesirable vegetation may include one or more of 

the following techniques: cultural, manual, mechanical, prescribed fire, competitive seeding, biological, 

and chemical.

4. When possible, grazing management practices will be designed to help control noxious weeds and other 

undesirable plants (such as cheatgrass, medusahead and thistles).

5. Opportunities will be sought to form partnerships with other public agencies and adjacent landowners to 

develop regionally effective and cost-efficient weed management strategies.

6. All treatments will be in accordance with policy and guidelines in the following current or subsequent 

programmatic vegetation management plans: (1) “Vegetation treatment on BLM administered lands in 

thirteen western States” (USDI-BLM, 1991) and (2) “Prineville District Integrated Weed Management 

Environmental Assessment (USDI-BLM 1994).”

7. Where possible, weed management within the planning area will be prioritized as follows:

a. Prevent new infestations by limiting weed seed dispersal, minimizing soil disturbance, and 

properly managing desirable vegetation.

b. Detect and eradicate new invaders.

c. Target roadways, watercourses, campgrounds, utility corridors and other high disturbance areas 

for a prevention and containment program.

d. Emphasize control of large-scale infestations (limiting the spread of noxious weeds and reducing 

the infestation level).

e. Focus initial efforts on small, manageable units with a component of desirable native plants (or 

desirable non-native plants), and then focus on the remaining infestation. Start from the outside 

and work toward the center of the infestation.

8. In high risk areas, prevention measures will include provisions in all land management activities, projects 

and agreements to inspect or certify that vehicles, equipment, livestock, supplies, and materials entering, 

using, or transporting across public lands are free of noxious weed seed or other reproductive parts of 

noxious weeds. Precautions will include ensuring use of weed-free hay/feed for livestock and weed-free 

seed in seeding projects.

9. Consider limiting season of use for ground disturbing activities to prevent the spread of weeds during and 

immediately after the flowering and seed production period.

10. Consider potential for spread of cheatgrass and other undesirable plants that could occur with disturbance by 

land uses or vegetation treatments, particularly within the lower elevation pumice sand community types.
583

Figure

A6-1. 

Resource Management Plan

A

reas

Final Environmental Impact Statement: Appendix 6
 584

Vegetation Treatments Using Herbicides on BLM Lands in Oregon
585

Final Environmental Impact Statement: Appendix 7

Appendix 7 – 

Additional Information about Noxious 

Weeds and Other Invasive Plants

Table of Contents

Oregon State Noxious Weed List............................................................................................................. 586

Common and Scientific Plant Names ...................................................................................................... 589

Noxious Weed Spread Rate References and Calculations....................................................................... 594

Additional Information about the Ecological Damage Caused by Invasive Plants................................. 598
 586

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table A7-1. Oregon State Noxious Weed List: Abundance and Alternative Where Effective Control Becomes

Available - June 2010. This list includes most of the noxious weeds actively managed by the BLM in Oregon, 

but additional plants may be designated on Federal or County lists.

Alternative 

where effective 

control is 

available1 Common Name

Noxious 

State List4

Abundance 

Category2

Number of OR counties where weed Weeds 

targeted for 

biocontrol 

is abundant agents

has limited 

distribution

is not 

known to 

occur

RA3 Starthistle, Iberian A A 0 1 36

RA3 Thistle, Taurian or bull cottonthistle A A 0 1 36

RA3 Thistle, Plumeless A A 0 2 35

RA3 Thistle, Wooly distaff A A 0 3 34

RA3 Yellow floating heart A A 0 3 34

RA3 Starthistle, Purple A A 0 1 26

RA3 Thistle, Smooth distaff A N 0 0 37

RA3 Policemans helmet B A 0 6 31

RA3 Dyers woad B A 0 9 28

RA3 Velvetleaf B A 0 11 26

RA3 Thistle, Scotch B A 15 4 18

RA3 Teasel, cutleaf B B 0 2 35

RA3 Broom, Portugese B B 1 1 35

RA3 Halogeton B B 1 2 33

RA3 Cocklebur, spiny B B 1 10 26

RA3 Thistle, Slender flowered B B 5 6 26 √

RA3 Buffalobur B B 0 15 22

RA3 Spanish heath B C 3 3 31

RA3 Broom, French B C 2 5 30 √

RA3 Ragweed B C 3 7 27

RA3 Thistle, Italian B C 3 6 27

RA3 Jubata grass (Purple Pampas grass) B C 2 9 26

RA3 Mediterranean sage B C 2 9 26

RA3 Thistle, Musk B C 4 10 23 √

RA3 Spurge laurel B C 3 12 22

RA3 Thistle, Milk B C 11 5 21 √

RA3 Houndstongue B C 9 10 18

RA3 Puncturevine B C 18 9 10 √

RA3 English Ivy B D 19 0 18

RA3 Tansy ragwort B D 21 11 5 √

RA3 Knapweed, Diffuse B D 12 21 4 √

RA3 Thistle, Bull B D 37 0 0 √

RA3 Starthistle, Yellow B E 12 14 11 √

RA3 Broom, Scotch B E 21 10 6 √

RA3 Flowering rush B E 37 0 0

RA3 Geranium, Herb Robert B N

RA3 Geranium, Shiny leaf B N

2 Camel thorn A A 0 0 37

2 African rue A A 0 1 36

2 Cordgrass, saltmeadow A A 0 1 36

2 Goatgrass, Barbed A A 0 1 36

2 Hawkweed, Mouse-eared A A 0 1 36

Oregon State Noxious Weed List
587

Final Environmental Impact Statement: Appendix 7

Alternative 

where effective 

control is 

available1 Common Name

Noxious 

State List4

Abundance 

Category2

Number of OR counties where weed Weeds 

targeted for 

biocontrol 

is abundant agents

has limited 

distribution

is not 

known to 

occur

2 Matgrass A A 0 1 36

2 Spurge, Myrtle A A 0 1 36

2 Yellowtuft – murale A A 1 0 36

2 Yellowtuft – corsicum A A 1 0 36

2 Cordgrass, smooth A A 0 2 35

2 Kudzu A A 0 2 35

2 Paterson’s curse A A 0 2 35

2 Knapweed, Squarrose A A 0 3 34

2 Hawkweed, Meadow A A 0 7 30

2 Hawkweed, Orange A A 0 8 29

2 Giant Hogweed A A 0 11 26

2 Skeletonleaf bursage A C 5 6 26

2 Cordgrass, common A N 0 0 37

2 Cordgrass, dense flower A N 0 0 37

2 European Water chestnut A N 0 0 37

2 Goatgrass, Ovate A N 0 0 37

2 Hawkweed, King-devil A N 0 0 37

2 Hawkweed, Yellow A N 0 0 37

2 Purple Nutsedge A N 0 0 37

2 Silverleaf Nightshade A N 0 0 37

2 Syrian bean-caper A N 0 0 37

2 Goatsrue A N

2 White Bryonia A N

2 Oblong spurge A N 0 1 36

2 Common reed A N

2 Biddy-biddy B A 0 3 34

2 Common cruprina B A 0 3 34

2 Parrot’s feather B A 0 3 34

2 Lesser celadine or fig buttercup B A 0 4 33

2 Broom, Spanish B A 0 5 32

2 Common bugloss B A 0 5 32

2 Spurge, Leafy B A 0 9 28 √

2 Garlic mustard B B 1 5 31

2 Knotweed, Himalayan B B 1 7 29

2 Johnsongrass B B 1 20 16

2 Yellow Flag Iris B B 9 14 14

2 Knotweed, Japanese B B 13 16 8

2 Knotweed, Giant B B 13 17 7

2 Purple loosestrife B B 17 16 4 √

2 False brome B C 4 7 26

2 Gorse B C 4 7 26 √

2 Goatgrass, Jointed B C 7 5 25

2 Butterfly bush B C 2 11 24

2 Old man’s beard B C 5 9 23

2 Sulfur cinquefoil B C 5 10 22

2 Whitetop,Hairy B C 4 12 21

2 Knapweed, Russian B C 7 11 19 √

2 whitetop, Lens-podded B C 7 11 19
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Alternative 

where effective 

control is 

available1 Common Name

Noxious 

State List4

Abundance 

Category2

Number of OR counties where weed Weeds 

targeted for 

biocontrol 

is abundant agents

has limited 

distribution

is not 

known to 

occur

2 Toadflax, Yellow B C 1 18 18 √

2 Rush skeletonweed B C 7 12 18 √

2 Whitetop, (Hoary cress) B C 7 13 17

2 Kochia B C 18 2 17

2 Knapweed, Meadow B C 14 9 14 √

2 Toadflax, Dalmation B C 9 16 12 √

2 Knapweed, spotted B C 8 27 2 √

2 Swainsonpea B C

2 Poison hemlock B D 37 0 0

2 St. Johnswort B D 37 0 0 √

2 Blackberry, Himalayan B E 20 16 1

2 Quackgrass B E 35 2 0

2 Thistle, Canada B E 37 0 0 √

2 Field bindweed B N 37 0 0 √

3 Coltsfoot A N 0 0 37

3 Hydrilla A N 0 0 37

3 Texas blueweed A N 0 0 37

3 Creeping yellow cress B A 0 4 33

3 Spikeweed B A 0 6 31

3 Saltcedar B B 1 10 26 √

3 Brazilian or S American waterweed B B 7 12 18

3 Yellow nutsedge B B 16 6 15

3 Perennial peavine B C 3 2 32

3 Watermilfoil, Eurasian B C 2 20 15

3 Perennial pepperweed B D 9 10 18

3 Medusahead rye B D 24 9 4

5 Horsetail, Giant B C 14 3 20

None Japanese dodder A N

None Small broomrape B A 0 7 30

None Dodder B C 13 12 12

RA = Reference Analysis

1

 Determined based on herbicides recommended by PNW Weed Management Handbook, internet sources or comparison of similar species. Other 

herbicides may be effective. Some of the herbicides may be effective only under certain conditions. It is based on individual species response to a 

particular treatment and without regard to infestation size, non-target species, access, slope, follow-up treatments, cost or other key factors in determining 

which treatment method is suitable for a particular infestation or site. Non-herbicide methods of treatment can be used to control species under the 

Reference Analysis when those treatments are feasible. Alternative 2 indicates that at least one of the currently available herbicides could be used to 

obtain some degree of control on these species. Alternatives 3, 4 or 5 indicates that of the treatments currently available none are effective. Information 

in this column, including identification of what species can be controlled with non-herbicide methods under the Reference Analysis, is derived from the 

information in Table A9-2 and the herbicides available under the different alternatives.

2 Abundance Categories indicate number of acres statewide: 

N= Not known A < 1000 B=1,000-10,000 C=10,000-100,000 D= 100,000-1,000,000 E>1,000,000 3 Reference Analysis. Effective on small or new infestations – Manual/mechanical methods kill plants. Not feasible on larger or more established 

infestations.

4

 “A” designated weeds are weeds of known economic importance which occurs in the state in small enough infestations to make eradication or 

containment possible; or is not known to occur, but its presence in neighboring states make future occurrence in Oregon seem imminent. Infestations are 

subject to eradication or intensive control when and where found.

“B” Designated Weeds are those of economic importance and regionally abundant, but which may have limited distribution in some counties. Control 

efforts are generally limited to intensive control at the state, county or regional level as determined on a site specific, case-by-case basis. Where 

implementation of a fully integrated statewide management plan is not feasible, biological control (when available) is the primary control method.

“T” Designated Weeds are priority noxious weeds designated by the Oregon State Weed Board as a target for which the ODA will develop and implement 

a statewide management plan. “T” designated noxious weeds are species selected from either the “A” or “B” list. 
589

Final Environmental Impact Statement: Appendix 7

Table A7-2. Common and Scientific Plant Names of Plants Potentially Requiring Management

Common Name Scientific Name Duration1 Growth 

Form Family Vegetation Type

African rue Peganum harmala P forb Zygophyllaceae Noxious Weed

Alder Alnus P shrub, tree Betulaceae Native Plant

Annual fescues Vulpia A graminoid Poaceae Invasive Plant

Babysbreath Gypsophila paniculata P forb Caryophyllaceae Invasive Plant

Bear’s breeches Acanthus mollis P forb Acanthaceae Invasive Plant

Biddy-biddy Acaena novae-zelandica P shrub Rosaceae Noxious Weed

Big leaf maple Acer macrophyllum P tree Aceraceae Native Plant

Big sagebrush Artemesia tridentata P shrub Asteraceae Native Plant

Bird cherry Prunus avium P tree Rosaceae Invasive Plant

Birdfoot trefoil Lotus corniculatus P forb Fabaceae Invasive Plant

Black henbane Hyoscyamus niger A, B forb Solanaceae Invasive Plant

Black locust Robinia pseudoacacia P tree Fabaceae Invasive Plant

Blackberry, Evergreen Rubus laciniatus P vine Rosaceae Invasive Plant

Blackberry, Himalayan Rubus armeniacus P shrub Rosaceae Noxious Weed

Blackberry, Himalayan Rubus discolor P shrub Rosaceae Noxious Weed

Blackgrass Alopecurus myosuroides A graminoid Poaceae Invasive Plant

Blackthorn Prunus spinosa P tree Rosaceae Invasive Plant

Bouncing bet Saponaria officinalis P forb Caryophyllaceae Invasive Plant

Brazilian or S American 

waterweed Egeria densa P aquatic forb Hydrocharitaceae Noxious Weed

Bristly dog’s-tail Cynosurus echinatus A graminoid Poaceae Invasive Plant

Broom, French Genista monspessulana P shrub Fabaceae Noxious Weed

Broom, Portugese Cytisus striatus P shrub Fabaceae Noxious Weed

Broom, Scotch Cytisus scoparius P shrub Fabaceae Noxious Weed

Broom, Spanish Spartium junceum P shrub Fabaceae Noxious Weed

Buffalobur Solanum rostratum A forb Solanaceae Noxious Weed

Bur buttercup Ceratocephala testiculata A forb Ranunculaceae Invasive Plant

Burdock, common Arctium minus B forb Asteraceae Invasive Plant

Burnweed Erectites minima A, P forb Asteraceae Invasive Plant

Butterfly bush Buddleja davidii P shrub Buddlejaceae Noxious Weed

Camel thorn Alhagi maurorum P shrub Fabaceae Noxious Weed

Cereal rye Secale cereal A graminoid Poaceae Invasive Plant

Cheatgrass Bromus tectorum A graminoid Poaceae Invasive Plant

Chicory Cichorium intybus B,P forb Asteraceae Invasive Plant

Climbing nightshade Solanum dulcamara P forb Solanaceae Invasive Plant

Clover spp Trifolium P forb Fabaceae Invasive Plant

Cocklebur, rough Xanthium strumarium A forb Asteraceae Invasive Plant

Cocklebur, spiny Xanthium spinosum A forb Asteraceae Noxious Weed

Coltsfoot Tussilago farfara P forb Asteraceae Noxious Weed

Common bugloss Anchusa officinalis P forb Boraginaceae Noxious Weed

Common cruprina Crupina vulgaris A forb Asteraceae Noxious Weed

Common knotweed Polygonum aviculare A,P forb Polygonaceae Invasive Plant

Common reed Phragmites australis P Graminoid Poaceae Noxious Weed

Common mullein Verbascum thapsus B forb Scrophulariaceae Invasive Plant

Common and Scientific Plant Names
 590

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Common Name Scientific Name Duration1 Growth 

Form Family Vegetation Type

Common Pear Pyrus communis P tree Rosaceae Invasive Plant

Common velvet-grass Holcus lanatus P graminoid Poaceae Invasive Plant

Conifers various P tree Pinaceae Native Plant

Cordgrass, common Spartina anglica P graminoid Poaceae Noxious Weed

Cordgrass, dense flower Spartina densiflora P graminoid Poaceae Noxious Weed

Cordgrass, saltmeadow Spartina patens P graminoid Poaceae Noxious Weed

Cordgrass, smooth Spartina alternifolia P graminoid Poaceae Noxious Weed

Creeping buttercup Ranunculus repens P forb Ranunculaceae Invasive Plant

Creeping yellow cress Rorippa sylvestris P forb Brassicaceae Noxious Weed

Crested dog’s-tail grass Cynosurus cristatus P graminoid Poaceae Invasive Plant

Dandelion Taraxacum officinale P forb Asteraceae Invasive Plant

Dense silkybent Apera interrupta A graminoid Poaceae Invasive Plant

Dodder Cuscuta spp. A,B,P forb Cuscutaceae Noxious Weed

Dyers woad Isatis tinctoria B, P forb Brassicaceae Noxious Weed

Elecampane inula Inula helenium P forb Asteraceae Invasive Plant

Elodea Elodea P aquatic forb Hydrocharitaceae Invasive Plant

English holly Ilex aquifolium P tree Aquifoliaceae Invasive Plant

English Ivy Hedera helix P vine Araliaceae Noxious Weed

European beach grass Ammophila arenaria P graminoid Poaceae Invasive Plant

European centaury Centaurium erythraea A, B forb Gentianaceae Invasive Plant

European Water chestnut Trapa natans P aquatic Trapaceae Noxious Weed

Evergreen huckleberry Vaccinium ovatum P shrub Ericaceae Native Plant

Feverfew Tanacetum parthenium P forb Asteraceae Invasive Plant

Field bindweed Convolvulus arvensis P forb Convolvulaceae Noxious Weed

Field mustard Brassica rapa A,B forb Brassicaceae Invasive Plant

Field sowthistle Sonchus arvensis P forb Asteraceae Invasive Plant

False brome Brachypodium sylvaticum P graminoid Poaceae Noxious Weed

Flowering rush Butomus umbellatus P Forb Butomaceae Noxious Weed

Garden cornflower or 

bachelor buttons Centaurea cyanus A forb Asteraceae Invasive Plant

Garden vetch Vicia sativa ssp. nigra A vine Fabaceae Invasive Plant

Garlic mustard Alliaria petiolata A, B forb Brassicaceae Noxious Weed

Geranium, Herb Robert Geranium robertianum A, B Forb Geraniaceae Noxious Weed

Gerranium, Shinyleaf Geranium lucidum A, B Forb Geraniaceae Noxious Weed

Giant Hogweed Heracleum mantegazzianum P forb Apiaceae Noxious Weed

Goatgrass, Barbed Aegilops triuncialis A graminoid Poaceae Noxious Weed

Goatgrass, Bulbed Aegilops ventricosa A graminoid Poaceae Invasive Plant

Goatgrass, Jointed Aegilops cylindrica A graminoid Poaceae Noxious Weed

Goatgrass, Ovate Aegilops ovata A graminoid Poaceae Noxious Weed

Goatgrass, Tausch’s Aegilops tauschii A graminoid Poaceae Invasive Plant

Goatsrue Galea officinalis P forb, subshrub Fabaceae Noxious Weed

Gorse Ulex europaeus P shrub Fabaceae Noxious Weed

Grasses A,P graminoid Poaceae Native Plant

Grasses, escaped Various NA graminoid Poaceae Invasive Plant

Halogeton Halogeton glomeratus A forb Chenopodiaceae Noxious Weed

Harding grass Phalaris aquatica P graminoid Poaceae Invasive Plant

Hawkweed, common Hieracium lachenallii P forb Asteraceae Invasive Plant

Hawkweed, King-devil Hieracium piloselloides P forb Asteraceae Noxious Weed
591

Final Environmental Impact Statement: Appendix 7

Common Name Scientific Name Duration1 Growth 

Form Family Vegetation Type

Hawkweed, Meadow Hieracium caespitosum P forb Asteraceae Noxious Weed

Hawkweed, Mouse-eared Hieracium pilosella P forb Asteraceae Noxious Weed

Hawkweed, Orange Hieracium aurantiacum P forb Asteraceae Noxious Weed

Hawkweed, Yellow Hieracium fendleri P forb Asteraceae Invasive Plant

Hawkweed, Yellow Hieracium floribundum P forb Asteraceae Noxious Weed

Hawthorn, Oneseed Crataegus monogyna P tree Rosaceae Invasive Plant

Hawthorn, Smooth Crataegus laevigata P tree, shrub Rosaceae Invasive Plant

Hazel Corylus cornuta P shrub Betulaceae Native Plant

Herb Robert Geranium robertianum A, B forb Geraniaceae Invasive Plant

Horehound Marrubium vulgare P forb Lamiaceae Invasive Plant

Horsetail, Giant Equisetum telmateia P forb Equisetaceae Noxious Weed

Houndstongue Cynoglossum officinale B forb Boraginaceae Noxious Weed

Hydrilla Hydrilla verticillata P aquatic forb Hydrocharitaceae Noxious Weed

Italian ryegrass Lolium perenne ssp. 

multiflorum A,P graminoid Poaceae Invasive Plant

Japanese dodder Cascuta japonica A vine Cuscutacea Noxious Weed

Johnsongrass Sorghum halepense P graminoid Poaceae Noxious Weed

Jubata grass (Purple Pampas 

grass) Cortaderia jubata P graminoid Poaceae Noxious Weed

Knapweed, Diffuse Centaurea diffusa A, B, P forb Asteraceae Noxious Weed

Knapweed, Meadow Centaurea debeauxii P forb Asteraceae Noxious Weed

Knapweed, Russian Acroptilon repens P forb Asteraceae Noxious Weed

Knapweed, spotted Centaurea stoebe B, P forb Asteraceae Noxious Weed

Knapweed, Squarrose Centaurea triumfetti P forb Asteraceae Noxious Weed

Knotweed, Bohemian Polygonum bohemicum P forb Polygonaceae Invasive Plant

Knotweed, Giant Polygonum sachalinense P forb Polygonaceae Noxious Weed

Knotweed, Himalayan Polygonum polystachyum P forb Polygonaceae Noxious Weed

Knotweed, Japanese Polygonum cuspidatum P forb Polygonaceae Noxious Weed

Kochia Kochia scoparia A forb Chenopodiaceae Noxious Weed

Kudzu Pueraria montana var lobata P vine Fabaceae Noxious Weed

Lepyrodiclis Lepyrodiclis holosteoides A forb Caryophyllaceae Invasive Plant

Lesser celadine or fig 

buttercup Ranunculus ficaria P forb Ranunculaceae Noxious Weed

Lesser hawkbit Leontodon taraxacoides A, B, P forb Asteraceae Invasive Plant

Madrone Arbutus menziesii P tree Ericaceae Native Plant

Marestail Conyza canadensis A, B forb Asteraceae Invasive Plant

Matgrass Nardus stricta P graminoid Poaceae Noxious Weed

Mediterranean sage Salvia aethiopis B forb Lamiaceae Noxious Weed

Medusahead rye Taeniatherum caput-medusae A graminoid Poaceae Noxious Weed

Mutiflora rose Rosa multiflora P shrub Rosaceae Invasive Plant

Narrowleaf plantain Plantago lanceolata A,B,P forb Plantaginaceae Invasive Plant

North Africa grass Ventenata dubia A graminoid Poaceae Invasive Plant

Oblong spurge Euphorbia oblongata P forb Euphorbiaceae Noxious Weed

Ocean spray Holodiscus discolor P shrub Rosaceae Native Plant

Old man’s beard Clematis vitalba P vine Ranunculaceae Noxious Weed

Orchardgrass Dactylis glomerata P graminoid Poaceae Invasive Plant

Oxeye daisy Leucanthemum vulgare P forb Asteraceae Invasive Plant
 592

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Common Name Scientific Name Duration1 Growth 

Form Family Vegetation Type

Pacific Rhododendron Rhododendron 

macrophyllum P shrub Ericaceae Native Plant

Pampas grass Cortaderia selloana P graminoid Poaceae Invasive Plant

Parrot’s feather Myriophyllum aquaticum P aquatic forb Haloragaceae Noxious Weed

Paterson’s curse Echium vulgare A, B, P forb Boraginaceae Invasive Plant

Paterson’s curse Echium plantagineum A,B forb Boraginaceae Noxious Weed

Pennyroyal Mentha pulegium P forb Lamiaceae Invasive Plant

Perennial peavine Lathyrus latifolius P forb Fabaceae Noxious Weed

Perennial pepperweed Lepidium latifolium P forb Brassicaceae Noxious Weed

Perennial ryegrass Lolium perenne ssp. perenne P graminoid Poaceae Invasive Plant

Periwinkle Vinca major P vine,forb Apocynaceae Invasive Plant

Poison hemlock Conium maculatum B forb Apiaceae Noxious Weed

Poison ivy Toxicodendron rhydbergii P shrub Anacardiaceae Native Plant

Poison Oak Toxicodendron diveralobum P shrub, vine Anacardiaceae Native Plant

Policemans helmet Impatiens glandulifera A forb Balsaminaceae Noxious Weed

Poverty brome Bromus sterilis A graminoid Poaceae Invasive Plant

Prickly lettuce Lactuca serriola A,B forb Asteraceae Invasive Plant

Prickly sowthistle Sonchus asper A forb Asteraceae Invasive Plant

Puncturevine Tribulus terrestris A forb Zygophyllaceae Noxious Weed

Purple foxglove Digitalis purpurea B forb Scrophulariaceae Invasive Plant

Purple loosestrife Lythrum salicaria P forb Lythraceae Noxious Weed

Purple Nutsedge Cyperus rotundus P graminoid Cyperaceae Noxious Weed

Quackgrass Elymus repens P graminoid Poaceae Noxious Weed

Rabbitbrush Ericameria spp P shrub Asteraceae Native Plant

Ragweed Ambrosia artemisiifolia A forb Asteraceae Noxious Weed

Red brome Bromus rubens A graminoid Poaceae Invasive Plant

Reed canarygrass Phalaris arundinacea P graminoid Poaceae Invasive Plant

Ripgut brome Bromus rigidus A,P graminoid Poaceae Invasive Plant

Rush skeletonweed Chondrilla juncea P forb Asteraceae Noxious Weed

Russian olive Elaeagnus angustifolia P tree Elaeagnaceae Invasive Plant

Salmonberry Rubus spectablis P shrub Rosaceae Native Plant

Saltcedar (tamarisk) Tamarix ramosissima P tree Tamaricaceae Noxious Weed

Shining geranium Geranium lucidum A,B forb Geraniaceae Invasive Plant

Silverleaf Nightshade Solanum elaegnifolium P forb Solanaceae Noxious Weed

Skeletonleaf bursage Ambrosia tomentosa P forb Asteraceae Noxious Weed

Slender oat Avena barbata A graminoid Poaceae Invasive Plant

Small broomrape Orobanche minor A forb Orobanchaceae Noxious Weed

Smalleaf periwinkle Vinca minor P vine,forb Apocynaceae Invasive Plant

Soft brome Bromus hordeaceus ssp. 

hordeaceus A graminoid Poaceae Invasive Plant

Spanish heath Erica lusitanica P Shrub Ericaceae Noxious Weed

Spikeweed Hemizonia pungens A forb Asteraceae Noxious Weed

Spotted Cat’s ear Hypocheris radicata P forb Asteraceae Invasive Plant

Spotted henbit Lamium maculatum P forb Lamiaceae Invasive Plant

Spreading hedge-parsley Torilis arvensis A forb Apiaceae Invasive Plant

Spurge laurel Daphne laureola P shrub Thymelaeaceae Noxious Weed

Spurge, Leafy Euphorbia esula P forb Euphorbiaceae Noxious Weed

Spurge, Myrtle Euphorbia myrsinites P forb Euphorbiaceae Noxious Weed
593

Final Environmental Impact Statement: Appendix 7

Common Name Scientific Name Duration1 Growth 

Form Family Vegetation Type

St. Johnswort Hypericum perforatum P forb Hypericaceae Noxious Weed

Starthistle, Iberian Centaurea iberica P forb Asteraceae Noxious Weed

Starthistle, Malta Centaurea melitensis A, B forb Asteraceae Invasive Plant

Starthistle, Purple Centaurea calcitrapa A, B, P forb Asteraceae Noxious Weed

Starthistle, Yellow Centaurea solstitialis A, B forb Asteraceae Noxious Weed

Sulfur cinquefoil Potentilla recta P forb Ranunculaceae Noxious Weed

Swainsonpea Sphaerophysa salsula P forb Fabaceae Noxious Weed

Sweet fennel Foeniculum vulgare B,P forb Apiaceae Invasive Plant

Sweetclover, white Melilotus alba A, B, P forb Fabaceae Invasive Plant

Sweetclover, yellow Melilotus oficinalis A, B, P forb Fabaceae Invasive Plant

Syrian bean-caper Zygophyllum fabago P forb Zygophyllaceae Noxious Weed

Tall fescue Schedonorus phoenix P graminoid Poaceae Invasive Plant

Tanoak Lithocarpos densiflora P tree Fagaceae Native Plant

Tansy ragwort Senecio jacobaea B, P forb Asteraceae Noxious Weed

Tansy, Common Tanacetum vulgare P forb Asteraceae Invasive Plant

Teasel, common Dipsacus fullonum B forb Dipsacaceae Invasive Plant

Teasel, cutleaf Dipsacus laciniatus B forb Dipsacaceae Noxious Weed

Texas blueweed Helianthus ciliaris P forb Asteraceae Noxious Weed

Thimble berry Rubus parviflorus P shrub Rosaceae Native Plant

Thistle, Bull Cirsium vulgare B, P forb Asteraceae Noxious Weed

Thistle, Canada Cirsium arvense P forb Asteraceae Noxious Weed

Thistle, Italian Carduus pycnocephalus A, B forb Asteraceae Noxious Weed

Thistle, Milk Silybum marianum A, B forb Asteraceae Noxious Weed

Thistle, Musk Carduus nutans B, P forb Asteraceae Noxious Weed

Thistle, Plumeless Carduus acanthoides B forb Asteraceae Noxious Weed

Thistle, Russian Salsola kali A forb Chenopodiaceae Invasive Plant

Thistle, Scotch Onopordum acanthium B forb Asteraceae Noxious Weed

Thistle, Slender flowered Carduus tenuiflorus P, A forb Asteraceae Noxious Weed

Thistle, Smooth distaff Carthamus baeticus A forb Asteraceae Noxious Weed

Thistle, Taurian or bull 

cottonthistle Onopordum tauricum B forb Asteraceae Noxious Weed

Thistle, wavyleaf Cirsium undulatum B,P forb Asteraceae Invasive Plant

Thistle, Whitestem distaff Carthamus leucocaulos A forb Asteraceae Invasive Plant

Thistle, Wooly distaff Carthamus lanatus A forb Asteraceae Noxious Weed

Toadflax, Dalmation Linaria dalmatica P forb Scrophulariaceae Noxious Weed

Toadflax, Yellow Linaria vulgaris P forb Scrophulariaceae Noxious Weed

Tree-of-heaven Ailanthus altissima P tree Simaroubaceae Invasive Plant

Tumbleweed or Prickly 

Russian thistle Salsola tragus A forb Chenopodiaceae Invasive Plant

Velvetleaf Abutilon theophrasti A forb Malvaceae Noxious Weed

Vine maple Acer circinatum P shrub Aceraceae Native Plant

Watermilfoil, Eurasian Myriophyllum spicatum P aquatic forb Haloragaceae Noxious Weed

Western juniper Juniperus occidentalis P tree Cupressaceae Native Plant

Western water hemlock Cicuta douglasii P forb Apiaceae Native Plant

White Bryonia Byonia alba P vine Cucurbitaceae Noxious Weed

Whitetop, (Hoary cress) Cardaria draba P forb Brassicaceae Noxious Weed

Whitetop, Lens-podded Cardaria chalapensis P shrub Brassicaceae Noxious Weed

Whitetop,Hairy Cardaria pubescens P forb Brassicaceae Noxious Weed
 594

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Common Name Scientific Name Duration1 Growth 

Form Family Vegetation Type

Wild carrot Daucus carota B forb Apiaceae Invasive Plant

Wild oat Avena fatua A graminoid Poaceae Invasive Plant

Wild proso millet Panicum miliaceum A graminoid Poaceae Invasive Plant

Wild safflower Carthamus oxyacantha A forb Asteraceae Invasive Plant

Willow Salix P shrub, tree Salicaceae Native Plant

Yellow Flag Iris Iris pseudacorus P forb Iridaceae Noxious Weed

Yellow floating heart Nymphoides peltata P aquatic forb Menyanthaceae Noxious Weed

Yellow glandweed Parentucellia viscosa A forb Scrophulariaceae Invasive Plant

Yellow nutsedge Cyperus esculentus P graminoid Cyperaceae Noxious Weed

Yellowtuft Alyssum murale A Forb Brassicaceae Noxious Weed

Yellowtuft Alyssum corsicum A Forb Brassicaceae Noxious Weed

1 A = Annual B = Biennial P = Perennial

Noxious Weed Spread Rate References and Calculations

Source of Current Noxious Weed Spread Rate Estimate of 12 Percent.

The Noxious Weed and Other Invasive Plants section in Chapter 4 notes that the current 1.2 million acres of 

noxious weeds on BLM lands in Oregon is spreading at an estimated rate of 12 percent annually, or currently 

144,000 acres per year. This estimate has been made after examining the following sources:

- The PEIS notes “a recent estimate of weed spread on all western federal lands is 10% to 15% annually 

(Asher and Dewey 2005 as cited in PEIS:3-27). Asher has indicated this estimate does not include 

cheatgrass (Bromus tectorum), and was made primarily by doing an acreage-weighted average of the 

common noxious weeds for which species-specific spread rates had been published (Asher, J. pers. 

comm.).1 

- The 1998 BLM’s National Strategy for Invasive Plant Management, Pulling Together, says “experts 

estimate that invasive plants already infest well over 100 million acres and continue to increase by 8 to 20 

percent annually” (USDI 1998).

- The 1999 Forest Service Stemming the Invasive Tide: Forest Service Strategy for Noxious and Nonnative 

Invasive Plant Management reports “on Federal lands in the Western United States, it is estimated that 

weeds occur on more than 17 million acres” (USDA 1999). Asher has calculated a 2,300 acres per day 

spread rate for BLM lands, and separately calculated a 2,300 acre per day spread rate for all other federal 

lands (Asher, J. pers. comm. and variously published). Applying the 4,600-acre per day sum of these 

estimates to the 17 million acres reported infested (above) results in an annual spread rate of 10.0 percent. 

However, the 17 million may include cheatgrass, which is not in J. Asher’s rate of spread estimate. If so, 

the actual percentage would be higher than 10.0 percent.

1 For example, the Spartina alterniflora infestation in Willapa Bay grew from 300 acres to 8,500 acres in the 19 years from 

1984 to 2003 (19.5 percent) (see WA DNR 2008). Duncan and Clark (2005) report 950,000 acres of yellow starthistle in 

Oregon with a spread rate of 17 percent; perennial pepperweed spread at an average annual rate of 11 percent in Utah and 

18 percent in Montana; dalmation toadflax has spread from introduction in 1908 to 32 states in 2002 at an annual rate of 11 

percent; cheatgrass 14 percent; musk thistle 12-22 percent, diffuse knapweed 8-14 percent; and so forth. 
595

Final Environmental Impact Statement: Appendix 7

- There are 1.2 million acres of noxious weeds on BLM lands in Oregon (combined district estimates 2007). 

An average compounded rate of spread necessary to reach 1.2 million acres is calculable if a starting 

date is known or assumed. It is known “weed invasions began a few centuries ago but primarily in the 

mid-1800s when weeds began arriving from other countries....” (Asher and Spurrier 1998), and even in 

the 1800s “about one hundred exotics per decade were establishing in the five northwest states” (Rice 

1999). If we assume spread didn’t become significant until 20 years after the 1849 gold rush, a 140 year 

compounded average spread rate of 8.7 percent would account for today’s 1.2 million acres.

- The Forest Service Region 6 (Oregon and Washington) 2005 Invasive Plant EIS notes “Invasive plant 

populations increase in acreage at an estimated rate of 8-12 percent per year on Forest Service System 

land [nationwide] (USDA 1999[b])” cited in USDA 2005:3-2. “Using this range, if one estimates spread 

at 10 percent per year....” (USDA 2005).

- “From, 1985 to 1996, invasive plants quadrupled to 17 million acres on western federal lands (Asher 

1998, Westbrooks 1998)” as cited in USDA 2005:3-2. To quadruple in 11 years requires a compound rate 

of 15.75 percent per year. 

The Forest Service and even the BLM west of the Cascades probably has a lower spread rate than the BLM in 

Oregon as a whole (in the area of 10 percent). The primary agent of noxious weed spread is disturbance, and 

that is likely more prevalent on the open flat BLM lands east of the Cascades. Additionally, the generally higher, 

steeper, more vegetated landscape on the National Forests would be outside of the ecological amplitude of many 

Mediterranean species invading BLM lands; access to OHVs is more restricted both legally and geographically; 

and certain windborne species don’t travel well on steeper more vegetated areas. Using the high end of the Forest 

Service’s 8-12 percent range, and taking the other figures at face value, a reasonable estimate of the current annual 

spread rate of noxious weeds on BLM lands in Oregon is 12 percent. Because Oregon has been controlling 

noxious weeds aggressively under the same direction since 1987, this rate is assumed to correspond, or in part 

be the product of, the current direction or No Action Alternative 2. The acres that would result from an annual 

increase of noxious weed acres (from the current 1.2 million) at a 12 percent rate for the next 15 years is shown 

on the right-most column on Tables A7-4, 5, and 6 below.

The BLM Western Oregon Plan Revision (WOPR) FEIS (USDI 2008) identifies 61 noxious weeds and an 

additional 69 invasive plants in the WOPR planning area (p. 3-274), and predicts the increase in timber harvest 

activities under all of the action alternatives would increase the risk of spreading invasive plants (p. 4-628). 

The increased risk is not quantified using the same parameters as discussed here, so a direct comparison is not 

possible, but it does not appear that the described increase would equal a whole percentage point. 

Scoping for the Vegetation Treatments EIS revealed a concern that roadside hazard tree and other salvage tree 

removal can result in a soil-disturbing piece of equipment traversing several miles of forest roads per day and 

potentially spreading any encountered noxious weeds over that larger area. This possibility is a part of the 

increased risk noted above. To some degree, such a risk should be mitigated by the BLM’s policy of requiring the 

development of a Noxious Weed Risk Assessment that identifies actions to be taken and monitoring to be done 

whenever analysis of proposed ground disturbing activities determines the activity will have a moderate or high 

risk of spreading noxious weeds (BLM Manual 9015; USDI 1992). 

Effective Treatments by Alternative

The treatment efficiency percentages and effectively treated acres by alternative shown on Table A7-3 below are 

from Table 4-3 and associated discussion in the Noxious Weeds and Other Invasive Plants section of Chapter 4. 

Gross treatment acres are from FEIS Table 3-3. This information is relevant to the calculations of weed spread 

rate in the following sections.
 596

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Table A7-3. Annual Acres of Effective Noxious Weed Control by Alternative

Alternative Gross Treatment 

Acres

Efficiency 

Percentage

Tent. Effectively 

Treated Acres

25% ROW Treat 

Benefit

Total Effectively 

Treated Acres

Reference Analysis 42,100 .30 12,630 n/a 12,630

2 45,500 .60 27,300 n/a 27,300

3 57,700 .80 46,160 n/a 46,160

4 57,700 .80 46,160 2,350 48,510

5 57,700 .80 46,169 2,350 48,510

Alternative 3 Spread Rate

The increase in effective treatments under Alternative 3 when compared to No Action Alternative 2 is 18,860 

acres (from Table A7-3). The reduction in the current 144,000 acre annual increase in noxious weeds the first 

year would be no more than this 18,860 acres. However, because treatments are targeted at populations in 

the introduction phase of the infestation, these treatments would prevent 10 times those acres (188,600 acres) 

over the next 15 year time period. For example, 100 acres of effective control treatments in 1980 are assumed 

to reduce noxious plants by 1000 acres by 1995. Because that gain comes from controlling acres early in the 

Invasion Lag Curve (Figure 4-2), the 188,600 acres of weeds prevented is spread along the same curve in the 

following percentages per year: 10, 5, 5, 5, 5, 5, 5, 5, 5, 5, 5, 10, 10, 10, 10 = 100%. Only 10 percent of the gain 

is achieved the first year, another 5 percent the next year, and so forth until the entire gain is achieved by the 15th

year. Another 18,860 acres is treated the next year, and the gains are additive. Thus in year two, the reduction in 

infested acres is the 18,860 acres treated that year, and the 9,430 acres credit from the previous year’s treatment. 

In decade 3, it’s 18,860+9,430+9,430=37,7200, and so forth. These gains continue to add up, until after 15 years, 

the 18,860 acres annual treatment are decreasing weed infestation acres by 188,600 acres per year. At that point, 

there are 1.86 million fewer acres infested than under Alternative 2, and the annual spread rate is slowed to 7 

percent (Table A7-4).

Table A7-4. Weed Spread of 12% Reduced by 10 Times 18,860 Acres of Effective Annual Control (Difference

Between Alts 2 and 3), Distributed Over 15 Decades at 10, 5, 5, 5, 5, 5, 5, 5, 5, 5, 5, 10, 10, 10 and 10% ea Decade

Alternative 3 Alternative 2

Year Begin Acreage 12 % Growth Effective 

Control End Acreage % increase from prev.

12% annual 

increase

1 1,200,000 1.12 1,344,000 18,860 1,325,140 1,200,000

2 1,325,140 1.12 1,484,157 28,290 1,455,867 9.87% 1,344,000

3 1,455,867 1.12 1,630,571 37,720 1,592,851 9.41% 1,505,280

4 1,592,851 1.12 1,783,993 47,150 1,736,843 9.04% 1,685,913

5 1,736,843 1.12 1,945,264 56,580 1,888,684 8.74% 1,888,223

6 1,888,684 1.12 2,115,326 66,010 2,049,316 8.50% 2,114,810

7 2,049,316 1.12 2,295,234 75,440 2,219,794 8.32% 2,368,587

8 2,219,794 1.12 2,486,169 84,870 2,401,299 8.18% 2,652,818

9 2,401,299 1.12 2,689,455 94,300 2,595,155 8.07% 2,971,156

10 2,595,155 1.12 2,906,574 103,730 2,802,844 8.00% 3,327,694

11 2,802,844 1.12 3,139,185 113,160 3,026,025 7.96% 3,728,018

12 3,026,025 1.12 3,389,148 132,020 3,257,128 7.64% 4,174,260

13 3,257,128 1.12 3,647,984 150,880 3,497,104 7.37% 4,675,171

14 3,497,104 1.12 3,916,756 169,740 3,747,016 7.15% 5,236,192

15 3,747,016 1.12 4,196,658 188,600 4,008,058 6.97% 5,864,535
597

Final Environmental Impact Statement: Appendix 7

Reference Analysis Spread Rate

The decrease in effective treatments under the Reference Analysis when compared to No Action Alternative 2 is 14,670 

acres. Implementation of the Reference Analysis would, it is predicted, increase the current 144,000 acre annual by 

14,670 acres. This reduction in effective treatment acres is shown as a negative number under effective control (Table 

A7-5). The weed spread rate under the Reference Analysis increases to 14 percent immediately and stays there through 

the 15-year period. An additional 2.7 million acres would become infested when compared to Alternative 2.

Table A7-5. Weed Spread of 12% Increased by 10 Times the 14,670 Acres Less Effective Annual Control

(Difference Between Alt 2 and the Reference Analysis, Shown as a Negative Number), Distributed over 15 

Decades at 10, 5, 5, 5, 5, 5, 5, 5, 5, 5, 5, 10, 10, 10 and 10% ea Decade

Reference Analysis Alternative 2

Year Begin Acreage 12 % Growth Effective 

Control End Acreage % increase from prev.

12% annual 

increase

1 1,200,000 1.12 1,344,000 -14,670 1,358,670 1,200,000

2 1,358,670 1.12 1,521,710 -22,005 1,543,715 13.62% 1,344,000

3 1,543,715 1.12 1,728,961 -29,340 1,758,301 13.90% 1,505,280

4 1,758,301 1.12 1,969,297 -36,675 2,005,972 14.09% 1,685,913

5 2,005,972 1.12 2,246,689 -44,010 2,290,699 14.19% 1,888,223

6 2,290,699 1.12 2,565,583 -51,345 2,616,928 14.24% 2,114,810

7 2,616,928 1.12 2,930,959 -58,680 2,989,639 14.24% 2,368,587

8 2,989,639 1.12 3,348,396 -66,015 3,414,411 14.21% 2,652,818

9 3,414,411 1.12 3,824,140 -73,350 3,897,490 14.15% 2,971,156

10 3,897,490 1.12 4,365,189 -80,685 4,445,874 14.07% 3,327,694

11 4,445,874 1.12 4,979,379 -88,020 5,067,399 13.98% 3,728,018

12 5,067,399 1.12 5,675,487 -102,690 5,778,177 14.03% 4,174,260

13 5,778,177 1.12 6,471,558 -117,360 6,588,918 14.03% 4,675,171

14 6,588,918 1.12 7,379,588 -132,030 7,511,618 14.00% 5,236,192

15 7,511,618 1.12 8,413,013 -146,700 8,559,713 13.95% 5,864,535

Alternatives 4 and 5 Spread Rate

The increase in effective treatments under Alternative 4 when compared to No Action Alternative 2 is 21,210 

acres. Applying the calculations and assumptions described above, the rate of noxious weed spread by year 15 is 

reduced to 6 percent (compared to 7 percent in Alternative 3 and 2.2 million fewer acres are infested (Table A7-6). 

Table A7-6. Weed Spread of 12% Reduced by 10 Times 21,210 Acres of Effective Annual Control (Difference

Between Alts 2 and 4), Distributed Over 15 Decades at 10, 5, 5, 5, 5, 5, 5, 5, 5, 5, 5, 10, 10, 10 and 10% ea Decade

Alternatives 4 and 5 Alternative 2

Year Begin Acreage 12 % Growth Effective 

Control End Acreage % increase from prev.

12% annual 

increase

1 1,200,000 1.12 1,344,000 21,210 1,322,790 1,200,000

2 1,322,790 1.12 1,481,525 31,815 1,449,710 9.59% 1,344,000

3 1,449,710 1.12 1,623,675 42,420 1,581,255 9.07% 1,505,280

4 1,581,255 1.12 1,771,006 53,025 1,717,981 8.65% 1,685,913

5 1,717,981 1.12 1,924,138 63,630 1,860,508 8.30% 1,888,223

6 1,860,508 1.12 2,083,769 74,235 2,009,534 8.01% 2,114,810

7 2,009,534 1.12 2,250,678 84,840 2,165,838 7.78% 2,368,587

8 2,165,838 1.12 2,425,739 95,445 2,330,294 7.59% 2,652,818

9 2,330,294 1.12 2,609,929 106,050 2,503,879 7.45% 2,971,156

10 2,503,879 1.12 2,804,345 116,655 2,687,690 7.34% 3,327,694

11 2,687,690 1.12 3,010,212 127,260 2,882,952 7.27% 3,728,018

12 2,882,952 1.12 3,228,907 148,470 3,080,437 6.85% 4,174,260

13 3,080,437 1.12 3,450,089 169,680 3,280,409 6.49% 4,675,171

14 3,280,409 1.12 3,674,058 190,890 3,483,168 6.18% 5,236,192

15 3,483,168 1.12 3,901,148 212,100 3,689,048 5.91% 5,864,535
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Additional Information about the Ecological Damage Caused by 

Invasive Plants

Invasive plants are non-native plants likely to cause economic or environmental harm or harm to human health 

(Executive Order 13112). They typically have biological traits that allow them to colonize new areas and 

successfully compete with native plants, and they are away from natural enemies or competitors that may have 

restricted growth in their native lands. Biological traits making them successful typically include one or more of 

the following characteristics: deep tap root systems and very little surface foliage, allowing them to grow later 

in the summer than most native rangeland plants; earlier growth and reproduction than most natives; long-lived 

seeds; adaptations for spreading long and short distances; production of many seeds from on plant; long lifespan; 

ability to delay flowering; ability to reproduce vegetatively; tolerance for a wide range of physical conditions; 

rapid growth; self pollination; ability to compete intensively for nutrients; thorns, poisons, or lack of palatability 

that keep them from being browsed; and production of toxic compounds that negatively affect neighboring plants 

(PEIS:3-26). 

Many invasive plants also have characteristics that cause long-term physical damage to soils. The limited 

foliage and non-fibrous root do little to protect soil from rain-splash and overland flow; annual grasses cure early 

resulting in frequent high-intensity wildfires damaging soils and exposing them to wind and rain; they change 

nutrient recycling permitting important nutrients to be lost from the site; and many poison soils with their roots 

or shed leaves. Invasive plants impact water quality by increasing erosion, changing nutrient cycling, decreasing 

stream flows, making streams less habitable by fish and reducing water available for people. Invasive plants can 

also change the seral progression of a site to the extent that forestland loses the ability to produce trees. Invasive 

plants create monocultures and otherwise displace native plant communities. As native plants are displaced, 

animals that depend on them lose forage, nesting sites, hiding cover and other essentials necessary for their 

survival. Invasive plants create fire safety issues as highly flammable cheatgrass encroaches on the wildlandurban interface. The coastal town of Bandon was destroyed and 11 citizens killed in 1936 by a fire propagated by 

gorse, a highly flammable invasive plant (Simberloff 1996). 

Invasive plants change ecosystems. Invasive plants compete with native plants for resources, thereby becoming 

dominant. More importantly they can outcompete plants that are food supplies for animals in the ecosystem. This 

may result in animals depending on nonnative plants for food or, if they are specialists, losing their food source 

entirely. Invasive plants normally lack predators and may more easily outcompete natives with their natural 

predators. Invasive plants are a problem because they alter the invaded ecosystem and species composition 

(Woods 1997) to such an extent that they threaten native flora and fauna. Invasive species capitalize on many 

techniques in order to invade ecosystems. There are three ways that biological invasions alter ecosystems 

according to D’Antonio and Vitousek (1992).

Invasive exotic plants alter rates of resource supply, trophic level relationships, and the disturbance regime. A 

highly disturbed ecosystem is susceptible to invasion (Hobbs and Huenneke 1992).

Selected citations from 2005 Region 6 Forest Service Invasive Plant EIS (USDA 2005:3-1 to 3-68)

- Spotted knapweed is an aggressive competitor and produces an allelopathic compound (pg.3-8).

- Yellow starthistle forms solid stands that dramatically reduce forage for livestock and wildlife. This 

species causes a fatal neurological disorder when ingested by horses called chewing disease (pg. 3-9).

- Soil erosion more than doubled in knapweed dominated areas compared to uninfested areas (pg 3-28). 

- Invasion by purple loosestrife makes habitat unsuitable for numerous birds, reptiles and mammals (pg 3-49)
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Final Environmental Impact Statement: Appendix 7

- Known effects of invasive plants to wildlife: embedded seeds leading to injury or death, scratches leading 

to infection, ingestion of plant parts leading to poisoning, cascading effect of direct or indirect mortality 

on other species (pg 3-49).

Trammel and Butler (1995) found that deer, elk, and bison avoided sites infested with leafy spurge. Tamarisk 

stands have fewer and less diverse populations of mammals, reptiles, and amphibians (Jakle and Gatz 1985, Olson 

1999). Invasion by purple loosestrife makes habitat unsuitable for numerous birds, reptiles, and mammals (Kiviat 

1996, Lor 1999, Rawinski 1982, Thompson et al. 1987, Weihe and Neely 1997, Weiher et al. 1996)

The rapid growth of many invasive plants allows them to out-compete native vegetation. This competitive 

advantage results in the loss of functional riparian communities, loss of rooting strength and protection against 

erosion, decreasing slope stability and increasing sediment introduction to streams, and impacts on water quality 

(Donaldson 1997).

Some invasive plants (such as knapweed) contain chemical compounds that make the plant unpalabtable to 

grazing animals. Chemical compounds in these invasive plants disrupt microbial activity in the rumen, or cause 

discomfort after being ingested, resulting in a reduced or avoided consumption of the invasive plant (Olson 1999).

Native plants with cultural significance, such as camas and bitterroot, are declining in number across the western 

landscape. This decrease is of great concern to many tribes, as traditional gathering areas have experienced a 

decline in productivity due to anthropogenic influences of the past century and the proliferation of invasive plant 

species - especially spotted knapweed and sulfur cinquefoil (Bonnicksen et al. 1998).

Numerous studies demonstrate reduced numbers and/or diversity in birds, reptiles, small mammals, and insects in 

stands of non-native plant species (Huenneke 1996). For example, kangaroo rat and ground squirrel populations 

were severely reduced or totally eliminated on sites infested with Russian knapweed in a study in Wyoming 

(Johnson et al. 1994). 

Studies in Montana show that spotted knapweed invasions reduced available winter forage for elk between fifty 

and ninety percent (Duncan 1997). 

Research shows that the total number of insects, total insect biomass and taxonomic richness of invertebrates 

associated with giant reed are significantly lower than that associated with native vegetation (Herrera 1997). 

Giant reed uses about three times as much water as the native plants, introduces an unnatural fire cycle into the 

ecosystem, and it easily replaces entire plant communities (Iverson 1993, Reiger and Kreager 1989).

Knapweeds are the best regional (Pacific Northwest) symptom of desertification, the loss of the productive 

potential of the land (Roche 1988).

The severe level of deterioration in four desertification classes is described in part as follows: "Undesirable forbs and 

shrubs have replaced desirable grasses or have spread to such an extent that they dominate the flora” (Dregne 1977).

Aggressive foreign plants spread quickly into natural areas, monopolize resources, and push out native flora and 

fauna - including endangered species (Cheater 1992).

The simplest effect of some invasions is the displacement of native plant species, by simple crowding, by 

competition for resources, or by other mechanisms. Many invasive plants form broad-leaved rosettes or in some 

other way shade out neighbors (Huenneke 1996).
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The impact of purple loosestrife on native vegetation has been disastrous, with more than 50 percent of the 

biomass of some wetland communities displaced. Monospecific blocks of this weed have maintained themselves 

for at least twenty years (Thompson et al. 1987).

In the absence of predators, immune systems or other biological control mechanisms adapted to counteract these 

species, populations of some exotics have exploded (Monnig 1992).

Infections in the eyes, mouth, and throat commonly occur in cattle and sheep feeding where medusahead is 

present (Bovey 1961, Hilken 1980).

Annual economic impacts of leafy spurge infestations on grazing and wildlands in Montana, North Dakota, South 

Dakota, and Wyoming are approximately $129,000,000 (Leitch 1994). 

The reduction in wildlife-associated recreation expenditures due to current leafy spurge infestations on wildlands 

in North Dakota is estimated to be $2,900,000 (Wallace et al. 1992).

In Montana, knapweed infestations result in an estimated direct annual impact of $14,000,000 with total 

secondary impacts of about $42,000,000 per year which could support over 500 jobs in the state’s economy 

(Hirsch and Leitch 1997). 

Scotch broom has been identified as the noxious weeds causing the highest productivity losses of any of Oregon’s 

noxious weeds, at $47 million annually (Radke and Davis 2000:19-20). 

Many studies and repeated landowner experiences show that weeds commonly reduce livestock carrying capacity 

from thirty-five percent to ninety percent (Hilken 1980, Bucher 1984). 

Runoff and sediment yield were fifty-six percent and 192 percent higher, respectively, for spotted knapweed than 

for bunch grass vegetation types (Lacey et al. 1989).

Salt cedar, a deep rooted shrub or small tree, uses an excessive amount of water. A mature salt cedar consumes 

as much as 800 liters of water per day -- 10 to 20 times the amount used by native species it tends to replace 

(Cooperrider 1995).

Tamarisk (also known as salt cedar) has been able to out compete willow and other riparian plants in many 

locations, greatly diminishing the quantity and quality of riparian habitat for migrant songbirds and vegetation 

dependent birds, like the endangered Yuma clapper rail at the Salton Sea and elsewhere (Dudley 1995). 

Tamarisk dominated riparian areas have depauperate faunas, even in the native range of tamarisk (Lovich 1996).

A study by DeLoach (1991) in the Lower Colorado Valley showed that for the entire year, salt cedar had only 

fifty-nine percent of the mean density of birds as the cottonwood-willow, screwbean and western honey mesquite 

communities. During the winter, saltcedar had only thirty-nine percent of the density of birds as other vegetative 

communities. The leaf litter of salt cedar increases soil salinity so that large areas are unfit for native vegetation 

and the wildlife that depend on that vegetation.

Spotted knapweed has been found to reduce grass production from 60-90 percent (Harris and Cranston 1979, 

Bedunah and Carpenter 1989, Wright and Kelsey 1997) decreasing carrying capacity for livestock and lowering 

the quality of winter range habitat for wildlife (Rice et.al. 1997).
601

Final Environmental Impact Statement: Appendix 7

Spotted knapweed produces a chemical, called catechin, that causes native vegetation to die (Kahn 2003).

In some parts of Theodore Roosevelt National Park, leafy spruge diminished bison forage by 83 percent and deer 

and elk forage by 70 percent (Stalling 1998).

Each wildlife species has specific habitat requirements for feeding and cover – which are different for different 

animals. Therefore, instead of monocultures of weeds (or plant communities being pushed toward monocultures 

by weeds) the native vegetation must be diverse to support the full wildlife community (Asher 2000). 

Lesser yellow legs and other shorebirds use shallow water areas in wetlands. They prefer habitats that are open, 

with low-profile vegetation and low plant cover, like flooded mud flats. Such areas are quickly invaded by 

reed canarygrass, which makes them unsuitable habitat for shorebirds. Foraging habitat for the 25 species of 

shorebirds, that use the Turnbull National Wildlife Refuge, in Washington, when migrating, has been substantially 

reduced by the weed (Rule 2004). 

Shallow, flooded, seasonal wetlands are important habitat for the migration, pairing and brood rearing of many 

of the duck species, especially mallards, cinnamon and blue-winged teal, and green-winged teal, on the Turnbull 

Wildlife Refuge. Once invaded by reed canarygrass these areas have less diverse and less abundant food 

resources. The dense thatch layer that develops also restricts access to these food resources (Rule 2004).

Aspen-dominated riparian communities on the Turnbull Wildlife Refuge refuge are the most important Habitat 

for 65 species of land birds. Reed canarygrass invades the understory of many of these stands. This reduces 

structural and floral diversity by impeding the growth of native understory shrubs and forbs. It also impedes 

the regeneration of aspen. The result is a significant decline in habitat diversity, which may lead to as much as a 

50-percent decrease in bird species diversity (Rule 2004).

The impact of purple loosestrife on native vegetation has been disastrous, with more than 50 percent of the 

biomass of some wetland communities displaced. Monospecific blocks of this weed have maintained themselves 

for at least twenty years (Thompson et al. 1987).

In its native habitat, purple loosestrife only comprises one to four percent of the native vegetation, but in North 

America densities of up to 80,000 stalks per acre have been recorded (Strefer 1996).

Purple loosestrife out competes native plant species and reduces biodiversity (Nyvall 1995).

Endangered, threatened, and rare birds completely avoided invasive Phragmites while utilizing neighboring short 

grass wetlands (Benoit and Askins 1997).

One study showed that when chukar partridge were given free access to all the medusahead caryopses (seed) they 

would eat, along with other dietary requirements, they suffered dramatic losses in body weight (Savage et al. 1969).

Research concerning chukar partridge habitat use and availability in the severely infested lower Salmon River 

Canyon of Idaho, revealed that chukars selected against (avoided) habitats with higher yellow starthistle ground 

cover (Lindbloom 1998).

The impact of (weed) invasions can be permanent when economic and environmental factors limit the ability of a 

managing agency to restore the ecosystem to a healthy state (NAS 2002) 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Loss of wildlife habitat function would be irretrievable (PEIS:2-32). 

In one research area in Colorado, dalmation toadflax recently increased 1,200 percent over a six year period 

(Beck 2009)

Weeds are spreading rapidly, and in some cases exponentially, in every cluster and sixty-six percent of the BLM/

FS lands are susceptible to knapweeds and yellow starthistle (Quigley and Arbelbide 1997).

Like human populations, weeds typically increase exponentially beginning

slowly, then doubling and redoubling (Kummerow 1992).

There were only minor populations of spotted knapweed in Montana in 1920. Today, there are about five million 

acres with another 29 million acres of highly susceptible land in that state alone (Duncan 1997).

Weed spread

Yellow starthistle was first reported near San Francisco and Seattle in the mid-1800’s. Today it infests over 12 

million acres in California and many millions of acres in Oregon, Washington, and Idaho. 

In 1993, Jackson county in southern Oregon, and Umatilla county in north east Oregon both reported explosions 

of yellow starthistle with over 100,000 acres in Jackson county and 200,000 acres in Umatilla county. Now, both 

counties report that the populations have at least doubled.

In 1970, there was about thirty-two acres of leafy spurge in the Theodore Roosevelt National Park in North 

Dakota. The use of herbicides was not allowed and now leafy spurge dominates over 4,400 acres of the park 

(Andrascik 1997). 

From just a few plants in western Idaho in 1954, rush skeletonweed now infests over four million acres as it 

continues to “leapfrog” to the east, now out beyond Shoshone, Idaho, and to the west into the Hells Canyon 

National Recreation Area in Oregon and Idaho.

References

Andrascik 1997 Andrascik, R. 1997. Leafy Spurge Newsletter 1(3):2-3

Cooperrider 1995 Cooperider, A., et. al. 1995. In, State of the Biome Uniqueness, Biodiversity, Threats and the 

Adequacy of Protection in the Sonoran Bioregion. The Wildland Project. March 1998,Tucson, Arizona

DeLoach 1991 DeLoach, J. 1991. Saltcedar, An Exotic Weed of Western North American RiparianAreas: A Review 

of Its Taxonomy, Biology, Harmful and Beneficial Values, and Its Potential for Biological Control. 

USDA Agriculture Research Service, Temple Tx. 

Donaldson 1997 Donaldson, S.G. 1997. Flood-borne-noxious weeds: impacts on riparian areas and wetlands. California 

Exotic Pest Plant Council. 1997 Symposium Proceedings. 

Dregne 1977 Dregne, H. 1977. Desertification of Arid Lands. Economic Geography 53 (4) 322-331.

Dudley 1995 Dudley, T., Collins, B. 1995. Biological Invasions in California Wetlands. Pacific Institute for Studies 

in Development, Environment, and Security. Oakland, Ca. p25. 

Duncan 1997 Duncan, C. 1997. Techline pp 5-10

Harris and Cranston 1979 Harris, P., and R. Cranston. 1988. An economic evaluation of control methods for diffuse and spotted 

knapweed in western Canada. Canadian J. Plant Sci. 59:375-382. 
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Final Environmental Impact Statement: Appendix 7

Herrera 1997 Herrera, A.M. 1997. Invertebrate community reduction in response to Arundo donax invasion at 

Sonoma Creek. Pp. 94-105. In: Dudley, T., J. Reynolds & M. Poteet (eds). The science and policy of 

environmental impacts and recovery. Environmental Science Senior Research Seminar, Univ. of Calif., 

Berkeley. 

Hirsch and Leitch 1997 Hirsch, S., J. Leitch. 1997. Economic Effect of Knapweed in Montana. Montana Weed Control 

Association Newsletter. 14:1. Winter 1997. 

Huenneke 1996 Huneneke, L. 1996. Ecological impacts of invasive plants in natural areas. Proceedings: Western 

Society of Weed Science 49:119-121

Iverson 1993 Iverson, M. 1993. The impact of Arundo donax on water resources. Arundo donax Workshop 

Proceedings, Ontario, CA. November 19, 1993, pp. 19-26. 

Jakl and Gatz 1985 Jakle, M.D., and Gatz, T.A. 1985. Herpetofaunal use of four habitats of the Middle Gila River 

drainage, Arizona. Paper presented at the North American Riparian Conference, April 16-18, 1985, 

Tucson, AZ

Kiviat 1996 Kiviat, E. 1996. Short Communications: American Goldfinch nests in purple loosestrife. Wilson 

Bulletin 108(1): p.182-6.

Lor 1999 Lor, S.K. 1999. Habitat use and population status of marsh birds in western New York. M.S. thesis. 

Department of Natural Resources, Cornell University, Ithaca New York. 135.

Rawinski 1982 Rawinski TJ. 1982. The ecology and management of purple loosestrife (Lythrum salicaria L.) in 

central New York. Cornell University, Ithaca, N.Y. ix:88.

Roche 1988 Roche, C. 1988. Knapweed Newsletter 2(4):1

Rule 2004 Rule, M. 2004. Invasive Plants: Winning the War on Weeds. 69th N. American Wildlife and Natual 

Resources Conference. Spokane, Wa., March 16, 2004. pg.19-20. 

Trammel and Butler 1995 Trammell, M.A., and Butler, J.L. 1995. Effects of exotic plants on native ungulate use of habitat. 

Journal of Wildlife Management 59((4)): p.808-16.

USDA 1999 USDA Forest Service. 1999. Stemming the Invasive Tide: Forest Service Strategy for Noxious and 

Nonnative Invasive Plant Management.

USDA 2005 USDA Forest Service. 2005. Pacific Northwest Region Invasive Plant Program: Preventing and 

Managing Invasive Plants. Final Environmental Impact Statement. Available at http://www.fs.fed.us/

r6/invasiveplant-eis/

USDI 1998 USDI Bureau of Land Management. 1998. National Strategy for Invasive Plant Management

WA DNR 2008 Washington Department of Natural Resources. 2008. Invasive Species - Spartina Eradication Project 

in Willapa Bay. Available at http://www.dnr.wa.gov/ResearchScience/Topics/AquaticHabitats/Pages/

aqr_is_spartina_eradication_project.aspx

Weihe and Neely 1997 Weihe, P.E., and Neely, R.K. 1997. The effects of shading on competition between purple loosestrife 

and broad-leaved cattail. Aquatic Botany 59: p.127-38.

Weiher et al 1996 Weiher, E., Wisheu, I.C., Keddy, P.A., and Moore, D.R.J. 1996. Establishment, Persistence, and 

Management Implications of Experimental Wetland Plant Communities. Wetlands 16(2): p.208-18.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon
605

Final Environmental Impact Statement: Appendix 8

Appendix 8 – 

Human Health and Ecological Risk Assessments

Risk Assessments

One of the Purposes identified in Chapter 1 of the Final EIS is: 6. Prevent herbicide control treatments from 

having unacceptable adverse effects to applicators and the public, to desirable flora and fauna, and to soil, air, 

and water. To help address this Purpose, the EIS relies on BLM and/or Forest Service-prepared Human Health 

and Ecological Risk Assessments for the 18 herbicides analyzed in this EIS. The Risk Assessments are used to 

quantitatively evaluate the probability (i.e. risk) that herbicide use in wildland settings might pose harm to humans 

or other species in the environment. As such, they address many of the risks that would be faced by humans, 

plants, and animals, including special status species, from the use of the herbicides. The level of detail in the Risk 

Assessments for wildland use exceeds that normally found in EPA’s registration examination.

Risk is defined as the likelihood that an effect (injury, disease, death, or environmental damage) may result from a 

specific set of circumstances. It can be expressed in quantitative or qualitative terms. While all human activities 

carry some degree of risk, some risks are known with a relatively high degree of accuracy because data have been 

collected on the historical occurrence of related problems (e.g. lung cancer caused by smoking, auto accidents 

caused by alcohol impairment, and fatalities resulting from airplane travel). For several reasons, risks associated 

with exposure to herbicides cannot be so readily determined. The Risk Assessments help evaluate the risks 

resulting from these situations.

Risks to non-target species associated with herbicide use are often approximated via the use of surrogate species, 

as toxicological data does not exist for most native non-target species. Survival, growth, reproduction, and other 

important sub-lethal processes of both terrestrial and aquatic non-target species were considered. Assessments 

considered acute and chronic toxicity data. Exposures of receptors1 to direct spray, surface runoff, wind erosion, 

and accidental spills were analyzed. 

Most of the Human Health and Ecological Risk Assessments were developed by the BLM for the 2007 PEIS, 

or by the Forest Service for the 2005 Pacific Northwest Region Invasive Plant Program EIS (see Table A8-

1). Three Human Health Risk Assessments used in this EIS (bromacil, diuron, and tebuthiuron) were used in 

BLM’s 1991 Vegetation Treatment on BLM Lands in Thirteen Western States EIS and more recent literature 

has been examined to ensure these Risk Assessments remain current. The Risk Assessments, for herbicides 

analyzed, total over 6,000 pages. The various sections of each Risk Assessment can be accessed on the web as 

described below, or obtained on compact disk by calling, emailing, or writing to the BLM at the contact points 

listed on the title page of this EIS. 

The Risk Assessments, related separate analyses, and the EIS include analysis of inerts and degradates for which 

information is available and not constrained by confidential business information (CBI) restrictions. Preparing 

a risk assessment for every conceivable combination of herbicide, tank mix, surfactant, adjuvant, and other 

possible mixture is not feasible, as the BLM cannot prepare hundreds of risk assessments, and the cost would be 

exorbitant. To the degree a toxic substance is known to pose a significant human or ecological risk, the BLM has 

1 An ecological entity such as a human, fish, plant, or slug.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

undertaken analysis to assess its impacts through risk assessments. Additional information about uncertainty in 

risk assessments is included in Appendix 13. 

When evaluating risks from the use of herbicides proposed in a NEPA planning document, reliance on EPA’s 

pesticide registration process as the sole demonstration of safety is insufficient. The U.S. Forest Service and 

Bureau of Land Management were involved in court cases in the early 1980’s that specifically addressed this 

question (principally Save Our Ecosystems v. Clark, 747 F.2d 1240, 1248 (9th Cir. 1984) and Southern Oregon 

Citizens v. Clark, 720 F. 2d 1475, 1480 (9th Cir. 1983)). These court decisions and others affirmed that although 

the BLM can use EPA toxicology data, it is still required to do an independent assessment of the safety of 

pesticides rather than relying on Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) registration alone.

This Court also found that FIFRA does not require the same examination of impacts that the BLM is required 

to undertake under NEPA. Further, risk assessments consider data collected from both published scientific 

literature and data submitted to EPA to support FIFRA product registration, whereas EPA utilizes the latter data 

only. The EPA also considers many wildland pesticide uses to be minor. Thus, the project-specific application 

rates, spectrum of target and non-target organisms, and specialized exposure scenarios evaluated by the BLM are 

frequently not evaluated by EPA in its generalized registration assessments.

The Risk Assessments are the source for much of the individual herbicide information presented in each of the 

effects sections in the EIS, including the high-moderate-low risk ratings shown in tables at the end of Chapter 3 

and referenced in Chapter 4. Individual Risk Assessment Tools (IRATs) are being, developed for each herbicide 

to assist field managers in translating risks to project design parameters. The use of these tools is explained in 

Chapter 3, Use of Individual Risk Assessment Tools During Implementation.

The component parts of the various Risk Assessments, and their origins, are shown on Table A8-1. Each part 

is available on the web via http://www.blm.gov/or/plans/vegtreatmentseis/riskassessments/index.php. At this 

address, each of the “X”s in the table are clickable links that access the respective section. The additional Risk 

Assessment information shown on Table A8-2 can be accessed at the above website as well.
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Final Environmental Impact Statement: Appendix 8

Table A8-1. Risk Assessments

Herbicide

Ecological Risk Assessments (ERA) Human Health Risk Assessments (HHRA)

2007 BLM PEIS1

2005 FS EIS2 Ecological & 

Human Health (and worksheet)

2007 BLM PEIS1

1991 BLM 

EIS3 Risk Assessment Appendices4 Risk 

Assessment

Appendices5

A B C D E A B C D E

2,4-D6 x (x)

Bromacil x x x x x x x

Chlorsulfuron x x x x x x x (x)

Clopyralid x (x)

Dicamba x (x) x x x x x x

Diquat x x x x x x x x x x x

Diuron x x x x x x x

Fluridone x x x x x x x x x x x

Glyphosate x (x)

Hexazinone x (x)

Imazapic x x x x x x x x x x x x

Imazapyr x (x)

Metsulfuron 

methyl x (x)

Overdrive x x x x x

Diflufenzopyr x x x x x x x x x x x x

Picloram x (x)

Sulfometuron 

methyl x x x x x x x x x x x x

Tebuthiuron x x x x x x

Triclopyr x (x)

1. 2007 PEIS: Risk Assessments developed for the 2007 Vegetation Treatments Using Herbicides on Bureau of Land Management 

Lands in 17 Western States Programmatic Environmental Impact Statement.

2. 2005 FS EIS: Risk Assessments developed for the 2005 Pacific Northwest Region Invasive Plant Program Final Environmental Impact Statement. These Risk Assessments are both human health and ecological. For chlorsulfuron and dicamba, the BLM has a more 

recent ERA and HHRA (respectively), so only the remaining part of the FS Risk Assessment was used

3. 1991 BLM EIS: Human Health Risk Assessments adopted with the 1991Vegetation Treatments on BLM Lands Record of Decision, 

and originally developed for the Forest Service’s 1988 Managing Competing and Unwanted Vegetation Final Environmental Impact 

Statement. as part of a HHRA that covers 16 herbicides. 

4. 2007 BLM PEIS Ecological Risk Assessment Appendices are as follows:

A. Relevant Data B. ERA Worksheets C. Listed Species D. CBI Information E. Tank Mix Risk Quotients

5. 2007 BLM PEIS Human Health Risk Assessment Appendices are as follows:

A. Herbicide Labels B. Spreadsheets C. AgDrift Modeling D. Gleams Modeling E. Public Uncertainty Analysis

6. The 2,4-D Risk Assessment was replaced in 2006.

Table A8-2: Additional Risk Assessment Information

2007 BLM PEIS ERA 2005 FS EIS ERA and HHRA 2007 BLM PEIS HHRA

Ecological Risk Assessment Protocol

Appendix A: AgDrift Modeling

Appendix B: Gleams Modeling

Preparation of Environmental Documentation and 

Risk Assessments

Nonylphenol Polyethoxylate-based (NPE) 

Surfactants

Appendix B – Spreadsheets

Occupational – All

Public – General
 608

Vegetation Treatments Using Herbicides on BLM Lands in Oregon
609

Final Environmental Impact Statement: Appendix 9

Appendix 9 – 

Additional Information About the 

18 Herbicides

Table of Contents

Herbicide Formulations Approved for Use on BLM Lands Nationally as of November 2009.................609

Target Species and Recommended Herbicide Controls.............................................................................617

Adjuvants Approved for Use on BLM Lands Nationally as of November 2009.......................................624

Individual Herbicide Summaries ...............................................................................................................627

Herbicide Formulations Approved for BLM Lands

Table A9-1 shows herbicide trade names that could be approved (depending on the alternative selected) for use on 

BLM lands in Oregon in 2010. These herbicides are approved for use by the EPA, approved for use in Oregon, 

and approved for use on BLM lands. This list is subject to change annually; it is just informational. Label 

restrictions apply. 

Table A9-1. Herbicide Formulations Approved for Use on BLM Lands Nationally as of November 2009

(This list is subject to change annually.)

Active Ingredient Trade Name Manufacturer EPA Reg. Number

Bromacil Bromacil 80DF Alligare, LLC 81927-4

Bromacil Hyvar X DuPont 352-287

Bromacil Hyvar XL DuPont 352-346

Bromacil + Diuron Bromacil/Diuron 40/40 Alligare, LLC 81927-3

Bromacil + Diuron DiBro 2+2 Nufarm Americas Inc. 228-227

Bromacil + Diuron DiBro 4+2 Nufarm Americas Inc. 228-386

Bromacil + Diuron DiBro 4+4 Nufarm Americas Inc. 228-235

Bromacil + Diuron Krovar I DF DuPont 352-505

Bromacil + Diuron Weed Blast 4G SSI Maxim 34913-19

Bromacil + Diuron Weed Blast Res. Weed Cont. Loveland Products Inc. 34704-576

Chlorsulfuron Chlorsulfuron E-Pro 75 WDG Nufarm Americas Inc. 79676-72

Chlorsulfuron NuFarm Chlorsulf Pro 75 WDG Nufarm Americas Inc. 228-672

Chlorsulfuron Telar DF DuPont 352-522

Chlorsulfuron Telar XP DuPont 352-654

Clopyralid CleanSlate Nufarm Americas Inc. 228-491

Clopyralid Clopyralid 3 Alligare, LLC 42750-94-81927

Clopyralid Cody Herbicide Alligare, LLC 81927-28

Clopyralid Pyramid R&P Albaugh, Inc. 42750-94

Clopyralid Reclaim Dow AgroSciences 62719-83
 610

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Active Ingredient Trade Name Manufacturer EPA Reg. Number

Clopyralid Spur Albaugh, Inc. 42750-89

Clopyralid Stinger Dow AgroSciences 62719-73

Clopyralid Transline Dow AgroSciences 62719-259

Clopyralid + 2,4-D Commando Albaugh, Inc. 42750-92

Clopyralid + 2,4-D Curtail Dow AgroSciences 62719-48

Clopyralid + 2,4-D Cutback Nufarm Americas Inc. 71368-72

2,4-D 2,4-D 4# Amine Weed Killer UAP-Platte Chem. Co. 34704-120

2,4-D 2,4-D Amine Helena Chem. Co. 5905-72

2,4-D 2,4-D Amine Setre (Helena) 5905-72

2,4-D 2,4-D Amine 4 Albaugh, Inc./Agri Star 42750-19

2,4-D 2,4-D LV 4 Albaugh, Inc./Agri Star 42750-15

2,4-D 2,4-D LV 6 Albaugh, Inc./Agri Star 42750-20

2,4-D 2,4-D LV 6 Ester Nufarm Americas Inc. 228-95

2,4-D 2,4-D LV4 Setre (Helena) 5905-90

2,4-D 2,4-D LV6 Helena Chem. Co. 4275-20-5905

2,4-D 2,4-D LV6 Setre (Helena) 5905-93

2,4-D Agrisolution 2,4-D Amine 4 Agriliance, L.L.C. 1381-103

2,4-D Agrisolution 2,4-D Amine 4 Winfield Solutions, LLC 1381-103

2,4-D Agrisolution 2,4-D LV4 Agriliance, L.L.C. 1381-102

2,4-D Agrisolution 2,4-D LV4 Winfield Solutions, LLC 1381-102

2,4-D Agrisolution 2,4-D LV6 Agriliance, L.L.C. 1381-101

2,4-D Agrisolution 2,4-D LV6 Winflied Solutions, LLC 1381-101

2,4-D Amine 4 Wilbur-Ellis Co. 2935-512

2,4-D Amine 4CA 2,4-D Weed Killer Loveland Products Inc. 34704-5

2,4-D Aqua-Kleen Nufarm Americas Inc. 71368-4

2,4-D Aqua-Kleen Nufarm Americas Inc. 228-378

2,4-D Barrage HF Helena 5905-529

2,4-D Barrage LV Ester Setre (Helena) 5905-504

2,4-D Clean Amine Loveland Products Inc. 34704-120

2,4-D Clean Crop Amine 4 UAP-Platte Chem. Co. 34704-5 CA

2,4-D Clean Crop Low Vol 6 Ester UAP-Platte Chem. Co. 34704-125

2,4-D Clean Crop LV-4 ES UAP-Platte Chem. Co. 34704-124

2,4-D Cornbelt 4 lb. Amine Van Diest Supply Co. 11773-2

2,4-D Cornbelt 4# LoVol Ester Van Diest Supply Co. 11773-3

2,4-D Cornbelt 6# LoVol Ester Van Diest Supply Co. 11773-4

2,4-D D-638 Albaugh, Inc./Agri Star 42750-36

2,4-D Esteron 99C Nufarm Americas Inc. 62719-9-71368

2,4-D Five Star Albaugh, Inc./Agri Star 42750-49

2,4-D Formula 40 Nufarm Americas Inc. 228-357

2,4-D HardBall Helena 5905-549

2,4-D Hi-Dep PBI Gordon Corp. 2217-703
611

Final Environmental Impact Statement: Appendix 9

Active Ingredient Trade Name Manufacturer EPA Reg. Number

2,4-D Lo Vol-4 Wilbur-Ellis Co. 228-139-2935

2,4-D Lo Vol-6 Ester Wilbur-Ellis Co. 228-95-2935

2,4-D Low Vol 4 Ester Weed Killer Loveland Products Inc. 34704-124

2,4-D Low Vol 6 Ester Weed Killer Loveland Products Inc. 34704-125

2,4-D LV-6 Ester Weed Killer Loveland Products Inc. 34704-6

2,4-D Opti-Amine Helena Chem. Co. 5905-501

2,4-D Platoon Nufarm Americas Inc. 228-145

2,4-D Saber Loveland Products Inc. 34704-803

2,4-D Saber CA Loveland Products Inc. 34704-803

2,4-D Salvo Loveland Products Inc. 34704-609

2,4-D Salvo LV Ester UAP-Platte Chem. Co. 34704-609

2,4-D Savage DF Loveland Products Inc. 34704-606

2,4-D Savage DF UAP-Platte Chem. Co. 34704-606

2,4-D Solve 2,4-D Albaugh, Inc./Agri Star 42750-22

2,4-D Unison Helena 5905-542

2,4-D Weedar 64 Nufarm Americas Inc. 71368-1

2,4-D Weedone LV-4 Nufarm Americas Inc. 228-139-71368

2,4-D Weedone LV-4 Solventless Nufarm Americas Inc. 71368-14

2,4-D Weedone LV-6 Nufarm Americas Inc. 71368-11

2,4-D WEEDstroy AM-40 Nufarm Americas Inc. 228-145

Dicamba Banvel Arysta LifeScience N.A. Corp. 66330-276

Dicamba Banvel Micro Flo Company 51036-289

Dicamba Clarity BASF Ag. Products 7969-137

Dicamba Cruise Control Alligare, LLC 42750-40-81927

Dicamba Diablo Nufarm Americas Inc. 228-379

Dicamba Dicamba DMA Albaugh, Inc./Agri Star 42750-40

Dicamba Rifle Loveland Products Inc. 34704-861

Dicamba Sterling Blue Winfield Solutions, LLC 7969-137-1381

Dicamba Vanquish Syngenta 100-884

Dicamba Vanquish Herbicide Nufarm Americas Inc. 228-397

Dicamba Vision Albaugh, Inc. 42750-98

Dicamba + 2,4-D Brash Winfield Solutions, LLC 1381-202

Dicamba + 2,4-D KambaMaster Nufarm Americas Inc. 71368-34

Dicamba + 2,4-D Outlaw Albaugh, Inc./Agri Star 42750-68

Dicamba + 2,4-D Range Star Albaugh, Inc./Agri Star 42750-55

Dicamba + 2,4-D Rifle-D Loveland Products Inc. 34704-869

Dicamba + 2,4-D Veteran 720 Nufarm Americas Inc. 228-295

Dicamba + 2,4-D Weedmaster BASF Ag. Products 7969-133

Dicamba + Diflufenzopyr Distinct BASF Ag. Products 7969-150

Dicamba + Diflufenzopyr Overdrive BASF Ag. Products 7969-150

Diquat Diquat E-Pro 2L Nufarm Americas Inc. 79676-75
 612

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Active Ingredient Trade Name Manufacturer EPA Reg. Number

Diquat Nufarm Diquat 2L Herbicide Nufarm Americas Inc. 228-675

Diquat NuFarm Diquat Pro 2L Herbicide Nufarm Americas Inc. 228-675

Diquat Reward Syngenta Crop Prot., Inc. 100-1091

Diuron Direx 4L DuPont 352-678

Diuron Direx 4L Griffin Company 1812-257

Diuron Direx 80DF Griffin Company 1812-362

Diuron Diuron 4L Loveland Products Inc. 34704-854

Diuron Diuron 4L Makteshim Agan of N.A. 66222-54

Diuron Diuron 80 WDG Loveland Products Inc. 34704-648

Diuron Diuron 80DF Agriliance, L.L.C. 9779-318

Diuron Diuron 80DF Alligare, LLC 81927-12

Diuron Diuron 80DF Winfield Solutions, LLC 9779-318

Diuron Diuron 80WDG UAP-Platte Chem. Co. 34704-648

Diuron Diuron-DF Wilbur-Ellis 00352-00-508-02935

Diuron Karmex DF DuPont 352-692

Diuron Karmex IWC DuPont 352-692

Diuron Karmex XP DuPont 352-692

Diuron Vegetation Man. Diuron 80 DF Vegetation Man., LLC 66222-51-74477

Fluridone Avast! SePRO 67690-30

Fluridone Sonar AS SePRO 67690-4

Fluridone Sonar Precision Release SePRO 67690-12

Fluridone Sonar Q SePRO 67690-3

Fluridone Sonar SRP SePRO 67690-3

Glyphosate Accord Concentrate Dow AgroSciences 62719-324

Glyphosate Accord SP Dow AgroSciences 62719-322

Glyphosate Accord XRT Dow AgroSciences 62719-517

Glyphosate Accord XRT II Dow AgroSciences 62719-556

Glyphosate Aqua Neat Nufarm Americas Inc. 228-365

Glyphosate Aqua Star Albaugh, Inc./Agri Star 42750-59

Glyphosate Aquamaster Monsanto 524-343

Glyphosate AquaPro Aquatic Herbicide SePRO Corporation 62719-324-67690

Glyphosate Buccaneer Tenkoz 55467-10

Glyphosate Buccaneer Plus Tenkoz 55467-9

Glyphosate ClearOut 41 Chem. Prod. Tech., LLC 70829-2

Glyphosate ClearOut 41 Plus Chem. Prod. Tech., LLC 70829-3

Glyphosate Cornerstone Winfield Solutions, LLC 1381-191

Glyphosate Cornerstone Plus Winfield Solutions, LLC 1381-192

Glyphosate Credit Xtreme Nufarm Americas Inc. 71368-81

Glyphosate Forest Star Albaugh, Inc./Agri Star 42570-61

Glyphosate Foresters Nufarm Americas Inc. 228-381

Glyphosate Gly Star Original Albaugh, Inc./Agri Star 42750-60
613

Final Environmental Impact Statement: Appendix 9

Active Ingredient Trade Name Manufacturer EPA Reg. Number

Glyphosate Gly Star Plus Albaugh, Inc./Agri Star 42750-61

Glyphosate Gly Star Pro Albaugh, Inc./Agri Star 42750-61

Glyphosate Glyfos Cheminova 4787-31

Glyphosate Glyfos Aquatic Cheminova 4787-34

Glyphosate Glyfos PRO Cheminova 67760-57

Glyphosate GlyphoMate 41 PBI Gordon Corp. 2217-847

Glyphosate Glyphosate 4 Vegetation Man., LLC 73220-6-74477

Glyphosate Glyphosate 4 PLUS Alligare, LLC 81927-9

Glyphosate Glyphosate 5.4 Alligare, LLC 81927-8

Glyphosate Glypro Dow AgroSciences 62719-324

Glyphosate Glypro Plus Dow AgroSciences 62719-322

Glyphosate Honcho Monsanto 524-445

Glyphosate Honcho Plus Monsanto 524-454

Glyphosate Mirage Loveland Products Inc. 34704-889

Glyphosate Mirage Herbicide UAP-Platte Chem. Co. 524-445-34704

Glyphosate Mirage Plus Loveland Products Inc. 34704-890

Glyphosate Mirage Plus Herbicide UAP-Platte Chem. Co. 524-454-34704

Glyphosate Rascal Winfield Solutions, LLC 1381-191

Glyphosate Rascal Plus Winfield Solutions, LLC 1381-192

Glyphosate Rattler Setre (Helena) 524-445-5905

Glyphosate Razor Nufarm Americas Inc. 228-366

Glyphosate Razor Pro Nufarm Americas Inc. 228-366

Glyphosate Rodeo Dow AgroSciences 62719-324

Glyphosate Roundup Original Monsanto 524-445

Glyphosate Roundup Original II Monsanto 524-454

Glyphosate Roundup Original II CA Monsanto 524-475

Glyphosate Roundup PRO Monsanto 524-475

Glyphosate Roundup PRO Concentrate Monsanto 524-529

Glyphosate Roundup PRO Dry Monsanto 524-505

Glyphosate Roundup PROMAX Monsanto 524-579

Glyphosate + 2,4-D Campaign Monsanto 524-351

Glyphosate + 2,4-D Landmaster BW Albaugh, Inc./Agri Star 42570-62

Glyphosate + 2,4-D Landmaster BW Monsanto 524-351

Glyphosate + Dicamba Fallowmaster Monsanto 524-507

Glyphosate + Dicamba GlyKamba Nufarm Americas Inc. 71368-30

Hexazinone Pronone 10G Pro-Serve 33560-21

Hexazinone Pronone 25G Pro-Serve 33560-45

Hexazinone Pronone MG Pro-Serve 33560-21

Hexazinone Velpar DF DuPont 352-581

Hexazinone Velpar L DuPont 352-392

Hexazinone Velpar ULW DuPont 352-450
 614

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Active Ingredient Trade Name Manufacturer EPA Reg. Number

Hexazinone + Sulfometuron 

methyl Oustar DuPont Crop Protection 352-603

Hexazinone + Sulfometuron 

methyl Westar DuPont Crop Protection 352-626

Imazapic Imazapic E 2 SL Etigra, LLC 79676-65

Imazapic Panoramic 2SL Alligare, LLC 66222-141-81927

Imazapic Plateau BASF 241-365

Imazapic + Glyphosate Journey BASF 241-417

Imazapyr Arsenal BASF 241-346

Imazapyr Arsenal Applicators Conc. BASF 241-299

Imazapyr Arsenal PowerLine BASF 241-431

Imazapyr Arsenal Railroad Herbicide BASF 241-273

Imazapyr Chopper BASF 241-296

Imazapyr Ecomazapyr 2 SL Vegetation Man., LLC 74477-6

Imazapyr Ecomazapyr 2SL Alligare, LLC 81927-22

Imazapyr Habitat BASF 241-426

Imazapyr Imazapyr 2 SL Vegetation Man., LLC 74477-4

Imazapyr Imazapyr 2SL Alligare, LLC 81927-23

Imazapyr Imazapyr 4 SL Vegetation Man., LLC 74477-5

Imazapyr Imazapyr 4SL Alligare, LLC 81927-24

Imazapyr Imazapyr E-Pro 2 - VM & Aquatic 

Herbicide Etigra, LLC 81959-8

Imazapyr Imazapyr E-Pro 2E - Site Prep & Basal Etigra, LLC 81959-7

Imazapyr Imazapyr E-Pro 4 - Forestry Etigra, LLC 81959-9

Imazapyr Polaris Nufarm Americas Inc. 228-534

Imazapyr Polaris AC Nufarm Americas Inc. 241-299-228

Imazapyr Polaris AC Nufarm Americas Inc. 228-480

Imazapyr Polaris AQ Nufarm Americas Inc. 241-426-228

Imazapyr Polaris Herbicide Nufarm Americas Inc. 241-346-228

Imazapyr Polaris RR Nufarm Americas Inc. 241-273-228

Imazapyr Polaris SP Nufarm Americas Inc. 228-534

Imazapyr Polaris SP Nufarm Americas Inc. 241-296-228

Imazapyr SSI Maxim Arsenal 0.5G SSI Maxim Co., Inc. 34913-23

Imazapyr Stalker BASF 241-398

Imazapyr + Diuron Imazuron E-Pro Etigra, LLC 79676-54

Imazapyr + Diuron Mojave 70 EG Alligare, LLC 74477-9-81927

Imazapyr + Diuron Sahara DG BASF 241-372

Imazapyr + Diuron SSI Maxim Topsite 2.5G SSI Maxim Co., Inc. 34913-22

Imazapyr + Metsulfuron 

methyl Lineage Clearstand DuPont 352-766

Imazapyr + Sulfometuron 

methyl + Metsulfuron methyl Lineage HWC DuPont 352-765

Imazapyr + Sulfometuron 

methyl + Metsulfuron methyl Lineage Prep DuPont 352-767
615

Final Environmental Impact Statement: Appendix 9

Active Ingredient Trade Name Manufacturer EPA Reg. Number

Metsulfuron methyl Escort DF DuPont 352-439

Metsulfuron methyl Escort XP DuPont 352-439

Metsulfuron methyl Metsulfuron Methyl DF Vegetation Man., L.L.C. 74477-2

Metsulfuron methyl MSM 60 Alligare, LLC 81927-7

Metsulfuron methyl MSM E-AG 60 EG Herbicide Etigra, LLC 81959-14

Metsulfuron methyl MSM E-Pro 60 EG Herbicide Etigra, LLC 81959-14

Metsulfuron methyl Patriot Nufarm Americas Inc. 228-391

Metsulfuron methyl PureStand Nufarm Americas Inc. 71368-38

Metsulfuron methyl + 

Chlorsulfuron Cimarron Extra DuPont 352-669

Metsulfuron methyl + 

Chlorsulfuron Cimarron Plus DuPont 352-670

Metsulfuron methyl + 

Dicamba + 2,4-D Cimarron MAX DuPont 352-615

Picloram Grazon PC Dow AgroSciences 62719-181

Picloram OutPost 22K Dow AgroSciences 62719-6

Picloram Picloram 22K Alligare, LLC 42750-79-81927

Picloram Picloram 22K Alligare, LLC 81927-18

Picloram Picloram K Alligare, LLC 42750-81-81927

Picloram Picloram K Alligare, LLC 81927-17

Picloram Tordon 22K Dow AgroSciences 62719-6

Picloram Tordon K Dow AgroSciences 62719-17

Picloram Triumph 22K Albaugh, Inc. 42750-79

Picloram Triumph K Albaugh, Inc. 42750-81

Picloram Trooper 22K Nufarm Americas Inc. 228-535

Picloram + 2,4-D Grazon P+D Dow AgroSciences 62719-182

Picloram + 2,4-D GunSlinger Albaugh, Inc. 42750-80

Picloram + 2,4-D HiredHand P+D Dow AgroSciences 62719-182

Picloram + 2,4-D Pathway Dow AgroSciences 62719-31

Picloram + 2,4-D Picloram + D Alligare, LLC 42750-80-81927

Picloram + 2,4-D Picloram + D Alligare, LLC 81927-16

Picloram + 2,4-D Tordon 101 R Forestry Dow AgroSciences 62719-31

Picloram + 2,4-D Tordon 101M Dow AgroSciences 62719-5

Picloram + 2,4-D Tordon RTU Dow AgroSciences 62719-31

Picloram + 2,4-D Trooper 101 Nufarm Americas Inc. 228-561

Picloram + 2,4-D Trooper P + D Nufarm Americas Inc. 228-530

Picloram + 2,4-D + Dicamba Trooper Extra Nufarm Americas Inc. 228-586

Sulfometuron methyl Oust DF DuPont 352-401

Sulfometuron methyl Oust XP DuPont 352-601

Sulfometuron methyl SFM 75 Alligare, LLC 81927-26

Sulfometuron methyl SFM 75 Vegetation Man., L.L.C. 72167-11-74477

Sulfometuron methyl SFM E-Pro 75EG Etigra, LLC 79676-16
 616

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Active Ingredient Trade Name Manufacturer EPA Reg. Number

Sulfometuron methyl Spyder Nufarm Americas Inc. 228-408

Sulfometuron methyl + 

Chlorsulfuron Landmark XP DuPont 352-645

Sulfometuron methyl + 

Metsulfuron methyl Oust Extra DuPont 352-622

Tebuthiuron Spike 20P Dow AgroSciences 62719-121

Tebuthiuron Spike 80DF Dow AgroSciences 62719-107

Tebuthiuron SpraKil S-5 Granules SSI Maxim Co., Inc. 34913-10

Tebuthiuron + Diuron SpraKil SK-13 Granular SSI Maxim Co., Inc. 34913-15

Tebuthiuron + Diuron SpraKil SK-26 Granular SSI Maxim Co., Inc. 34913-16

Triclopyr Ecotriclopyr 3 SL Vegetation Man., LLC 72167-49-74477

Triclopyr Element 3A Dow AgroSciences 62719-37

Triclopyr Element 4 Dow AgroSciences 62719-40

Triclopyr Forestry Garlon XRT Dow AgroSciences 62719-553

Triclopyr Garlon 3A Dow AgroSciences 62719-37

Triclopyr Garlon 4 Dow AgroSciences 62719-40

Triclopyr Garlon 4 Ultra Dow AgroSciences 62719-527

Triclopyr Pathfinder II Dow AgroSciences 62719-176

Triclopyr Relegate Nufarm Americas Inc. 228-521

Triclopyr Remedy Dow AgroSciences 62719-70

Triclopyr Remedy Ultra Dow AgroSciences 62719-552

Triclopyr Renovate 3 SePRO Corporation 62719-37-67690

Triclopyr Renovate OTF SePRO Corporation 67690-42

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-384

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-518

Triclopyr Tahoe 3A Nufarm Americas Inc. 228-520

Triclopyr Tahoe 4E Nufarm Americas Inc. 228-385

Triclopyr Tahoe 4E Herbicide Nufarm Americas Inc. 228-517

Triclopyr Triclopry 4 Alligare, LLC 81927-11

Triclopyr Triclopyr 3 Alligare, LLC 81927-13

Triclopyr Triclopyr 3 SL Vegetation Man., LLC 72167-53-74477

Triclopyr Triclopyr 4EC Alligare, LLC 72167-53-74477

Triclopyr + 2,4-D Candor Nufarm Americas Inc. 228-565

Triclopyr + 2,4-D Crossbow Dow AgroSciences 62719-260

Triclopyr + 2,4-D Everett Alligare, LLC 81927-29

Triclopyr + Clopyralid Brazen Nufarm Americas Inc. 228-564

Triclopyr + Clopyralid Prescott Herbicide Alligare, LLC 81927-30

Triclopyr + Clopyralid Redeem R&P Dow AgroSciences 62719-337
617

Final Environmental Impact Statement: Appendix 9

Target Species and Recommended Herbicide Controls

Table A9-2 shows which herbicides are recommended for what species. The information pertains primarily 

to established or larger infestations; small infestations of noxious or invasive weeds of many species may be 

effectively controlled with non-herbicide methods such as hand pulling or digging. Recommended herbicides are 

necessary for effective/cost effective control of difficult-to-control species. Public comments about additional 

invasive species and treatment recommendations were used to update the information in this table between the 

Draft EIS and the Final EIS.

Table A9-2. Target Species and Recommended Herbicide Controls

Nonherbicide 

methods 

effective8

Alternative 

where 

recommended 

herbicide 

available1 Common Name

2,4-DBromacilChlorsulfuronClopyralidDicambaDiflufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr

Noxious Weeds

No 2 African rue √ √ √ √

No 2 Biddy-biddy √ √

No 2 Blackberry, Himalayan √3 √ √ √ √ √

No 3

Brazilian or S American 

waterweed √ √

Yes5 2 Broom, French √3 √ √ √ √3 √

Yes5 2 Broom, Portugese √3 √ √ √ √3 √

Yes5 2 Broom, Scotch √3 √ √ √ √3 √

No 2 Broom, Spanish √3 √ √ √ √3 √

Yes 2 Buffalobur √ √ √

No 2 Butterfly bush √ √

No 2 Camel thorn √ √ √ √

Yes 2 Cocklebur, spiny √ √ √ √ √

No 3 Coltsfoot √

No 2 Common bugloss √ √ √ √ √

Yes6 2 Common cruprina √3 √ √3 √ √

No 2 Common reed √

No 2 Cordgrass, common √ √

No 2 Cordgrass, dense flower √ √

No 2 Cordgrass, saltmeadow √ √

No 2 Cordgrass, smooth √ √

No 3 Creeping yellow cress √

No None Dodder

Yes 2 Dyers woad √ √ √ √

Yes5 2 English Ivy √ √

Yes6 2 European Water chestnut √

No 2 Field bindweed √ √ √

No 2 False brome √
 618

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Nonherbicide 

methods 

effective8

Alternative 

where 

recommended 

herbicide 

available1 Common Name

2,4-DBromacilChlorsulfuronClopyralidDicambaDiflufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr

Yes5 3 Flowering rush √

Yes6 2 Garlic mustard √

Yes 2 Geranium, Herb Robert √ √

Yes5 2 Geranium, Shiny leaf √ √ √

No 2 Giant Hogweed √ √

Yes7 2 Goatgrass, Barbed √ √ √

Yes7 2 Goatgrass, Jointed √2 √ √

Yes7 2 Goatgrass, Ovate √ √ √

Yes7 2 Goatsrue √ √ √

No 2 Gorse √3 √ √ √ √3 √

Yes 2 Halogeton √ √ √ √

No 2 Hawkweed, King-devil √3 √ √3 √ √3

No 2 Hawkweed, Meadow √3 √ √3 √ √

No 2 Hawkweed, Mouse-eared √3 √ √3 √ √3

No 2 Hawkweed, Orange √3 √ √3 √ √

No 2 Hawkweed, Yellow √3 √ √3 √ √

No 5 Horsetail, Giant √

Yes5 2 Houndstongue √ √ √ √2

No 3 Hydrilla √ √

No None Japanese dodder

No 2 Johnsongrass √ √2 √ √ √

Yes5 2

Jubata grass (Purple 

Pampas grass) √ √

Yes 2 Knapweed, Diffuse √2 √2 √

Yes9 2 Knapweed, Meadow √ √ √3 √ √ √2 √

No 2 Knapweed, Russian √ √ √

No 2 Knapweed, spotted √ √ √2

No 2 Knapweed, Squarrose √ √3 √ √ √ √

No 2 Knotweed, Giant √ √ √ √ √

No 2 Knotweed, Himalayan √ √ √ √ √

No 2 Knotweed, Japanese √ √ √ √ √

No 2 Kochia √2 √ √ √

No 2 Kudzu √ √

No 2

Lesser celadine or fig 

buttercup √

No 2 Matgrass √ √

Yes5 2 Mediterranean sage √ √ √

No 3 Medusahead rye √ √

No 2 Oblong spurge √ √ √ √ √ √

No 2 Old man’s beard √ √

No 2 Parrot’s feather √ √
619

Final Environmental Impact Statement: Appendix 9

Nonherbicide 

methods 

effective8

Alternative 

where 

recommended 

herbicide 

available1 Common Name

2,4-DBromacilChlorsulfuronClopyralidDicambaDiflufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr

No 2 Paterson’s curse √ √ √ √ √

No 3 Perennial peavine √

No 3 Perennial pepperweed √3 √ √ √

No 2 Poison hemlock √ √ √ √ √

Yes 2 Policemans helmet √ √ √

Yes5 2 Puncturevine √ √ √

No 2 Purple loosestrife √ √ √ √

No 2 Purple Nutsedge √ √

No 2 Quackgrass √3 √3 √ √

Yes 2 Ragweed √3 √ √ √

No 2 Rush skeletonweed √ √ √ √2

No 3 Saltcedar √ √

No 2 Silverleaf Nightshade √ √ √ √

No 2 Skeletonleaf bursage √3 √3 √

No None Small broomrape

Yes 2 Spanish heath √3 √3 √

No 3 Spikeweed √

Yes 3 Spurge laurel √

No 2 Spurge, Leafy √ √ √

No 2 Spurge, Myrtle √ √ √ √ √

No 2 St. Johnswort √ √ √

Yes5 2 Starthistle, Iberian √3 √3 √ √ √

Yes5 2 Starthistle, Purple √3 √3 √ √3 √

Yes 2 Starthistle, Yellow √ √2 √

No 2 Sulfur cinquefoil √ √2 √ √ √2

No 2 Swainsonpea √ √

No 2 Syrian bean-caper √ √3 √ √3 √

Yes 2 Tansy ragwort √ √ √ √ √

Yes 2 Teasel, cutleaf √ √ √3 √3 √ √ √

No 3 Texas blueweed √

Yes5 2 Thistle, Bull √2 √ √ √2,3 √3 √ √

No 2 Thistle, Canada √ √ √2 √

Yes 2 Thistle, Italian √ √ √ √

Yes 2 Thistle, Milk √ √ √ √3 √3 √ √ √

Yes 2 Thistle, Musk √2 √ √3 √2 √ √

Yes 2 Thistle, Plumeless √ √ √ √3 √3 √2 √ √ √

Yes 2 Thistle, Scotch √3 √ √ √3 √ √ √

Yes 2 Thistle, Slender flowered √ √ √ √

Yes 2 Thistle, Smooth distaff √ √

Yes5 2

Thistle, Taurian or bull 

cottonthistle √ √ √
 620

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Nonherbicide 

methods 

effective8

Alternative 

where 

recommended 

herbicide 

available1 Common Name

2,4-DBromacilChlorsulfuronClopyralidDicambaDiflufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr

Yes5 2 Thistle, Wooly distaff √ √

No 2 Toadflax, Dalmation √ √ √ √

No 2 Toadflax, Yellow √ √

Yes 2 Velvetleaf √ √2 √

No 3 Watermilfoil, Eurasian √ √

No 2 White Bryonia √3 √ √ √ √3

No 2 Whitetop, (Hoary cress) √ √ √ √ √ √ √

No 2 whitetop, Lens-podded √ √ √ √ √

No 2 Whitetop,Hairy √ √ √ √ √

No 2 Yellow Flag Iris √ √ √ √ √

Yes 2 Yellow floating heart √ √

No 3 Yellow nutsedge √

No 2 Yellowtuft (2 sp) √ √ √ √ √ √ √

Invasive Plants

No 3 Annual fescues √ √ √

No 3 Babysbreath √ √

No 4 Bare ground √ √ √

No 3 Bear’s breeches √

Yes 3 Bird cherry √ √

No 3 Birdfoot trefoil √

No 3 Black henbane √ √ √ √ √

No 3 Black locust √ √ √ √

No 3 Blackberry, Evergreen √3 √ √ √ √

No 3 Blackgrass √ √

No 3 Blackthorn √

No 5 Bouncing bet √ √3 √3

No 3 Bristly dog’s-tail √ √

Yes 3 Bur buttercup √ √ √ √ √

Yes 3 Burdock, common √2 √3 √2 √ √2 √3

Yes 3 Burnweed √

No 3 Cereal rye √ √ √

No 3 Cheatgrass √ √

No 3 Chicory √ √ √2 √ √2

No 3 Climbing nightshade √

No 3 Clover spp √

Yes 3 Cocklebur, rough √ √

No 3 Common knotweed √ √ √

Yes 3

Common or Wooly 

mullein √ √ √ √ √2

No 3 Common Pear √ √ √

No 3 Common velvet-grass √ √
621

Final Environmental Impact Statement: Appendix 9

Nonherbicide 

methods 

effective8

Alternative 

where 

recommended 

herbicide 

available1 Common Name

2,4-DBromacilChlorsulfuronClopyralidDicambaDiflufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr

No 3 Creeping buttercup √

No 3 Crested dog’s-tail grass √ √

No 3 Dandelion √

No 3 Dense silkybent √ √

No 3 Elecampane inula √

No 3 Elodea √ √

No 3 English holly √ √

NA 3

escaped ornamental 

grasses √ √

No 3 European beach grass √ √

Yes 3 European centaury √ √

No 3 False indigo √ √ √

No 3 Feverfew √ √ √ √ √

Yes 3 Field mustard √ √ √

No 3 Field sowthistle √ √ √

Yes 3

Garden cornflower or 

bachelor buttons √ √ √3 √ √ √ √

No 3 Garden vetch √ √ √ √

Yes 3 Goatgrass, Bulbed √ √ √

Yes 3 Goatgrass, Tausch’s √ √ √

No 3 Harding grass √ √

No 3 Hawkweed, common √ √ √ √ √

No 3 Hawkweed, Yellow √ √ √ √ √

No 3 Hawthorn, Oneseed √

No 3 Hawthorn, Smooth √

Yes 3 Herb Robert √

No 3 Horehound √ √3 √3 √

No 3 Italian ryegrass √ √ √

No 3 Knotweed, Bohemian √ √ √ √

Yes5 None Lepyrodiclis

Yes 3 Lesser hawkbit √

No 3 Marestail √

No 3 Mutiflora rose √3 √ √3 √

Yes 3 narrowleaf plantain √ √ √

No 3 North Africa grass √ √ √

No 3 Orchardgrass √ √

No 3 Oxeye daisy √ √ √ √2

Yes 3 Pampas grass, Uruguayan √ √

No 3 Paterson’s curse √ √ √ √ √

No 3 Pennyroyal √

No 3 Perennial ryegrass √ √
 622

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Nonherbicide 

methods 

effective8

Alternative 

where 

recommended 

herbicide 

available1 Common Name

2,4-DBromacilChlorsulfuronClopyralidDicambaDiflufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr

No 3 Periwinkle √ √

No 3 Poverty brome √ √

Yes 3 Prickly lettuce √

No 3 Prickly sowthistle √ √ √

Yes 3 Purple foxglove √ √ √ √ √

No 3 Red brome √ √

No 3 Reed canarygrass √ √

No 3 Ripgut brome √ √

No 3 Russian olive √ √

No 3 Shining geranium √ √ √

No 3 slender oat √ √

No 3 smalleaf periwinkle √ √

No 3 soft brome √ √

No 3 Spotted Cat’s ear √

No 3 spotted henbit √ √

No 3 Spreading hedge-parsley √ √ √ √

Yes 3 Starthistle, Malta √ √3 √3 √ √

No 3 sweet fennel √ √

Yes 3 sweetclover, white √

Yes 3 sweetclover, yellow √

No 3 tall fescue √ √

No 3 Tansy, Common √ √ √ √2 √ √2

Yes 3 Teasel, common √ √ √ √3 √3 √ √ √

Yes 3 Thistle, Russian √ √ √

No 3 Thistle, wavyleaf √ √ √ √3 √3 √ √ √

Yes 3 Thistle, Whitestem distaff √ √

No 3 Tree-of-heaven √3 √3 √ √ √ √ √

Yes 3

Tumbleweed or Prickly 

Russian thistle √ √ √ √ √ √

No 3 Wild carrot √ √

Yes 3 Wild oat √ √

No 2 Wild proso millet √ √ √

Yes 3 Wild safflower √ √

No 2 Yellow archangel √

No 3 Yellow glandweed √ √ √ √ √

Native and Other Non-Invasive Vegetation8

No 4 Alder √ √ √

No 4 Big leaf maple √ √

Yes 4 Big sagebrush √ √ √ √

Yes 4 Conifers √ √ √

No 4 Evergreen huckleberry
623

Final Environmental Impact Statement: Appendix 9

Nonherbicide 

methods 

effective8

Alternative 

where 

recommended 

herbicide 

available1 Common Name

2,4-DBromacilChlorsulfuronClopyralidDicambaDiflufenzopyr+DiquatDiuronFluridoneGlyphosateHexazinoneImazapicImazapyrMetsulfuronPicloramSulfometuronTebuthiuronTriclopyr

No 4 Grasses √ √ √ √

No 4 Hazel √2 √ √2

No 4 Madrone √ √ √ √

No 4 Ocean spray √

No 4 Pacific Rhododendron

No 4 Poison ivy √3 √ √ √3

No 4 Poison Oak √3 √ √ √ √3

Yes 4 Rabbitbrush √ √ √

No 4 salmonberry √ √ √ √

No 34 Tanoak √ √ √ √ √

No 4 Thimble berry √ √ √

No 4 Vine maple √ √ √ √

Yes 4 Western juniper √

No 4 Western water hemlock √

No 4 Willow √ √ √ √ √ √ 1 Based on the experience of District Weed Specialists and various references, primarily the Pacific Northwest Weed Management 

Handbook (OSU 2009), the Weed Control Methods Handbook (Tu et al. 2001), Weeds of California and other Western States (DiTomaso 

and Healy. 2007), Biology and Management of Noxious Rangeland Weeds (Sheley and Petroff 1999), The Nature Conservancy Element 

Stewardship Abstracts (TNC 2009). Other herbicides may be effective. Some of the herbicides may be effective only under certain 

conditions.

2 Excellent control, recommended from multiple sources.

3

 Used in combination with another herbicide (tank mix)

4 To control Sudden Oak Death, allowed under Alternative 3.

5 Effective on small or new infestations (manual/mechanical methods kill plants) but not feasible on larger or more established 

infestations.

6 Infestations require repeat visits for effective control –Manual/mechanical kill most plants, sprouts and germinating seeds require 

additional treatment. For larger infestations, herbicide use is recommended.

7 Some cropping systems and fallow are effective. These techniques are not likely to be compatible with wildland management.

8

 Native and other non-invasive vegetation is included on this table because a) it is important to know what native and other non-invasive 

species might be collaterally damaged by particular herbicides, and b) Alternatives 4 and 5 permit the use of herbicides for the control of 

native and other non-invasive species under certain circumstances. 

9

 The Institute of Applied Ecology found that hand pulling was the only non-herbicide control effective on meadow knapweed, although it 

was expensive.
 624

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

References:

DiTomaso, J.M. and E.A. Healy. 2007. Weeds of California and other Western States. UC DANR Publ. #3488. 

1808 pp.

Oregon State University. 2009. Pacific Northwest Weed Management Handbook. Editor: Ed Peachey. Available at 

http://weeds.ippc.orst.edu/pnw/weeds?01W_INTR06.dat

Sheley, Roger L, and Janet K. Petroff. 1999. Biology and Management of Noxious Rangeland Weeds. Oregon 

State University Press. Corvallis, Oregon.

The Nature Conservancy. 2009. The Nature Conservancy Element Stewardship Abstracts. Available at http://

www.imapinvasives.org/GIST/ESA/index.html

Tu, M., C. Hurd, and J. M. Randall. 2001. Weed Control Methods Handbook: Tools & Techniques for Natural 

Areas. The Nature Conservancy, http://www.invasive.org/gist/handbook.html. June 2001.

Adjuvants Approved for Use on BLM Lands Nationally

Table A9-3. Adjuvants Approved for Use on BLM Lands Nationally as of November 2009

(This list is subject to change annually.)

Adjuvant Type Trade Name Manufacturer

Surfactants

Non-ionic Actamaster Soluble Spray Adj. Loveland Products Inc.

Non-ionic Actamaster Spray Adjuvant Loveland Products Inc.

Non-ionic Activator 90 Loveland Products Inc.

Non-ionic Agripharm 90 Walco International

Non-ionic Agrisolutions Preference Agriliance, LLC.

Non-ionic Agrisolutions Preference Winfield Solutions, LLC

Non-ionic Aqufact Aqumix, Inc.

Non-ionic Baron Crown (Estes Incorporated)

Non-ionic Brewer 90-10 Brewer International

Non-ionic Cornbelt Premier 90 Van Diest Supply Co.

Non-ionic Induce Setre (Helena)

Non-ionic LI-700 Loveland Products Inc.

Non-ionic N.I.S. 80 Estes Incorporated

Non-ionic Optima Helena

Non-ionic R-900 Wilbur-Ellis

Non-ionic Red River 90 Red River Specialties, Inc.

Non-ionic Spec 90/10 Helena

Non-ionic Spray Activator 85 Van Diest Supply Co.

Non-ionic Spreader 90 Loveland Products Inc.

Non-ionic Super Spread 7000 Wilbur-Ellis

Non-ionic Super Spread 90 Wilbur-Ellis

Non-ionic UAP Surfactant 80/20 Loveland Products Inc.

Non-ionic X-77 Loveland Products Inc.

Spreader/Sticker Agri-Trend Spreader Agri-Trend

Spreader/Sticker Attach Loveland Products Inc.

Spreader/Sticker Bind-It Estes Incorporated

Spreader/Sticker Bond Loveland Products Inc.

Spreader/Sticker Cohere Helena
625

Final Environmental Impact Statement: Appendix 9

Adjuvant Type Trade Name Manufacturer

Spreader/Sticker CWC 90 CWC Chemical, Inc.

Spreader/Sticker Insist 90 Wilbur-Ellis

Spreader/Sticker Lastick Setre (Helena)

Spreader/Sticker Nu-Film-IR Miller Chem. & Fert. Corp.

Spreader/Sticker R-56 Wilbur-Ellis

Spreader/Sticker Surf-King PLUS Crown (Estes Incorporated)

Spreader/Sticker Tactic Loveland Products Inc.

Spreader/Sticker TopFilm Biosorb, Inc.

Silicone-based Aero Dyne-Amic Helena

Silicone-based Bind-It MAX Estes Incorporated

Silicone-based Dyne-Amic Helena

Silicone-based Freeway Loveland Products Inc.

Silicone-based Kinetic Setre (Helena)

Silicone-based Phase Loveland Products Inc.

Silicone-based Phase II Loveland Products Inc.

Silicone-based SilEnergy Brewer International

Silicone-based Silnet 200 Brewer International

Silicone-based Silwet L-77 Loveland Products Inc.

Silicone-based Sun Spreader Red River Specialties, Inc.

Silicone-based Sylgard 309 Wilbur-Ellis

Silicone-based Syl-Tac Wilbur-Ellis

Silicone-based Thoroughbred Estes Incorporated

Oil-based

Crop Oil Concentrate Agri-Dex Helena

Crop Oil Concentrate Brewer 83-17 Brewer International

Crop Oil Concentrate Crop Oil Concentrate Helena

Crop Oil Concentrate Crop Oil Concentrate Loveland Products Inc.

Crop Oil Concentrate Herbimax Loveland Products Inc.

Crop Oil Concentrate Majestic Crown (Estes Incorporated)

Crop Oil Concentrate Mor-Act Wilbur-Ellis

Crop Oil Concentrate R.O.C. Rigo Oil Conc. Wilbur-Ellis

Crop Oil Concentrate Red River Forestry Oil Red River Specialties, Inc.

Methylated Seed Oil Hasten Wilbur-Ellis

Methylated Seed Oil Methylated Spray Oil Conc. Helena

Methylated Seed Oil MSO Concentrate Loveland Products Inc.

Methylated Seed Oil Red River Supreme Red River Specialties, Inc.

Methylated Seed Oil Sun Wet Brewer International

Methylated Seed Oil Sunburn Red River Specialties, Inc.

Methylated Seed Oil SunEnergy Brewer International

Methylated Seed Oil Sunset Red River Specialties, Inc.

Methylated Seed Oil Super Spread MSO Wilbur-Ellis

Methylated Seed Oil + Organosilicone Inergy Crown (Estes Incorporated)

Vegetable Oil Amigo Loveland Products Inc.

Vegetable Oil Competitor Wilbur-Ellis

Vegetable Oil Noble Estes Incorporated

Fertilizer-based

Nitrogen-based Bronc Wilbur-Ellis

Nitrogen-based Bronc Max Wilbur-Ellis

Nitrogen-based Bronc Max EDT Wilbur-Ellis

Nitrogen-based Bronc Plus Dry EDT Wilbur-Ellis
 626

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Adjuvant Type Trade Name Manufacturer

Nitrogen-based Bronc Total Wilbur-Ellis

Nitrogen-based Cayuse Plus Wilbur-Ellis

Nitrogen-based Dispatch Loveland Products Inc.

Nitrogen-based Dispatch 111 Loveland Products Inc.

Nitrogen-based Dispatch 2N Loveland Products Inc.

Nitrogen-based Dispatch AMS Loveland Products Inc.

Nitrogen-based Flame Loveland Products Inc.

Nitrogen-based Quest Setre (Helena)

Special Purpose or Utility

Buffering Agent Buffers P.S. Helena

Buffering Agent Oblique Red River Specialties, Inc.

Buffering Agent Spray-Aide Miller Chem. & Fert. Corp.

Buffering Agent Tri-Fol Wilbur-Ellis

Colorants BullsEye Milliken Chemical

Colorants Hi-Light Becker-Underwood

Colorants Hi-Light WSP Becker-Underwood

Colorants Marker Dye Loveland Products Inc.

Colorants Signal Precision

Compatibility/ Suspension Agent Blendex VHC Setre (Helena)

Compatibility/ Suspension Agent E Z MIX Loveland Products Inc.

Compatibility/ Suspension Agent Support Loveland Products Inc.

Deposition Aid Agripharm Drift Control Walco International

Deposition Aid Bivert Wilbur-Ellis

Deposition Aid Compadre Loveland Products Inc.

Deposition Aid Coverage G-20 Wilbur-Ellis

Deposition Aid CWC Sharpshooter CWC Chemical, Inc.

Deposition Aid Cygnet Plus Brewer International

Deposition Aid EDT Concentrate Wilbur-Ellis

Deposition Aid Intac Plus Loveland Products Inc.

Deposition Aid Liberate Loveland Products Inc.

Deposition Aid Mist-Control Miller Chem. & Fert. Corp.

Deposition Aid Pointblank Helena

Deposition Aid Poly Control 2 Brewer International

Deposition Aid ProMate Impel Helena

Deposition Aid Reign Loveland Products Inc.

Deposition Aid Secure Ultra Red River Specialties, Inc.

Deposition Aid Sta Put Setre (Helena)

Deposition Aid Strike Zone DF Helena

Deposition Aid Weather Gard Loveland Products Inc.

Defoaming Agent Cornbelt Defoamer Van Diest Supply Co

Defoaming Agent Defoamer Brewer International

Defoaming Agent Fighter-F 10 Loveland Products Inc.

Defoaming Agent Fighter-F Dry Loveland Products Inc.

Defoaming Agent Foam Buster Setre (Helena)

Defoaming Agent Foam Fighter Miller Chem. & Fert. Corp.

Defoaming Agent No Foam Wilbur-Ellis

Diluent/Deposition Agent Hy-Grade EC CWC Chemical, Inc

Diluent/Deposition Agent Hy-Grade I CWC Chemical, Inc

Diluent/Deposition Agent Improved JLB Oil Plus Brewer International

Diluent/Deposition Agent JLB Oil Plus Brewer International
627

Final Environmental Impact Statement: Appendix 9

Adjuvant Type Trade Name Manufacturer

Diluent/Deposition Agent Red River Basal Oil Red River Specialties, Inc.

Foam Marker Align Helena

Foam Marker R-160 Wilbur-Ellis

Invert Emulsion Agent Redi-vert II Wilbur-Ellis

Tank Cleaner All Clear Loveland Products Inc.

Tank Cleaner Cornbelt Tank-Aid Van Diest Supply Co.

Tank Cleaner Kutter Wilbur-Ellis

Tank Cleaner Neutral-Clean Wilbur-Ellis

Tank Cleaner Tank and Equipment Cleaner Loveland Products Inc.

Tank Cleaner Wipe Out Helena

Water Conditioning Blendmaster Loveland Products Inc.

Water Conditioning Choice Loveland Products Inc.

Water Conditioning Choice Weather Master Loveland Products Inc.

Water Conditioning Choice Xtra Loveland Products Inc.

Water Conditioning Cut-Rate Wilbur-Ellis

Water Conditioning Rush Crown (Estes Incorporated)

Individual Herbicide Summaries

The following information about each of the 18 herbicides has been compiled for reference from information within 

the EIS. More information, including comparisons with other herbicides, can be found at the following locations:

• Examples of product names used on BLM lands can be found in this Appendix (Appendix 9);

• Species that an herbicide is effective on is contained in Appendix 7;

• Estimated Annual Treatment Acres is from Table 3-3 (Chapter 3);

• Selected Risk Categories includes data from Table 3-12 through 3-21 (Chapter 3), which summarizes the 

Risk Assessment information in (uncirculated) Appendix 8. H (High), M (Moderate), L (Low), and 0 (no 

risk) risk categories are defined in the Chapter 3 tables;

• Leaching, persistence and half-life information can be found in: 

◦ Table 3-1 (The 18 Herbicides section in Chapter 3)

◦ Table 4-14 (Soil Resources section in Chapter 4)

◦ Table 4-17 (Water Resources section in Chapter 4)

◦ Table 4-20 (Wetlands and Riparian Areas section);

• PEIS Mitigation Measures and Standard Operating Procedures can be found in Appendix 2; and,

• All other information can be found in the The 18 Herbicides section in Chapter 3.
 628

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

2,4-D is a post emergent foliar applied herbicide that is selective to broadleaf plants.

Species that it is effective on: 2,4-D is effective on about half of the Oregon-listed noxious weeds 2,4-D

(see Table A9-2).

Examples of Product Names used on BLM lands: Many (see Table A9-1).

Commercial formulations with other active ingredients: Many. Commercial formulations currently available to the BLM 

include mixtures with clopyralid, dicamba, glyphosate, metsulfuron methyl, picloram, and triclopyr.

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual 

Application Rates

(lbs/acre) 

Typical: 1

Maximum: 1.9

(PEIS Mitigation 

Measures limit 2,4-D to 

typical application rates 

where feasible)

Noxious Weeds 6,700 1,800 8,500 Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 1,900 2,100 4,000 Alternative 3 total

ROWs, Admin, Recreation Sites 700 200 900

Habitat Improvement 600 100 700

Alternative 4 (Proposed Action) total 3,100 2,300 5,400

Additional allowed under Alt 5 2,100 100 2,200

Alternative 5 total 5,200 2,300 7,500

Why is the Oregon BLM considering the use of this herbicide? 2,4-D is 

effective on a wide range of broadleaf weeds while protecting most grasses. 

While having additional herbicides available can allow for more target specific 

control, having one herbicide that controls a vast range of vegetation could 

reduce operator error that can occur while mixing and applying herbicides. 

The Oregon BLM has used 2,4-D without incident to human health for 23 

years. In addition, adding a small amount of 2,4-D to a tank mix can improve 

the effectiveness of the other herbicides and reduce the likelihood of weed 

resistance. Additional information about 2,4-D can be found in Appendix 12. 2,4-D is available under the No Action 

Alternative (Alternative 2); use of 2,4-D drops statewide under all of the action alternatives.

Selected Risk Categories

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site Drift

Low boom

Surface 

Runoff

Accidental 

Spill

Chronic 

Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical H 0 0 L L M L M 0

Maximum H 0 0 M L M M M 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation Consumption of Contaminated vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental

Chronic / 

Long-term

Acute / 

Accidental Chronic / Long-term

Typical 0 L 0 L 0 M 0

Maximum L L 0 L 0 M 0

Leaching, Persistence, and Half-life

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils (days)

PLP Leaching PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

20-100 33,900 Intermediate Intermediate Low Moderate Low 10 333

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation 

& Cultural
629

Final Environmental Impact Statement: Appendix 9

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide

• Minimize the size of application areas, where practical, when applying 2,4-D to limit impacts to wildlife, 

particularly through contamination of food items. (MM)

• Do not apply 2,4-D across large application areas, where feasible, to limit impacts to livestock, 

particularly through contamination of food items. (MM)

• Consider the size of the application area when making applications of 2,4-D in order to reduce potential 

impacts to wild horses and burros. (MM)

• Do not apply 2,4-D in HMAs during the peak foaling season (March through June, and especially in May 

and June). (MM)

• Do not exceed the typical application rate when applying 2,4-D in known traditional use areas. (MM)

• Use the typical application rate, where feasible, when applying 2,4-D to reduce risk to workers and the 

public. (MM)
 630

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Bromacil is pre and post emergent soil applied herbicide that is not selective.

Species that it is effective on: spiny Cocklebur, Johnsongrass, Quackgrass, Syrian bean-caper, 

Horehound. Used for bare ground

Examples of Product Names used on BLM lands: Hyvar X and Hyvar XL

Commercial formulations with other active ingredients: Bromacil + Diuron is sold as Kroval I DF, Weed Blast Res., Weed 

Cont., DiBro 2+2, DiBro 4+2, and Weed Blast 4G

Species that it is effective on: spiny Cocklebur, Johnsongrass, Quackgrass, Syrian bean-caper, Horehound. Used for bare ground

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual 

Application Rates

(lbs/acre)

Typical: 4

Maximum: 12

(PEIS Mitigation 

Measures limit bromacil 

to typical application 

rates where feasible)

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases NA NA NA Alternative 3 total

ROWs, Admin, Recreation Sites 700

NA

700

Habitat Improvement 0 0

Alternative 4 (Proposed Action) total 900 900

Additional allowed under Alt 5 0 100 100

Alternative 5 total 900 100 1,000

Why is the Oregon BLM considering the use of this herbicide? Bromacil, 

like diuron, is a non-selective herbicide that kills all vegetation. The primary 

use for bromacil would be in communications sites such as cell phone, radio, 

television tower sites, electrical substations, or similar facilities where complete 

vegetation control is desired to reduce fire risk and maintenance costs. 

Selected Risk Categories

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low 

boom

Surface 

Runoff

Accidental 

Spill

Chronic 

Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical H M 0 NE NE S, R, C 0 0 NE

Maximum H M 0 H NE NE S, R 0 NE

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / Accidental Chronic / Long-term

Typical 0 0 0 0 0 NE NE

Maximum 0 L L 0 L M NE

Leaching, Persistence, and Half-life

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP Leaching PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

32 700 High High Intermediate Moderate Moderate / 

High 60-240 144-198

Bromacil

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
631

Final Environmental Impact Statement: Appendix 9

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

• Minimize the use of bromacil in watersheds with downgradient ponds and streams if potential impacts to 

aquatic plants are identified. (MM)

• Minimize the size of application areas, where practical, when applying bromacil to limit impacts to 

wildlife, particularly through contamination of food items. (MM)

• Do not apply bromacil in rangelands, and use appropriate buffer zones (Tables A2-1 and 2) to limit 

contamination of off-site vegetation, which may serve as forage for wildlife. (MM)

• Do not apply bromacil across large application areas, where feasible, to limit impacts to livestock, 

particularly through contamination of food items. (MM)

• Do not apply bromacil in rangelands, and use appropriate buffer zones (Tables A2-1 and 2) to limit 

contamination of off-site vegetation, which may serve as forage for wildlife. (MM)

• Consider the size of the application area when making applications of bromacil in order to reduce potential 

impacts to wild horses and burros. (MM)

• Do not apply bromacil in grazing lands within herd management areas (HMAs), and use appropriate 

buffer zones identified in Tables A2-1 and 2 to limit contamination of vegetation in off-site foraging 

areas. (MM)

• Do not apply bromacil in HMAs during the peak foaling season (March through June, and especially in 

May and June) (MM)

• Do not exceed the typical application rate when applying bromacil in known traditional use areas. (MM)

• Avoid applying bromacil or tebuthiuron aerially in known traditional use areas. (MM)

• Use the typical application rate, where feasible, when applying bromacil to reduce risk to workers and the 

public. (MM)

• Avoid applying bromacil aerially. (MM)
 632

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Chlorsulfuron is a pre and early post emergent soil and foliar applied herbicide 

that is selective to broadleaf plants. It is effective on Common bugloss, Chlorsulfuron

Dyers woad, Giant Horsetail, Houndstongue, Oblong spurge, Paterson’s 

curse, Perennial pepperweed, Puncturevine, Leafy Spurge, Myrtle Spurge, Syrian bean-caper, cutleaf Teasel, Bull 

Thistle, Canada Thistle, Milk Thistle, Plumeless Thistle, Scotch Thistle, Dalmation Toadflax, Yellow Toadflax, 

Whitetop (Hoary cress), Lens-podded whitetop, Hairy Whitetop, Common or Wooly mullein, Feverfew, Field 

mustard, Paterson’s curse, Purple foxglove, Spreading hedge-parsley, Common Tansy, common Teasel, Thistle, 

wavyleaf, Wild carrot, and Yellow glandweed

Examples of Product Names used on BLM lands: Telar DF and Telar XP.

Commercial formulations with other active ingredients: Metsulfuron methyl + Chlorsulfuron is sold as Cimarron Extra and 

Cimarron Plus; Sulfometuron methyl + Chlorsulfuron is sold as Landmark XP.

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual 

Application Rates

(lbs/acre)

Typical: 0.047

Maximum: 0.141

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 3,300 NA 3,300 Alternative 3 total

ROWs, Admin, Recreation Sites 900

NA

900

Habitat Improvement 0 0

Alternative 4 (Proposed Action) total 4,100 4,100

Additional allowed under Alt 5 0 100 100

Alternative 5 total 4,100 100 4,200

Why is the Oregon BLM considering the use of this herbicide? 

Chlorsulfuron is an ALS-inhibitor that is effective against grasses and 

broadleaf plants such as whitetop, perennial pepperweed, Mediterranean 

sage, and thistles. It is often mixed with 2,4-D to reduce the likelihood of 

developing plant resistance and to produces more immediately visible results. 

It can also be used on toadflax and knapweeds. 

Selected Risk Categories

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical H M 0 NE NE 0 0 0 0

Maximum H M 0 H NE 0 L 0 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 NE NE

Maximum 0 0 0 0 0 0 NE

Leaching, Persistence, and Half-life

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP Leaching PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

40 7,000 High High Intermediate Moderate Moderate 40 109-263

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 Limit the aerial application of chlorsulfuron to areas with difficult land access, where no other means of application 

are possible. (MM)

•	 Limit application of chlorsulfuron via ground broadcast applications at the maximum application rate. (MM)

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation 

& Cultural
633

Final Environmental Impact Statement: Appendix 9

Clopyralid is a post emergent foliar applied herbicide that is selective to broadleaf plants. 

Species that it is effective on: Many (see Table A9-2).

Examples of Product Names used on BLM lands: Spur, Pyramid R&P, Clopyralid 3, Stinger, and Transline.

Commercial formulations with other active ingredients: Clopyralid + 2,4-D is sold as Curtail and Commando. Triclopyr + 

Clopyralid is sold as Redeem R&P.

Species that it is effective on: Many.

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual 

Application Rates

(lbs/acre)

Typical: 0.35

Maximum: 0.5

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 1,400 300 1,700 Alternative 3 total

ROWs, Admin, Recreation Sites 700 0 700

Habitat Improvement 0 100 100

Alternative 4 (Proposed Action) total 2,000 300 2,300

Additional allowed under Alt 5 0 0 0

Alternative 5 total 2,000 300 2,300

Why is the Oregon BLM considering the use of this herbicide? Clopyralid 

would target many of the same species as picloram, but is more selective. 

It is effective on knapweeds and Canada thistle, while minimizing risk to 

surrounding desirable brush, grass, and trees.

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical 0 0 0 H 0 0 0 0 0

Maximum L 0 0 H 0 0 0 0 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 L 0 L 0 M 0

Maximum 0 L 0 L 0 M 0

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

2 1,000 High Intermediate Low Moderate Moderate 40 >1,000

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide: None

Clopyralid

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 634

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Dicamba is a pre and post emergent foliar applied herbicide that is selective to broadleaf 

and woody plants (see Table A9-2).

Examples of Product Names used on BLM lands: Dicamba DMA, Vision, Banvel, Clarity, Rifle, Banvel, Diablo, and 

Vanquish

Commercial formulations with other active ingredients: Dicamba + 2,4-D is sold as Outlaw, Range Star, Weedmaster, 

Rifle-D, KambaMaster, and Veteran 720

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual 

Application Rates

(lbs/acre)

Typical: 0.25

Maximum: 2

(PEIS Mitigation 

Measures limit 2,4-D to 

typical application rates 

where feasible)

Noxious Weeds 4,500 100 4,600 Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 800 200 1,000 Alternative 3 total

ROWs, Admin, Recreation Sites 600 100 700

Habitat Improvement 100 0 100

Alternative 4 (Proposed Action) total 1,400 200 1,600

Additional allowed under Alt 5 100 0 100

Alternative 5 total 1,400 200 1,600

Why is the Oregon BLM considering the use of this herbicide?

Dicamba has been used extensively on thistles and perennial pepperweed; in 

combination with 2,4-D on mustards and knapweeds; and, in combination with 

picloram for rush skeletonweed. Use would drop under the action alternatives, 

and chlorsulfuron and metsulfuron methyl would be used for many of these 

treatments. However, dicamba provides good burn-down right up to seed set, 

which extends the treatment window. 

Selected Risk Categories: 

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical H 0 0 NE NE 0 0 0 0

Maximum H 0 0 NE NE 0 L L 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 L 0 0 0

Maximum 0 L 0 M 0 0 0

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

2 400,000 High Intermediate Low Moderate Low 14 >1,000

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 To minimize risks to terrestrial wildlife, do not exceed the typical application rate for applications of dicamba where 

feasible. (MM)

•	 Do not apply dicamba across large application areas, where feasible, to limit impacts to livestock, particularly 

through contamination of food items. (MM)

•	 Consider the size of the application area when making applications of dicamba in order to reduce potential impacts 

to wild horses and burros. (MM)

Dicamba

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation 

& Cultural
635

Final Environmental Impact Statement: Appendix 9

Diflufenzopyr + Dicamba is a post emergent soil applied herbicide that is 

selective to broadleaf plants

Species that it is effective on: Meadow Knapweed, Squarrose Knapweed, cutleaf Teasel, 

Bull Thistle, Milk Thistle, Musk Thistle, Plumeless Thistle, Garden cornflower or 

bachelor buttons, Malta Starthistle, common Teasel, and wavyleaf Thistle,

Examples of Product Names used on BLM lands: Overdrive, Distinct

Species that it is effective on: Meadow Knapweed, Squarrose Knapweed, cutleaf Teasel, Bull Thistle, Milk Thistle, Musk 

Thistle, Plumeless Thistle, Garden cornflower or bachelor buttons, Malta Starthistle, common Teasel, and wavyleaf Thistle,

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual 

Application Rates

(lbs/acre)

Typical: 0.2625

Maximum: 0.4375 on 

oil, gas, and mineral 

sites. Maximum rate on 

rangeland: 0.35

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases NA NA NA Alternative 3 total

ROWs, Admin, Recreation Sites NA NA NA

Habitat Improvement NA NA NA

Alternative 4 (Proposed Action) total NA NA NA

Additional allowed under Alt 5 NA NA NA

Alternative 5 total 100 100 200

Why is the Oregon BLM considering the use of this herbicide? Diflufenzopyr 

+ Dicamba is included only in Alternative 5. It would be used for many of the 

same species as dicamba. It can be used in a mixture with picloram, triclopyr, and 

clopyralid, allowing for a reduced rate of these chemicals.

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical M 0 0 NE NE NE Maximum H 0 0 M NE

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 NE NE

Maximum 0 0 0 0 0 0 NE

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 Minimize the size of application areas, where practical, when applying to limit impacts to wildlife, particularly 

through contamination of food items. (MM)

•	 Do not apply across large application areas, where feasible, to limit impacts to livestock, particularly through 

contamination of food items. (MM)

•	 Consider the size of the application area when making applications in order to reduce potential impacts to wild 

horses and burros. (MM)

•	 Do not exceed the typical application rate in HMAs during the peak foaling season in areas where foaling is known 

to take place. (MM)

Diflufenzopyr 

+ dicamba

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 636

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Diquat is a post-emergent aquatic non-selective herbicide. It is effective on Brazilian or South 

American waterweed, Hydrilla, Parrot’s feather, Eurasian Watermilfoil, Yellow floating heart, and Elodea

Examples of Product Names used on BLM lands (see Table A9-1): Reward

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total Annual 

Application Rates

 (lbs/acre)

Typical: 1

Maximum: 4

(PEIS Mitigation Measures 

limit diquat to typical 

application rates where 

feasible)

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases NA NA NA Alternative 3 total

ROWs, Admin, Recreation Sites

Habitat Improvement NA NA NA

Alternative 4 (Proposed Action) total

Additional allowed under Alt 5 100 100 200 Alternative 5 total

Why is the Oregon BLM considering the use of this herbicide? Diquat is an 

aquatic herbicide that is included only in Alternative 5. Of the 18 herbicides 

analyzed in the PEIS, this is the only herbicide that can control giant salvinia, 

which has not been found in Oregon.

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical H L NE NE NE NE L L NE

Maximum H M NE H NE NE M L NE

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 L 0 L NE NE

Maximum 0 L M L H H NE

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils (days)

PLP Leaching PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

1,000,000 718,000 Very Low Low High High High 1,000 >1,000

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide (see Appendix 2):

•	 Limit the use of diquat in water bodies that have native fish and aquatic resources. (MM)

•	 Do not aerially apply diquat directly to wetlands or riparian areas . (MM)

•	 Avoid use of diquat in riparian pasture while pasture is being used by livestock. (SOP)

•	 Do not exceed the typical application rate when applying 2,4-D, bromacil, diquat, diuron, fluridone, hexazinone, 

tebuthiuron, and triclopyr in known traditional use areas. (MM)

•	 Limit diquat applications to areas away from high residential and traditional use areas to reduce risks to Native 

Americans. (MM)

•	 Use the typical application rate, where feasible, when applying 2,4-D, bromacil, diquat, diuron, fluridone, 

hexazinone, tebuthiuron, and triclopyr to reduce risk to workers and the public. (MM)

•	 Limit diquat application to ATV, truck spraying, and boat applications to reduce risks to workers; limit diquat 

applications to areas away from high residential and subsistence use to reduce risks to the public. (MM)

Diquat

Areas where BLM could use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
637

Final Environmental Impact Statement: Appendix 9

Diuron is a pre-emergent herbicide applied to the soil.

Species that it is effective on: Herb Robert Geranium, Shiny leaf Geranium, Quackgrass, 

Syrian bean-caper, Horehound. Used for bare ground

Examples of Product Names used on BLM lands: Karmex DF, Karmex XP, Karmex IWC, Direx 4L, Direx 80DF, Diuron 

4L, Diuron 80 DF, Diuron 80 WDG

Commercial formulations with other active ingredients:

Tebuthiuron + Diuron sold as SpraKil SK-13 Granular and SpraKil SK-26 Granular

Imazapyr + Diuron sold as Mojave 70 EG, Sahara DG, Imazuron E-Pro, and SSI Maxim Topsite 2.5G

Bromacil + Diuron sold as Kroval I DF, Weed Blast Res. Weed Cont, DiBro 2+2, DiBro 4+2, and Weed Blast 4G

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total Annual 

Application Rates

(lbs/acre)

Typical: 6

Maximum: 20

(PEIS Mitigation Measures 

limit diuron to typical 

application rates where 

feasible)

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases NA NA NA Alternative 3 total

ROWs, Admin, Recreation Sites 1200 100 1200

Habitat Improvement 0 0 0

Alternative 4 (Proposed Action) total 1200 100 1300

Additional allowed under Alt 5 0 0 0

Alternative 5 total 1200 100 1300

Why is the Oregon BLM considering the use of this herbicide? The primary 

use for diuron would be in communications sites such as cell phone, radio, 

television tower sites, electrical substations, or similar facilities where no 

vegetation is desired. A bare ground herbicide would permit treatments of these 

sites every 2-3 years (see the Administrative Sites, Roads, and Rights-of-Way 

section in Chapter 4). It also has use as a site-preparation tool for nursery beds.

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical M 0 0 NE NE S, R S S, R, C NE Maximum H L 0 H NE S, R

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 M 0 0 NE NE

Maximum 0 L H L M H NE

Leaching, Persistence, and Half-life: 

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP Leaching PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

480 42 Intermediate High Intermediate Moderate Moderate 90 5-100

Diuron

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 638

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

• To minimize risks to workers and the public, terrestrial wildlife, wild horses, burros, and livestock, do not 

exceed the typical application rate for applications of diuron where feasible. (MM)

• Avoid applying diuron aerially. (MM)

• Minimize the use of diuron in watersheds with downgradient ponds and streams if potential impacts to 

aquatic plants are identified. (MM)

• Limit the use of diuron in watersheds with characteristics suitable for potential surface runoff that have fishbearing streams during periods when fish are in life stages most sensitive to the herbicide(s) used. (MM)

• Minimize the size of application areas, where practical, when applying diuron to limit impacts to wildlife, 

particularly through contamination of food items. (MM)

• Do not apply diuron in rangelands and use appropriate buffer zones (Tables A2-1 and 2) to limit 

contamination of off-site vegetation, which may serve as forage for wildlife. (MM)

• Do not apply diuron across large application areas, where feasible, to limit impacts to livestock, 

particularly through contamination of food items. (MM)

• Consider the size of the application area when making applications of diuron in order to reduce potential 

impacts to wild horses and burros. (MM)

• Do not apply diuron in grazing lands within herd management areas (HMAs), and use appropriate buffer 

zones identified in Tables A2-1 and 2 to limit contamination of vegetation in off-site foraging areas. (MM)

• Do not apply diuron in HMAs during the peak foaling season (March through June, and especially in May 

and June) (MM)

• Evaluate diuron applications on a site-by-site basis to avoid risks to humans. There appear to be few 

scenarios where diuron can be applied without risk to workers. (MM)
639

Final Environmental Impact Statement: Appendix 9

Fluridone is a post emergent aquatic herbicide that is effective on submersed plants.

Species that it is effective on: South American waterweed, Elodea, Hydrilla, and Watermilfoil

Examples of Product Names used on BLM lands: Avast!, Sonar AS, Sonar Precision 

Release, and Sonar Q, and Sonar SRP

Species that it is effective on: South American waterweed, Elodea, Hydrilla, and Watermilfoil

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total Annual 

Application 

Rates 

(lbs/acre)

Typical: 0.15

Maximum: 1.3

(PEIS Mitigation Measures 

limit fluridone to typical 

application rates where 

feasible)

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 100 200 300 Alternative 3 total

ROWs, Admin, Recreation Sites 0 0 0

Habitat Improvement 0 0 0

Alternative 4 (Proposed Action) total 100 200 300

Additional allowed under Alt 5 0 0 0

Alternative 5 total 100 200 300

Why is the Oregon BLM considering the use of this herbicide? Fluridone is an 

aquatic herbicide that requires prolonged plant contact, so it can only be used on 

aquatic plants in still water. It would be used primarily on Brazilian waterweed, 

elodea, hydrilla, and watermilfoil.

Selected Risk Categories: 

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical NE NE NE NE NE NE 0 0 NE

Maximum NE NE NE L NE NE 0 0 NE

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 NE NE

Maximum 0 0 0 0 0 M NE

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

1000 10 Low Intermediate Intermediate Low Low 21 4-270

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 Do not exceed the typical application rate when applying fluridone in known traditional use areas. (MM)

•	 Use the typical application rate, where feasible, when applying fluridone to reduce risk to workers and the public. (MM)

Fluridone

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 640

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Glyphosate is a post emergent soil or foliar applied herbicide that is non-selective. It 

is effective on about two thirds of the State-listed noxious weeds (see Table A9-2).

Examples of Product Names used on BLM lands: Many (see Table A9-1).

Commercial formulations with other active ingredients: Glyphosate is sold in combination with 2,4-D Dicamba and Imazapic.

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual Application Rates

(lbs/acre)

Typical: 2

Maximum: 7

(PEIS Mitigation Measures 

limit 2,4-D to typical 

application rates where 

feasible)

Noxious Weeds 700 5,200 5,900 Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 400 2,300 2,700 Alternative 3 total

ROWs, Admin, Recreation Sites 1,000 300 1,300

Habitat Improvement 100 200 300

Alternative 4 (Proposed Action) total 1,300 2,700 4,000

Additional allowed under Alt 5 100 100 200

Alternative 5 total 1,300 2,700 4,000

Why is the Oregon BLM considering the use of this herbicide? In addition to 

being used on broadleaf weeds and woody species, glyphosate has been used to 

treat medusahead in eastern Oregon. However, it is a non-selective herbicide 

and can harm desirable plants, so use has been limited to areas where this is an 

acceptable treatment. Glyphosate could be used on administrative sites, rights-ofway, and recreation sites under the Proposed Action (Alternative 4). Glyphosate 

and 2,4-D have been the only two aquatic herbicides available to the BLM for the 

past 23 years, and use would decrease as more aquatic herbicides became available. 

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical L 0 0 M 0 0 0 0 0

Maximum M 0 0 M 0 0 0 L 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 L 0 H 0

Maximum 0 L 0 L 0 H 0

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP Leaching PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

24,000 900,000 Very Low High High Moderate Moderate 47 12-70

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 Minimize potential risks to terrestrial wildlife, livestock, wild horses, and burros by applying glyphosate at the 

typical application rate where feasible. (MM)

•	 Where practical, limit glyphosate to spot applications in grazing land and wildlife habitat areas to avoid 

contamination of wildlife food items. (MM)

•	 Either avoid using glyphosate formulations containing POEA, or seek to use formulations with the least amount of 

POEA, to reduce risks to amphibians. (MM)

•	 Where feasible, limit glyphosate to spot applications in rangeland. (MM)

Glyphosate

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
641

Final Environmental Impact Statement: Appendix 9

Hexazinone is a pre and post emergent soil and foliar applied herbicide that is effective 

on grasses, broadleaf, and woody plants. It is effective on African rue and grasses.

Examples of Product Names used on BLM lands: Velpar ULW, Velpar L, and Velpar DF

Commercial formulations with other active ingredients: Hexazinone + Sulfometuron methyl is sold as Westar

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual Application Rates

(lbs/acre)

Typical: 2

Maximum: 4 

(PEIS Mitigation Measures 

limit hexazinone to typical 

application rates where 

feasible)

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 100 100 200 Alternative 3 total

ROWs, Admin, Recreation Sites 100 200 300

Habitat Improvement 0 100 100

Alternative 4 (Proposed Action) total 100 200 300

Additional allowed under Alt 5 0 100 100

Alternative 5 total 100 200 300

Why is the Oregon BLM considering the use of this herbicide? Hexazinone 

would be primarily used in administrative sites, utility and road rights-of-way, 

and along the deer exclosure fence lines at the seed orchards where vegetation 

must be removed to facilitate maintenance. It could also be used on African 

rue, a bushy invasive perennial that is toxic to people and livestock.

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical M 0 0 H M 0 0 0 0 Maximum M 0 0 H M 0 L

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 L 0 0 0

Maximum L 0 0 L 0 L 0

Leaching, Persistence, and Half-life: 

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

54 33,000 High High Intermediate High Moderate to 

High 90 30-180

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 To minimize risks, do not exceed the typical application rate for applications of hexazinone where feasible. (MM)

•	 Do not exceed the typical application rate of hexazinone in HMAs during the peak foaling season in areas where 

foaling is known to take place. (MM)

•	 Do not exceed the typical application rate when applying 2,4-D, bromacil, diquat, diuron, fluridone, hexazinone, 

tebuthiuron, and triclopyr in known traditional use areas. (MM)

•	 Where practical, limit hexazinone to spot applications in grazing land and wildlife habitat areas to avoid 

contamination of wildlife food items. (MM)

•	 Where feasible, limit glyphosate and hexazinone to spot applications in rangeland. (MM)

•	 Do not apply hexazinone with an over-the-shoulder broadcast applicator (backpack sprayer). (MM)

Hexazinone

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 642

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Imazapic is a pre and post emergent soil applied herbicide that is selective to some 

broadleaf plants and grasses. 

Species that it is effective on: Common bugloss, Giant Hogweed, Barbed Goatgrass, Jointed Goatgrass, Ovate Goatgrass, 

Halogeton, Johnsongrass, Meadow Knapweed, Squarrose Knapweed, Kochia, Medusahead rye, Oblong spurge, Paterson’s 

curse, Purple Nutsedge, Spurge, Leafy, Spurge, Myrtle Syrian bean-caper, cutleaf Teasel, Whitetop (Hoary cress), Lenspodded whitetop, Hairy Whitetop, Wild proso millet, Yellow Flag Iris, Yellow nutsedge, Annual fescues, Cereal rye, 

Cheatgrass, Common or Wooly mullein, Garden cornflower or bachelor buttons, Bulbed Goatgrass, Tausch’s Goatgrass, 

Italian ryegrass, North Africa grass, Paterson’s curse, Purple foxglove, Spreading hedge-parsley, tall fescue, Common Teasel, 

Russian Thistle, Tumbleweed or Prickly Russian thistle, and Yellow glandweed

Examples of Product Names used on BLM lands: Plateau and Panoramic 2SL

Commercial formulations with other active ingredients: Imazapic + Glyphosate is sold as Journey

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual Application Rates

(lbs/acre)

Typical: 0.0313

Maximum: 0.1875

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 11,000 500 11,500 Alternative 3 total

ROWs, Admin, Recreation Sites 400 100 500

Habitat Improvement 2,300 100 2,400

Alternative 4 (Proposed Action) total 13,500 500 14,000

Additional allowed under Alt 5 2,100 100 2,200

Alternative 5 total 15,500 500 16,000

Why is the Oregon BLM considering the use of this herbicide? Imazapic, an 

ALS-inhibitor, is especially effective against the invasive annual grasses such as 

cheatgrass and medusahead, which infest more than 5 million acres in eastern 

Oregon. At low rates, it is selective for these grasses, leaving the perennial 

herbaceous species critical for restoration. The BLM does not currently have an 

effective method of treating these fire-prone invasive annual grasses. 

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical L 0 0 NE NE NE 0 NE NE

Maximum M 0 0 H NE NE 0 NE NE

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 NE NE

Maximum 0 0 0 0 0 0 NE

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils (days)

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

137 2,200 High High Intermediate High Moderate 120-140 >1,000

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide: None.

Imazapic

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
643

Final Environmental Impact Statement: Appendix 9

Imazapyr is a pre and post emergent soil and foliar applied herbicide that is non-selective. 

It is effective on many species (see Table A9-2).

Examples of Product Names used on BLM lands (see Table A9-1): Arsenal, Arsenal 

Applicators Conc., Arsenal PowerLine, Arsenal Railroad Herbicide, Chopper, Ecomazapyr 2 SL, Habitat, Imazapyr 2 SL, 

Imazapyr 4 SL, Imazapyr E-Pro 2 - VM & Aquatic Herbicide, Imazapyr E-Pro 2E - Site Prep & Basal, Imazapyr E-Pro 4 – 

Forestry, Polaris, Polaris AC, Polaris AQ, Polaris Herbicide, Polaris RR, Polaris SP, SSI Maxim Arsenal 0.5G, and Stalker

Commercial formulations with other active ingredients:

Imazapyr + Diuron is sold as Imazuron E-Pro, Mojave 70 EG, Sahara DG, and SSI Maxim Topsite 2.5G

Imazapyr + Metsulfuron methyl is sold as Lineage Clearstand and Lineage HWC

Imazapyr + Sulfometuron methyl + Metsulfuron methyl is sold as Lineage Prep

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual Application 

Rates

(lbs/acre)

Typical: 0.45

Maximum: 1.25

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 300 1,200 1,500 Alternative 3 total

ROWs, Admin, Recreation Sites 100 500 600

Habitat Improvement 600 100 700

Alternative 4 (Proposed Action) total 1,000 1,600 2,600

Additional allowed under Alt 5 100 100 200

Alternative 5 total 1,100 1,600 2,700

Why is the Oregon BLM considering the use of this herbicide? Imazapyr 

is an ALS-inhibitor that is effective against brushy and woody species such 

as saltcedar and Russian olive. It would also be used on tanoak to control 

sudden oak death. At high doses, it is an effective bare ground herbicide that 

could be used in areas other bare ground herbicides are not registered for. It 

is used to treat African rue, Japanese knotweed, and leafy spurge.

Selected Risk Categories: 

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical M 0 0 H 0 0 0 0 0 Maximum M 0 0 H 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 0 0

Maximum 0 0 0 L 0 L 0

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

100 >11,000 High High Intermediate Moderate Moderate to 

High 25-141 >500

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide: None

Imazapyr

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 644

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Metsulfuron methyl is a post emigrant soil or foliar applied herbicide that 

is selective to broadleaf or woody plants. It is effective on African rue, 

Himalayan Blackberry, Common bugloss, Dyers woad, Field bindweed, 

Gorse, Halogeton, Houndstongue, Kochia, Paterson’s curse, Poison hemlock, Purple loosestrife, St. Johnswort, Sulfur 

cinquefoil, Tansy ragwort, cutleaf Teasel, Bull Thistle, Milk Thistle, Plumeless Thistle, Thistle, Scotch, Whitetop,(Hoary cress), 

Lens-podded whitetop, Hairy Whitetop, Yellow Flag Iris, Black henbane, Evergreen Blackberry, Bouncing bet, Feverfew, Italian 

ryegrass, Paterson’s curse, spotted henbit, Common Tansy, common Teasel, Russian Thistle, wavyleaf Thistle, Tree-of-heaven, 

Tumbleweed or Prickly Russian, thistle, Wild carrot, Conifers, Salmonberry, Tanoak, Thimble berry, Willow

Examples of Product Names used on BLM lands (see Table A9-1): Escort DF, Escort XP, Metsulfuron Methyl DF, MSM 60, 

MSM E-AG 60 EG Herbicide, MSM E-Pro 60 EG Herbicide, Patriot, and PureStand

Commercial formulations with other active ingredients:

Sulfometuron methyl + Metsulfuron methyl is sold as Oust Extra

Metsulfuron methyl + Chlorsulfuron is sold as Cimarron Extra and Cimarron Plus

Metsulfuron methyl + Dicamba + 2,4-D is sold as Cimarron MAX

Imazapyr + Metsulfuron methyl is sold as Lineage Clearstand

Imazapyr + Sulfometuron methyl + Metsulfuron methyl is sold as Lineage HWC and Lineage Prep

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual Application Rates

(lbs/acre)

Typical: 0.03

Maximum: 0.15

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 2000 500 2500 Alternative 3 total

ROWs, Admin, Recreation Sites 400 100 500

Habitat Improvement 100 0 100

Alternative 4 (Proposed Action) total 2300 600 2900

Additional allowed under Alt 5 100 0 100

Alternative 5 total 2300 600 2900

Why is the Oregon BLM considering the use of this herbicide? Metsulfuron 

methyl has similar targets and effects as chlorsulfuron, but can cause more 

harm to desired meadow grasses. It could be used on perennial pepperweed, 

whitetop and other mustards, and blackberries. It can also be used to control 

conifer trees under power lines.

Selected Risk Categories

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical L 0 0 H 0 0 0 0 - Maximum M 0 0 H 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 0 0

Maximum 0 0 0 0 0 0 0

Leaching, Persistence, and Half-life 

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

35 9,500 High High Intermediate Moderate Low 30 338

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide (see Appendix 2):

•	 Limit the aerial application of metsulfuron methyl to areas with difficult land access, where no other means of 

application are possible. (MM)

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural

Metsulfuron methyl
645

Final Environmental Impact Statement: Appendix 9

Picloram is a pre and post emergent foliar applied herbicde that is selective to broadleaf and 

Woody plants. It is effective on many species (see Table A9-2).

Examples of Product Names used on BLM lands: Grazon PC, OutPost 22K, Picloram 22K, Picloram K, Tordon 22K, 

Tordon K, Triumph 22K, Triumph K, Trooper 22K

Commercial formulations with other active ingredients:

Picloram + 2,4-D is sold as Grazon P+D, GunSlinger, HiredHand P+D, Pathway, Picloram + D, Tordon 101 R Forestry, 

Tordon 101M, Tordon RTU, Trooper 101, and Trooper P + D

Picloram + 2,4-D + Dicamba is sold as Trooper Extra

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual Application 

Rates

(lbs/acre)

Typical: 0.35

Maximum: 1

Noxious Weeds 3,600 200 3,800 Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 1,100 400 1,500 Alternative 3 total

ROWs, Admin, Recreation Sites 200 100 300

Habitat Improvement 1,300 0 1,300

Alternative 4 (Proposed Action) total 2,500 500 3,000

Additional allowed under Alt 5 100 0 100

Alternative 5 total 2,500 500 3,000

Why is the Oregon BLM considering the use of this herbicide? Picloram has 

been used on rush skeletonweed, knapweeds, toadflax, and thistles, and provides 

good residual control. Use would decrease under any of the action alternatives, and 

clopyralid, which is more selective, would likely be used instead. However, it is 

also effective on western juniper and could be used to improve sage grouse habitat. 

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical L 0 0 0 0 0 0 0 0 Maximum M 0 0 0 0 L

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation Consumption of Contaminated vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 L 0

Maximum 0 0 0 0 0 L 0

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

16 200,000 High High Intermediate Moderate Moderate/

High 20-300 >500

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 Do not apply picloram across large application areas, where feasible, to limit impacts to livestock, particularly 

through contamination of food items. (MM)

•	 Consider the size of the application area when making applications of picloram in order to reduce potential impacts 

to wild horses and burros. (MM)

Picloram

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 646

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Sulfometuron methyl Sulfometuron methyl is a pre and post emergent soil or foliar applied 

herbicide that is not selective. It is effective on Bouncing bet, Bur 

buttercup, Field mustard, Barbed Goatgrass, Bulbed Goatgrass, Jointed 

Goatgrass, Ovate Goatgrass, Grasses, Johnsongrass, Reed canarygrass, 

and salmonberry

Examples of Product Names used on BLM lands: Oust DF, 

Oust XP, SFM 75, SFM E-Pro 75EG, and Spyder

Commercial formulations with other active ingredients:

Sulfometuron methyl + Chlorsulfuron sold as Landmark XP 

Sulfometuron methyl + Metsulfuron methyl sold as Oust Extra

Hexazinone + Sulfometuron methyl sold as Oustar and Westar

Imazapyr + Sulfometuron methyl + Metsulfuron methyl sold as Lineage HWC an d Lineage Prep

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total

Annual Application 

Rates

(lbs/acre)

Typical: 0.14

Maximum: 0.38

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 400 100 500 Alternative 3 total

ROWs, Admin, Recreation Sites 500 0 500

Habitat Improvement 100 100 200

Alternative 4 (Proposed Action) total 900 100 1,000

Additional allowed under Alt 5 100 100 200

Alternative 5 total 900 200 1,100

Why is the Oregon BLM considering the use of this herbicide? Like imazapic, sulfometuron methyl (an ALS-inhibitor) 

is effective against cheatgrass and medusahead. It has a shorter half-life than imazapic, which speeds restoration efforts. 

However, sulfometuron methyl is not applied aerially, and is not registered for 

use in rangeland, and a current EPA proposal would limit its use in drier areas 

(see Chapter 1). This would limit its use on grasses to invasive grasses occurring 

in woodlands and forest openings. In addition, sulfometuron methyl is effective 

on mustards and can harm desirable forb species. In high doses, it would be used 

on road rights-of-way as a bare ground herbicide.

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site Drift

Low boom

Surface 

Runoff Accidental Spill Chronic 

Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical 0 0 0 NE NE NE 0 NE NE Maximum L 0 0 H NE

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 NE NE

Maximum 0 0 0 0 0 0 NE

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP Leaching PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

78 70 Intermediate High Low Low Low 20 60

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 Do not apply sulfometuron methyl aerially. (MM)

•	 Minimize the use of sulfometuron methyl in watersheds with downgradient ponds and streams if potential impacts to 

aquatic plants are identified. (MM)

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
647

Final Environmental Impact Statement: Appendix 9

Tebuthiuron is a pre and post emergent soil applied herbicide that is selective to 

broadleaf and woody plants

Species that it is effective on: Halogeton and sagebrush

Examples of Product Names used on BLM lands: Spike 20P, Spike 80DF, and SpraKil S-5 Granules

Commercial formulations with other active ingredients: Tebuthiuron + Diuron is sold as SpraKil SK-13 Granular and 

SpraKil SK-26 Granular

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total Annual Application 

Rates

(lbs/acre)

Typical: 0.5

Maximum: 4

(PEIS Mitigation 

Measures limit 

tebuthiuron to typical 

application rates where 

feasible)

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases NA NA NA Alternative 3 total

ROWs, Admin, Recreation Sites 100

NA

100

Habitat Improvement 300 300

Alternative 4 (Proposed Action) total 300 300

Additional allowed under Alt 5 500 100 600

Alternative 5 total 800 100 900

Why is the Oregon BLM considering the use of this herbicide? Tebuthiuron 

would primarily be used at low rates to thin sagebrush to improve habitat for 

sage grouse and other species. It could also be used at high rates as a bare 

ground herbicide.

Selected Risk Categories:

Terrestrial Vegetation Macrophytes Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical M 0 0 NE NE NE 0 R NE Maximum H 0 0 H NE SR SR

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation

Consumption of Contaminated 

vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / 

Accidental Chronic / Long-term

Typical 0 0 0 0 0 NE NE

Maximum 0 0 L 0 0 L NE

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

80 2,500 High High Intermediate High High 360 unknown

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 To minimize risks to the public and workers, terrestrial wildlife, livestock, wild horses, and burros, do not exceed the 

typical application rate, where feasible. (MM)

•	 Do not exceed the typical application rate when applying in known traditional use areas. (MM)

•	 Avoid applying tebuthiuron aerially in known traditional use areas. (MM)

Tebuthiuron

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
 648

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Triclopyr is a post emergent foliar applied herbicide that is selective to broadleaf 

and woody plants. It is effective on many species (see Table A9-2).

Examples of Product Names used on BLM lands: Triclopyr 4EC, Element 3A, Element 4, Forestry Garlon XRT, Garlon 

3A, Garlon 4, Garlon 4 Ultra, Remedy Ultra, Pathfinder II, Tahoe 3A, Tahoe 3A, Tahoe 4E, Renovate 3, Renovate OTF, 

Ecotriclopyr 3 SL, and Triclopyr 3 SL

Commercial formulations with other active ingredients: Triclopyr + 2,4-D is sold as Crossbow; Triclopyr + Clopyralid is 

sold as Redeem R&P

Estimated Annual Treatment Acres East of the 

Cascades

West of the 

Cascades Total Annual Application 

Rates

(lbs/acre)

Typical: 1

Maximum: 10

(PEIS Mitigation 

Measures limit triclopyr 

to typical application 

rates where feasible)

Noxious Weeds NA NA NA Alternative 2 (No Action) total

Invasive Plants and Pests and Diseases 700 1,500 2,200 Alternative 3 total

ROWs, Admin, Recreation Sites 600 800 1,400

Habitat Improvement 700 100 800

Alternative 4 (Proposed Action) total 1,900 2,200 4,100

Additional allowed under Alt 5 300 100 400

Alternative 5 total 2,200 2,300 4,500

Why is the Oregon BLM considering the use of this herbicide? Triclopyr 

is effective on woody plants, and would be used on saltcedar, Russian olive, 

blackberries, brooms, and other shrubs. It is the preferred treatment for purple 

loosestrife, and could be used to control woody species in recreation sites.

Selected Risk Categories:

Terrestrial Vegetation 

(Susceptible)

Macrophytes

(Susceptible)

Worker Public

Direct 

Spray

Off-site 

Drift

Low boom

Surface 

Runoff Accidental Spill Chronic Exposure

Wearing 

soiled gloves

General 

Exposure 

Boom spray

Consumption of 

Contaminated Water

Acute / 

Accidental

Chronic / 

Long-term

Typical H L M H 0 0 0 0 0

Maximum H M H H L L L L 0

Small mammal Bird Fish

Direct Spray

Consumption of Contaminated 

vegetation Consumption of Contaminated vegetation Accidental 

spill

Chronic 

Acute / exposure

Accidental Chronic / Long-term Acute / Accidental Chronic / Long-term

Typical L 0 0 L L NE 0

Maximum M 0 0 M M NE 0

Leaching, Persistence, and Half-life:

Koc Solubility

SPISP II Rating – Leaching Potential Persistence Half life in soils

PLP 

Leaching

PSRP Solution 

Runoff

PARP Adsorbed 

Particle Runoff Water Soils Aerobic Anaerobic

20 (salt)

780 (ester) 435 High High Intermediate Moderate Moderate 46 <1

PEIS Mitigation Measures and Standard Operating Procedures specific to this herbicide:

•	 To minimize risks to workers and the public, terrestrial wildlife, livestock, wild horses, and burros do not exceed the 

typical application rate, where feasible, for applications of triclopyr. (MM)

•	 Do not apply triclopyr across large application areas, where feasible, to limit impacts to livestock, particularly 

through contamination of food items. (MM)

•	 Consider the size of the application area when making applications of triclopyr in order to reduce potential impacts 

to wild horses and burros. (MM)

Triclopyr

Registered for use:

Rangeland Forestland Riparian & 

Aquatic

Oil, Gas, & 

Minerals

Right-ofwayRecreation & 

Cultural
649

Final Environmental Impact Statement: Appendix 10

Appendix 10 -

Response to Public Comments 

on the September 2009 Draft EIS

Table of Contents

Response to Comments to the 2009 Draft EIS .................................................................................................. 651

Introduction............................................................................................................................................... 651

Organization of this Appendix.................................................................................................................. 651

Summary............................................................................................................................................................... 652

Chapter 1 – Purpose and Need ........................................................................................................................... 653

Proposed Action........................................................................................................................................ 657

Alternatives to the Proposed Action ......................................................................................................... 657

Non-BLM Actions Potentially Affecting the Use of Herbicides on BLM Lands in Oregon.................... 659

Chapter 2 – The Alternatives.............................................................................................................................. 661

Alternatives Eliminated From Detailed Study.......................................................................................... 667

Comparison of the Effects of the Alternatives.......................................................................................... 671

Potential Mitigation .................................................................................................................................. 672

Chapter 3 – Background and Assumptions for Effects Analysis..................................................................... 675

The 18 Herbicides..................................................................................................................................... 675

Assumptions and Information about Treatment Acres ............................................................................. 678

Risk Assessments...................................................................................................................................... 683

Methodology for Assessing Effects.......................................................................................................... 692

Chapter 4 – Affected Environmental and Environmental Consequences...................................................... 693

Incomplete and Unavailable Information ................................................................................................. 693

Cumulative Impacts.................................................................................................................................. 694

Environmental Setting .............................................................................................................................. 698

Noxious Weeds and Other Invasive Plants............................................................................................... 699

Native and Other Non-Invasive Vegetation .............................................................................................. 701

Pests and Diseases (Sudden Oak Death)................................................................................................... 705

Climate Trends, Projections, and Implications......................................................................................... 707

Soil Resources........................................................................................................................................... 709

Water Resources........................................................................................................................................ 713

Wetlands and Riparian Areas.................................................................................................................... 720

Fish............................................................................................................................................................ 721

Wildlife Resources.................................................................................................................................... 724

Livestock................................................................................................................................................... 729

Wild Horses and Burros............................................................................................................................ 730

Fire and Fuels............................................................................................................................................ 730

Timber....................................................................................................................................................... 732

Paleontological and Cultural Resources................................................................................................... 732
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Visual Resources....................................................................................................................................... 732

Wilderness and Other Special Areas......................................................................................................... 733

Recreation/Interpretive Sites..................................................................................................................... 734

Administrative Sites, Roads, and Rights-of-Way ..................................................................................... 734

Social and Economic Values..................................................................................................................... 737

Environmental Justice............................................................................................................................... 739

Implementation Costs............................................................................................................................... 741

Human Health and Safety......................................................................................................................... 743

Other Environmental Consequences......................................................................................................... 749

References............................................................................................................................................................. 750

Distribution List................................................................................................................................................... 750

Appendix 2 – Standard Operating Procedures and Mitigation Measures from the PEIS............................ 751

Appendix 3 – Monitoring .................................................................................................................................... 752

Appendix 5 – Federally Listed and other Special Status Species.................................................................... 754

Appendix 8 – Human Health and Ecosystem Risk Assessments..................................................................... 756

Appendix 9 – Additional Information About the Herbicides........................................................................... 756

Miscellaneous........................................................................................................................................................ 757

References.............................................................................................................................................................. 759
651

Final Environmental Impact Statement: Appendix 10

Response to Public Comments on the September 

2009 Draft EIS 

Introduction

The public comment period for the Vegetation Treatments using Herbicides on BLM Lands in Oregon Draft 

Environmental Impact Statement (Draft EIS) began on October 2 and ran through December 1, 2009. Agencies, 

officials, and the public were invited to comment of the Draft EIS. During the 60-day public comment period, 

803 communications were received in the form of letters, postcards, and emails (collectively referred to as letters). 

The BLM continued to accept and process letters received between December 2 and the completion of public 

comment analysis on January 6, 2010. During this time, the BLM processed an additional 240 letters. 

Letters were received from a variety of interests including individuals, organizations (including watershed 

councils), businesses, and Federal, State, and local (including soil and water conservation districts) government 

agencies. Letters were received from 10 of the 50 states, as well as from India, but the majority of letters 

originated from Oregon. The letters are part of the public record on the EIS and are available for public 

inspection. Individuals or organizations who submitted comment letters (including form letters) have been added 

to the EIS distribution list, and will receive, unless otherwise requested, a CD-ROM containing the Final EIS.

All of the letters received between October 2, 2009 and January 6, 2010 were processed by a public comment 

coding team who identified over 500 substantive comments and passed them along to the EIS resource specialist 

for consideration and response. Resource specialists created comment statements, responses, and made resultant 

corrections or additions to the Final EIS. Comment statements are summary statements that identify and describe 

specific concerns with the analysis or the alternatives considered. Unique concerns generated their own comment 

statement and similar concerns voiced in multiple letters were grouped into one comment statement (40 C.F.R. 

1503.4(b)). Letters were not treated as votes; all letters were treated equally and were not given weight by the 

number received, organizational affiliation, or other status of the respondents. All substantive comments have 

responses presented in this appendix, and many resulted in improvements to the analysis presented in the Final 

EIS. We very much appreciate the public’s review and participation.

Six letters were received between January 7 and April 1, 2010. Four of these were duplicative form letters, but 

the remaining two letters were reviewed by the BLM. Issues identified by the authors of these letter were not 

included in this appendix, though several points were incorporated into the Final EIS and some of the other points 

had been made by previous respondents.

Organization of this Appendix

This appendix contains the comment statements and responses, organized to follow the order of the Final EIS. 

The comments and responses are intended to be explanatory in nature; if there are any inadvertent contradictions 

between this Appendix and the text in the Final EIS, the Final EIS prevails. 

Letters received from Federal, State, and local governments are responded to in this Appendix, and displayed in 

their entirety in Appendix 11.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Summary

1. Comment: The Summary should include costs and benefits, or refer the reader to specific pages in the 

Environmental Impact Statement (EIS) where these are discussed.

Response: The Final EIS Summary now includes page references to the EIS for items discussed. However, 

there are elements of the analysis that may not be in the Summary. CEQ regulations at C.F.R. 1502.12 state, 

“Each environmental impact statement shall contain a summary which adequately and accurately summarizes 

the statement. The summary shall stress the major conclusions, areas of controversy (including issues raised by 

agencies and the public), and the issues to be resolved (including the choice among alternatives). The summary 

will normally not exceed 15 pages.” 

2. Comment: There are value-laden sentences heavily biased toward the Proposed Action (Alternative 4). Using 

the term “some” risk trivializes both the scope and severity of potential risks while the conclusion that slowing 

noxious weed spread “more than compensates for the risks incurred” is totally unsubstantiated.

Response: The statement regarding “more than compensates for the risks incurred” in the Summary has been 

edited to clarify that it only applies to resource values, not to the potential for worker and public health effects. 

Otherwise, the statement summarizes the general conclusions in the individual resource sections in Chapter 4 that, 

across the range of alternatives, the spread of invasive weeds will be more likely to degrade resource values than 

the herbicides proposed for use. 

3. Comment: The Summary does not indicate how long the various herbicides remain toxic in the environment.

Response: Half-lives vary depending upon whether the herbicide is exposed to sunlight, in the soil, or in water, 

and whether conditions are aerobic or anaerobic. In addition, degradates can be variously toxic. These subjects 

are addressed in the Water Resources and Soil Resources sections in Chapter 4, and do not lend themselves to 

easy compilation in the Summary. The term “toxic” is a relative term that does not represent a single point, since 

different herbicides can have potential effects to different portions of the environment (e.g. fish, non-target plants, 

or human health). 

4. Comment: The Summary does not indicate how the health effects of herbicide use have been factored into the 

analysis of the cost-effectiveness of herbicide use.

Response: The EIS includes, and the Summary summarizes, the potential risks from both herbicides and invasive 

plants to human health and the environment. These discussions, particularly the effects of invasive plants on 

the environment, are often qualitative; the financial value of a healthy ecosystem is difficult to quantify, and 

no numerical comparison of environmental risk versus benefit is possible. Individual Risk Assessment Tools 

currently being prepared by the BLM National office for each herbicide will help site-specific plans evaluate any 

human and environmental health risks associated with proposed and alternative treatments. No human health 

effects are factored into a cost-effectiveness equation because no increase in health care or other health costs are 

associated with herbicide use described by the alternatives.

5. Comment: The Summary discussion of herbicide use along rights-of-way and recreation sites dwells on the 

positive without mentioning that the additional herbicides would negatively affect soil, air, water, native plants, 

wildlife, and humans.
653

Final Environmental Impact Statement: Appendix 10

Response: The Summary does not include such a discussion because the EIS analysis indicated that the proposed 

uses, with implementation of Standard Operating Procedures and PEIS Mitigation Measures, presented very little 

risk to the environment. However, the Summary has been combined with the rest of the EIS, and a reference to 

the Comparison of the Effects of the Alternatives section in Chapter 2 has been added to the What are the Effects 

of the Alternatives section in the Summary. 

Chapter 1 – Purpose and Need

6. Comment: The Need and Purposes are so narrowly construed as to preclude consideration of the various 

impacts of individual herbicides, application methods, or treatment objectives as a factor in decision-making.

Response: The Need narrowly focuses on herbicides because other elements of weed prevention and control are 

currently available and being implemented to the maximum extent practicable. Twenty-five years of being limited 

to four herbicides, and those being only available for noxious weed control, has assured development and heavy 

reliance on prevention, early detection, and control using non-herbicide methods. 

Regarding consideration of the individual herbicides, the alternatives are structured to display different 

mixes of herbicides and treatment objectives. The objectives of Alternative 3 are all included in Alternative 

4 (the Proposed Action) and Alternative 5, but Alternatives 4 and 5 each add additional treatment objectives 

and additional herbicides. In addition, Alternative 5 permits aerial application west of the Cascades, while 

Alternatives 3 and 4 do not. A discussion of the potential for each herbicide to have adverse effects on each 

resource is included in most of the resource sections; a 2,4-D discussion has been added as Appendix 12 and 

additional information about the specific uses of each herbicide has been added to Chapter 3 to supplement 

information already included on the “Herbicide Information” table at the start of Chapter 3, Table A9-2, and 

elsewhere. This information will allow the decision-maker to consider individual herbicides, treatments, and 

region of the State, with respect to environmental risk. The Decision to be Made section in Chapter 1 notes the 

decision-maker can add or delete individual herbicides from the selected alternative in the Record of Decision.

The only area where the analysis does not describe the effects of dropping individual herbicides is in the 

calculation of weed spread. Table A9-2 provides information about which herbicides control which target plant, 

and several of the potential target plants are susceptible to only one of the available herbicides. Beyond this, the 

implications of dropping a single herbicide are discussed more qualitatively. The EIS did not attempt to identify 

the high-priority control species and then analyze the implications of excluding individual herbicides from 

Alternative 3 because: a) priorities will likely change over the 15-year life of the EIS; b) there is no complete 

inventory of all invasive plant populations, so priorities and emphasis might change with additional information; 

c) the needs and priorities of the Oregon Department of Agriculture, cooperators, and adjacent landowners will 

vary by geographic area and time; and, d) with the possible exception of 2,4-D (see Appendix 12), the estimate 

of future noxious weed spread rate under Alternative 3 is too gross to reveal the implications of eliminating 

individual herbicides. A discussion of this analysis weakness in this area has been added to the Incomplete and 

Unavailable Information section early in Chapter 4. 

Within the constraints of the existing data, the BLM considered having additional alternatives between Alternative 

2 (the No Action Alternative) and Alternative 3, to examine the implications of removing specific herbicides 

from Alternative 3. The BLM determined there would be little discernable detectable difference between such 

alternatives (not already made clear by the individual herbicide discussions), in part because Standard Operating 

Procedures, PEIS Mitigation Measures, site-specific planning, and other measures minimize the likelihood of 

adverse effects to resources regardless of the alternative, and in part because resultant differences in weed spread 

could not be reasonably estimated. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

7. Comment: The Need and Purposes seem to be narrowly construed to allow for, and promote the increased use 

of, herbicides, rather than to effectively prevent and control the spread of invasive plants, which is more in the 

public interest.

Response: Chapters 1 and 2 have both been edited to clarify that the alternatives are all set in the context of the 

existing vegetation management program, where the prevention and early detection of noxious weeds and other 

invasive plants has, and will continue to have, primary emphasis. Those elements of the program are common 

to all alternatives, and are already authorized or assumed in existing Land and Resource Management Plans 

(Appendix 6) and district weed management Environmental Assessment documents.

Increases in the acres treated with herbicides under the action alternatives are predicted in part because the four 

herbicides currently available (and acres treated with non-herbicide methods) are not effectively controlling the 

spread of invasive plants.

8. Comment: The scope of the EIS is too broad; herbicide use beyond noxious weed control requires greater 

analysis and public input. The EIS proposes that additional herbicides would be used to, “treat any vegetation 

to meet safety and operation objectives in administrative sites” [including schools and parks], and to “...treat 

any vegetation as needed to control pests and diseases,” and to, “...treat any vegetation to achieve habitat goals 

specified in approved Recovery Plans...” The BLM must specifically state what is covered and what is not. The 

scope is wide open and would allow all types of actions outside of the main intent to control high priority plants. 

A program of this magnitude requires a detailed analysis of environmental impacts that cannot be deferred until a 

later time.

Response: The EIS is not a vegetation management plan; the need to manage vegetation is well established in 

Land and Resource Management Plans and other plans, law, policy, existing district Environmental Assessments, 

and by State and National policy. The EIS also does not analyze projects. The acres in the analysis are simply 

annual estimates of the types of projects that would be identified and analyzed at the district level. The EIS is 

primarily a cumulative effects analysis of a proposal to, consistent with the PEIS selected alternative, permit the 

use of additional herbicides as one tool to meet existing vegetation management objectives.

Herbicide uses proposed in Alternative 3 are similar to Alternative 2 (No Action), adding relatively minor 

herbicide use for non-noxious invasive plants and pest and disease control to an otherwise existing program. 

Alternative 3 would reduce (when compared to Alternative 2) the total pounds of herbicides that would be applied 

and would reduce the number of acres treated annually with herbicides having a moderate public and worker 

health risk category (the EIS does not propose to add any herbicides in the high risk category). This portion of 

the analysis addresses the use of different herbicides in a portion of the vegetation management program that is 

already using herbicides. The scope of the analysis, therefore, is limited to an examination of herbicides and 

related effects. The potential for these herbicides to slow the spread of invasive weeds, and the environmental 

advantages of that slowing, are also considered.

The comment suggests that adding herbicides for rights-of-ways and other uses in Alternative 4 (Proposed Action) 

and Alternative 5 are a whole new program area for herbicides and warrants a more detailed analysis and program 

justification than presented in the EIS. The EIS suggests, however, that the uses proposed in Alternatives 4 and 

5 are not so different from those suggested by Alternative 3. The BLM is already managing vegetation in these 

areas, and BLM cooperators are already using herbicides to meet their safety and maintenance responsibilities 

on adjacent lands. Most of the estimated herbicide treatment acres would replace, acre for acre, vegetation 

treatments that are already taking place using mowers and other non-herbicide methods. (The remainder, at least 

under Alternative 4 (the Proposed Action), would be for Conservation Strategy-specified, but currently undone, 
655

Final Environmental Impact Statement: Appendix 10

habitat improvements for Special Status species1.) Herbicides would only be used for a small percentage of these 

currently ongoing vegetation treatments. Each of these Alternative 4 (the Proposed Action) and 5 objectives 

would be subject to their own site-specific Environmental Assessment or EIS analysis; district weed control 

Environmental Assessments would only address invasive plant control. Since this EIS examines the cumulative 

effects of herbicide use on BLM lands in Oregon, it is correct that it should also cover the future estimated level 

of these additional uses. The Need and Purposes recognize, at the programmatic scale, the BLM’s obligation 

to manage vegetation. The alternatives correctly propose making additional tools available. The information 

available about risks, as well as the Standard Operating Procedures and PEIS Mitigation Measures, all comport to 

these additional uses. The analysis considers the nature of these uses from an herbicide effects standpoint. The 

resultant estimated level of use is adequate for the examination of cumulative effects, but it is not a commitment 

or approval for specific projects. 

It should be noted that the analysis carefully separates the invasive plant control objective from the administrative 

sites and habitat improvement objectives, taking care not to justify one with the other (although the likelihood of 

some incidental invasive plant control from native vegetation roadside herbicide treatments is identified). The 

conclusions in most resource sections that invasive plants will cause more adverse effects than the proposed 

herbicides, for example, applies only to the invasive plant control portion of the proposal. Any decision to adopt 

the additional administrative areas and habitat improvement treatments would need to be based upon EISdescribed risks and benefits specifically related to those objectives. 

The Comparison of the Effects of the Alternatives section in Chapter 2 has been edited to more clearly separate 

and display the effects of invasive plant control versus the effects of the administrative sites and habitat 

improvement objectives added in Alternatives 4 and 5. The Record of Decision will also address these two 

aspects of the decision separately.

9. Comment: The 1.2 and 5 million acre figure for current noxious weed and invasive plant infestations seems 

purposefully alarmist when it is admitted in the small print footnotes that an undisclosed number of these acres 

may only contain a few invasive plants per acre.

Response: The sentence states, “About 1.2 million of the 15.7 million acres of BLM lands in Oregon are 

currently infested at some level with noxious weeds...” (emphasis added), and then footnotes that “some level” 

ranges from monocultures to a few plants per acre. Given that most invasive plants spread exponentially once 

they have become established, the BLM is rightfully concerned that there are noxious weeds on 1.2 million 

acres. While some of these acres may never become fully occupied, in part because biological controls help limit 

population densities of some weeds, native species and other environmental values are compromised. Other 

areas have become monocultures, with most or all native plants totally excluded. The five million acre figure was 

derived from satellite imagery, and on those acres, invasive annual grasses are dominant. A map of these acres 

east of the Cascades is included in the Fire and Fuels section in Chapter 4.

There is no estimate of net acres occupied with noxious weeds on BLM lands. One study of 21 noxious weeds in 

Oregon estimated that 32 million infested acres represented 6.5 million net acres or about 20 percent (Radke and 

Davis 2000)(see Noxious Weeds and Other Invasive Plants in Chapter 4). Assuming that ratio applied to BLM 

lands and all noxious weeds, the current 12 percent annual noxious weed spread rate would result in 1.2 million 

net acres, and 6 million infested acres, in about 15 years. 

1 The Special Status Species Program includes species listed as Threatened or Endangered, proposed for listing, as well 

as Bureau Sensitive species
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

10. Comment: The Purposes do not present compelling needs for herbicide use. Purpose 3 fails to acknowledge 

natural cycles of western juniper expansion; Purposes 3 and 4 suggest herbicides can cure problems caused by 

livestock grazing, off-highway vehicles (OHVs), roading, and other invasive plant pathways; Purpose 5 suggests 

the BLM should adversely impact the environment because their neighbors are doing it; regarding Purpose 6, 

having more herbicides will not reduce wildlife effects unless the more toxic herbicides are dropped; and so forth.

Response: The Purpose statements are not required to present a compelling need. The statements are broad 

management objectives or issues that the Need and scoping comments identified as desirable, and thus are 

extensions or clarifications of the Need. The general discussions under each Purpose, however, are suppositions 

for how the alternatives might help. Whether or not the alternatives actually help meet the Purposes and whether 

adverse effects result from the process, are the subject of the analysis in Chapter 4. Thus, the truth, significance, 

and importance of the discussion under each Purpose is to be confirmed or rejected by the subsequent analysis 

in the remainder of the document. The decision-maker will determine which alternative best meets the Need and 

Purposes by examining the analysis described in Chapters 2 and 4. 

11. Comment: Regarding Purpose 2, there is no compelling need to spray native vegetation with herbicides. 

Spraying along roads and within recreation sites will expose my family to herbicides.

Response: The Purposes represent issues or subdivisions of the Need for analysis purposes. The analysis 

in Chapter 4 (and summarized in Chapter 2) will be used by the decision-maker to determine the degree to 

which this and other Purposes are met, including Purpose 6, “prevent herbicide control treatments from having 

unacceptable adverse effects to applicators and the public,...” Reasons for using herbicides in these areas 

include: control of invasive plants too small to be detected by invasive plant control crews; control of native 

plants injurious or fatal to recreation site users like poison oak and water hemlock; cost savings of about $1 

million per year that could be transferred to other maintenance budgets or returned to utility subscribers; fire 

protection around communication sites, transmission poles, and other improvements; reduced worker injury from 

non-herbicide methods – particularly those from chainsaw use on steep slopes under power lines; and, reduced 

site-disturbance. The Human Health and Safety section shows that herbicide applications following label and 

Standard Operating Procedure requirements will present an extremely low risk to public travel, recreation, and 

even consuming sprayed forest products like berries and mushrooms. Sprayed areas would be signed for hours 

to days as required by the herbicide label and Standard Operating Procedures. The decision-maker will weigh 

these and other points to determine whether the benefits support selection of this portion of the Proposed Action 

(Alternative 4).

12. Comment: What is the target species for the habitat improvement suggested by Purpose 3 and permitted in 

Alternatives 4 and 5? Many birds and amphibians are particularly susceptible to herbicides, and many animals 

depend upon plants to survive.

Response: Habitat improvement treatments under Alternative 4 (the Proposed Action) would be those directly 

accomplishing needs identified in Conservation Strategies or plans identified in Endangered Species Act recovery 

or delisting plans. For example, imazapic might be used to control medusahead invading the North Bank Habitat 

Management Area, an important habitat area near Roseburg at the core of the southern population of the recently 

delisted Columbian white-tailed deer. Maintenance of habitat in this area is identified in the Post-Delisting 

Monitoring Plan for the Douglas County Distinct Population Segment of the Columbian White-tailed Deer (USDI 

2006d) as critical to continued recovery of the white-tailed deer. Any herbicide use would be subject to site-specific 

analysis that would help identify the potential for harm to other species in the area. Many of the proposed habitat 

improvement treatments under Alternative 5 would benefit sage grouse, and would be subject to site-specific analyses. 
657

Final Environmental Impact Statement: Appendix 10

Proposed Action

13. Comment: The massive escalation in herbicide-affected acreage, and the sudden inclusion of up to 14 

additional herbicides, means that the past policies of the BLM have failed. It is evident that the BLM is trying to 

remedy its past failure by sudden remedial measures.

Response: The number and acreage of invasive plants in Oregon continues to increase in all land use allocations. 

In general, this increase is driven by increased human mobility, international trade, increased recreational use of 

wildlands, and many other factors. The BLM in Oregon has been restricted to using only four herbicides since a 

1984/87 court injunction. An increase in the number of herbicides, needed for some time and now proposed by this 

EIS, is made possible in part by the recent completion of herbicide Risk Assessments. Additionally, several of the 

proposed herbicides have been developed since the BLM’s last (USDI 1989) EIS addressing herbicide use in Oregon.

Of the predicted 13,600-acre increase in herbicide treatments of invasive plants under the action alternatives 

(when compared to the No Action Alternative), 11,500 acres would be with imazapic. Almost all of this would 

go to controlling medusahead east of the Cascades, an invasive annual grass not well controlled by the four 

herbicides currently available and therefore spreading relatively unrestrained. Treatment of the remaining 2,100 

additional acres generally represents opportunities for controlling invasive plants not reasonably controllable with 

the four herbicides currently available, or by non-herbicide methods. Examples include perennial pepperweed 

and saltcedar. With this acreage increase, total pounds of herbicides used for invasive plants would decrease 35 

percent when compared to the No Action Alternative.

Additional herbicide acres are proposed for administrative sites and habitat improvement under Alternatives 4 and 

5, but these are not related to invasive weed spread.

Alternatives to the Proposed Action

14. Comment: The EIS only fully considered alternatives that would lessen protections for BLM forests and 

watersheds. These would fail to meet BLM’s obligations to protect Federally Listed species and provide for 

recovery, protect clean water, provide for recreation, and protect clean water and wildlife habitat.

Response: None of the alternatives would “lessen protections” for BLM forests and watersheds. Alternative 

3 would lessen the total pounds of herbicides applied per year when compared to Alternative 2 (No Action). 

Alternatives 3 and 4 would decrease the average pounds per acre applied, and decrease the acres treated with high 

and moderate-risk herbicides, when compared to Alternative 2. The analysis relies on a large body of evidence 

and experience when it determines that invasive plants are adversely affecting virtually all resource values. An 

increase in the number of herbicides available would increase the likelihood that local managers would be able 

to select an herbicide that would control problem weeds while also protecting non-target resources. The analysis 

indicates water, fish, wildlife, and other resource values are at little risk from the herbicides, herbicide use levels, 

and applications examined in the EIS. The EIS, and subsequent site-specific projects, are subject to Endangered 

Species Act consultation. 

15. Comment: There needs to be an alternative focused on prevention, particularly in view of the need to avoid 

adding to the anthropogenic causes of climate change.

Response: Prevention is already the BLM’s first priority for invasive weed control (see Integrated Vegetation 

Management in Chapter 3). The EIS analysis does not support the position that an increase in the number of 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

herbicides available for use would change the BLM’s contribution to climate change. The Air Quality section in 

Chapter 4, for example, found the Proposed Action (Alternative 4) would result in the lowest levels of particulate 

matter of any alternative. Total pounds of herbicide used specifically for invasive plant control would decrease 

under the action alternatives when compared to Alternative 2 (No Action), and the additional herbicide use 

proposed for administrative sites, recreation sites, and rights-of-way would simply replace treatments currently 

done with non-herbicide methods. The Implications of the Alternatives on Climate Change section in Chapter 4 

indicates plant community changes could have both positive and negative effects on climate change.

16. Comment: Effective cultural, mechanical and biological treatments should be considered in all situations and 

utilized when they are likely to be as effective as chemical treatments. The alternative should limit herbicide use 

to rare cases in small areas where absolutely no other alternative exists, or as a last resort when other options have 

proven to be inadequate, ineffective, or inefficient.

Response: Existing policy may not be significantly different from that suggested in the comment. The BLM’s 

Integrated Vegetation Management policies, described in Chapter 3, require BLM to accomplish pest management 

through cost-effective means that pose the least risk to humans, natural and cultural resources, and to the 

environment. Additional information describing the BLM’s treatment method selection process has been added 

to this section. The process strikes a balance between providing adequate tools for managing vegetation and 

protecting the environment, while assuring protection of the environment from those tools themselves. Nonherbicide treatment methods are not always gentler on the environment and human health. 

17. Comment: If the “additional, generally newer, herbicides are more target-specific, can be used in lower 

doses, and are generally less likely to adversely affect non-target plants and animals than the four herbicides 

currently in use,” why is there no alternative that would drop the current four in favor of the new ones?

Response: The statement is a general one, and use of the currently available four herbicides would decrease 

even under Alternative 4, where total acres and treatment objectives are substantially increased. However, 

because most of the newer herbicides are more target-specific, an alternative completely without the current four 

herbicides would effectively control fewer of the noxious weeds than the No Action Alternative (see Table A9-2). 

18. Comment: Weeds are spreading at an estimated 144,000 acres per year, but the Proposed Action 

(Alternative 4) would only treat 58,400 acres annually (all methods). The EIS should include an alternative 

that treats more than 144,000 acres per year.

Response: The EIS does not fully examine the size of the Oregon BLM invasive plant control program, but 

considers options within current budget trend constraint. Within that budget constraint, the Need indicates 

additional or more effective tools are necessary. The only additional efficiencies known beyond those already 

available to the BLM in Oregon is the availability of additional herbicides. The treatment acres estimated for each 

alternative are estimated only for effects purposes, are limited by the current budget trends assumption, and are 

not goals in themselves.

An examination of the size of the overall invasive plant control program is beyond the scope of this analysis. 

Such an examination would need to consider the specific effects and practicality of control for specific weeds or 

groups of weeds. Several noxious weeds, such as Himalayan blackberry, occupy more than one million acres 

statewide (all ownerships). Well-established, widespread weeds are often treated in specific locations such as 

in critical habitats, or in newly infested areas, but remaining areas are generally treated with biological controls 

or not at all. While biological controls seldom eliminate a weed, they can reduce their dominance and allow 

restoration of some portion of normal ecosystem function. These acres are not reflected in the estimated annual 
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treatment acres under each alternative; biological control numbers on Table 3-3 are “releases.” See Noxious 

Weeds and Other Invasive Plants in Chapter 4 for additional information. 

Non-BLM Actions Potentially Affecting the Use of Herbicides on 

BLM Lands in Oregon

19. Comment: The National Marine Fisheries Service is examining the effects of 37 pesticides, including 

2,4-D, diuron, and triclopyr BEE, on protected salmon and steelhead. The BLM states that they will stop using 

these chemicals when and if the Environmental Protection Agency (EPA) and/or National Marine Fisheries 

Service find them to be harmful. Rather than using these chemicals until they are found to be lethal or 

detrimental to the environment or human health, the BLM should stop using them until they have been found to 

be safe for fish and humans.

Response: The National Marine Fisheries Service is completing Endangered Species Act consultation on 37 

pesticides the EPA determined “may affect” anadromous fish. As part of that consultation, the National Marine 

Fisheries Service would determine if protective measures for these fish are needed and what they would be. Their 

review is not expected to address other elements of the environment, nor human health. The alternatives include 

Standard Operating Procedures and PEIS Mitigation Measures that limit risks to non-target species (Appendix 2), 

and even stricter Conservation Measures near water containing Threatened, Endangered, and Proposed species 

(see Appendix 5). The BLM would also follow whatever protection measures result from the EPA/National 

Marine Fisheries Service consultation. These protection measures could include banning some or all of these 

pesticides, but it would be premature to assume that they would.

20. Comment: In the Northwest Coalition for Alternatives to Pesticides / National Marine Fisheries Service 

Settlement Agreement to Examine 37 Pesticides, the EIS states that the proposed use of 2,4-D, triclopyr BEE, 

and diuron is not likely to substantially contribute to anadromous fish effects. The BLM should not make this 

assumption before the studies are completed, and the BLM should not use any herbicides until studies are 

complete.

Response: The BLM has done extensive analysis to study the effects of all of the proposed herbicides, and has 

adopted Standard Operating Procedures and PEIS Mitigation Measures to limit effects to non-target species. 

These include maintaining buffer distances from bodies of water, using spot treatments, and minimizing use near 

fish-bearing water bodies. The BLM estimated uses would be less than 1% of the 2,4-D in the State, less than 2% 

of the diuron, and less than 4% of the triclopyr (Cumulative Impacts, Chapter 4), the analysis documented in the 

Fish section in Chapter 4 indicates the BLM is unlikely to substantially contribute to anadromous fish effects.

21. Comment: As described near the beginning of Chapter 4 in the Draft EIS, the Natural Resources Defense 

Council has petitioned the EPA to revoke all food and water residue tolerances and cancel all registrations for 2,4-

D. The BLM should suspend any consideration of 2,4-D until the EPA has completed its review and issued final 

guidance on its permissible uses.

Response: The description mentioned in the comment has been moved to the end of Chapter 1, to a new section 

called Non-BLM Actions Potentially Affecting the Use of Herbicides on BLM Lands in Oregon. It is the BLM’s 

understanding that the EPA is currently seeking comments on the Natural Resources Defense Council petition, 

not conducting a 2,4-D “review.” The BLM is following current EPA guidance on permissible uses. The EPA 

completed a Reregistration Eligibility Decision of 2,4-D in 2005, and the Forest Service completed a new Risk 

Assessment for 2,4-D in 2006. 
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22. Comment: As a result of a lawsuit filed against the EPA by the Washington Toxics Coalition in 2002, a 

Federal judge ordered (in 2004) that “buffer zones” be placed around salmon bearing streams for the application 

of several pesticides including 2,4-D, diuron, and triclopyr BEE. The buffers include a 20 yard no application 

zone adjacent to salmon bearing waters when specific pesticides are being applied by ground methods and a 100-

yard buffer during aerial applications to protect Threatened and Endangered salmon species. The stream buffers 

of 10, 25, and 100 feet for hand, broadcast, and aerial spray should be revised for 2,4-D, diuron, and triclopyr 

BEE to meet that Federal Court order. 

Response: A subsection addressing this issue has been added to the Non-BLM Actions Potentially Affecting the 

Use of Herbicides on BLM Lands in Oregon section in Chapter 1. The court order stems from a finding that the 

EPA had not completed consultation with the National Marine Fisheries Service on registration labels permitting 

pesticide applications near certain salmon-bearing streams. Since the original issue was consultation, the order 

setting larger stream buffers contains an exception for agency programs subject to National Marine Fisheries 

Service consultation. Because the BLM consulted with the National Marine Fisheries Service on the PEIS, is 

consulting on this EIS, and will consult again on site-specific projects, the herbicide use proposed in this EIS fully 

meets the provisions of this exception. 

23. Comment: Directed by the State legislature, the Oregon Department of Environmental Quality has developed 

a comprehensive list of toxic pollutants related to surface waters in an attempt to protect human health and the 

environment. The BLM’s proposed use of herbicides runs counter to Oregon Department of Environmental 

Quality’s and the State Legislature’s intent to reduce such herbicide use.

Response: The Oregon Department of Environmental Quality’s list of toxic pollutants includes 118 water 

pollutants, including mercury, DDT, and PCBs. The list does not include any of the 18 herbicides analyzed in this 

EIS.

24. Comment: The Draft EIS does not discuss the draft Oregon Department of Environmental Quality Priority 

Toxics Focus List that indentifies diuron, glyphosate, and 2,4-D as toxics warranting analysis for reduction.

Response: A subsection discussing this issue has been added to the Non-BLM Actions Potentially Affecting 

the Use of Herbicides on BLM Lands in Oregon section in Chapter 1. The draft list identifies State of Oregon 

program priorities for these three herbicides. All three will be analyzed for their effects to land quality as a 

household hazardous waste, and to water quality because they are Pesticides of Interest (see the Water Resources

section in Chapter 4 for more information) and are on the Willamette Toxics Monitoring Program Analyte List. In 

addition, diuron is on the Drinking Water Source Monitoring Program Contaminant List.

The Proposed Action (Alternative 4) would reduce the use of 2,4-D and glyphosate when compared to the No 

Action Alterative (Alternative 2). Standard Operating Procedures and PEIS Mitigation Measures do not allow 

the use of diuron anywhere near water. If these herbicides were identified as toxics needing further reduction, the 

BLM would follow any applicable, resulting regulations for these herbicides.

25. Comment: The EPA has only just begun reviewing herbicides for endocrine disruption, so the EPA and BLM 

don’t really know which herbicides are endocrine disruptors..

Response: Presented with evidence that some materials could be endocrine disruptors, Congress instructed 

the EPA to initiate an endocrine disruptor screening program to screen pesticide chemicals and environmental 

contaminants for their potential to affect the endocrine systems of humans and wildlife. The EPA has identified an 

initial list of 67 “Tier 1” pesticides for screening, but have announced that “nothing in the approach for generating 
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Final Environmental Impact Statement: Appendix 10

the initial list provides a basis to infer that any of the chemicals selected interfere with or are suspected to interfere 

with the endocrine systems of humans or other species” (EPA 2010). A discussion of this screening has been 

added to Chapter 1. The BLM conducted its own review of endocrine disrupting potential for the 18 herbicides 

addressed in this EIS (see Potential Endocrine Disrupting Chemicals in the Human Health and Safety section in 

Chapter 4). None of the herbicides have any mention in the literature of having endocrine disruption effects with 

the exception of diuron and 2,4-D, and evidence is inconclusive for these two herbicides.

Chapter 2 – The Alternatives

26. Comment: The alternatives are weighted in favor of herbicide use and are hence unfairly stacked.

Response: The BLM has a need to manage, protect, and restore vegetation. Some of this need arises from the 

variety of uses that take place on BLM lands, and some arises from the intrusion of invasive plants, and wildfire. 

The BLM is already managing vegetation in a variety of ways to meet this need, and a full range of management 

tools is available, authorized, and being used - with the exception of herbicides. Since all of the districts’ Land 

and Resource Management Plans already consider and prescribe noxious weed and other vegetation management, 

the EIS was designed primarily to examine the cumulative effects (statewide) of making additional herbicides 

available as additional tools available for use on BLM lands in Oregon to meet existing management priorities. 

27. Comment: The Draft EIS pretends to offer five alternatives but admits Alternatives 1 and 2 are only for 

comparison. In reality, the range of alternatives represented by Alternatives 3 through 5 is too narrow. There 

should be an alternative that eliminates the most toxic herbicides.

Response: The Draft EIS noted that only Alternatives 3, 4, and 5 would meet the Need. Nevertheless, the 

inclusion of a non-herbicide reference analysis as “Alternative 1” was confusing. The Final EIS keeps the 

analysis, but clearly labels it as a “Reference Analysis.” It is included to help provide a baseline from which 

herbicide and weed spread effects can be measured or described. The other alternatives retain their Alternatives 

2, 3, 4, and 5 Draft EIS designations to avoid confusion between alternatives in the Draft and Final EIS. The No 

Action Alternative (Alternative 2) is required by National Environmental Policy Act (NEPA) regulations. 

This EIS tiers to, and incorporates the analysis in, the 2007 PEIS, which examined several other alternatives. In 

this EIS, an action alternative that allowed for fewer than 11 herbicides was not developed because the Standard 

Operating Procedures, PEIS Mitigation Measures, site-specific planning, and other requirements address concerns 

about the toxicity of individual herbicides proposed in Alternative 3. A shorter list of herbicides available would 

be less likely to meet the need for action, but would not result in less harmful herbicide exposure. However, the 

decision-maker could decide to remove one or more herbicide active ingredients in the final decision as explained 

in the Decision to be Made section in Chapter 1. 

28. Comment: In the description of Alternatives in Chapter 2 of the Draft EIS, the no herbicides alternative is 

discounted with no analysis or explanation.

Response: Since every element of Alternative 1 is currently available to, and being used by, the BLM in Oregon 

now as part of the current direction, and since the discussion of the Need indicates the current direction is not 

adequate, Alternative 1 by definition does not meet the Need. For this reason, it was incorrect to include it as 

an Action Alternative in the Draft EIS. However, since the analysis of this alternative did provide a valuable 

benchmark from which to measure the effects of using herbicides, even at current levels, it has been retained in 

the Final EIS as a “Reference Analysis.” Preliminary analysis indicates if this remained an “alternative” and 
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was selected, it would have a negative effect on the accomplishment of the Need and most, if not all, of the eight 

Purposes, when compared with the No Action Alternative (Alternative 2). 

29. Comment: The potential success of a no herbicide alternative was underestimated because it did not consider 

the potential for American Reinvestment and Recovery Act (ARRA) funds to provide weed control jobs.

Response: The EIS used a current budget trends assumption. The BLM requested and received economic 

stimulus funds for weed control. However, it would be hard to quantify how this temporary funding increase 

might disproportionately affect a no herbicides alternative (the Reference Analysis in the Final EIS) because all 

alternatives include non-herbicide treatments. Since the weed control need exceeds the potential funding and 

workforce, it is likely stimulus moneys would have been used for all kinds of treatments, not as a substitute for 

herbicides. Stimulus funds are not long-term; recent federal budget predictions indicate BLM funding will be 

declining for the next three years.

30. Comment: The EIS does not acknowledge that the “no herbicides” policy used by the Eugene District, 

rather than failing to manage weeds, has put forth a concerted effort to employ nontoxic weed control methods 

already proven effective. The creation of green jobs is supposedly a high priority for the government, and manual 

removal of weeds is an ideal opportunity to employ rural residents in economically struggling communities.

Response: On the Eugene District, the use of both manual and mechanical control methods has been a cost 

effective way to get invasive plant control work done mainly because of the Secure Rural Schools Act funding, 

which has provided inmate and youth workforces. This funding source is not expected to continue. With a 

decrease of funding, treatments will need to be cost-effective. Manual and mechanical control has been successful 

primarily on small populations of target species and where multiple years of treatment have finally exhausted 

plant resources. Both mechanical and manual control work are expected to continue in selected areas on target 

species. Certain species or certain sizes of infestations, however, cannot be effectively controlled without the 

use of herbicides. The current practice of cutting or mowing these areas annually to reduce seed production, 

never actually eradicates the weeds. Because of that, the BLM in the Eugene area has not been able to increase 

control efforts beyond a set of selected sites, thus limiting the progress made on invasive plant eradication on a 

landscape scale. In addition, restoration efforts for critically Endangered and Threatened plant species and other 

susceptible habitats that are currently being invaded cannot be effectively recovered without herbicide treatments. 

Infestations of new species will require a rapid response and effective treatment, which manual and mechanical 

treatments may not provide. 

31. Comment: What is the current policy for herbicide use on BLM lands in Oregon? Is it permissible to spray 

any “native vegetation,” or only vegetation that has been declared a noxious weed?

Response: With a minor exception for glyphosate use to control Sudden Oak Death in 2009-2010, and European 

beach grass control in Curry County 2009-2011, only 2,4-D, dicamba, picloram, and glyphosate may be used, and 

these may only be applied to county, State, or Federally Listed noxious weeds. Oregon State’s June 2010 list of 

120 noxious weeds is shown on Table A7-1 in Appendix 7. The current policy is represented by Alternative 2 (No 

Action) in the EIS. 

32. Comment: The EIS does not make it clear if spraying of regeneration harvest units would be allowed 

under any alternative, and if aerial spraying of regeneration harvests is allowed under the No Action Alternative 

(Alternative 2) and Alternative 5.
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Final Environmental Impact Statement: Appendix 10

Response: Spraying within harvest units would be allowed, but not because they are harvest units. The herbicide 

uses that would be permitted under each alternative including the No Action Alternative (Alternative 2) are described 

in The Alternatives section in Chapter 2. The alternatives exclude herbicide use “specifically for livestock forage or 

timber production.” However, noxious weed control could occur in harvest units under Alternative 2 (No Action), 

and invasive weed control could occur in harvest units under any of the action alternatives, either to control a new 

infestation or as part of a broader attempt to control an invasive plant population in a geographic area. Aerial 

application could be used west of the Cascades in Alternatives 2 (as it is now) and 5, but its use would be rare. These 

treatments would not target native plants, even if they were competing with planted trees. The first two paragraphs 

in the Timber section in Chapter 4 provides additional detail. 

33. Comment: Applying six different herbicides in lakes and streams is too many.

Response: As noted in Chapter 1, Purpose 6, having more herbicides available generally increases the opportunity 

to control the target species while minimizing the effects to non-target plants and other organisms. Having additional 

herbicides registered for aquatic use available increases the likelihood of having an herbicide available that will meet 

specific control objectives while minimizing environmental risk. The aquatic herbicide diquat is not included in the 

Proposed Action (Alternative 4). Normally only one of these herbicides would be used at any given time or place. 

Aquatic applications normally involve considerable need and interagency planning.

34. Comment: The Draft EIS states in Chapter 1 that it “does not propose the use of herbicides specifically for 

commodity production such as projects to improve timber growth or livestock forage.” This statement is not 

reflected in the rest of the EIS. Throughout the EIS, the BLM describes how vegetation affects commodities and 

economics, and bases the need to remove weeds on commodity production. For instance, the EIS describes how 

ranching and logging on lands adjacent to BLM will commercially benefit by the BLM using herbicides; how 

herbicides will be used to control Sudden Oak Death because the BLM needs to protect the local nursery industry, 

and how herbicides are needed to protect tree-plantations from undesirable weeds that “slow regeneration and tree 

seedling growth.” There is an entire section on the environmental consequences on timber production.

In fact, everything from roadside spraying to facilitate log truck passage, to maintenance of utility rights-of-way, 

to cheatgrass spraying to increase cattle grazing, is aimed at greater commercial production and higher economic 

return. The BLM misspoke when claiming commodity production has nothing to do with their proposal to use 

additional herbicides.

Response: The term “commodity production” was broader than the EIS intended, and this term has been replaced 

with “specifically for livestock forage or timber production” to better describe the limits intended in the analysis. 

Herbicide use specifically for livestock forage or timber production is not included under any of the alternatives. 

As noted in the comment, however, herbicide uses proposed in the EIS would have economic benefits.

35. Comment: Aerial spraying west of the Cascades should be an option in all alternatives. In many cases, 

helicopters are actually more of a necessity west of the Cascades because of the steep terrain. Limiting vegetation 

treatments to ground methods on steep terrain presents both safety issues for individual ground applicators and 

unnecessarily high costs. Western Oregon has many remote areas away from people, population centers, and 

water, and the risk to humans or any resource is low to negligible. These areas would qualify for treatment with 

helicopters and their use should be considered on a case-by-case basis.

Helicopter application technology has advanced in the past few years allowing applications to be done with safety 

and precision. The use of shape files with a Satloc® navigation system and half-boom applications along streams 

and property lines are several recent and well-used techniques. A National Spray Drift Task Team has concluded, 

“With good drift management practices, drift can be practically reduced to zero.”
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Because helicopters can be more productive, treatments that are more effective would be realized when small 

“windows” of treatment opportunities exist due to weather, weed development, or other factors. Effective weed 

treatments would therefore reduce the need for re-treatments and reduce the overall use of herbicides. For most 

herbicides, including 2,4-D, potential exposure to applicators is less when applied by helicopter. Eliminating 

aerial application from Alternatives 3 and 4 (the Proposed Action) needlessly constrains attainment of the 

Purposes and Need.

Response: Aerial application is proposed to remain a tool east of the Cascades under all alternatives, and west 

of the Cascades in Alternatives 2 and 5. Aerial application is excluded from Alternatives 3 and 4 west of the 

Cascades in part because of a lack of need, and formalizing that point in the EIS simplifies the analysis and more 

clearly defines (for the public and the resource effects descriptions in the EIS) the range of treatments that could 

be expected. No districts west of the Cascades are currently using aerial methods for the control of noxious 

weeds, even though aerial methods are permitted under the No Action Alternative (Alternative 2). Potential 

needs for aerial applications under Alternatives 3 and 4 (the Proposed Action) were considered. These included 

the possibility of treating large expanses of invasive annual grasses in oak savannah types in the southern part of 

the State or in the North Bank Habitat Management Area near Roseburg; treating Portuguese broom within its 

relatively small infested area near Roseburg; and, treating transmission corridors, particularly those with pipelines 

or other improvements permitting relatively low application height. The likelihood these treatments would be 

proposed, and that their objectives could not be reasonably met using non-aerial methods, was small compared 

with the benefits of simply excluding these treatments from Alternatives 3 and 4. 

36. Comment: The BLM does not currently do aerial application of the four herbicides currently used. 

Therefore, Alternative 2 should also prohibit aerial spraying to be a true No Action Alternative. 

Response: There is currently no prohibition against aerial herbicide applications in Alternative 2. Chapter 3 

Treatment Methods shows about seven percent of the herbicides currently used by the BLM in Oregon against 

noxious weeds are applied aerially, all east of the Cascades. No aerial applications have been done west of the 

Cascades in recent memory, but the spread of noxious weeds such as medusahead rye in oak savannah habitats 

could conceivably lead to such proposals. Alternatives 3 and 4 (the Proposed Action) exclude aerial application 

west of the Cascades.

37. Comment: Alternative 4 (the Proposed Action) should not include 2,4-D, given this herbicide’s potential for 

adverse health effects in humans, fish, birds, invertebrates, and wildlife in general.

Response: Concerns with 2,4-D were raised during scoping and again during the public comment period on 

the Draft EIS. At each of these steps, the BLM has carefully considered its risks, available mitigation measures, 

and its potential role in meeting the Need to decide whether to continue to keep it in one or more of the action 

alternatives. A summary of information reviewed after the public comment period on the Draft EIS is included in 

Appendix 12. In short, reasons for keeping it in the action alternatives in the Final EIS include: 

1) The districts have considerable experience with this herbicide and its effects on target and non-target 

vegetation, and have been using it without incident since 1987; 

2) the total statewide use under the Proposed Action is projected to decrease by one-third when compared to 

the No Action Alternative (Alternative 2); 

3) approximately half of the 2,4-D acres would be treated with ounces per acre as a part of tank mixes 

(although it is acknowledged the Risk Assessment does not find that this necessarily reduces risks), and; 

4) 2,4-D remains an effective, selective herbicide that is often the best choice for many situations and is thus 

crucial for meeting the Need. 
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Final Environmental Impact Statement: Appendix 10

Site-specific herbicide selection would continue to be guided by BLM policy that requires weed control “through 

cost-effective means that pose the least risk to humans, natural and cultural resources, and the environment” 

(USDI 2007e). 

For any herbicide or use, the decision-maker may modify the selected alternative to remove an herbicide or 

modify its use, if the environmental effects of such a change are reasonably clear. A discussion of this possibility 

has been added to the Decision to be Made section in Chapter 1. Additional information about the uses and need 

for each specific herbicide has been added to Appendix 9.

38. Comment: 2,4-D should not be used on public lands because it can vaporize and cause effects miles from the 

application site, particularly to ultra-susceptible crops like wine grapes. 

Response: The Native and Other Non-Invasive Vegetation section in Chapter 4 has been edited to note that 

grapes can be ultra-susceptible to 2,4-D and can be damaged for a considerable distance downwind of application 

sites. This sensitivity is also mentioned on 2,4-D product labels, and would be a consideration in site-specific 

analysis. All of the action alternatives would result in a decrease in the use of 2,4-D when compared with the 

No Action Alternative (Alternative 2). Alternatives 3 and 4 (the Proposed Action) would not permit aerial 

applications west of the Cascades. When herbicides are used Standard Operating Procedures (Appendix 2) help 

protect adjacent crops by requiring the use of drift prevention measures such as: no spraying when wind is above 

10 miles per hour or precipitation is imminent; use of large herbicide droplets and drift reduction agents where 

appropriate; use of low volatile formulations; use of low pressure equipment; use of herbicide free buffer strips 

where appropriate; and notification of adjacent landowners.

39. Comment: It appears Alternative 4 (the Proposed Action) would expand BLM’s authority to spray all 

vegetation including at schools on leased BLM lands, campgrounds, and picnic areas.

Response: Yes, the Proposed Action would permit the BLM to use herbicides to meet safety and maintenance 

objectives along roads and around other developments including campgrounds. It would also allow holders of 

rights-of-way, permits, and public purpose leases (such as schools, fire stations, airports, transfer stations, and 

other municipal or non-profit group-owned improvements) to use herbicides to meet safety and maintenance 

objectives around their improvements. The BLM would not require owners of these improvements to use 

herbicides; Alternatives 4 and 5 would simply permit their use.

40. Comment: Alternative 4’s (the Proposed Action) “recreation sites” are poorly defined. Would undesignated 

OHV trails be sprayed? Would BLM roads be sprayed even though there is no public access?

Response: Invasive plants might be sprayed anywhere on BLM lands under Alternatives 3 through 5, the same 

as noxious weeds are currently treated under the No Action Alternative (Alternative 2). Under Alternative 4 (the 

Proposed Action) and Alternative 5, native and other non-invasive vegetation on designated and undesignated 

OHV trails would not be sprayed; they are not included or inferred by the list of administrative sites, recreation 

sites, and rights-of-way listed for Alternative 4 (the Proposed Action) in Chapter 2. Regarding BLM roads 

without public access, the Administrative Sites, Recreations Sites, and Rights-of-Way section in Chapter 4 notes 

that generally only noxious weed and other invasive plant management is anticipated for non-system roads, even 

under Alternative 4 (the Proposed Action) and Alternative 5. 

41. Comment: It is unclear if Alternative 4 (the Proposed Action) includes the ability to preventatively remove 

host species of the invasive pathogen Sudden Oak Death (Phythophthora ramorum) outside of infested sites.

Response: Alternatives 4 and 5 are additive; each includes all treatments and herbicides included in the next lower 

alternative. The three action alternatives would permit and anticipate herbicide treatments of native species serving 
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as pest hosts in State-designated control areas. This includes the preventative removal of host species of Sudden Oak 

Death surrounding infestations. The EIS does not address specific projects however; a site-specific Environmental 

Assessment or EIS would be part of the site-specific decision-making regarding treatment methods. 

42. Comment: Alternative 5’s lack of specificity as to how and where herbicides would be used “for a 

fairly unspecified group of projects” (Summary of the Major Effects of Each Alternative in Chapter 2) is both 

unacceptable and probably illegal.

Response: The EIS primarily examines, at the programmatic scale, the cumulative human health and 

environmental effects of using additional herbicides on BLM lands in Oregon. To conduct this analysis, the BLM 

asked vegetation management personnel on the nine districts in Oregon to estimate, for each of the alternatives, 

annual herbicide use levels, treatment types, and general treatment locations for the next 15 years. Alternative 

5 would permit herbicide uses for all vegetation management needs except livestock forage production and 

timber production. Additional uses permitted by Alternative 5 are estimated (in the EIS) to be mostly habitat 

improvement projects east of the Cascades, mostly involving imazapic or 2,4-D. The effects described in the EIS 

are based on those estimates. The BLM would periodically examine actual use to determine if the analysis in the 

EIS is still adequate. 

The EIS does not set weed treatment priorities or approve projects. Specific treatment needs and resource 

protection priorities are identified in district Land and Resource Management Plans, district weed management 

Environmental Assessments, and other site-specific plans. Prior to any specific herbicide treatment, site-specific 

analyses would be conducted, with the opportunity for public comment. These site-specific analyses would 

identify the potential effects of specific herbicide treatments. Deferring site-specific analysis of actual herbicide 

treatment proposals is consistent with NEPA, since without the ability to identify, among other things, the specific 

location of an undetermined treatment, it is impossible to identify what the potential site-specific effects of 

such a project might be. Nothing in NEPA, FLPMA, or the Land and Resource Management Plans requires the 

BLM to propose an actual herbicide activity plan or site-specific proposals at this time; site-specific vegetation 

management proposals that include an herbicide component will be developed at a later date based on the 

alternative selected from this EIS. The acreage and herbicide application figures used for analysis purposes in this 

EIS were gross estimates only, made for the purposes of describing potential statewide risks and effects.

The Summary of the Major Effects of Each Alternative section no longer appears in Chapter 2; it has been 

replaced with Table 2-5, Comparison of the Effects of the Alternatives. The Summary of the Major Effects of 

Each Alternative still appears in the Summary however.

43. Comment: In the table “Selected Parameters for Each Alternative...,” why are there no differences in the 

number of acres of herbicide versus non-herbicide control between Alternatives 3 through 5? Why is there no 

alternative examining various levels of non-herbicide control?

Response: Alternatives 3 through 5 all would permit the use of herbicides to control invasive plants. Thus, the 

invasive plant portion of these three alternatives is essentially the same. Alternative 4 (the Proposed Action) 

and Alternative 5 would also permit the use of herbicides for objectives outside of invasive plant control. Those 

additional treatment acres are shown on the same table, but on the line titled Native Plant Herbicide Annual 

Treatment Acres.

An examination of various levels of non-herbicide treatments is outside the scope of the analysis because such 

treatments are already available and being used by policy to the extent practicable. The EIS includes a no 

herbicide Reference Analysis (“Alternative 1” in the Draft EIS) to provide a benchmark of the implications of 

using no herbicides.
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Final Environmental Impact Statement: Appendix 10

Alternatives Eliminated From Detailed Study

44. Comment: In order to find the most ecologically effective alternative, the BLM should fully develop and 

analyze all of the alternatives eliminated from detailed study, except the use of household chemicals (we know 

what saltlicks do to soils).

Response: The reasons for the rejection of each of these alternatives are explained for each in Chapter 2. Most 

are outside the scope of this analysis because the treatments they include are already permitted and being used; are 

legally required to be accomplished some other way; or were already analyzed in the PEIS to which this EIS tiers 

and which is incorporated as Appendix 1. 

45. Comment: In the Alternatives Eliminated from Detailed Study section of Chapter 2, the EIS justifies keeping 

ALS-inhibiting herbicides in part by explaining they are needed for effective control of perennial pepperweed, 

hoary cress, and to a lesser extent, saltcedar. Just how big of a problem are these three species? What do they 

affect, and how seriously. What is their current extent in Oregon? What non-chemical measures can be used to 

control them?

Response: According to Table A7-1, these are all State-listed Category B noxious weeds, which are by definition 

invasive, likely to cause significant environmental or economic harm. Perennial pepperweed occupies more than 

100,000 acres in the State (all ownerships), occurs in about half of Oregon counties, and is abundant in a quarter 

of them. The Wetlands and Riparian Areas section says the Warner Wetlands near Hart Mountain in Lake County, 

for example, is critical to nesting waterfowl and other wildlife, and is infested with perennial pepperweed. It is 

BLM’s biggest cooperative weed control project with Oregon Department of Agriculture. Annual nesting success 

of ducks in this wetland has been positively correlated with the success of perennial pepperweed control. Saltcedar 

and perennial pepperweed are known to extract salts from deep in the soil and deposit it on the surface making the 

site unsuitable for native plants. Saltcedar is in the 1,000 to 10,000 acre abundance category, and is found in 11 

Oregon counties, 1 abundantly. It is an efficient riparian area competitor east of the Cascades, displacing native 

plants and adversely affecting all riparian functions including. The Water Resources section says a mature saltcedar 

consumes as much as 800 liters of water per day, 10 to 20 times the amount used by native species it tends to replace 

(Cooperrider 1995). Hoary cress is in the 10,000 to 100,000 acre abundance category, and similarly overruns 

riparian habitats. None of these three noxious weeds can be effectively controlled without herbicides.

All of the above information is drawn from tables in Appendix 7 or 9, and from examples included in the EIS 

for effects comparison purposes. The EIS does not set weed treatment priorities or approve projects. Specific 

treatment needs and resource protection priorities are identified in district’s Resource Management Plans, and in 

district weed management Environmental Assessments and other site-specific plans.

46. Comment: The EIS needs to evaluate the impact of eliminating or reducing the root causes of noxious weed 

infestations in order to prevent new infestations. Grazing, mining, logging, and vehicle use all contribute to the 

spread of weeds and the BLM needs to consider whether noxious weeds and other invasive plants can be better 

controlled by increasing the use of herbicides or decreasing these root causes. 

Response: A wide variety of management activities including grazing, timber harvest, mining, and public 

recreation are mandated by the FLPMA, the O&C Act, and other policy and direction. These activities do 

contribute to the spread of weeds, and it is the role of each district’s Land and Resource Management Plan to 

identify an appropriate mix of uses and practices consistent with land capability, long-term productivity, and 

ecosystem health. The potential for an activity to contribute to resource degradation (such as the spread of 

noxious weeds and other invasive plants) is one consideration in determining appropriate uses. An alternative 
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proposing to reduce various management activities implicated in weed spread, and the reasons for its elimination, 

is included in the Alternatives Eliminated From Detailed Study section of Chapter 2. Such proposals are outside 

the scope of this EIS because a reconsideration of the mix of land uses is the specific purview of the land 

management planning process described in the FLPMA.

47. Comment: Using herbicides to control weeds spread by livestock grazing and timber harvest only benefits 

ranchers and loggers, at the expense of the public and the environment. The EIS should consider an alternative that 

addresses grazing, timber harvest, road construction, OHV use, prescribed fire, and other management activities 

implicated in the spread of invasive weeds. Decrease or modify these activities and weed spread will decline.

Response: Livestock grazing, timber harvest, OHV use, camping, hiking, wildfire control, boating, and all other 

activities on or near BLM lands variously contribute to the spread of invasive weeds. However, as noted in the 

Background section in Chapter 1, the FLPMA and O&C Act both specify that the BLM will provide for various 

land uses and outputs, and accommodate various developments for the public good. It is the role of various levels 

of planning, beginning with each district’s Land and Resource Management Plan, to identify the appropriate mix 

of uses consistent with land capability, long-term productivity and ecosystem health, and compatibility with other 

uses. The potential for an activity to contribute to resource degradation (such as the spread of noxious weeds and 

other invasive plants) is one consideration in determining appropriate uses. Activity plans tiered to the Land and 

Resource Management Plan (such as allotment management plans) similarly consider implications on noxious 

weed spread. At the project scale, BLM policy requires that when a proposed management activity (such as a 

timber sale or road construction) has a moderate or high risk for establishing noxious weeds, BLM must prescribe 

follow-up monitoring as well as identify project actions that need to be taken in order to reduce or prevent the 

spread of noxious weeds (USDI 1992b). 

The Reduce Management Activities Implicated in Weed Spread alternative in the Alternatives Eliminated From 

Detailed Study section of Chapter 2 addresses this issue.

48. Comment: Studies indicate that vinegar herbicides can perform as well or better than chemical herbicides 

(Cornell University 2008). 

Response: Risk assessments are necessary to support BLM use of herbicides, even for common items like 

vinegar (see the Risk Assessments section in Chapter 3). So far, there in not enough evidence that vinegar would 

provide effective target species control while protecting ecosystem values. Thus, the BLM has not completed a 

risk assessment for vinegar used as an herbicide.

49. Comment: The EIS should include an alternative that minimizes the use of herbicides and increases the use 

of volunteers, inmates, and other crews using hand tools, herds of goats, and so forth. People could adopt an 

acre, road, or developed site and remove noxious weeds. These may be more expensive, but not when human 

and environmental health is considered. The jobs would benefit the economy. Without a rigorous look at these 

alternatives, the EIS does not satisfy NEPA.

Response: The BLM already uses volunteers and other groups to the extent they are available. However, it 

has been difficult to recruit volunteers for difficult jobs or remote locations. Other crews (inmates, contract 

crews) are used, but complete reliance involves logistical considerations that can increase costs and personnel 

needs over other methods. The State of Oregon added noxious weed control to its Adopt-A-Highway program 

in 2009. Having groups adopt popular recreation sites might be a good place to start with BLM. This kind of 

experimentation is already encouraged by BLM policies, and could be done using volunteer agreements. The 

BLM’s current invasive plant control program already makes use of non-herbicide methods to the extent practical, 
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Final Environmental Impact Statement: Appendix 10

and nothing in the Proposed Action (Alternative 4) suggests decreasing these efforts. As stated in Chapter 1, the 

Need is for more effective control measures, meaning a greater suite of herbicides available and an increase in 

the acres treated with herbicides annually. Issues related to herbicide use are addressed in part through Standard 

Operating Procedures, PEIS Mitigation Measures, and site-specific analysis. 

50. Comment: The EIS should include an alternative that uses the same budget costs to create manual labor jobs.

Response: The Implementation Costs section in Chapter 4 shows that the Reference Analysis for no herbicide 

use would cost $600,000 more than the No Action Alternative (Alternative 2), while treating 3,400 fewer acres per 

year. The Noxious Weeds and Other Invasive Plants section in Chapter 4 estimates such an approach would be 

about half as effective at controlling treated noxious weed infestations as Alternative 2. (Increased cost estimates 

for Alternative 3 come in part from cooperator and other project funds that would become available if the program 

were more effective at controlling weeds.) 

51. Comment: It is disingenuous to reject the Increase Funding to Pay for Additional Non-Herbicide Control 

Treatments Alternative because of “adverse environmental effects” associated with non-herbicide methods, or 

because it would require asking for more funding. 

Response: The discussion under this alternative has been rewritten to explain that since the weed control need 

exceeds funding, expecting and using increased funding to pay for the current level of activity at an increased 

cost would be inappropriate. The Need seeks to improve the effectiveness of the current program. A current 

budget trends assumption for all alternatives permits a realistic comparison of their relative effectiveness at 

accomplishing the Need. Future budget increases, if any, could be applied to the selected alternatives to further 

reduce the spread of weeds.

52. Comment: Given that other apparently less toxic and persistent herbicides are now available for use, the 

BLM should include an alternative that prohibits the use of the most toxic, persistent, mobile, and non-selective 

herbicides, including 2,4-D, picloram, dicamba, glyphosate with POEA surfactant, triclopyr BEE, bromacil, 

diuron, hexazinone, and tebuthiuron. Just as the Forest Service Region 6 has dropped the use of 2,4-D and 

dicamba and is not even considering use of the very toxic diquat, diuron, bromacil, and tebuthiuron, so too can 

the BLM drop the planned use of the most toxic herbicides listed above, in addition to picloram. Based on an 

examination of Table A9-2, such an alternative would control most of the invasive weeds. Some of the others 

have commercial value (like St. John’s wort), so permits could be issued for complete collection.

Response: In general, the availability of a broader range of herbicides permits selection of the one that would 

best accomplish the control objective while minimizing site-specific adverse effects. In addition, having more 

than one herbicide to control a plant helps avoid having weed populations develop resistance. Exclusion of the 

“most toxic” herbicides is relative; the BLM already excludes use of more than 80 other herbicides registered for 

use in Oregon, often because they are more toxic. A discussion of the uses and considerations for each herbicide 

has been added to the EIS in Appendix 9, and additional information about 2,4-D had been added in Appendix 12.

Regarding the Forest Service herbicides, bromacil, diuron, and tebuthiuron are included in Alternative 4 to meet 

developed site management or habitat improvement objectives outside of the scope of the Forest Service analysis. 

2,4-D and dicamba are retained because they control many species and provide a good burn-down right up to 

seed-set, important qualities when a small weed control staff is covering districts larger than a million acres. 

Glyphosate with POEA and triclopyr BEE are more toxic to fish and certain other organisms than glyphosate 

without POEA or triclopyr. The risk categories shown in the EIS are for the more toxic formulations, which 

would not be used near water. 
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Collection and sale of noxious weeds is illegal in Oregon, so proposing to control those with medicinal value by 

colleting would not a be a valid control strategy. 

53. Comment: The EIS should consider the approach described in the Restoring Native Ecosystems Alternative, 

which focuses on prevention and restoration. The alternative is displayed in Appendix I of the PEIS. Important 

parts of the alternative were deemed outside the scope and excluded from consideration in the PEIS, but it should 

be included in the Oregon EIS. The native ecosystems alternative meets the purpose and need better than any of 

the other alternatives because it avoids the causal actions that would perpetuate the 12 percent annual increase in 

invasive species.

Response: The Restoring Native Ecosystems Alternative displayed in PEIS Appendix I was reviewed for 

its applicability to the Oregon EIS Need and Purposes, in its entirety, and in parts. The 2002 policy analysis 

conducted by the BLM’s Technology Center in Denver, Colorado (also in Appendix I) was reviewed as well, as 

was PEIS Alternative E, which presented some elements of the proposal. The policy analysis findings appear to 

be wholly applicable to the Oregon EIS; elements of the proposed alternative are either similar to existing policy, 

contrary to legal direction, or outside the scope of this analysis. The reasons for not selecting Alternative E at 

the west-wide level apply to Oregon. The Oregon EIS action alternatives fit completely within the selected PEIS 

Alternative in order to comply with National direction.

54. Comment: The EIS should include examination of the Natural Selection Alternative presented during 

scoping and previously presented to the South Deer Landscape Management Project on the Medford District. 

Preventative and passive vegetation management as prescribed in the Natural Selection Alternative are proactive 

treatments for controlling invasive species, restoring native vegetation, and reducing fire fuel density on public 

land. The EIS should not avoid analyzing these techniques simply because they do not meet a traditional 

definition of vegetation “treatments.” The analysis needs to examine the Natural Selection Alternative’s 

contribution to all ecosystem values, services, products, and uses including purification of air and water, nutrient 

cycling, pollination, herbs and medicinal, recreation and tourism, healthy working environment, chemical drift, 

cumulative effects, the eminent and lethal threat to salmon and aquatic systems, carbon sequestration, and use of 

fossil fuels, just to name a few.

Response: The Natural Selection Alternative, as presented by the Deer Creek Valley Natural Resource 

Conservation Association, was analyzed in the South Deer Landscape Management Project Environmental 

Analysis on the Medford District (USDI 2005g). The alternative presents itself as emphasizing natural succession 

and maintenance of fully stocked natural stands. Management disturbances are minimized; timber harvest comes 

from trees about to be naturally shaded out; and the use of prescribed natural fire is minimized. Invasions of 

non-native species are preempted by canopy coverage, minimal soil disturbance, and minimal prescribed or wild 

fire. Weed control is accomplished with physical removal, manual application of least toxic effective chemicals, 

and weed prevention protocols and eradication, in accordance with the Medford District’s Integrated Weed 

Management plan and programmatic EIS. Grazing, recreation, and other potential disturbances do not appear to 

be specifically addressed.

The Natural Selection Alternative proposal is a land management alternative more appropriately considered in the 

FLPMA-required land and resource management planning process, or in project specific landscape management 

plans such as South Deer, and as such is outside the scope of this EIS and not responsive to its Purpose and 

Need. The invasive plant control portion of the Natural Selection Alternative is not significantly different from 

the Integrated Vegetation Management approach already used by the BLM and a part of the action alternatives, 

as evidenced by the Natural Selection Alternative’s stated reliance on/consistency with the Medford District’s 

Integrated Weed Management Plan. The Natural Selection Alternative emphasis on prevention is also consistent 
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Final Environmental Impact Statement: Appendix 10

with existing BLM direction applicable to all of the action alternatives. The suggestions for how to accomplish 

that are outside the scope of the EIS because the EIS is not examining the full range of existing prevention and 

treatment options.

55. Comment: Instead of structuring the EIS to develop a range of alternatives centered around the need to 

intensively alter and treat still relatively intact native vegetation and spray weeds everywhere, the BLM should 

consider a range of alternatives that focus on restoring cheatgrass-infested lands and protecting native vegetation 

as much as possible. Expansion of cheatgrass pushes communities across thresholds from which natural recovery 

is difficult - if even possible.

Response: The BLM’s vegetation management program includes restoring cheatgrass-infested lands and 

protecting native vegetation. Much of the acreage increase between No Action (Alternative 2) and Alternative 

3 would be the use of a new herbicide, imazapic, that would effectively control cheatgrass and medusahead to 

facilitate restoration of the sage-forb communities on the east side of Oregon. 

56. Comment: The alternatives should allow the use of herbicides for the full range of multiple uses including 

timber and livestock forage production. The O&C Act requires timber production. BLM policy ensures only 

appropriate uses would go forward. Limiting herbicides to non-commodity objectives is a waste of public 

resources and an abrogation of management responsibilities.

Response: The BLM has chosen to limit the scope of the Proposed Action (Alternative 4) in order to simplify the 

analysis. This does not preclude the BLM from proposing and analyzing additional herbicide uses in the future.

Comparison of the Effects of the Alternatives

57. Comment: The Additional Effects by Resource subsection in chapter 2 is heavily biased toward herbicide 

use, sometimes with no mention of impacts of increased herbicide use with very toxic herbicides.

Response: The summary resource effects paragraphs in the Draft EIS have been replaced with an effects 

comparison table in the Final EIS to contrast, rather than summarize, the effects of the alternatives. Then to 

help ensure this section accurately reflects the analysis in Chapter 4, the comparison table has been reviewed 

and edited by the Chapter 4 resource specialists with instructions to include significant effects and inform the 

decision-maker about the important points revealed by their analysis. However, the section focuses on herbicide 

use because the alternatives are about adding herbicides. The analysis is clear that with the Standard Operating 

Procedures and PEIS Mitigation Measures, human and environmental risks are low or minimized, and there are 

substantial environmental benefits to their use. Reporting on this important analysis conclusion is not a “bias.” 

The potential for toxic herbicide effects is discussed in the resource effects sections in Chapter 4 and displayed on 

the effects comparison tables in Chapter 2.

58. Comment: The Visual Resource section’s statement in Chapter 2 that “long-term benefits of protecting 

native plant communities would outweigh any short-term adverse effects of herbicide treatments” seems to be an 

unsubstantiated ideological mantra used to override any legitimate objections from the public.

Response: This statement in Chapter 2 was an oversimplification of the effects reported in more detail in the 

Visual Resources section in Chapter 4. Invasive weed monocultures are assumed less visually desirable than 

more diverse native vegetation. The visual effect of using herbicides to treat vegetation varies depending on 

which herbicide is applied and how it is applied. When herbicides are applied directly to an invasive plant using 
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a backpack sprayer or wicking method, the short-term visual impact is browned and dead vegetation mixed with 

green native vegetation. When non-selective herbicides are applied aerially or with a boom sprayer, the resulting 

short-term visual effect is one of an open, browned landscape. Long-term benefits of protecting native plant 

communities would outweigh any short-term visual adverse effect of herbicide treatments.

59. Comment: There seems to be an automatic assumption in the Comparison of the Effects of the Alternatives 

section that non-herbicide control is always more expensive regardless of plant type, the availability of volunteer 

crews, etc, because the analysis ignores the hidden costs of herbicides to water quality, fisheries, edible plants, 

cultural native plants, human health, and so forth.

Response: The necessarily undetailed summary comparison sections in Chapter 2 reflect the conclusions of 

the more detailed resource sections in Chapter 4. The Chapter 4 Implementation Costs section compares the 

implementation costs of the various alternatives, and does not attempt an overall cost/benefit analysis. Regarding 

natural resource values, the resource specialists preparing the individual resource sections of the EIS compared 

the degradation expected from invasive plants with the risks of using herbicides, and generally concluded the risks 

from herbicides was low, while the risks from invasive plants was substantially higher. While both sides of this 

comparison include qualitative judgments, various estimates of the economic impact of invasive plants, and the 

quantitative risk calculations made in the Risk Assessments and reflected on the “Risk Categories” tables at the 

end of Chapter 3, tend to support this conclusion.

60. Comment: The Comparison of the Effects of the Alternatives section concludes that herbicide risks would be 

“negligible.” What does negligible mean in the real world? What context and severity of impacts would occur 

to what values and which species? This term fails the accurate science and disclosure test of quantification and 

qualification.

Response: The supporting context, severity, and quantification are in the more detailed sections in Chapter 

4. Those sections report on the potential for herbicides to cause various adverse effects, but also note that 

implementation of the Standard Operating Procedures and PEIS Mitigation Measures would, by design2 and when 

coupled with site-specific analysis and project design, reduce risk to the point where significant adverse effects 

at the programmatic scale would be unlikely. This conclusion is consistent with the BLM’s experience with 

herbicides over the past 25 years. 

A section on the relationship between the Standard Operating Procedures, PEIS Mitigation Measures, and the 

Potential for Adverse Effects is presented at the end of Chapter 3. This section summarizes the finding from the 

resource discussions in Chapter 4, that these measures “should make the potential for adverse effects negligible, 

de minimus, or at worst, “minimized”.”

Potential Mitigation

61. Comment: Identified mitigation measures should be mandatory unless other means are fully justified as 

meeting the mitigation need, not just rejected because of cost or presumed less effectiveness. Otherwise, the 

public and decision-maker cannot assume essential protection from serious impacts, since the EIS relies on 

mitigation as foundational to Risk Assessment conclusions.

2 Adverse effects identified in the 2007 PEIS, to which the Oregon EIS tiers, resulted in the preparation of corresponding 

mitigation measures. The 2007 PEIS Record of Decision adopted ALL of these mitigation measures. Thus, by 

definition, the potential for adverse effects when viewed at the west-wide programmatic scale should be minimized 

when PEIS Mitigation Measures are implemented. 
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Final Environmental Impact Statement: Appendix 10

Response: Risk Assessments are analytical examinations of the potential for adverse effects given modeled 

and described exposures and doses. There is no assumption in the Risk Assessments about Standard Operating 

Procedures or PEIS Mitigation Measures. Standard Operating Procedures and PEIS Mitigation Measures are the 

BLM’s way of insuring that the adverse risks identified in the Risk Assessments are avoided. 

The analysis of effects in the EIS assumes application of all Standard Operating Procedures and PEIS Mitigation 

Measures, listed in Appendix 2, (unless, as the comment suggests, site-specific analysis indicates their objectives 

can be met some other way.) The Standard Operating Procedures reflect various BLM policies. The PEIS 

Mitigation Measures were selected by the 2007 PEIS Record of Decision and apply to all herbicide use on BLM 

lands in the 17 western states, and are a part of all alternatives in the Oregon EIS. 

Potential Mitigation measures in Chapter 2 of the Oregon EIS are in addition to the PEIS Mitigation Measures. 

NEPA requires identification of mitigation measures, if possible and within limits, for all adverse effects identified 

in the analysis. The Oregon EIS analysis identifies the potential for adverse effects (in spite of the application of 

all Standard Operating Procedures and PEIS Mitigation Measures), and thus identifies Oregon-specific potential 

mitigation measures (Chapter 2). This is no surprise; programmatic or site-specific analysis below the westwide scale of the PEIS would be expected to identify more site-specific adverse effects. To the degree that any 

of the EIS-identified potential mitigation measures are necessary to avoid contributing to listing or meeting any 

other legal requirements, they would be adopted. Potential mitigation measures based on other adverse effects, 

however, will be examined by the decision-maker to determine if the described adverse effects, and the degree 

to which they would mitigate an identified adverse effect, is significant enough to justify the investment and/or 

constrain the proposal. Upon consideration of potential mitigation measures, there is no substantive requirement 

to mitigate all adverse effects (40 C.F.R. 1505.2).

62. Comment: The NEPA requirement that in the Record of Decision, the decision-maker must state whether 

all practicable means to avoid or minimize environmental harm from the selected alternative have been adopted, 

and if not, state why not, implies the need to seriously consider and analyze in detail a variety of less harmful 

alternatives including most of those suggested by the public and not analyzed in detail. This NEPA requirement 

does not seem to have been met by the EIS.

Response: NEPA does not require that proposed actions or decisions have no significant adverse effects. 

Similarly, the requirement to identify whether or not adverse effects can be mitigated does not infer the EIS must 

include alternatives that are outside the scope or would not meet the Need simply to avoid such effects. The 

EIS includes a range of alternatives that would meet the Need. The EIS also addresses (in Chapter 2 and/or in 

this section) all public proposals for additional alternatives with a potential to meet the Need, as well as publicsuggested mitigation measures.

63. Comment: The BLM should take an active role in having a forb component in native seed mixtures to 

accurately reflect the plant communities on BLM lands.

Response: The BLM has an existing policy to use native seed in restoration (USDI 1992a; USDI 2008a). Nonnative seed may be used following NEPA analysis that documents the need for other than native seed primarily 

to protect the soil resource and future site potential. Restoration is already an element of Integrated Vegetation 

Management and other vegetation management direction, and reconsideration of, or a change in, BLM native seed 

policies and direction is outside the scope of this EIS.

64. Comment: How are 100 and 200-foot buffers determined for wells and springs? Are these adequate? There 

should be no herbicide spraying in or near hydrological-connected ditches and roads (wet or dry). Mitigations 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

should also prohibit herbicide sprays near water and restrict herbicide use in dry riparian buffers to the winter 

hibernation or aestivation period to more fully protect amphibians and susceptible mollusks – or (preferable) 

use non-herbicide control methods. Not using herbicides on native plants would help reduce risk to ungulates 

and other wildlife. Herbicide impacts to Federally Listed and other Special Status species should be completely 

avoided. Maximum application rates should be prohibited.

Response: Most of the points suggested by this comment are already required by the Standard Operating 

Procedures, PEIS Mitigation Measures, or other laws and policies. Since most of the potential for adverse effects 

was identified in the PEIS, few additional potential adverse effects are identified in the Oregon EIS. Some of the 

measures suggested by the comment are not PEIS Mitigation Measures, but no adverse effect has been identified 

that would indicate their being needed. Determination of spring and well minimum buffers is based on the 

potential for drift, the potential for herbicides to be carried to water intakes by rain events, and the potential for 

adverse human health effects. Most existing treatments are spot sprays or daubs with little potential for longdistance drift.

65. Comment: Herbicides should not be broadcast sprayed in riparian areas.

Response: Standard Operating Procedures for Wetlands and Riparian Areas specify the use of wick or 

backpack sprayer.

66. Comment: Herbicides should not be sprayed on amphibian habitat. 

Response: Such a prohibition would effectively eliminate many treatment projects in riparian/wetland habitats. 

In addition to site-specific planning that would consider important amphibian habitat, Standard Operating 

Procedures and PEIS Mitigation Measures (Appendix 2) require avoidance of POEA-containing glyphosate; 

avoidance of critical wildlife breeding or staging periods; the use of water buffer zones for herbicides not labeled 

for aquatic use; and others. The analysis in the Wildlife Resources section in Chapter 4 indicates some of the 

herbicides are toxic to amphibians, some are not, and some are unknown. The analysis also points out that the 

two aquatic herbicides currently available to the BLM in Oregon (2,4-D and glyphosate) are toxic to amphibians, 

while some of those that would be added by Alternative 3 are not. Amphibians included in the Special Status 

Species Program or Survey and Manage would be specifically considered during site-specific analysis to meet the 

requirements of those programs.

67. Comment: As moths and butterflies are among the larger group of pollinators, the EIS should specify 

the following: 

1. Maintain herbicide free buffer zones around patches of important pollinator nectar and pollen sources.

2. Maintain herbicide free buffer zones around patches of important pollinator nesting habitat (called host 

plants for Lepidoptera) and hibernacula (pupa and cocoons).

3. Make special note of pollinators that have single host plant species and minimize herbicide spraying on 

those plants and in their habitats.

Response: These recommendations are already within the Standard Operating Procedures for pollinators listed in 

Appendix 2. The effects analysis in this EIS assumes Standard Operating Procedures would be followed or that a 

site-specific determination is made that they are unnecessary to achieve the intended protection or objective.

68. Comment: Some herbicides are highly persistent and should not be used. For example, in areas with edible 

and medicinal plants and fungus, the theoretical “safe time” to enter the area and use these plants may be one-tothree years after application, or longer with repeated applications, making prevention of adverse human health 

effects by posting unlikely.
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Final Environmental Impact Statement: Appendix 10

Response: Some of the more persistent herbicides (diuron, bromacil) included in the analysis are soil-applied and 

would not result in human exposures for people gathering food and medicinal plants. Herbicides on vegetation, 

exposed to moisture and sunlight, break down far more quickly. Site posting requirements are specified 

accordingly. The potential for herbicides to adversely affect persons actively engaged in food collection is 

examined in the Risk Assessments and discussed in the Human Health and Safety section in Chapter 4. 

69. Comment: The alternatives need to include guidelines that protect edible wild mushrooms and medicinal 

plants. This particularly applies to Alternative 4 (the Proposed Action) and Alternative 5’s proposal for broadcast 

treatments of native plants along roadsides and other areas.

Response: The Risk Assessments summarized at the end of Chapter 3 and discussed in the Human Health and 

Safety section in Chapter 4 indicate the amount of these herbicides likely reaching, then being ingested or contacted 

by, collectors and end users of mushrooms and other forest products presents a very low risk of harm. Both of these 

products are recognized as valuable wildland resources and products. Standard Operating Procedures and required 

signing would reduce direct user exposure. Herbicide treatments potentially affecting these two products would be 

subject to site-specific analysis. That analysis should recognize and consider the potential for herbicide applications 

to affect both populations of, and users of, mushrooms and other forest products. 

Chapter 3 – Background and Assumptions for 

Effects Analysis

The 18 Herbicides

70. Comment: The EIS did not include an analysis of the inert ingredients. The BLM needs to fully disclose 

the active and so-called inert ingredients of all of the approved herbicides, and fully describe their ecological and 

health effects, both individually and in combination. Inert ingredients can be toxic to target and non-target species 

and they can persist in soil and water. Inert ingredients - especially in combination with other pesticides - can be 

more toxic to humans and fish than the listed ingredients.

We acknowledge that the BLM attributes the analysis deficiency to current law that permits pesticide makers to 

hide the identity of the inert ingredients by claiming trade secrets. However, without revealing this information, 

the BLM does not comply with NEPA requirements to disclose effects.

Response: The BLM recognizes that certain inert ingredients can be toxic to target and non-target species. It 

is the manufacturer’s intention that they enhance toxicity or exposure to target species. BLM evaluated inert 

compounds to assess affect on non-target species. Many inert compounds are naturally occurring substances. 

Some, such as nontoxic mineral compounds, do persist in soil. The BLM and Forest Service evaluated inert 

ingredients and two surfactants, POEA and R-11, are specifically addressed in Appendix D of the PEIS. R-11 

is no longer used by the BLM, and POEA in glyphosate is reflected in the risk category for glyphosate shown in 

Chapter 3 and discussed in the various resource effects sections in Chapter 4. The Adjuvants, Impurities, and 

Other Ingredients section in Chapter 3 has been expanded to better describe the BLM analysis of inerts. Potential 

effects are discussed in the Fish, Wildlife Resources, and Human Health and Safety sections in Chapter 4. 

Additional information about uncertainty related to these materials in included in Appendix 13.
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Pesticide manufacturers usually disclose their inert ingredients only to the EPA and the BLM. The BLM is 

prohibited by law from disclosing the actual inert ingredients because they are considered proprietary. In 

response to petitions asking the EPA to require that these ingredients be identified on the labels of products that 

include them in their formulations, the EPA has initiated rulemaking to increase public availability of the identities 

of the inert ingredients in pesticide products. A 60-day public comment period began December 23, 2009, and 

was extended an additional 60 days. The EPA has not yet reported on the results. Any new information about 

herbicide toxicity will be incorporated into subsequent site-specific analyses. A description of this rule-making 

effort is included in Chapter 1.

71. Comment: The EIS needs to identify toxic active ingredients, adjuvants, and exact formulas and analyze 

impacts of formulas and tank mixes.

Response: Active ingredients were identified for all herbicides. Common names are typically used in discussing 

herbicides rather than chemical formulas, as they are long, technical, and generally not understood except by 

organic chemists. Formulas are available at many locations; see for instance the Herbicide Handbook (Vencill et 

al. 2002). EPA licensing and Risk Assessments are conducted with the herbicides as formulated, so any risks are 

included in the risk categories. For example, the EIS points out that adverse effects to fish attributed to glyphosate 

may be more attributable to the surfactant POEA rather than the active ingredient itself. The BLM evaluated inert 

ingredients, degradates, adjuvants and tank (combined) mixes in the Risk Assessments, and results are described 

in Chapter 3 and in the Fish, Wildlife Resources, and Human Health and Safety sections in Chapter 4. A detailed 

discussion of uncertainty in the Risk Assessments (relative to those materials) is included in Appendix 13. The 

Risk Assessments considered repeated use within the same areas; maximum label rates are per year. An additional 

description of the analysis of these materials done by the BLM has been added to Chapter 3.

72. Comment: In the Fish section of the EIS, the BLM is assuming that inert ingredients would not represent a 

substantial part of the herbicide product. This may or may not be true, and should not be assumed to be. 

Response: The comment mischaracterizes the statement in the Fish section in Chapter 4. The Fish section 

states that toxic inerts would not represent a substantial part of the herbicide product (emphasis added). The EPA 

ranks inerts based on their toxicity, and few of the herbicide products that would be used on BLM lands have 

toxic inerts. More information about inerts and toxicity can be found in Chapter 3. A list of herbicide products 

that could be approved for use on BLM lands is shown in Appendix 9. This list includes products screened by 

the BLM for the absence of toxic inerts and adjuvants identified by the EPA, Risk Assessments, and additional 

available information. The BLM’s list of approved products changes annually as new information is acquired.

73. Comment: The statement that differences in the number of herbicides available east and west of the Cascades 

is based on differences in native vegetation types and invasive plant occurrence is contrary to earlier statements 

about population density and public acceptance. 

Response: Differences in population density and public acceptance did not influence the selection of herbicides 

for the various alternatives. The incorrect text in the Comparison of the Effects of the Alternatives section in 

Chapter 2 has been deleted. The differences in herbicides east and west of the Cascades are based on differences 

in vegetation and weed spread, registered uses, objectives, and environmental conditions such as fire risk or the 

prevalence of watercourses. For example, a persistent, soil-applied herbicide could be used along roadsides 

east of the Cascades to remove fire-prone dry grasses, while the same herbicide would not be used west of 

the Cascades because the risk of roadside grass fires is low, bare ground in roadside ditches would erode, and 

roadside-applied persistent herbicides might end up in nearby streams.
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The Differences in the Number of Herbicides Proposed East and West of the Cascades section in Chapter 3 has 

been edited to better reflect these reasons.

74. Comment: There needs to be a process for making new herbicides available for use by the BLM in Oregon 

as more effective, less persistent herbicides become available. For example, aminopyralid should be added to the 

herbicides included in Alternative 4 (the Proposed Action).

Response: The process for adding additional herbicides is prescribed by the BLM national office. The process 

is described in Appendix 4, and it includes the preparation of Ecological and Human Health Risk Assessments 

followed by NEPA analysis. Such analysis is expensive, and is undertaken only after a significant need is 

identified. Aminopyralid is being considered for this process. The BLM does not rely on the EPA registration 

alone to determine if an herbicide is appropriate for use on wildlands. The process is slow, but helps minimize the 

potential for adverse public or ecosystem effects.

This issue is addressed further in the Alternatives Eliminated From Detailed Study section in Chapter 2, under an 

alternative named Consider the Use of Different Herbicides Other than the 18 Being Considered.

75. Comment: The Proposed Action (Alternative 4) would increase the use of 2,4-D and diuron, both of which 

have been shown to have adverse effects to human health.

Response: The Proposed Action (Alternative 4) proposes to increase the number of herbicides available so that 

herbicides that are more effective on certain plants or in certain areas can be used. Hence, the Proposed Action 

would actually decrease the use of 2,4-D statewide by one-third. Potential effects to human health are described 

in the Human Health and Safety section in Chapter 4, and 2,4-D information is summarized in Appendix 12. 

Diuron is one of the new herbicides that would become available under the Proposed Action. Diuron is a nonselective herbicide that would be used to kill all vegetation in areas such as along pavement edges or around 

communication towers, electrical substations, and other non-public use areas where vegetation would degrade 

pavement, harm structures, or spread fire. Most use would be east of the Cascades; use of diuron is estimated 

at 100 acres annually west of the Cascades. Summaries about each herbicide, including explanations of what 

each herbicide would be used for, have been added to the Final EIS in Appendix 9. Potential health effects are 

addressed in the Human Health and Safety section in Chapter 4.

76. Comment: Diuron is long-lived, contaminates water, is harmful to fish, has harmful effects on people, and is 

a risk to all susceptible wildlife. Why would it be considered for use west of the Cascades?

Response: Diuron’s persistence and non-selectivity make it useful for complete vegetation control within 

seldom-visited enclosed communication sites to reduce maintenance costs and prevent wildfire damage. It is also 

useful within a foot or two of pavement edges to prevent plants from encroaching on and damaging road edges. 

It would not normally be used within the roadside ditches west of the Cascades because the ditches connect to 

streams, because grass or other low vegetation is often desirable to stabilize drainage structures, and for other 

environmental reasons cited in the comment. Because of the concerns noted, use is estimated at 100 acres per 

year west of the Cascades and would occur only where unacceptable adverse environmental effects could be 

avoided. A potential mitigation measure has been added to Chapter 2, requiring consideration of the roadside 

ditch connection in all project analyses for roadside treatments.

Although the Draft EIS described how administrative sites and roads would benefit from Alternative 4 (the 

Proposed Action), benefits were generally not attributed to specific herbicides. Additional information about the 

specific uses and risks has been added to the EIS for each herbicide in Chapter 3. In addition, the Administrative 
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Sites, Roads, and Rights-of-Way section in Chapter 4 now specifically describes the benefits of the persistent 

herbicides (diuron, bromacil, tebuthiuron) added by Alternative 4.

Assumptions and Information about Treatment Acres

77. Comment: The EIS does not have an alternative that would deal with any sort of integrated weed 

management nor does it provide a protocol for determining the best or most appropriate treatments. The BLM 

should have a process for examining other methods before it resorts to herbicides.

Response: All of these suggestions are requirements of the BLM’s Integrated Vegetation Management policy 

(USDI 2008a, USDI 2007e, and others). The alternatives propose to add additional herbicides to the BLM’s 

existing noxious weed and other vegetation management programs. Other elements of Integrated Vegetation 

Management and BLM policies for determining the best or most appropriate treatments are already in place and 

apply to all alternatives. Prevention, followed by early detection and rapid response, would remain the BLM’s 

highest priority weed control strategies, for example. The description of Integrated Vegetation Management in 

Chapter 3 is intended to set the context for the alternatives. The introduction to the Need in Chapter 1, and the 

Introduction in Chapter 2, both state that the alternatives would only add additional herbicides to the existing 

Integrated Vegetation Management program. The Integrated Vegetation Management section in Chapter 3 has 

been supplemented with a discussion of how, following BLM policies, vegetation treatment methods are selected.

78. Comment: The EIS defers reconsideration of ground-disturbing management activities by, in part, saying 

planning of management activities must consider and mitigate their role in noxious weed spread. Since weeds 

are spreading at 12 percent in part because of management activities, there is little evidence the policy is being 

followed. 

Response: The discussion under the Reduce Ground-Disturbing Activities alternative in Chapter 2 has been 

rewritten to place the emphasis where it belongs, that being that reconsideration of other management activities is 

more correctly the purview of the resource management planning process required by the FLPMA and outside the 

scope of this analysis. 

Risk and other discussions throughout the EIS analysis assume compliance with existing BLM policies. For 

the preparation of project NEPA documents, it is customary for districts and field offices to maintain a policy 

checklist. Such lists would be expected to include the policy of considering and mitigating each projects role 

in noxious weed spread. In consideration of this comment, however, three random timber sale Environmental 

Assessments were selected from each of the Coos Bay and Roseburg District websites. The control of noxious 

weeds was displayed prominently in each, and the control of noxious weeds was a specific project objective in 

one. Based on these points, various EIS references to this BLM policy do not appear to be overstated. 

79. Comment: The EIS should explain how the risks associated with ground disturbing activities proposed by 

BLM are documented and implemented.

Response: All NEPA planning processes for ground disturbing projects and projects that have the potential to 

alter plant communities must include a noxious weed risk assessment when it is determined that a proposed action 

may introduce or spread noxious weeds. If the risk assessment determines there is a moderate to high risk of 

spreading noxious weeds, then actions must be taken to reduce or prevent the spread of noxious weeds. Example 

actions include modifying the project to include seeding the disturbed area with native species, controlling 

existing infestations of noxious weeds prior to project implementation and incorporating prevention measures 
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into the project design or as contract stipulations. Results of the risk assessment are filed in the appropriate NEPA 

project file (USDI 1992b). This policy in mentioned in the Integrated Vegetation Management section in Chapter 

3 of the EIS, and explained in more detail in Appendix 3, in the Existing Monitoring section.

80. Comment: Given that certain BLM vegetation management projects are treated as categorical exclusions 

and not analyzed under environmental impact statements, the EIS should address invasive plant concerns for 

categorical exclusion projects. Management activities proposed as categorical exclusion projects should be 

assessed in light of their effects upon invasive plant prevention.

Response: The potential for a vegetation management project to spread invasive plants is a consideration in 

deciding whether a categorical exclusion is appropriate. However, the use of a categorical exclusion would 

not nullify the policy requirement to conduct a noxious weed risk assessment and include mitigation, a control 

strategy, and monitoring if the risk of spreading noxious weeds is moderate or high.

81. Comment: The EIS is flawed because it is based on the projected spread of invasive plants without 

addressing prevention. Education should be a key component of weed prevention and the EIS should address 

specific plans for outreach for public participation in weed prevention and eradication efforts.

Response: The Integrated Vegetation Management discussion in Chapter 3 notes that prevention, including 

education, remain the BLM’s highest priority strategy for weed control. This and other elements of Integrated 

Vegetation Management are in place, are common to all alternatives, and take precedence over herbicide use. 

82. Comment: The EIS needs to clearly describe the decision-making process and risk considerations for 

selecting between herbicide and non-herbicide methods at the site-specific scale.

Response: Department of the Interior integrated pest management policy states that “Bureaus will accomplish 

pest management through cost-effective means that pose the least risk to humans, natural and cultural resources, 

and the environment” and requires bureaus to “[e]stablish site management objectives and then choose the 

lowest risk, most effective approach that is feasible for each pest management project” (USDI 2007e). A list of 

parameters that affect how vegetation treatment methods are selected has been added to Integrated Vegetation 

Management section of Chapter 3. These parameters include potential impacts to humans, fish, and wildlife; 

opportunities to conserve native vegetation; and, proximity of the treatment area to susceptible areas, such as 

wetlands, streams, or habitat for species of concern.

83. Comment: To avoid loss of habitat and food for wildlife, the BLM should be extremely careful not to harm 

beneficial plants and trees.

Response: In treating invasive vegetation with both herbicide and non-herbicide methods, the BLM tries to avoid 

harm to non-target species. Invasive weeds, herbicides, and non-herbicide methods to remove plants all have the 

potential to harm beneficial plants and trees. Integrated Vegetation Management, Standard Operating Procedures, 

and PEIS Mitigation Measures all serve to help avoid damage to non-target species. Descriptions of these can 

be found in Chapter 3 and Appendix 2. When working with invasive plants, it is usually beneficial to minimize 

disturbance to adjacent native plants 1) so they can help restore the treatment area, and 2) so invasive plants do 

not invade disturbed sites. 

84. Comment: The EIS does not adequately disclose and consider the fact that using herbicides is less effective 

than other alternatives because it kills not only the target plant but also often kills the non-target plant, which 

reduces the cover of desired native vegetation and creates more opportunities for weedy plants to invade treated 
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areas. Hand pulling and carefully targeting just the invasive plants leaves more of the native plants in place to 

reoccupy the site and prevent future establishment of weeds.

Response: Herbicide use would be done in the context of Integrated Vegetation Management, where the best 

tool (or tools) for the job would be selected. Typically, invasive species would be targeted, retaining native plants 

to reoccupy the site regardless of the treatment method used. In many instances, carefully targeting the invasive 

plant with herbicides (using spot treatments) is far more effective than hand pulling. Some species break apart 

and spread when pulled, some infestations are too large to be effectively controlled by hand, and many times hand 

pulling has to be repeated many times in order to be effective, which can cause trampling of nearby vegetation 

and disturb wildlife. The soil disturbance associated with many non-herbicide methods is more conducive to 

reinfestation than spot herbicide treatments. When necessary, planting and reseeding would be done in areas 

where monocultures of invasive weeds have reduced the likelihood of natural revegetation with native species. 

More than 80% of the estimated herbicide use under the Proposed Action (Alternative 4) would be with herbicides 

that are selective to specific types of plants (e.g. grasses, broadleaf, etc). Additionally, Standard Operating 

Procedures and PEIS Mitigation Measures help prevent or minimize damage to non-native plants.

85. Comment: Opportunities should be explored to provide washing stations to prevent the spread of weeds 

by vehicles.

Response: Washing stations have been considered, as have discounts at local existing washing facilities. 

Signing at OHV staging areas and boat landings warn of the dangers of invasive weeds and direct users to 

existing facilities. Liability, cost, vandalism, water contamination, and other issues affect consideration of 

washing stations. Consideration of washing stations, however, is an existing element of Integrated Vegetation 

Management, and a reconsideration or change of emphasis regarding this issue is outside the scope of this EIS.

86. Comment: Restoration and monitoring plans must be drafted and funds allotted at the same time as control 

measures are implemented.

Response: There are restoration and monitoring requirements that apply to each invasive plant control treatment. 

Many of those specifically addressing herbicide use are described in the Integrated Vegetation Management 

section in Chapter 3, or in Appendix 3. General project implementation monitoring is also conducted to ensure 

consistency with NEPA and Land and Resource Management Plan decisions.

87. Comment: No apparent scientific methodology was applied to come up with the estimates of annual 

herbicide use; they appear to be over-exaggerations.

Response: The estimates of annual herbicide use were developed by the district vegetation managers with 

knowledge of the existing district needs and management direction. District weed coordinators with many years of 

experience coordinating, and planning the current Integrated Vegetation Management program related to noxious 

weeds helped prepare these estimates. Estimates are based in part on past use, which is reported annually by the 

district and state offices to the National office and the EPA. However, the EIS is clear that these numbers are 

estimates for cumulative effects analysis purposes only, and are not decisions to manage vegetation. Actual herbicide 

use could vary based on many factors including new and/or previously unknown infestations of weeds. Site-specific 

analysis would be used to determine and confirm the need to treat vegetation, and examine site-specific effects. If 

actual herbicide use is less than these estimates, then the EIS-described herbicide risks would be reduced.

88. Comment: The “Estimated Annual Acres Treated in Rights-of-Way, Administrative Sites, and Recreation 

Sites” table in Chapter 3 shows such a wide range of acres that may be treated that the information is meaningless. 

It makes it impossible to estimate the potential impacts.
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Final Environmental Impact Statement: Appendix 10

Response: In the Draft EIS, the estimated annual acreages of treatments shown in a table in Chapter 3 and used 

throughout the document for Alternatives 4 and 5 were partially based on weighted averages of ranges shown in 

this table. For the Final EIS, district experts were asked to re-estimate the acreages based on the herbicide, rather 

than use the multiple herbicides by project type approach that was used in the Draft EIS. This provided a more 

meaningful estimate of the acreages to be displayed in the Final EIS. However, the weighted averages used in the 

Draft EIS and the estimated acres used in the Final EIS are similar.

89. Comment: The BLM should follow the Forest Service in prohibiting maximum application rates.

Response: The 2005 Region 6 Forest Service Record of Decision does not prohibit the use of maximum 

application rates shown in the Forest Service EIS (USDA 2005:4-2) and adopted by its Record of Decision. The 

Forest Service typical and maximum rates are similar to those being considered in this EIS.

90. Comment: The EIS should recognize that herbicides have to be used repeatedly because one application will 

not be effective. Noxious weeds are hard to destroy, so herbicides will have to be used repeatedly because one 

application will not be enough to be effective. Most herbicide use requires multiple applications each year for 

three to five years.

Response: Noxious weeds are often hard to destroy, and for those situations needing herbicides, it is best to find 

the right herbicide for the control objectives. The four currently available herbicides are not very effective on 

some weeds (e.g. whitetop), but have been used multiple times to suppress these weeds to prevent flowering and 

thus slow weed spread. The additional herbicides proposed in Alternative 3 would greatly increase the likelihood 

that the right herbicide would be available, so one application could kill plants that would otherwise need years 

of pulling or other treatments. If one area is treated more than once in a year, it is usually to find missed areas 

or plants. In such cases, maximum and typical annual rates would still apply. That is, an herbicide would not 

be applied more, within that entire year, than then permitted by the maximum annual rates shown on Table 3-1 

in Chapter 3. For invasive weed populations treated in consecutive years, the amount of herbicide used should 

decrease as control objectives are met. Weed treatments are frequently evaluated for effectiveness (see Appendix 

3), and the BLM would not want to treat vegetation, year after year, with a method that was ineffective. 

91. Comment: The BLM should make a specific measurable commitment to reducing or eliminating its reliance 

on herbicides over time.

Response: Nothing in the noxious weed spread calculations, or in advances in alternative control methods, 

indicates that the need for herbicides will significantly decline in the 15-year planning horizon considered in this 

EIS. New weed infestations will continue to be discovered, and resource values will continue to benefit from their 

effective control. However, the herbicide application acres in the EIS are only estimates for analysis purposes. 

They are neither minimums nor maximums, and no treatments are authorized by this EIS. If there were a reduced 

need for herbicides in the future, it would be reflected in site-specific decisions.

92. Comment: The EIS should restrict herbicide use to a last resort, and acknowledge the research done by 

Rinella et al (2009) which indicates herbicide use can exacerbate invasive weed problems.

Response: Rinella et al. (2009) documents the 16th year examination of native forb species responses when an 

herbicide, in this case enough picloram to remain soil active for some months, was applied once to a grass/forb 

area infested with leafy spurge in an effort to improve livestock forage on a ranch in Montana. Both the forbs 

and the invasive leafy spurge were substantially reduced by the spray (but not the grass), and reinvasion of leafy 

spurge subsequently occupied those sites, locally extirpating some of the forb species. The paper acknowledges 
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the initial reduction in forb species was to blame, and contrasts the study with a similar one where the forb 

component was retained, and post-treatment reinvasions did not reduce the forb community. 

The results of this study do not contradict the analysis in this EIS. The studied herbicide application scenario, 

however, has little resemblance to those described in this EIS. For example, the Wildlife Resources section in 

Chapter 4 states “few broad-scale treatments of native vegetation are anticipated to be conducted under any 

of the alternatives unless they are specifically designed to benefit wildlife habitat (Chapter 3, Assumptions 

about Herbicide Treatments). Invasive plant treatments are generally directed only at noxious weeds and other 

invasive plants either by treating only the invasive plant or by using a selective herbicide. The objective of those 

treatments is to remove weeds and restore native (or other non-invasive) vegetation. Treatments are designed 

to reduce damage to native vegetation and reduce unnecessary site disturbance that favors reinvasion by the 

invasive plants.” As noted in the quote, there is similar language in the Assumptions about Application Methods 

section in Chapter 3. One broad-scale herbicide use estimated to occur in the EIS under Alternative 3 is imazapic 

applications on areas infested by medusahead rye, or recently burned areas likely to become heavily infested with 

this invasive annual grass. Current medusahead treatments using glyphosate can kill desirable forbs, but imazapic 

at low rates is selective for annual grasses. Imazapic would be available for medusahead control under the action 

alternatives, and is desired specifically to decrease the likelihood of having the adverse effects of using glyphosate 

described in Rinella et al. (2009).

The treatment described in the article involved a one-time treatment to improve livestock forage. No such 

treatments are envisioned from this EIS. Invasive plant treatments are usually targeted just at the invasive plants, 

and require monitoring within two years. The Noxious Weeds and Other Invasive Plant section in Chapter 4 

describes noxious weed treatments under Alternatives 3-5 as being about 80 percent effective, meaning a return to 

the site is usually necessary to spot treat missed and newly emerging plants. Weed control staff are aware that a 

lack of follow-up will often result in failure to achieve control.

93. Comment: The adverse impacts of methods and scale of herbicide applications are not addressed.

Response: Chapter 3 (Background and Assumptions for Effects Analysis) provides an explanation as to the 

methods and scale of herbicide applications; Chapter 4 (Affected Environment and Environmental Consequences) 

shows the impacts (adverse and beneficial) of the herbicide applications described in Chapter 3.

94. Comment: The EIS fails to adequately consider the detrimental impacts of aerial spraying thousands of acres 

of clear-cut forests.

Response: The EIS does not propose or imply that thousands of acres of clear-cut forests would be sprayed 

with herbicides. All alternatives exclude the use of herbicides for timber production; most herbicide use after 

timber harvest would be to keep invasive plants from spreading or gaining a foothold. Aerial spraying would not 

be allowed west of the Cascades under Alternatives 3 and 4 (the Proposed Action) and would occur rarely (if at 

all) under Alternative 2 (the No Action Alternative) and Alternative 5. Aerial spraying would occur more often 

east of the Cascades, but BLM’s dry forests east of the Cascades are managed to promote forest stand health. 

Timber volume production is not an objective, and treatments are generally thinning (and not clear-cuts). Aerial 

application of herbicides east of the Cascades would be used primarily to control monocultures of invasive weeds 

like yellow starthistle and medusahead or where ground access is difficult. 

95. Comment: The authority to apply herbicides aerially as described in the EIS is excessively broad. Aerial 

application of herbicides should be subject to NEPA analysis on a project-by-project basis.
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Final Environmental Impact Statement: Appendix 10

Response: As noted in Chapter 3, about seven percent of the noxious weed herbicide treatments currently 

being conducted by the BLM in Oregon are done with planes (two percent) or helicopters (five percent). These 

applications follow project-level site-specific analysis. Any future applications conducted pursuant to this EIS 

would be similarly subject to NEPA analysis at the site-specific scale. The aerial applications levels described in 

Chapter 3 are the assumptions under which the EIS’s cumulative effects analysis is based, and are not decisions to 

conduct projects. Alternatives 3 and 4 (the Proposed Action) would not allow aerial herbicide application west of 

the Cascades.

96. Comment: The BLM should be cautious about dousing post-wildfire landscapes with imazapic as proposed. 

What would be the effects to other plants and wildlife re-colonizing the areas or surviving the fire?

Response: The BLM exercises the caution suggested in the comment; the brief statement about expected 

imazapic use the Comparison of the Effects of the Alternatives section in Chapter 2 does not include a discussion 

of all the caution and considerations that would go into site-specific planning for such use. Chapter 3 states that 

imazapic is selective for “some broadleaf and grasses.” It would be used primarily to control monocultures of 

invasive annual grasses such as cheatgrass and medusahead while retaining native forbs to help with restoration, 

and some would be used to prevent invasive grass reinvasion after major fires prior to seeding. The Native and 

Other Non-Invasive Vegetation section notes the estimated 11,000 acres annually of imazapic east of the Cascades 

would be used to control monocultures of invasive annual grasses, and that imazapic has a low-to-moderate risk 

of harming non-target plants. These treatments would result in a corresponding 5,000-acre increase in native 

seeding because the invasive grasses could be controlled. Both the Fish and Wildlife Resources sections note that 

imazapic is one of the lowest risk herbicides to these two resources of any of the herbicides proposed for use. In 

any event, the potential for damage to remaining native vegetation critical to habitat and restoration, or to on-site 

fauna, would be reconsidered at the site-specific scale. 

The statement about using imazapic to prevent grass reinvasion and prepare restoration sites, while true, was 

incorrectly included in the Fire and Fuels section of the Comparison of the Effects of the Alternatives section in 

Chapter 2 of the Draft EIS; restoration has not been identified in the EIS as a “fire and fuels” objective. This point 

has been moved to the Native and Other Non-Invasive Vegetation subsection in this same section of Chapter 2. 

Risk Assessments

97. Comment: There is not enough research on potential damage to fish and wildlife.

Response: The EPA requires pre-market multiple toxicity, persistence, and environmental fate tests prior to 

registration. The toxicity tests include mammals, fish, plants, and other taxa. Prior to registration, in an effort to 

evaluate risk to fish and wildlife, the EPA also examines ecological risks to fish and wildlife including Threatened 

and Endangered species. The Forest Service and the BLM have conducted additional Risk Assessments of the 

herbicides analyzed in this EIS, to examine the available literature relating to fish and wildlife toxicity. The 

resource effects sections in Chapter 4 further cite relevant literature published since development of the Risk 

Assessments. Herbicides are heavily studied. There is enough information available for the decision-maker to 

understand the potential for significant environmental effects at the programmatic scale. Additional analysis will 

occur when site-specific projects are proposed.

An overview of the EPA and Risk Assessment processes, including a discussion of the types of information they 

each consider, has been added to the Final EIS as Appendix 13.
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98. Comment: In some cases, herbicides may seem less toxic because they are newer and we know less about them. 

Response: Much has been learned about the effects of pesticides and other chemicals in our environment 

in the past few decades, and more is known about groups of herbicides, adjuvants, and other materials. The 

development of newer herbicides has been informed by studies on older herbicides. Use of chemicals in society 

is regulated by various entities; pesticides are regulated by the EPA. The EPA requires toxicity, persistence, and 

environmental fate tests prior to registration. The EPA has registered each of the herbicides for specific uses 

identified in the EIS. Herbicide labels are required by the EPA to contain a section on health hazard information 

for workers and users. The BLM and Forest Service have also completed Risk Assessments for the herbicides in 

this EIS that examine plausible exposure scenarios specific to wildland uses. The Risk Assessments acknowledge 

and quantify risks. These identified risks are the reason for the Standard Operating Procedures and PEIS 

Mitigation Measures (see Standard Operating Procedures, PEIS Mitigation Measures, and the Potential for 

Adverse Effects at the end of Chapter 3), and serve as the basis for the effects (risk) discussions in Chapter 4.

99. Comment: The alternatives should include all EPA-tested and approved herbicides.

Response: As noted in the Risk Assessments section in Chapter 3, the United States Court of Appeals for the 

Ninth Circuit has found the EPA registration procedures to be inadequate to meet the wildland applications 

hard look requirements of NEPA. Risk Assessments build upon the EPA registration information by adding 

information from the scientific literature, and considering applications in wildland settings that appeared to be 

“minor” in the EPA registration process. Risk assessments are not completed for other herbicides because the cost 

is high compared to need, or preliminary indications are that the BLM would not want to use them. The BLM 

nationally maintains a list of Risk Assessments it considers to adequately cover wildland use, and periodically 

conducts literature searches to check the accuracy of less recent Risk Assessments. The BLM also maintains a 

list of approved adjuvants, selected based on absence of known toxicity (see Table A9-3 in Appendix 9). From 

these two sources, the BLM maintains a list of specific products known to contain only approved herbicides 

and adjuvants. The list of approved herbicides and formulations is updated annually. Those approved in 2009 

are shown in Appendix 9, Table A9-2. There are over 80 additional herbicides registered for use in Oregon that 

the BLM has not approved for use on BLM lands. Use of other herbicides is limited to experimental uses. The 

process for adding herbicides to the BLM National list is described in Appendix 4.

100. Comment: The EIS failed to consider the impact of pesticides even if labels are followed. Labels often 

do not consider the latest scientific findings, such as new information on impacts to amphibians and long-term 

impacts to human health.

Response: The EPA updates label requirements regularly as new information is compiled. The BLM did not rely 

solely on herbicide label information for the Risk Assessments. Risk Assessments include the EPA registration 

data for toxicity studies, fate and transport studies, chemical physical properties and other information. Literature 

searches were also conducted. The herbicides discussed in the EIS include only those having been subject to 

acceptable Risk Assessments and approved by the BLM nationally. It should be noted that Standard Operating 

Procedures and PEIS Mitigation Measures are applied after, and in response to, risks identified for Risk 

Assessment scenarios. Thus, actual risk from BLM use envisioned in this analysis is typically very low.

101. Comment: Despite a considerable body of data on acute exposure effects from the proposed list of 

herbicides, it is important to recognize that the chronic and sublethal risks are not yet well characterized. The 

historical record of pesticide toxicology reveals many cases of serious and unexpected adverse effects associated 

with pesticides that were not predictable from standard acute toxicity tests. Because of these unknown risks, we 

encourage use of non-chemical alternatives with known risks wherever feasible.
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Final Environmental Impact Statement: Appendix 10

Response: Besides acute toxicity testing, the EPA does require extensive chronic toxicity testing. Information 

about the types of data used during the EPA’s registration process has been added to the Final EIS in Appendix 

13. Chronic and sub-lethal effects are discussed in the Risk Assessments, and risk categories summarized on the 

“Risk Categories” tables at the end of Chapter 3, and discussed in the resource sections in Chapter 4, include risk 

categories for chronic exposure.

102. Comment: The EIS fails to analyze short-term effects on plants and wildlife during and directly following the 

application of herbicides. Since long-term effects are the focus of BLM’s analysis, it is unclear how many plants 

and animals will be killed or harmed during applications, and how that immediate contact might contaminate future 

generations. Given that many plants and animals might perish, the cumulative effect could be devastating.

Response: Risk Assessments examine plausible individual acute and chronic exposure scenarios, and resultant 

identified risks have been the basis for development of Standard Operating Procedures and PEIS Mitigation 

Measures, which minimize risk. Then, assuming the Standard Operating Procedures and PEIS Mitigation Measures 

are applied, and considering the generally limited scope of BLM herbicide uses, the potential for adverse effects 

to individual resources are addressed within Chapter 4. Many of those sections identify little or no risk in both the 

short and long-term, even at the very site-specific scale. The Fish, Wildlife Resources, and particularly the Native 

and Other Non-Invasive Vegetation section, however, identify risks to certain individuals from certain herbicides. 

For example, glyphosate with POEA is identified as toxic to directly sprayed amphibians away from riparian areas. 

(Glyphosate with POEA would not normally be used within riparian areas.) Most of the herbicides are toxic to nontarget plants if they are sprayed. These resource sections point out, however, that these adverse effects would be at 

the scale of the individual organism, and no long-term effect from herbicides is anticipated at the population scale. 

For Special Status species, those species’ assumed sensitivity and the requirement for pre-project clearances reduces 

the likelihood of adverse effects even at the scale of the individual organism.

Many of the resource sections in Chapter 4 do identify a likely long-term adverse effect from the continued spread 

of noxious weeds and other invasive plants.

103. Comment: The safety of most of these chemicals has not been determined using modern analytical methods 

in double blind tests. Most of the safety literature has been developed by those most in a position to profit. The 

government has no business releasing these agents for widespread use when their effects are so poorly known.

Response: The EPA requires extensive toxicological testing in multiple plant and animal species prior to 

registration using modern analytical methods. A certain portion of the testing is funded by the manufacturer, but 

it is conducted in independent laboratories using scientific methods approved by the EPA. The BLM does not 

rely only on this testing however; Risk Assessments are prepared, further examining the available literature to 

determine the implications of using the pesticides in wildland settings. Overviews of the EPA registration and 

reregistration processes, and of the BLM and Forest Service’s Human Health and Ecological Risk Assessment 

processes, have been added as Appendix 13. 

104. Comment: How many hazardous chemicals have been tested in situations where winds blow cattletrampled and de-stabilized herbicide-encrusted soils into waters or onto migratory birds eggs or into pygmy rabbit 

burrows as well as on the vegetation that pygmy rabbits eat?

Response: The Risk Assessments test maximum plausible exposure scenarios. Exposure to lesser quantities 

by less direct methods would simply have less effect (lower risk); testing these specific scenarios is not needed 

to understand risks. Dust transport of herbicides on soils into water was specifically addressed in the Water 

Resources section in Chapter 4. Most of the herbicides considered in the EIS are applied to foliage, not soil, so 

the scenarios described in the comment would be limited.
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Toxicity testing is performed on concentrated active ingredients. In the environment, herbicides are transformed 

by hydrolysis, photolysis, sorption, and biodegradation to less normally less toxic compounds and various 

degradates, each at lower concentration. The Ecological Risk Assessment scenarios addressed consumption of 

contaminated vegetation, and the Soils Resources section addressed effects on soil organisms. Many herbicides 

are rapidly degraded in soils, waters, and plant surfaces (see Soil Resources and Native and Other Non-Invasive 

Vegetation sections).

105. Comment: A full analysis of the adverse effects of all herbicides and their associated chemicals, including 

where multiple chemicals may be used, must be conducted under real-world degraded wild lands situations. 

Increased weather extremes under climate change scenarios must be incorporated into these Risk Assessments.

Response: Risk Assessments are performed using herbicide application type and rate information, exposure 

pathways including fate and transport models of migration through soil, water, and air, and multiple human and 

non-target species’ categories, to estimate risk as comprehensively as possible. The reason many wild lands are 

degraded is because of invasive species; there is no reason to believe that the risk models would not be applicable 

to degraded wild lands. Nor is there reason to believe climate change would affect herbicide exposures.

106. Comment: 1) BLM exposure scenarios were not as inclusive for the public as Forest Service exposure 

scenarios. 2) Failure to include water and food consumption could understate risk. 3) The exact methodology for 

assigning risk categories is not transparent. 

Response: 1 and 2) The BLM exposure scenarios were equally or more inclusive than Forest Service scenarios 

and included exposure to berry pickers, anglers, swimmers, ingestion of water, berries, and fish (see Human 

Health Risk Assessment Methodology in the Human Health and Safety section in Chapter 4). 3) The risk category 

methodology is almost identical between the two Federal Agencies. Appendix 13 has been added to the Final EIS 

to make information about the BLM and Forest Service Risk Assessment processes more available. 

107. Comment: The EIS does not clearly explain what the term “moderate toxicity” means.

Response: As discussed in the High, Moderate, and Low Risk in BLM and Forest Service Risk Assessments 

section of Chapter 3, the Risk Assessments for each herbicide evaluated in this EIS established a Risk Quotient 

(RQ) for each herbicide evaluated by BLM and a HQ (hazard quotient) for herbicides evaluated by the Forest 

Service. The EPA identifies a Level of Concern (LOC) for herbicides, which is the dose of the herbicide above 

which effects would be expected. In absence of information indicating otherwise, the LOC is generally 1/10 of 

the Lowest Observed Adverse Effect Level (LOAEL); or, the lowest dose level where there was a statistically 

significant increase in frequency or severity of lethal or sublethal adverse effects to the test organism. The RQ is 

calculated by dividing the Estimated Exposure Concentration (ECC) by the Toxicity Reference Value (TRV). The 

ECC is the dose that an organism would be exposed to under the test scenario (a cow eating only sprayed grass for 

a day, for example) and the TRV is the toxicity of the herbicide - usually the No Observed Adverse Effect Level 

(NOAEL) or the LOAEL. When the RQ is equal to 10 to 100 times the most conservative LOC for an herbicide 

(generally equal to the LOAEL to 10 times the LOAEL), BLM determined it to be a “moderate risk.” 

108. Comment: How do risk categories translate in real term effects? Are RfDs (Reference Dose) and TIs 

Toxicity Index) or TRVs (Toxicity Reference Value) expressed in comparable units of measurement and do the 

calculations of dividing EECs (Estimated Exposure Concentration) by TRVs really express the hazard? It seems 

that low or moderate risk categories could result in mortality or severe effects to the most vulnerable species.

Response: Computed environmental exposure concentrations were divided by toxicity reference values to derive 

risk quotients. Values greater than 1.0 indicate a level of risk that increases with the numerical value, but the 
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Final Environmental Impact Statement: Appendix 10

relationship between dose and response may not always be linear. Because of this uncertainty and because of the 

thousands of exposure scenarios evaluated, a category system was used. The category schemes described in the 

Risk Assessments section of Chapter 3 reflect the severity of risk.

The RfDs and TRVs use the same units of measurement (e.g. mg/kg body weight/day). The calculations are used 

by toxicologists to express the hazard. 

Regarding the “real term effects,” the High, Moderate, and Low Risk in BLM and Forest Service Risk Assessments

section in Chapter 3 attempts to put the risk categories in useable terms. The lower range for the L, or low, risk 

category is theoretically the level at which an effect began to be discernable in testing or modeling. The minimum 

identified effect may have been skin or eye irritation, leaf damage, and so forth. The lower range is not usually 

the level at which effects were actually notices, because uncertainty factors are added to address hypersensitive 

individuals, or accommodate uncertainties in the measurements, such as inferring effects to one species based on 

actual tests on other species. Uncertainty factors are typically multiples of 10, so the assumed Lowest Observable 

Effects dose could have been inflated 10, 100, or even 1,000 times for uncertainties. Thus, exposure of the 

average individual to the dose identified as having an effect probably would not have an effect. Nevertheless, the 

L or low category indicates risks start at that point. The moderate risk category indicates risk starts at doses onetenth those of the low categories; high is one-hundredth of the testing scenario dose. Testing scenarios are severe 

(e.g. soaking the test animal), so Standard Operating Procedures and PEIS Mitigation Measures such as buffers, 

wind speed limits, and so forth, as well as required safety equipment, limit exposure to substantially less than 

tested doses. For herbicides with moderate and high risk categories for a particular species, special cautions are 

implemented. For example, buffers for Special Status plant species are set at the shortest tested distance where no 

effect was discernable or predicted. Some are as large as 1,500 feet for some herbicides (Table A2-1). The low, 

moderate, or high human health risk categories shown on the “Risk Categories” tables at the end of Chapter 3 are 

more conservative than the EPA risk categories (Caution, Warning, or Danger/Poison) used on herbicide labels.

109. Comment: The increase in application and addition of new herbicides pose significant risks to the 

environment. In particular, the Proposed Action (Alternative 4) increases the risk of contamination of Oregon’s 

water, further threatens already imperiled species, and may endanger the health of local residents and those who 

use public lands.

Response: Nothing in the analysis indicates the current or proposed use of herbicides would pose a significant 

risk to the environment; the analysis seems to indicate not. The risk categories for each herbicide are based on 

scenarios plausible before the application of the Standard Operating Procedures and PEIS Mitigation Measures. 

Using the risk categories from the Risk Assessments and summarized on tables at the end of Chapter 3, and 

the estimated herbicide treatment acres for each alternative shown on Table 3-3, the Comparison of the Effects 

of the Alternatives table in Chapter 2 (Table 2-5) shows that the Proposed Action (Alternative 4) would treat 

fewer acres with moderate or high-risk herbicides than the No Action Alternative (Alternative 2), even though 

total acres treated with herbicides would nearly triple. The Proposed Action would use additional herbicides 

that have generally been chosen because they are less toxic than the four currently allowed on BLM lands. The 

risks to different organism groups are not related– e.g. an herbicide that is moderately toxic to birds may have no 

toxicity to fish. However, the Human Health and Safety section shows that herbicides that have a moderate risk to 

humans (the EIS does not propose using any herbicides that have a high risk to humans) are used on an estimated 

1,200 less acres annually under Alternative 4 (the Proposed Action) than under Alternative 2 (the No Action 

Alternative). All wildlife risk decreases between Alternative 2 and 3; herbicides that have moderate or high risk 

decrease between an estimated 800 acres annually (insects) to 8,900 acres (birds). Risks from herbicides between 

Alternatives 3 and 4 go up as risks from non-herbicide methods go down. Alternative 4 (the Proposed Action) 

would allow herbicide treatments in rights-of-way, administrative sites, and recreation sites; methods currently 

used are usually mechanical (mowing and chainsaws) which have their own set of risks.
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In addition, a larger number of available herbicides allows the most appropriate herbicide to be used. For 

example: one herbicide might be more effective at killing a weed and has less risk to non-target plants than 

another herbicide, but the first herbicide poses more risk to fish. If the herbicide application does not occur near a 

body of water, then risk to fish – an important consideration – might be completely irrelevant.

110. Comment: The EIS fails to adequately consider the harm from drift.

Response: Various drift scenarios are addressed on the “Risk Categories” tables at the end of Chapter 3, and 

considered and discussed under applicable herbicides in the various resource sections throughout Chapter 4. The 

discussions of drift in the Water Resources section includes a table of drift distances by droplet size; the AgDrift 

model is discussed in the Fish section; and Appendix 2 includes tables of buffer distances to avoid drift damage to 

Special Status species. In addition to drift, post-application off-site movement is addressed. Because most of the 

risks discussed in the EIS result from drift (as most non-target species would not be directly sprayed), addressing 

drift is an important component of the EIS.

111. Comment: In 2001, the EPA changed the legal definition of pesticide ‘drift’ to ‘the movement of liquid 

droplets.’ Previously, the definition included the movement of vapor. Vaporization occurs when the pesticides/

herbicides interact with the sun. It is a known fact that pesticides/herbicides drift much farther when vaporized 

than they do as liquid droplets. The current EIS refers to drift of droplets but never once mentions the more farreaching drift by vaporization. Elimination of vapor as a drift exposure to adjacent lands appears to be a loophole 

to not be responsible for herbicide pollution.

Response: Herbicide labels include restrictions against “drift,” so the EPA defines what that term means when it 

is on a label. In 2001, the EPA proposed to define drift as: 

Spray or dust drift is the physical movement of pesticide droplets or particles through the air at the time of 

pesticide application or soon thereafter from the target site to any non- or off-target site. Spray drift shall 

not include movement of pesticides to non- or off-target sites caused by erosion, migration, volatility, or 

windblown soil particles that occurs after application or application of fumigants unless specifically addressed 

on the product label with respect to drift control requirements (EPA 2001).

The 2001 EPA notice also said the EPA’s “drift” focus is “within relatively short distances (up to 1/2 mile)”, that 

“under certain circumstances lower levels of pesticides may drift considerably farther”, and that “pesticide vapor 

and the off-target movement of pesticides by other means...can nevertheless present substantial risks to humans 

and the environment. The EPA generally addresses these routes of exposure and associated risk at the individual 

pesticide level through its regulatory programs.” In short, the definition applies to an application term, but in no 

way presumes to set geographic limits on the area of potential effect. A discussion of the EPA action has been 

added to Chapter 1.

The BLM and Forest Service Risk Assessments consider the effects of herbicide contact, and do not distinguish 

whether that contact is from liquid, droplets, vapor, on blowing dust, in waters, or from other mechanisms in or 

out of the EPA’s drift definition. A background discussion about drift has been added to the Risk Assessments

section in Chapter 3. 

Herbicides have very low vapor pressures. One study showed that with more volatile insecticides, little or no 

vapor drift was detected 9-27 meters downwind for insecticides with vapor pressures less than 1x10-4 mm Hg 

(Woodward et al. 1997). All of the herbicides covered by the EIS have very low vapor pressures (maximum is 

4x10-6 mm Hg and they range to as low as 5.5x10-16 mm Hg; Vencill et al. 2002).
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Final Environmental Impact Statement: Appendix 10

112. Comment: The AgDrift model may be inadequate for forest and range settings, which are more complex 

than agricultural fields.

Response: For the past 25 years, the Forest Service has evaluated AgDrift and their similar version (AgDisp) 

to develop accurate, validated models that predict the behavior of pesticides applied by aerial application 

above forests. An extensive field study and model validation effort confirmed the predictive capability of the 

computational engine that drives the near-wake solution scheme in both AgDisp and AgDrift (Thistle 2005). The 

range settings would not differ significantly from those used for agriculture, because topography and application 

heights would be similar.

113. Comment: Even if the BLM aerially applies herbicides in compliance with the labels, it runs the risk of 

acting in a negligent manner by failing to designate a sufficiently large buffer zone around navigable waters. 

Considering the high density of adjacent waters to some of the area where aerial application is proposed, the 

probability of herbicide drift entering navigable waters increases significantly under the BLM’s Proposed Action 

(Alternative 4).

Response: A subsection addressing drift has been added to the Risk Assessments section of Chapter 3. 

Identification of water bodies during site-specific planning, constantly improving drift reduction agents, and 

improving technology regarding spray equipment including instant, pinpoint navigational equipment on aircraft, 

continues to reduce the likelihood of aerially applied herbicides reaching water bodies. The Proposed Action 

(Alternative 4) does not include aerial applications west of the Cascades in part because of numerous, sometimes 

hard to detect even from the ground, water bodies there. Standard Operating Procedure-prescribed buffers 

often exceed label requirements, and Special Status species’ buffers can exceed a thousand feet (Table A2-1 in 

Appendix 2). “Drift” is a primary exposure scenario addressed in the risk categories and discussed in the resource 

sections in Chapter 4, so any risk is well considered and displayed for consideration by the decision-maker and 

during subsequent site-specific analysis. This EIS does not propose projects. There is no basis for the claim that 

buffers would be too small or that subsequent treatments would be negligent. 

Most of the projected increase in aerially applied herbicides under the Proposed Action (Alternative 4) is for 

imazapic east of the Cascades. The “Risk Categories” tables at the end of Chapter 3 show imazapic to have no 

risk to the public or any element of the environment except plants, at every examined scenario including spills 

into water bodies. 

114. Comment: The BLM’s inability to prepare a Risk Assessment for all combinations of herbicide mixes, and 

for all adjuvants and inerts, suggests the need for a precautionary approach, including the avoidance of the more 

toxic herbicides and prohibiting boom sprays.

Response: Uncertainty factors used to set apparent No Observable Effect Levels, and the doses assumed by the 

Risk Assessments when setting risk categories, are precautionary in nature. Additionally, the BLM uses buffers 

and other Standard Operating Procedures and PEIS Mitigation Measures that often exceed label requirements. 

When using tank mixes, risks are considered additive, not proportionate to the amount of each herbicide in the 

mix (as a precaution against unforeseen synergistic effects). Special Status species’ risk categories were based, 

generally, on an assumption they are ten times more susceptible than non-Special Status species. These and other 

factors are part of the precautionary approach used with BLM herbicide applications. 

115. Comment: Synergistic effects of multiple herbicides and tank mixes have not been adequately analyzed. In 

addition, what is meant by the statement, “BLM generally does not tank mix diquat, fluridone, and tebuthiuron?”
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Response: BLM assessed commonly used tank mixes in the Ecological Risk Assessments by adding, not 

proportioning, risk quotients for each component in part to allow for unforeseen synergistic effects. Like results 

for separate active ingredients, results varied from no risk to elevated risk to wildlife, and aquatic and terrestrial 

plants. PEIS Mitigation Measures apply to components in tank mixes as well as single active ingredients. 

Numerous tank mixes are addressed in the Risk Assessments and results suggest some synergistic effects occur 

with some mixes, but that the risk increase is too small to change the risk categories.

Tank Mix Risk Quotient Risk Assessment appendices (Appendix 8) were not prepared for diquat, fluridone, and 

tebuthiuron because the BLM generally does not use these in tank mixes.

116. Comment: 2,4-D: 1) is persistent in streams, rivers, and wells; 2) residue has been found by the CDC in 

25% of Americans; 3) is found in 60% of air samples; and, 4) involved in many incidents.

Response: According to the EPA’s 2005 Reregistration Eligibility Decision Document: 1) The degradation 

of 2,4-D was rapid (half-life= 6.2 days) in aerobic mineral soils. The half-life of 2,4-D in aerobic aquatic 

environments was 15 days. Monitoring data considered in the EPA’s assessment were the USGS National 

Water Quality Assessment Program (NAWQA) groundwater and surface water database, USGS/EPA reservoir 

monitoring database, National Drinking Water Contaminant Occurrence Database (NCOD), and EPA’s Storage 

and Retrieval environmental data system (STORET). Review of these databases was conducted to provide peak 

and median concentrations. Additionally, the quality of data was evaluated for targeting pesticide use areas, 

detection limits, and analytical recoveries. The monitoring data indicate that 2,4-D is detected in groundwater 

and surface water. In addition, 2,4-D is detected in finished drinking water. Maximum concentrations of 2,4-D 

in surface source water and ambient groundwater are 58 ug/L and 14.8 ug/L, respectively. The median 2,4-D 

concentration of 1.18 ug/L was derived from finished water samples in the NCOD database. The highest time 

weighted annual mean (TWAM) concentration was 1.45 ug/L from the NAWQA database containing non-targeted 

data reflecting pesticide concentrations in flowing water as opposed to more stationary bodies of water such as 

ponds, lakes, and reservoirs. 2) BLM could find no published information on this part of the comment. 3) BLM 

could find no find no published information on this part of the comment. 4) Drift is a concern for all herbicide 

spray formulations. Label instructions and PEIS Mitigation Measures are intended to minimize drift. Typical 

application rates showed no risk to terrestrial plants and most aquatic plants. Appendix 13 provides additional 

information specifically about 2,4-D.

117. Comment: The EIS does not reveal that 2,4-D is linked with bladder cancer and testicular problems in dogs.

Response: The EPA Reregistration Eligibility Decision document for 2,4-D does not mention any types of 

cancers or testicular effects in canines (EPA 2005a). The Reregistration Eligibility Decision process is described 

in Appendix 13. Health Canada’s 2,4-D reregistration announcement addressed the cancer question as follows:

Based on re-examination of the data, various scientists and workgroups have concluded that there is no 

relationship between 2,4-D use and canine malignant lymphoma (CML). Although a 1991 article by the 

National Cancer Institute (NCI) indicated a link between dogs with CML and dog-owners that applied 2,4-

D to their lawn, a 1991-1992 independent panel concluded that the NCI study design was severely flawed 

and, in fact, did not show an association between CML and 2,4-D use. In 1999, scientists at Michigan State 

University re-examined the NCI data and also concluded that there was no relationship between 2,4-D use and 

CML (Health Canada 2009).

118. Comment: According to the Journal of Pesticide Reform, glyphosate: 1) is carcinogenic to humans causing 

non-Hodgkin’s lymphoma, miscarriages, causes reduction of male reproductive capacity; 2) affects plants that 

birds use; 3) affects fish immune systems, causes genetic damage to amphibians; 4) is persistent into the fall 

harvest season; and, 5) has been found in streams in King County (JPR 2004).
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Final Environmental Impact Statement: Appendix 10

Response: 1) The BLM has reviewed Hardell (1999), which was cited in this journal article; the authors do 

not show glyphosate causes Non-Hodgkin’s lymphoma (NHL), nor was the sample size sufficient to report 

a significant association. Recent work by De Roos et al. (2005) with a larger sample size and improved 

epidemiologic techniques failed to show any link with NHL, all cancers or cancers by target organ, with the 

exception of a “suggested” association with multiple myeloma (although sample size is again small). Neither 

the EPA, nor the consensus of the scientific community conclude glyphosate is carcinogenic and the EPA 

Reregistration Eligibility Decision for Glyphosate (EPA 1993) does not mention any form of cancer or male 

reproductive effect. The glyphosate Risk Assessment discusses the referenced miscarriages documents and finds 

a) that the 95 percent confidence interval included 1.0 (no effect), and b) that the apparent effect evaporated when 

the data was correlated with the known maternal age risk factor. 

2) Any herbicide will affect plants for which it is designed to kill, including plants that birds use for forage; 

however, much of the Proposed Action (Alternative 4) is targeted at invasive plants that would not be essential to 

native bird species. 

3) Glyphosate formulations with adjuvant POEA have been found toxic to fish and amphibians, however 

glyphosate minus POEA is of much lower toxicity. BLM will restrict use of POEA near aquatic habitats as a 

PEIS Mitigation Measure. 

4) Glyphosate is moderately persistent in soil and has low potential to leach to groundwater (see the Soil

Resources and Water Resources sections in Chapter 4). The citation’s “into the fall harvest season” indicates the 

study is from agriculture use, which is far different from the uses proposed by the BLM. 

5) It is not surprising glyphosate would be found in urban streams in and around Seattle; glyphosate is widely 

used and readily available at home and garden centers.

119. Comment: A Human Health Risk Assessment should have been completed for Overdrive 

(diflufenzopyr + dicamba).

Response: Human Health Risk Assessments were done for both diflufenzopyr and for dicamba (dicamba is 

proposed specifically to be used in combination with diflufenzopyr). The combination of these herbicides in a 

tank mix or commercial product would result in an additive impact to human health (hazard index), depending on 

the concentration and application rate of each ingredient, thus a specific Human Health Risk Assessment for the 

combination is not necessary. The mixture of the two ingredients changes the risk to vegetation compared to each 

used separately, thus an Ecological Risk Assessment was prepared for the combination.

120. Comment: The EPA did not accept staff recommendations that picloram registration not be continued. In 

addition, according to the Journal of Pesticide Reform of Spring, 1998: 1) picloram causes damage to internal 

organs and is contaminated with hexachlorobenzene, which causes cancer of internal organs; 2) picloram is toxic 

to fish, persistent, and mobile in soil; and, 3) runoff has damaged crops (JPR 1998)

Response: The BLM cannot address internal EPA (deliberative) communications. Picloram is still registered 

by the EPA. 1) Picloram is rated by the EPA as being only slightly toxic to humans via ingestion. Picloram is 

contaminated with <100 ppm hexachlorobenzene (HCB). The EPA’s 1995 Reregistration Eligibility Decision Fact 

Sheet for picloram rated the carcinogenic risk from the trace contaminant HCB in picloram to the general public as 

being negligible and the risk for workers mixing picloram as “not-unacceptable,” (see detail in the Human Health 

and Safety section in Chapter 4). 2) Picloram is moderately persistent and mobile in soil (see the Soil Resources

section in Chapter 4). The Risk Assessments show it is highly toxic to susceptible fish under a spill scenario, and 
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low to non-toxic under all other scenarios (“Risk Categories” tables at the end of Chapter 3). 3) Any herbicide runoff 

has potential to damage non-target vegetation. Standard Operating Procedures for application and PEIS Mitigation 

Measures (including buffer distances) are intended to prevent such occurrences. The risks described here are 

acknowledged in the Risk Assessment and reflected in the risk categories and use recommendations.

121. Comment: According to the Risk Assessments, sulfometuron methyl causes various health effects, has been 

found in surface waters, persists in soils, drift has caused crop damage, and it causes cancer and developmental toxicity.

Response: Sulfometuron methyl was identified in the EIS as having moderate potential for leaching, is 

moderately persistent in soil, and is rarely found in surface water (see the “Herbicide Information” table near 

the beginning of Chapter 3 and the Soil Resources and Water Resources sections in Chapter 4). The EPA 

Reregistration Eligibility Decision document for Sulfometuron Methyl found no credible information that 

sulfometuron methyl causes cancer or developmental toxicity (EPA 2008b). The Risk Assessment says “The EPA 

(2003b) states that the carcinogenicity of sulfometuron methyl is not yet evaluated. However, no carcinogenic 

effects have been detected in either rats or mice exposed to sulfometuron methyl (EPA 1990 as cited in Extoxnet 

1996b). Therefore, it is reasonable to assume that sulfometuron methyl would not be classified as a likely 

carcinogen” (ENSR 2005j). A crop damage incident is described in the EIS. Standard Operating Procedures and 

PEIS Mitigation Measures preclude similar (aerial) applications.

122. Comment: The Human Health Risk Assessments used for bromacil, diuron, and tebuthiuron were 

completed in 1991. Information that is more current is available, and should have been considered in the EIS.

Response: As noted in the Risk Assessments section in Chapter 3, these Human Health Risk Assessments 

were used in BLM’s 1991 Vegetation Treatment on BLM Lands in Thirteen Western States EIS, and literature 

that is more recent has been examined to ensure that these Risk Assessments remain current. Additional new 

information is published all the time; however, no new information has been found thus far that changes the 

findings in these 1991 Risk Assessments. The BLM completed Risk Assessments for all herbicides where 

literature searches indicated new findings.

Methodology for Assessing Effects

123. Comment: In general, in the EIS, the risks of non-herbicide control are over-stated and the risks of 

herbicide use are downplayed. The EIS discusses the threat of invasive plants to various resources, but fails 

to give equal attention to the numerous threats posed by herbicides to water quality, soils, wildlife, air quality, 

humans, recreation, Wilderness, Special Status species, etc.

Response: The primary focus of the analysis in Chapter 4 and the Risk Assessments regards the use of herbicides 

and their potential to affect on the resources listed in the comment. PEIS Mitigation Measures and Standard 

Operating Procedures limit many of the risks. Non-herbicide methods are also addressed because it is easy to 

forget that substitute non-herbicide methods are not benign. The effects of non-herbicide methods are poorly 

quantified, however, so it is difficult to see how they are “over-stated.” Non-herbicide methods also have standard 

operating procedures and mitigation measures, but they (like herbicides), would still have some risk. Chapter 

3 explains the assumptions that the resource specialists worked from. Chapter 4 explains the environmental 

consequences of the alternatives (including the effects of herbicides, non-herbicide methods, and untreated 

invasive plants). Appendix 2 includes the PEIS Mitigation Measures and Standard Operating Procedures common 

to all alternatives in this EIS for the use of herbicides. Appendix 8 has detailed Risk Assessments for each 

proposed herbicide. All of the assumptions and discussion of the relative risks are presented in detail.
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Final Environmental Impact Statement: Appendix 10

124. Comment: The use of herbicides trades one harm for another. While the EIS correctly states invasive 

plants are upsetting the natural balance, it also acknowledges that human activities have been to blame. Now 

humans propose to introduce herbicides, affecting the balance in ways that may surpass the effects of invasive 

species. The BLM should take a conservative approach until further research conclusively demonstrates that the 

introduction of new herbicides is safe and will not have unintended consequences.

Response: EPA registration, Risk Assessments, and the EIS have taken a hard look at the potential for the 

proposed herbicides to do environmental harm, and information in these documents reasonably demonstrates 

that the herbicides are unlikely to have significant unintended adverse effects when used as proposed. Standard 

Operating Procedures and PEIS Mitigation Measures are designed to virtually eliminate the potential for 

significant adverse effects, and the effects discussions in the resource sections in Chapter 4 assume their 

application. However, as noted near the start of Chapter 4, resource management is uncertain and always will be. 

Not using herbicides is also a management decision with implications (see Reference Analysis). The BLM uses 

herbicides conservatively, following site-specific analysis and appropriate Endangered Species Act consultation.

Chapter 4 – Affected Environment and 

Environmental Consequences

Incomplete and Unavailable Information

125. Comment: Despite stating the CEQ requirements for how to proceed with an EIS with incomplete or 

unavailable information, the EIS section on this does not appear to supply the information required by CEQ points 

3 (a summary of existing credible scientific evidence which is relevant to evaluating the reasonably foreseeable 

significant adverse impacts on the human environment), or 4 (the agency’s evaluation of such impacts based upon 

theoretical approaches or research methods generally accepted in the scientific community).

Response: The Incomplete and Unavailable Information section in Chapter 4 explains how the Risk Assessments 

deal with each of these points. Resultant conservative risk categories are carried into the specific resource effects 

and the Human Health and Safety sections in Chapter 4. Adjuvants and inerts are also discussed in the Risk 

Assessments, and recommendations for avoiding adverse effects are presented. The Final EIS, in Chapter 3 and 

in the Fish section in Chapter 4, includes additional information about adjuvants and inerts. 

126. Comment: The EIS fails to address synergistic effects of multiple herbicides.

Response: The EIS acknowledges that there is a high degree of uncertainty surrounding potential effects from 

multiple complex mixtures and multiple exposures (Incomplete and Unavailable Information early in Chapter 

4). To address concerns over herbicide use the BLM and Forest Service have supplemented the EPA herbicide 

registration information with over 6,000 Pages of Environmental and Human Health Risk Assessments (Appendix 

8). These assessments address the potential for synergistic effects. Where applicable, those risks have been 

noted. For example, the increased potency of 2,4-D tank mixes is addressed. The EIS notes that tank mix risk 

quotients are added, not proportioned, in part to account for the potential for synergistic effects.

127. Comment: The EIS failed to adequately consider the impact of mistakes on water quality, wildlife, and 

human health. Mistakes will happen and herbicides will be applied in places and at times that are not allowed. 

The EIS should not assume that herbicides would always be used according to the label. Humans are fallible. 
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Some people who may apply herbicides on BLM lands may not be able to read and understand what is written 

on the labels. The analysis needs to conduct a Risk Assessment that accounts for the high likelihood of chemical 

accidents and misuse.

Response: The Risk Assessments section in Chapter 3 notes that risk categories were developed for exposures to 

direct spray, surface runoff, wind erosion, and accidental spills through the Risk Assessment process. A summary 

of these risk categories are displayed on the “Risk Categories” tables at the end of Chapter 3, and are used in 

the various resource sections in Chapter 4. The Incomplete and Unavailable Information section notes “Risk 

Assessments test or model a range of plausible scenarios including spills and direct applications on non-target 

organisms, but exposure beyond those modeled is possible,” and goes on to describe a recent example. The 

Accidental Spill or Misapplication section describes various spill scenarios, as well as the acknowledgement that 

misapplications will occur, a likelihood potentially increased when new herbicides are being used for the first 

time. Reducing such incidents is one objective of some of the existing and potential implementation monitoring 

described in Appendix 3. There is no evidence of a human health incident having occurred with a BLM herbicide 

application in Oregon in the past 25 years. 

The potential impacts of spills are specifically addressed in the Native and Other Non-Invasive Vegetation section 

both generally and for specific herbicides; in the Water Resources section where it is specifically addressed in 

both the Direct Application and Leaching sections; in the Wetlands and Riparian Areas section both generally 

and for most of the herbicides specifically; in the Fish section generally and under a specific heading of Water 

Contamination from Accidental Spills, under most of the specific herbicide discussions, and under the discussion 

of each alternative; variously in the Wildlife Resources section; in the Environmental Justice section; and, in 

the Human Health and Safety section. Impacts from misapplications are the same as those for spills (at a much 

smaller scale) or for collateral damage, addressed in all sections.

Accidental applications at the wrong sites, or with the wrong materials, would usually adversely affect the 

treated plants and, potentially, susceptible species that were to be avoided. Other effects would generally be 

as assessed in the analysis since applications would still be at rates specified on the label. Applicators must 

have state licenses, and part of the written test for that license requires reading labels. In cases where direct 

supervision fails, post-project monitoring can find errors. Districts generally already select a certain percentage of 

implemented projects for on-the-ground review, to insure agreements made during the planning (NEPA) process 

were implemented as intended. Appendix 3 in this EIS suggests, under Potential Monitoring, that some minimum 

number of high-profile herbicide projects be selected on each district annually for similar post-project monitoring 

by a group that includes weed control and herbicide experts.

The comment does not suggest why the analysis is not adequate, or identify what additional information would 

make it so.

Cumulative Impacts

128. Comment: The Cumulative Impacts section fails to discuss the cumulative impacts of the herbicides that the 

BLM wants to use at a statewide scale.

Response: This EIS is a programmatic EIS discussing - at the statewide scale - the effects of the BLM’s use 

of herbicides to various resources, including human health, native vegetation, and wildlife. Since the entire 

programmatic analysis is essentially a cumulative effects analysis, miscellaneous information applicable to more 

than one section was presented early in Chapter 4 to help provide context to individual sections, particularly 
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as some of those sections refer to those actions. Some of the ongoing actions described in the Draft EIS in 

the Cumulative Impacts section, however, are not impacts. These have been moved to the Non-BLM Actions 

Potentially Affecting the Use of Herbicides on BLM Lands in Oregon section in Chapter 1.

129. Comment: In the Cumulative Impacts section, the Draft EIS states that the Oregon Department of 

Agriculture’s Pesticide Usage Reporting System 2008 report did not include households. This is not true.

Response: The Oregon Department of Agriculture required businesses to report their pesticide use, but did not 

require households to do the same. However, the 2008 report does include a household component. The Gilmore 

Research Group conducted a Household Pesticide Use Survey in 2008, which asked about 2,000 households in 

Oregon to track their pesticide use. Response and reporting consistency were so poor that the Oregon Department 

of Agriculture did not extrapolate that information out to make any conclusions about other households in the 

State. This has been clarified and further described in the Cumulative Impacts section early in Chapter 4. 

130. Comment: The Draft EIS does not disclose the cumulative impacts of their past spray actions.

Response: A section addressing past spray actions has been added to the Cumulative Impacts section early 

in Chapter 4. 

Being limited to four herbicides has contributed to the spread of invasive plants because of restrictions and/or 

limitations on the plants that can be controlled by these herbicides, and the places that they can be used. Limiting 

the number of herbicides can also contribute to some invasive plants becoming resistant to certain herbicides. 

These issues are discussed in the Noxious Weeds and Other Invasive Plants section. 

131. Comment: Private timber companies are aerially spraying the lands that surround and are intermixed with 

the O&C lands. The BLM is proposing to use herbicides on these checkerboard lands, and thus will double the 

amount of herbicides that are already being sprayed over neighboring children, houses, food, and animals. The 

EIS needs to consider the cumulative impacts of spraying additional herbicides in the same area where private 

industrial timber companies are already spraying thousands of acres.

Response: Timber companies that are using herbicides to grow timber would be using herbicides in a different 

manner, and in greater quantities, than proposed by the BLM. The BLM currently uses herbicides on noxious 

weeds on O&C lands. While the number of herbicides available under the Proposed Action (Alternative 4) 

would increase, and the types of vegetation that could be sprayed would change, the estimated annual pounds 

of herbicides applied west of the Cascades, and the acres sprayed with herbicides rated in the EIS as having a 

moderate or high risk to the environment or human health, would decrease under the Proposed Action (Tables 3-4 

and 2-6). The number of acres sprayed under Alternative 4 (the Proposed Action) would increase, but application 

methods are primarily methods that target distinct vegetation, and PEIS Mitigation Measures and Standard 

Operating Procedures would limit impacts to non-target species. (Aerial spray would not be permitted on BLM 

lands west of the Cascades under Alternative 4.) Therefore, cumulative effects from the Proposed Action on O&C 

lands would be expected to differ little from the No Action Alternative (Alternative 2). It is unknown how much 

herbicide is used on the private portion of checkerboard lands, but the BLM’s contribution to Oregon State totals 

is shown in the Cumulative Impacts section. A public comment letter from industry suggested that better invasive 

plant control on BLM lands, whether because of increased availability of herbicides or incidentally during rightsof-way maintenance, would likely reduce the invasive plant treatments required on industry lands. A subsection 

addressing this potential effect has been added to the Cumulative Impacts section. 

132. Comment: The EIS should note that better control of invasive plants would reduce the need for neighboring 

landowners to use herbicides on their lands.
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Response: Although the Draft EIS noted many times that adjacent non-BLM land resources would benefit from 

better control of BLM weeds, the implication that cross-boundary resources might benefit from a reduced overall 

need to treat non-BLM lands was only touched on in the Draft EIS at one point. In the Native and Other NonInvasive Vegetation section, the Draft EIS noted “Other native ecosystems on BLM lands may also suffer when 

invasive plants spread from BLM lands. Adjacent landowners may control these weeds with less environmentally 

friendly methods or products. Collateral damage may occur near property lines, and landscape-scale values such as 

watershed or wildlife values may be degraded by these well intended treatments, particularly west of the Cascades 

where the checkerboard ownership often means the BLM manages no more than 50 percent of any watershed.”

A subsection addressing this topic has also been added to the Cumulative Impacts section early in Chapter 4.

133. Comment: It is generally believed that rangeland degradation exacerbates populations of grasshoppers and 

Mormon crickets, so as more areas of BLM lands become overrun with cheatgrass, more acres will be sprayed 

with insecticides Moreover, in the past two years, there has been a large increase in lands sprayed for West Nile 

virus. The Draft EIS does not evaluate this co-occurrence, or overlap, of lands likely to be sprayed for weeds and 

with insecticides.

Response: Most insecticide treatments on BLM lands in Oregon are likely to be spatially or temporally separated 

from most herbicide treatments proposed in this EIS, so virtually few organisms except, conceivably, plants, 

would be expected to have active doses of both materials at the same time. Any overlaps of concern should be 

identified in site-specific analyses; ongoing invasive plant treatments would be a consideration during insecticide 

spray planning, in part, because of the widespread use of noxious weed biological controls. Of 157,000 acres of 

Oregon grasshoppers sprayed statewide by the Animal and Plant Health Inspection Service and/or the Oregon 

Department of Agriculture in 2009, about 34,000 acres were on BLM lands. No BLM acres were sprayed for 

Mormon cricket (Brown 2009). 

Cumulative adverse effects to humans or other elements of the environment are most likely when two pesticides 

share a common mechanism of toxicity. That is, they both affect an organism the same way. Cumulative effects 

assessments conducted by the EPA typically begin by grouping pesticides by mechanism of toxicity (EPA 2002). 

Because insecticides and herbicides work so differently, even a concurrent application would be unlikely to result 

in significant additive environmental effects when both products are applied within label limits. Synergism is not 

impossible however; the 2,4-D Risk Assessment reports that 2,4-D induced cytochrome P450 (a natural animal 

enzyme that processes toxins) in the southern armyworm (Spodoptera eridania) and caused synergistic effects on 

insecticide toxicity (Kao et al. 1995). In addition, exposure to 2,4-D caused decreased carbaryl and permethrin 

insecticide toxicity. This discussion has been added to the Cumulative Impacts section. 

134. Comment: The EIS did not adequately consider the proposed increase in the number of proposed wind and 

geothermal energy sites, transmission lines, and gas pipelines that will result in large-scale disturbance, which will 

allow for significant inroads to be made by invasive species, which will prompt the BLM to douse public lands 

with herbicides.

Response: The EIS took into account new energy projects in the State. District experts were asked to estimate 

herbicide use for the next 10-20 years, and were specifically asked to consider current and future developments 

under each administrative site, recreation site, and right-of-way category listed under Alternative 4 in Chapter 2. 

These include geothermal facilities, wind energy facilities, utility distribution, and pipelines.

New permits require mitigation measures and restoration plans for disturbed sites. The analysis for such projects 

follows BLM policy described in Chapter 3 and Appendix 3, that proposals with a moderate or high risk for 
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establishing noxious weeds require follow-up monitoring as well as identification of project actions that need to 

be taken in order to reduce or prevent the spread of noxious weeds. 

135. Comment: The EIS must assess the levels and degree of desertification that have occurred across the 

Oregon EIS area. This is necessary to understand the likelihood of soil erosion, accelerated runoff, and other 

forms of drift, and to understand the amounts of chemicals likely to be applied over time. This is necessary 

to understand the capability and suitability of these lands for livestock grazing, the productivity and carrying 

capacity of these lands for grazing, the current or likely future extent of cheatgrass and other hazardous fuels 

problems linked to desertification and livestock or other degradation, the need for treatments, and the type of 

treatments that may best be applied, the risks associated with treatments, and the likely effectiveness or success 

of any treatments undertaken under the EIS. The effects of alternatives, their ability to meet any objectives, and 

the ability of actions under the EIS to maintain, enhance, or restore habitats and populations of Special Status and 

other important species and native plant communities depend on the current environmental conditions of the lands 

where they would be applied.

Response: As noted in Chapter 1, the underlying need to which the alternatives respond is for more effective 

vegetation control measures to better meet the BLM’s existing noxious weed and other vegetation management 

responsibilities. Actual use of new herbicides made available by the selection of one of the action alternatives 

would be for meeting objectives identified in existing Land and Resource Management Plans, Conservation 

Strategies, Facilities Maintenance Plans, health and safety responsibilities, or other plans and direction. 

Differences in activity levels between alternatives in this EIS are estimates to help quantify the potential for 

adverse effects using herbicides (and to put them in context with other effects), and are not decisions to conduct 

vegetation management activities. The selected alternative would not authorize any activities. 

An understanding of the capability of lands for grazing, or a detailed study of the implications of cheatgrass on 

fire danger or habitat decline, thus, is outside the scope of this analysis and unnecessary for an understanding of 

cumulative adverse effects of the proposed level of herbicide use and the alternatives. The descriptions of the 

biomes early in Chapter 4, and the Affected Environment sections in the specific resource sections (also in Chapter 

4), are adequate to support the analysis of the differences between the alternatives. This is a programmatic EIS; 

the degree to which herbicides might adversely affect described resources are themselves cumulative impacts. 

Further, the activities expected to be conducted with any new herbicides are nearly all aimed at improving 

vegetation conditions and/or restoring native ecosystems, and thus are not expected to significantly contribute 

to adverse effects that may be resulting from other activities on BLM and adjacent lands. Exceptions to this 

generalization include water quality, air quality, and fish effects. The potential for herbicides to affect these 

resources is cumulative to other factors degrading these resources. Such cumulative effects are described in those 

specific sections.

136. Comment: The EIS does not adequately examine the direct, indirect, synergistic, and cumulative effects 

of the use of herbicides in the context of ecological problems associated with continued disturbances such as 

livestock grazing. There is an inadequate assessment of the current environmental setting, including the degree 

of severity of desertification and degradation of watersheds; disturbance across land ownership boundaries; fuels 

treatments; chronic livestock and grazing management impacts; and baseline information on wildlife species 

(including many Special Status and other declining species) focused on habitat loss and fragmentation of habitats 

and populations across native vegetation communities targeted by the EIS for large-scale treatment. There is no 

analysis of the Fundamentals of Rangeland Health (FRH) assessments or current Ecological Site Inventory (ESI) 

that is necessary to provide a baseline of current land condition and thus understanding of risk of weed expansion/

dominance and amount of herbicide use that may be occurring. ESI and other information are necessary to 

understand the current ecological condition and health of the lands, and the adverse effects of livestock grazing 

disturbance on them. Unless the environmental setting in which the herbicide use and continued land use 
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disturbances such as grazing and vegetation treatments would occur are fully revealed and assessed based on 

sound ecological and Best Available Science, the BLM cannot develop a reasonable range of alternatives, nor 

apply adequate analysis of impacts of the Proposed Action (Alternative 4) or alternatives.

Response: As noted in Chapter 1, the underlying need to which the alternatives respond is for more effective 

vegetation control measures to better meet the BLM’s existing noxious weed and other vegetation management 

responsibilities. The alternatives in the EIS are not weed or vegetation management plans, which is a much broader 

topic. Actual use of new herbicides made available by the selection of one of the action alternatives would be for 

meeting objectives identified in existing Land and Resource Management Plans, Conservation Strategies, Facilities 

Maintenance Plans, health and safety responsibilities, grazing allotment management plans, or other plans and 

direction. Differences in activity levels between alternatives are district estimates, made to help quantify the 

potential for adverse and positive effects using herbicides (and to put them in context with other effects). These 

estimates are not decisions to conduct vegetation management activities. Site-specific conditions and applicable 

management direction would be considered at the project scale before actual treatments are authorized.

The inventories and assessments referenced in the comment contributed to the descriptions of the biomes early in 

Chapter 4, and to the Affected Environment subsections in several of the specific resource sections, also in Chapter 

4. Those descriptions are adequate to support the analysis of the environmental effects of the alternatives, and the 

alternatives are set in the context of existing vegetation-related management and activities. The potential effects 

of grazing on climate change or desertification, or even on weed spread, are outside the scope of this EIS and 

more correctly left to Land and Resource Management Planning and allotment and grazing management plans. 

Environmental Setting

137. Comment: There appears to be no information in the Oregon EIS on the current ecological conditions of 

the affected lands with respect to cheatgrass, or mapping and analysis of areas of Oregon public lands that are 

vulnerable to cheatgrass and other weed spread with continued livestock grazing disturbance, etc. The EIS fails to 

provide criteria and alternatives that would “manage” and “treat” areas with small amounts of cheatgrass or that 

are at great risk of its expansion by removing grazing or other intensive disturbances.

Response: Cheatgrass and other annual grasses are identified in the Noxious Weeds and Other Invasive Plants

section in Chapter 4 as an issue on approximately five million acres. These grasses are described as a threat to native 

ecosystems by displacing native plant communities, displacing wildlife habitat communities for species such as 

sage grouse, and increasing fire incidence, which affects sagebrush communities and can create a fire hazard in the 

wildland-urban interface. This information provides a context and basis for the estimates of annual herbicide use 

under each alternative, and helps set the context for the analysis of effects. However, estimated treatment acres are 

for analysis of effects at the programmatic scale, and do not represent plans or commitments of resources.

A complete discussion of the management of cheatgrass, or an examination of land uses and their effects on 

the spread of cheatgrass and other invasive plants, is outside the scope of this analysis. The alternatives simply 

examine the effects of adding additional herbicides to the BLM’s existing vegetation management programs in 

Oregon, with an emphasis on examining the environmental and human health risks at the programmatic scale. 

The resource descriptions in the Biomes, Noxious Weeds and Other Invasive Plants, and various other resource 

sections in Chapter 4 is sufficient to understand the differences in effects between the programmatic alternatives, 

three of which include imazapic and other selective herbicides effective on annual grasses. Consideration of 

various land uses, their sustainability, and their effects on other ecosystem components is more correctly left to the 

Land and Resource Management Planning process required and defined by the FLPMA.
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Site-specific decisions to alter grazing or change other management practices to avoid spreading small populations 

of invasive plants are always an option; stopping weed populations while they are small is a management priority. 

These and other Integrated Vegetation Management actions would remain available under all alternatives. 

Noxious Weeds and Other Invasive Plants

138. Comment: Missing from the EIS is an unbiased examination of the ultimate causes of the asserted epidemic 

of invasive species or the full-range of options to deal with that problem.

Response: A discussion of the spread of invasive plants is included in the Noxious Weeds and Other Invasive 

Plants section, particularly under the subheading Mechanisms of Invasion. The full range of available control 

treatments is discussed, for background purposes, in Chapter 3 under Assumptions and Information about 

Treatment Acres. A consideration of the weed spread implications of various resource management practices, 

and the adoption of noxious weed control as a management emphasis, is included in the Land and Resource 

Management Plan for each BLM district (see Appendix 6). Reconsideration of management plan decisions is 

outside the scope of this EIS; the EIS proposes simply to make additional herbicides available to the BLM’s 

existing vegetation management programs.

139. Comment: Weeds spread geometrically and logarithmically, not linearly. The longer the delay to treat 

weeds, the higher the costs to resources, as well as operation and maintenance costs.

Response: The Invasion Lag Curve in the Noxious Weeds and Other Invasive Plants section shows a geometric 

relationship for individual weed infestations. Costs are higher (or impractical) if weeds spread before control is 

attempted. Thus, as the Noxious Weeds and Other Invasive Plants section in Chapter 4 points out, control efforts 

are generally focused on new weeds, new populations, and edges of larger populations. However, the noxious 

weeds in Oregon are now at various positions on the Lag Curve. The twelve percent weed spread rate estimate 

described in this section averages all of the noxious weeds on BLM lands in Oregon, and all populations, and 

provides a representation of the problem and how the Alternatives could make a difference in the long-term (15 

years).

140. Comment: There is no basis offered for the conclusion that two-thirds of the noxious weeds cannot be 

controlled with non-herbicide methods. Table A7-1 lists them, but there is no explanation for the basis. In 

addition, Table A7-1 makes it clear that Alternative 4 (the Proposed Action) and Alternative 5 are not necessary.

Response: The Alternatives 2 through 5 species that cannot be effectively controlled with non-herbicide methods 

listed on Table A7-1 are those receiving a “no” in the “Non-herbicide methods effective” column on Table A9-

2, but there was little documentation on either table in the Draft EIS indicating the basis for those decisions. 

They are based on the experience of district weed coordinators and various references, primarily the Pacific 

Northwest Weed Management Handbook (OSU 2009); the Weed Control Methods Handbook (Tu et al. 2001), 

Weeds of California and other Western States (DiTomaso and Healy 2007); Biology and Management of Noxious 

Rangeland Weeds (Sheley and Petroff 1999); and The Nature Conservancy Element Stewardship Abstracts (TNC 

2009). A footnote has been added to Tables A7-1 and A9-2 to this effect.

Alternatives 4 and 5 add additional herbicides and objectives for controlling native vegetation to meet 

maintenance and safety objectives around developments, to conduct certain habitat improvement projects, and (in 

the case of Alternative 5) meet other objectives. The noxious weed list on Table A7-1 has little bearing on these 

Alternative 4 (the Proposed Action) and Alternative 5 objectives.
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141. Comment: Many of the “weeds” you propose to target have medicinal values and are of great value.

Response: In the discussion of non-native plants early in the Noxious Weeds and Other Invasive Plants section, 

“medicinal” has been added to the list of reasons why plants may have been moved into Oregon. There is no 

doubt many of the State listed noxious weeds and other invasive plants continue to have value at some level; 

that is the reason many of these plants were introduced into Oregon in the first place. Noxious weeds, however, 

are those that are too successful, have departed from their limited intended purpose, or were successful but 

management objectives have changed. Invasive plant control efforts could make some medicinally important 

plants more difficult to find at the local scale. BLM control efforts are not likely, however, to make medicinally 

important plants unavailable to those who need them. However, State law makes it illegal to own or sell Statelisted noxious weeds, so the BLM refrains from issuing collection permits for them, regardless of their “value” or 

intended uses.

142. Comment: The EIS fails to consider a reasonable degree of tolerance. With invasive plants having become 

dominant across so much of the landscape, and the economy in decline, it is preposterous to presume an ability to 

gain control over the invasive situation. Eradication is not a sane strategy, and, generally, we have more important 

battles to wager than the one on invasives plants. Invasive weed control must be carefully targeted to protect the 

most threatened native organisms at least cost.

Response: Most of this comment reflects BLM’s current weed control strategies. The BLM coordinates weed 

control efforts with the Oregon Department of Agriculture, as well as with local weed control districts and 

neighboring landowners and managers. None of these landowners or agencies have the resources to remove all 

invasive plants. Therefore the State has classified their 120 listed noxious weeds into two categories based on 

priority for control, with that priority being influenced heavily by how widely spread a weed already is. “A” list 

weeds are those of known economic importance which occurs in small enough infestations to make eradication 

or containment possible; or is not known to occur, but its presence in neighboring states make future occurrence 

in Oregon seem imminent. Management direction for these is normally eradication or intensive control when and 

where found. Remaining weeds are on the “B” list (at least locally common). Species from either list may also 

be assigned to a “T” list (special management plan needed). The assignments for each weed, and the description 

of the three categories, are shown on Table A7-1. BLM treatments may not follow the State priorities exactly 

because of local resource protection issues. Protecting a Special Status species’ habitat or uninfested watershed, 

for example, may be a priority regardless of how well established the weed is elsewhere in the State or what 

list it is on. With noxious weeds spreading on BLM lands at an estimated 144,000 acres per year, some degree 

of tolerance is required. Biological controls are being used (when available and after Oregon Department of 

Agriculture approval) to reduce the impact of many of the most widespread weeds.

143. Comment: The EIS missed an opportunity to conduct a real analysis of the risks of weed spread and the 

futility of treatments, if livestock grazing continues at or near current levels.

Response: As noted in this appendix under Alternatives Eliminated From Detailed Study, a reconsideration of 

grazing capacity is outside the scope of this EIS and is more correctly left to planning implementing the FLPMA, 

Taylor Grazing Act, and other direction.

144. Comment: The invasive plant “problem” is an invention of the herbicide industry in order to sell 

more herbicides.

Response: Economic and ecological effects have been documented by numerous experts. Independent estimates 

of financial losses exceed $100 million for single species within single states (e.g. Radke and Davis 2000; the 
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Global Invasive Species Information Network; and others). Global impacts from invasive species including 

invasive plants have been estimated to be five percent of the world’s gross national product (Simpson 2004). The 

International Union for the Conservation of Nature notes that a significant proportion of species now considered 

extinct were driven to extinction by invasive species (IUCN 2008). The United States Invasive Species Council 

has a budget of $1.2 billion and is chaired by the Secretaries of Commerce, Interior, and Agriculture (NISC 2006). 

The Council estimates invasive species (including plants) cost the U.S. Economy over $100 billion per year, 

and they are the second biggest cause (after habitat loss) for species becoming Federally Listed as Threatened or 

Endangered. There are also several Federal and State laws requiring the BLM to actively prevent and suppress 

noxious weeds (see Background section in Chapter 1).

145. Comment: The EIS should consider the information in the book Invasion Biology: Critique of a 

Pseudoscience, by David Theodoropoulos (2003).

Response: Information from the book Invasion Biology: Critique of a Pseudoscience was considered in the 

development of this EIS. The book states that not all non-native species are bad; species move from place to place 

and have historically done so; native ecosystems are not inherently weak and prone to invasion; and, non-native 

species are not inherently competitively inherently superior to the natives. Analysis in this EIS does not contradict 

these points. However, the book also refutes science that shows that invasion is a major threat to Endangered 

species; evidence that economic costs of invasions are in the hundreds of billions of dollars; and, asserts there are 

connections between invasion biology and the pesticide industry. These assertions are contrary to the majority of 

invasive plant research examined in the creation of this EIS and/or are beyond the scope of this analysis. 

Native and Other Non-Invasive Vegetation

146. Comment: Please explain why desirable non-native plants are considered “native vegetation.”

Response: This definition of native vegetation has been removed, and the phrase “native and other non-invasive 

vegetation” has been used in the text where such a distinction is needed. Lumping desirable non-native plants 

with native plants was intended to be shorthand for a class of vegetation that might only be treated with herbicides 

in Alternative 4 (the Proposed Action) and Alternative 5, but the combination not only caused confusion, but also 

conflicted with referenced policy to use only “native species” in restoration treatments.

147. Comment: The EIS views the expansion of native western juniper as a problem, when it is really just a 

natural and expected result of climate change, livestock grazing, and altered fire regimes. The BLM should not 

expect to change the course of western juniper expansion until these other factors are reversed. Western juniper 

can live to be 1600 years old, and provides important wildlife habitat (e.g. ash-throated flycatcher, black-throated 

gray warbler, roosting cavities for bats, and nesting for raptors) and forest watershed function. Control of western 

juniper is resulting in hotter, drier sites more prone to weed invasion. 

Response: Western juniper is an important source of shelter and food for a variety of animal species. It is 

a native species in Oregon and performs important ecological functions. However, for a variety of reasons 

(including a reduction of fire frequency), there has been a several fold expansion of western juniper. This 

expansion adversely affects other native shrubs, forbs, bunchgrasses and habitats of the sagebrush steppe, and 

threatens the Eastern Forest Biome ponderosa pine forests at lower elevations. Western juniper invasion results in 

reduced shrub abundance and reduced ground water, and contributes to loss of riparian plant species (Bedell et al. 

1993). The BLM is currently controlling some western juniper by using chaining, mowing, prescribed fire, and 

cutting and burning. If herbicides were available, they would be used primarily where western juniper a few feet 

high can be controlled with spot treatments. 
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However, decisions about how much western juniper to control and where, are outside of the scope of this EIS. 

The EIS attempts to describe why and how herbicides would be used under Alternative 4 (the Proposed Action) 

and 5 only so that likely herbicide uses can be understood in a multi-resource analysis context, and a reasonable 

cumulative effects analysis of the use of herbicides can be prepared. District personnel familiar with local land 

management plans and existing vegetation management priorities made the estimates. A complete discussion of 

the reasons for vegetation management including the control of certain western juniper in certain areas is outside 

the scope of this analysis and would be duplicative of district-level management plans, Conservation Strategies, 

and other analyses. 

148. Comment: There is inadequate analysis of herbicide impact to Federally Listed and other Special Status 

plants growing on roadsides. 

Response: Proposed roadside herbicide use would require a site-specific analysis that includes a review by the 

area botanist, wildlife biologist, and fish biologist per BLM’s Special Status Species Program policy as discussed in 

the subsection Endangered, Threatened and other Special Status Plant Species in Chapter 4. Where these species 

are known or their habitat is suspected, the resource specialists would conduct surveys and/or prescribe appropriate 

mitigation measures to avoid impact to Special Status species. The wording in the EIS has been edited to indicate 

these surveys and resultant protection measures would likely eliminate most of the risks to these species.

149. Comment: The EIS suggests habitat improvement under Alternative 4 (the Proposed Action) and 

Alternative 5 could have risk to non-target plants. The EIS does not discuss whether inadvertent spraying of 

Special Status species, contamination of their food or prey, and accidental spills would harm these species. 

Simply listing these species in an appendix is not adequate.

Response: Potential effects to Special Status wildlife or fish species, and to the soils and waters within 

their habitats, are addressed in those respective sections in Chapter 4. Those discussions reference the “Risk 

Categories” tables at the end of Chapter 3, which include risk categories for sensitive/susceptible species. The 

potential to adversely affect the Federally Listed or other Special Status species for which each Conservation 

Strategy is written would also be considered in the site-specific analysis for the project. These analyses 

would normally be done on a site-by-site basis; habitat improvement projects would not be included in each 

district’s weed management Environmental Assessment. Conservation Measures for Federally Listed species, 

Standard Operating Procedures, PEIS Mitigation Measures, and BLM policies for Special Status species would 

substantially reduce the likelihood that treatments would directly affect these species. 

The EIS statement that habitat improvement treatments “could have risk to non-target plants [although] 

applications would be specifically designed to improve overall habitat conditions” is in reference to non-Special 

Status native plants making up the habitat for Special Status fish or wildlife. Some collateral damage might be 

acceptable in the interest of long-term habitat improvement. However, if the Special Status species in question 

were a plant, herbicides would likely not be used nearby if any damage were anticipated 

150. Comment: The EIS should address whether or not plants affected by herbicides could grow back mutated, 

and whether this would harm wildlife.

Response: Herbicide effects on plants vary based on the type of herbicide. In general, plants affected by 

herbicides will exhibit symptoms of abnormal growth or dieback of tissues. Symptoms appear hours to weeks 

following exposure and include wilt, yellowing, loss of pigment, dieback, twisted leaves or stems and malformed 

leaves. Herbicide injury may also result in reduced flowering and seed production. There is no reason to believe 

future generations would be mutated, or if they were, that such mutations would affect wildlife.
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151. Comment: The EIS should explain how many non-target species would be eliminated by herbicide use.

Response: No non-target species would be eliminated by herbicide use. While some individuals may be harmed, 

the impact to a particular species would not threaten its continued existence. On all herbicide treatments, sitespecific analysis would consider various local factors and apply Standard Operating Procedures and PEIS Mitigation 

Measures that would minimize impact to non-targets. Special Status species would get additional protections.

152. Comment: The EIS should more thoroughly consider the special concerns of the Sulfonylurea (SU) 

herbicides. These herbicides are capable of interfering with reproduction of plants even at exposure levels that 

show no damage to plants. A rare or susceptible native annual plant may be unintentionally damaged if is unable 

to properly reproduce due to exposure to a SU. A lawsuit resulted from a BLM application of sulfometuron 

methyl in Idaho over damage to nearby crops

Response: The sulfonylureas (chlorsulfuron, metsulfuron methyl, and sulfometuron methyl) and the similarly 

acting imidazolinones (imazapic and imazapyr) work by inhibiting the plant enzyme acetolactate synthase (ALS). 

An alternative eliminating the use of these five ALS inhibiting herbicides was suggested during scoping and 

was eliminated from detailed study (Chapter 2). The PEIS analyzed the special concerns associated with ALS 

inhibitors and considered an alternative without them. They have been retained in the alternatives in part because 

they are potentially less harmful to plants, animals, and humans than other herbicide active ingredients proposed, 

and some of the most problematic weeds are best controlled with them. ALS-specific Standard Operating 

Procedures were designed to prevent adverse effects from these herbicides outside the area of application. 

Additional information about the potential for these herbicides to affect non-target plants, including Special Status 

species, has been added to Chapter 4 in the Final EIS. 

The sulfometuron methyl crop damage incident is discussed under Spills in the Cumulative Impacts section 

in Chapter 4. Standard Operating Procedures now preclude BLM application of this herbicide aerially. In 

November 2008, the EPA announced that its sulfometuron methyl Reregistration Eligibility Decision was 

available for review and comment. In the Reregistration Eligibility Decision, the EPA proposes to prohibit 

application of sulfometuron methyl in counties with an annual rainfall of less than 10 inches and the use on 

powdery dry soil or light sandy soil when it is predicted that there is less than a 60 percent chance of rainfall 

within 48 hours. A final decision from the EPA has not been issued. Information about this EPA action is 

included in the Final EIS near the end of Chapter 1. 

153. Comment: The EIS should address the potential for herbicides to drift onto adjacent organic farmlands.

Response: Although the various resource sections in Chapter 4 are intended to discuss effects of BLM actions 

across ownership boundaries, and site-specific analyses would consider potential effects to adjacent lands, the 

Draft EIS did not specifically identify adjacent and/or ultra- susceptible plants on adjacent private lands. A 

discussion of this risk has been added to the Native and Other Non-Invasive Vegetation section in Chapter 4. 

In addition to site-specific analysis and ensuring herbicide labels are followed, existing Standard Operating 

Procedures help protect adjacent land uses by requiring the use of drift prevention measures such as no spraying 

when wind is above 10 miles per hour or precipitation is imminent; use of large herbicide droplets and drift 

reduction agents where appropriate; use of low volatile formulations; use of low pressure equipment; use of 

herbicide free buffer strips where appropriate; and notification of adjacent landowners. When aerial application 

is considered, spraying near agricultural lands is limited; application can only occur when wind speed is below 

6 mph; application is avoided during periods of adverse weather conditions (snow or rain imminent, fog or air 

turbulence); and, height and speed of application are limited by type of aircraft.
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154. Comment: The EIS should consider the effects of herbicides to wild edible mushrooms (e.g. chanterelles, 

matsutakes, and porcinis) as a commercial resource and not just in the Environmental Justice section.

Response: The Native and Other Non-Invasive Vegetation section in Chapter 4 reports on the findings from the 

few studies found pertaining to herbicide impact on fungi. In laboratory tests at herbicide levels much higher 

than would occur in actual use, growth of fungi was inhibited. In studies using rates similar to amounts used in 

vegetation treatments, fungi seem relatively unaffected by herbicides (Busse et al. 2003, Houston et al. 1998). No 

studies were found regarding these specific ectomychorrhizal species. The risk of herbicide contamination of wild 

edible mushrooms of the forest is expected to be limited because most herbicide applications would be directed 

treatments on invasive plant infestations, and in rights-of–ways, rather than within healthy forests where these 

conifer root-dependent species are found.

155. Comment: The EIS needs to recognize some plants on the target list might also be collected for human use 

as medicinal plants.

Response: The Risk Assessments evaluated human subsistence populations (Native American) who gather and 

use large amounts of range and forest products and generally found no risk (see “Risk Categories” tables at the 

end of Chapter 3). When herbicides are used, the site of spraying would be posted to inform the public that an 

herbicide has been used in the area. If medicinal plants are noxious weeds (see Table A7-1), Oregon law does 

not permit their sale, purchase, propagation, or transport. The BLM does not issue permits for the collection of 

noxious weeds such as milk thistle and St. John’s wort, even if they have medicinal uses. 

156. Comment: The EIS says herbicides are designed to kill plants, so they will kill non-target plants if they 

contact them. The EIS should discuss the effects to rare plants and fungi from the increased use of glyphosate and 

imazapyr to treat Sudden Oak Death in Curry County.

Response: The addition of herbicides to existing treatments is not expected to have additional impact on rare 

plant populations. Glyphosate would be used to target individual tanoak trees by direct application to the 

cambium of tanoak or backpack spray to re-sprouting foliage. The risk for offsite movement of this herbicide 

from these treatments is very low. Risk from imazapic would be higher but would also be mitigated by Standard 

Operating Procedures, PEIS Mitigation Measures, and (for Federally Listed species) Conservation Measures. 

Chapter 4 discusses the risks of these herbicides to non-target plants. Currently there are no Special Status or 

Survey and Manage plants known in the Sudden Oak Death control area. Additionally, proposals for herbicide 

use are subject to site-specific analysis. At that time, pre-project clearances would determine the presence of 

Special Status species and their habitat. When Special Status species are present, mitigation measures are added 

to conserve and or recover Federally Listed species, or to reduce or eliminate threats to proposed or Bureau 

Sensitive species. 

157. Comment: Although the EIS emphasizes targeting noxious weeds, the door is left open for any type of use 

the BLM feels is convenient or necessary.

Response: All of the action alternatives would target invasive plants, a slightly larger category of non-natives 

than State listed noxious weeds. They would also target native vegetation as needed to control pests and diseases 

in State-identified control areas (the Sudden Oak Death control area being the only current example). Alternative 

4 (the Proposed Action) would also target native vegetation in very specific areas for very specific objectives – 

safety and maintenance treatments around developments and for achieving habitat goals specified in Conservation 

Strategies for Federally Listed and other Special Status species. Alternative 5 would indeed permit the use of 

herbicides for any vegetation management except livestock forage and timber production. In all these cases, 
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Final Environmental Impact Statement: Appendix 10

however, the estimated acres included in the analysis are an important indicator of what the BLM might “feel is 

convenient or necessary.” For example, 5,000 acres per year have been estimated for Alternative 5 objectives. All 

but 200 acres of this is east of the Cascades, and most would be for additional habitat improvement projects. In 

addition, fuels treatment would be allowed under Alternative 5 but “is unlikely to occur” (Fire and Fuels, Chapter 

4). There are 250 acres per year estimated for Sudden Oak Death control, 9,300 estimated for rights-of-way, 

administrative sites, and recreation sites (much of which would be used by permit holders and cooperators), and 

5,700 estimated for habitat improvement under Alternative 4 (the Proposed Action). While these are estimates 

for analysis, not absolute caps, they nevertheless are de facto reasonable representations of the level and type of 

treatments intended by the provisions of each alternative.

158. Comment: The effects of herbicide use on rights-of-way and administrative sites have not been adequately 

addressed. What native plants and wildlife would be hurt, and to what extent?

Response: Currently mowing, cutting, and chipping are the primary methods of control of vegetation 

encroaching on roads, utility corridors, and administrative sites. Some of these treatments could be replaced 

with herbicides. Any native plants occurring within the normal clearing limits of those sites might be damaged 

or killed. On utility corridors, vegetation may be removed or managed at a height that does not interfere with 

power or pipelines. Typically, tall trees would be removed and grasses, forbs, and shrubs would be encouraged. 

Trees that resprout after cutting like alder and maple would be the primary target for herbicides. On some 

administrative sites or rights-of-way, all vegetation is removed, especially if it represents an unacceptable fire 

hazard. The risks of collateral damage to off-site plants are addressed in the Native and Other Non-Invasive 

Vegetation section, and risks that herbicides on plants would be ingested by wildlife are discussed in the Wildlife 

Resources section. 

159. Comment: The EIS does not explain what native vegetation would be targeted for “habitat improvement.” 

What native species would benefit? Is this just a disguise for livestock forage increases?

Response: Habitat improvements under Alternative 4 (the Proposed Action) could treat any native or non-native 

vegetation to achieve habitat goals specified in (usually interagency) Conservation Strategies for Federally Listed 

or other Special Status species. An example might be sagebrush thinning to improve habitat for sage grouse, 

if called for in an established Conservation Strategy document. Under Alternative 5, “habitat improvement” is 

a broader term that could include habitat for fish, wildlife, and plants. An example might be reducing western 

juniper to improve water availability for native plants such as aspen, wildlife such as mule deer, and aquatic 

species. Identification of specific vegetation to be controlled or favored would depend upon the objectives of the 

particular project, and be subject to site-specific analysis. All of the alternatives in this EIS exclude herbicide use 

specifically for livestock forage production.

Pests and Diseases (Sudden Oak Death)

160. Comment: The Comparison of Effects By Alternative section of Chapter 2 states, “There are essentially no 

negative environmental [effects] associated with the 250 acres per year of herbicide applications expected to occur 

under Alternatives 3-5 for Sudden Oak Death.” Maybe this statement reflects some kind of unstated weighting 

of impacts, but this is not appropriate NEPA analysis. Both the beneficial and adverse impacts must be fully 

disclosed and weighted in the open daylight of public discourse.

Response: This summary statement was indeed too encompassing. It would be more correct to say that the use 

of herbicides to control pest and disease spread represents less than one percent of the total herbicide use proposed 
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under the action alternatives, and no significant adverse impacts specifically attributable to Sudden Oak Death 

related herbicide applications are discernable in this programmatic EIS. The text was removed from Chapter 2 

when the Comparison of the Effects of the Alternatives section was changed to be a comparison table. 

The statement did not intend to suggest there might not be adverse effects requiring mitigation, or conceivably an 

EIS, at the project-specific scale. This EIS focuses on cumulative effects of herbicide application statewide and 

does not authorize any treatments. Use of herbicides on BLM lands to help control Sudden Oak Death would be 

examined in a project-specific Environmental Assessment or EIS. 

161. Comment: The initial control area for Sudden Oak Death was 9 square miles in 2001, and 160 square miles 

in 2008. The EIS indicates that if the infestation continues to spread, these [250 acres of tanoak treatments per 

year] would be expected to increase. The EIS does not establish a threshold to trigger reconsideration of the scale, 

methods, or species to be treated as the spatial scale and intensity of Sudden Oak Death treatments expands.

Response: The EIS estimates the herbicide use that would result from adoption of one of the alternatives, 

and examines the cumulative effect of that use at the programmatic scale. The acres are estimates for analysis 

purposes, and no treatments would be authorized by the Record of Decision. When actual treatments exceed 

or differ from those analyzed in programmatic NEPA documents in potentially significant ways, the BLM 

examines the adequacy of existing NEPA analysis. The examination primarily considers the likelihood of having 

a significant level of effects not identified and considered in the original Record of Decision. A doubling of the 

acres treated for Sudden Oak Death, but not exceeding the total glyphosate use west of the Cascades examined 

is the EIS (for example), could still fall within the programmatic effects analyzed in this EIS. Actual treatment 

decisions would be made with site-specific analyses that would tier, in whole or in part, to this EIS. Those 

site-specific analyses themselves would consider the continued applicability of the EIS analysis. Finally, actual 

Sudden Oak Death control is examined with site-specific analysis. If Sudden Oak Death control work expands 

significantly, a separate EIS examining all Sudden Oak Death control activities by Federal Agencies might be 

needed, even if herbicide use remains within the estimates of this EIS. In either case, a decision to use herbicides 

on oaks or other species would be looked at in one of those analyses. This EIS does not examine the Sudden 

Oak Death control program, but only examines the cumulative effects of the herbicide portion of that and other 

vegetation management programs.

162. Comment: If the Sudden Oak Death outbreak remains small, it probably can and should be dealt with 

using non-chemical methods. If the Sudden Oak Death outbreak greatly expands, then the effects of largescale “scorched-earth” vegetation treatments may become very significant especially if it is accomplished 

with chemicals. The Pests and Diseases section of the EIS says, “If the infestation continues to spread, these 

[treatment] acres would be expected to increase.” There is a point at which the treatment of the disease may 

be worse than the disease itself. The EIS does not establish adequate safeguards or thresholds to trigger 

reconsideration of the scale and methods of treatment as the spatial scale and intensity of Sudden Oak Death 

treatments expand.

Response: The effects of managing Sudden Oak Death without the use of herbicides on BLM lands are 

described under Alternative 2 (No Action) and the Reference Analysis; the infestation continues to spread and the 

suboptimal tanoak control on BLM lands is believed to be contributing to that spread. Regarding a maximum 

level of treatments, effects in the EIS are based on estimates of average annual acres to be treated. These are not 

guaranteed minimums or maximums; the acres are only estimates for analysis purposes. If future use significantly 

exceeds estimates at the programmatic scale, a review of NEPA adequacy would determine if the EIS still applies. 

Since Sudden Oak Death control would be subject to site-specific analysis, the adequacy question relative to this 

EIS might be limited to the continued adequacy of the EIS analysis for cumulative effects. Increases in Sudden 

Oak Death treatments alone would not necessarily violate the analysis assumptions.
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Final Environmental Impact Statement: Appendix 10

163. Comment: The EIS says it is not precisely known how much more effective herbicides are when compared 

to non-herbicide treatments to corral Sudden Oak Death-hosting tanoak, with the opinion of pathologists being 

that non-herbicide methods are 15 to 30 percent less effective. While we are concerned about the loss of oaks, 

increasing herbicide use for this purpose is not safe or proven to be effective.

Response: The estimated 250 acres per year herbicide use on tanoaks to control Sudden Oak Death on BLM 

lands within the State-identified Sudden Oak Death control area is included in the herbicide use estimates 

for Alternatives 3 through 5. No specific adverse effect attributable to this specific use was identified at the 

programmatic scale. Herbicide applications on National Forest System lands within the control area are currently 

made with aquatic-formula glyphosate in compliance with existing Fish and Wildlife Service Biological Opinion 

(USDI 2008b). The potential for adverse effects from glyphosate control of tanoaks to control Sudden Oak Death 

was examined at the project scale in an Environmental Assessment completed by the Coos Bay BLM District in 

May, 2010. No significant effects were identified.

Regarding the effectiveness of treatments, the EIS stated “...it is not precisely known how much more effective; data 

are currently being gathered and is expected to be available in 2009. The opinion of pathologists is that the approach 

currently used by BLM without herbicide use is 15 to 30 percent less effective than the herbicide approach” (Pests 

and Diseases section). The promised 2009 data is now available and has been incorporated into the Final EIS. 

Pathologists established 119 plots (2008-2009) around the stumps of the known-infected tanoak trees that had been 

cut, and examined all host vegetation remaining on the sites. Six percent of the 106 plots on private lands had 

infected tanoak re-sprouts (post-treatment) using herbicide in some form (injected, stump-top application or sprout 

spray). Thirty-eight percent of 13 plots on BLM lands where herbicide was not used had infected tanoak re-sprouts 

(post-treatment). While the small non-herbicide sample size reduces the statistical strength of the apparent trend, 

the data nevertheless supports the pathologist’s earlier impressions that herbicide use reduces the number of infected 

sprouts post treatment, thus reducing the potential for continued spread of the disease. 

However, as with other treatments described in this EIS, the selection of treatment methods is outside the scope of 

this EIS. The 250-acre per year estimate included in this EIS is for cumulative effects analysis purposes only, and 

does not represent a commitment to a particular treatment method. Treatment decisions would be made following 

site-specific analysis.

164. Comment: It is not clear in the discussion of Sudden Oak Death that aquatic-labeled glyphosate would be 

used to protect fish, or that stream buffers would apply. Why not use imazapyr since it is less toxic to fish?

Response: The EIS section discussing Sudden Oak Death indicates glyphosate and/or imazapyr might be used. 

As with other herbicide use by the BLM in Oregon, the Standard Operating Procedures and PEIS Mitigation 

Measures would apply. These include requirements for stream buffers, and the use of glyphosate with low or no 

POEA near streams. Certain formulations of glyphosate and imazapyr are labeled for riparian and aquatic use. 

A final decision about if, how, and which herbicide to apply is subject to site-specific analysis. Aquatic-labeled 

glyphosate is being used on adjacent National Forest System lands, in accordance with a Biological Opinion 

(USDI 2008b) from the Fish and Wildlife Service.

Climate Trends, Projections, and Implications

165. Comment: The EIS claims manual methods of weed control are not desirable because those methods use 

fossil fuels, but never admits that herbicides are made from fossil fuels, and their application uses fossil fuels, 

equating to likely far greater fossil fuel use than manual methods.
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Response: This discussion, from Chapter 1, simply notes non-herbicide methods also have adverse effects, and 

includes the use of fossil fuels as one of those. No comparative analysis is made here or elsewhere in Chapter 

1. The emissions estimates in the Air Quality section do indicate that exhaust from control treatments would be 

much higher for non-herbicide treatments than for herbicide treatments. Exhaust is created by mechanical (not 

manual) equipment. Mechanical control methods typically require more trips to the site (lower production rates) 

and use more fossil-fuel burning equipment than herbicide treatments. Some fossil fuels would be used in the 

manufacture of herbicides (as they would be refining fossil fuels for use in mechanical equipment) and for some 

packaging. Some, but not all, herbicide formulations may have their origin in fossil fuels. However, the quantity 

of herbicides applied at typical rates ranges from two pounds (glyphosate) to less than one ounce (several) per 

acre (see the “Estimated Annual Pounds of Herbicide...” table in Chapter 3). The active ingredients in powder 

or concentrate form are typically mixed with several gallons of water to make the spray mix; the BLM no longer 

permits the use of petroleum products as carriers. Thus, there is no reason to believe that spraying a roadside, for 

example, would use any more fossil fuel than mowing the same road.

166. Comment: The Comparison of the Effects of the Alternatives section in Chapter 2 refers only to climate 

change-related increases in temperature and/or CO2. The EIS does not recognize that future climate changerelated increases in temperature and changes in precipitation are actually very region and sub-region specific and 

may not favor invasive plants west of the Cascades. Changes are also speculative east of the Cascades.

Response: Although CO2 levels are predicted to increase from historic levels, temperature and rainfall changes 

resulting from global climate change could be either up or down as suggested in the coment, depending upon 

location. The Comparison of the Effects of the Alternatives section has been changed to say that CO2 increases 

will likely favor invasive plants, and that disturbances to native plant communities exacerbated by significant 

shifts in temperature or rainfall would likely be exploited by invasive plants. 

It is certainly possible that a warming wetting trend west of the Cascades will not benefit invasive plants as 

visibly, or to the same degree, as climate changes in other areas of the State. However, there are invasive plants in 

Oregon from all over the world. Any change in environmental conditions would result in some vegetation shift, 

and that can be expected to be exploited by invasive plants.

167. Comment: The EIS should also include a discussion of the interactions between climate change (changes 

in fire regimes, increased CO2 concentrations, changes in precipitation and temperature regimes, changes in 

the frequencies of droughts, heat waves and cold snaps, and so forth) and other natural and anthropogenic 

disturbances (logging, OHV use, grazing, planned and unplanned fires, and so forth) that may increase the 

frequency and extent of soil disturbance, thereby exacerbating invasive plant problems. 

Response: In large part, the science needed for this type of discussion is not available. How climate change may 

interact with anthropogenic disturbances and management activities has not been studied or simulated. Several 

studies have examined the potential impacts of different forest management scenarios on carbon storage, but these 

studies have only taken place under the current climate, not taking into account how changing climate may also 

alter site capability. A small number of studies have examined how increasing atmospheric CO2 concentrations 

may affect certain invasive plants (see Implications of Climate Change on Invasive Plants in Chapter 4) but none 

of those studies has examined subsequent interactions between plant response to increased CO2 concentrations 

and livestock grazing. Several climate change projections have included a projected increase in fire size, intensity 

and severity, and an increase in insect outbreaks in forests but none have included a projection of disturbance 

regime changes in rangeland ecosystems nor have such projections included a discussion on expected interactions 

with other natural or anthropogenic disturbances. 
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Final Environmental Impact Statement: Appendix 10

168. Comment: The EIS should discuss carbon storage.

Response: The effects of the alternatives on climate change and carbon storage has been added to the Climate 

Trends, Projections, and Implications section in Chapter 4.

Soil Resources

169. Comment: Treating administrative sites and rights-of-way acres with herbicides (instead of mechanical 

means) is more toxic to soil organisms or disruptive to nutrient cycling. These impacts cannot be compared to 

erosion and compaction from non-herbicide methods. Erosion and compaction effects can be better understood, 

and more easily mitigated and restored. 

Response: Some herbicides could reduce, but not eliminate, soil microorganisms and nutrient cycling processes. 

The expected recovery for these reductions in populations comes in several (1-3) growing seasons as native or 

seeded vegetation returns to the site. 

The acres in administration sites, rights-of-way and recreation areas not treated with herbicides would continue 

to be treated through mechanical or manual means. Using mechanical equipment repeatedly in rights-of-ways, 

administrative sites, and recreation sites generally does not denude the sites enough to allow erosion. When soil 

is lost from such sites, the potential to restore the soil organisms and cycling processes will take much longer to 

return, as soil (weathered rock and organic components) will need to be replaced in order to provide a medium for 

populations of organisms to live and process nutrients. Compaction reduces soil air space, infiltration of water and 

also reduces or changes the type of populations of organisms. Compaction occurs under the wheeled track portion 

of the treated area. This compaction can be repeated every year or several times a year in some instances. While 

this compaction could be restored with an aerator, they are not often utilized, as the equipment for these types of 

environments is not readily available or is more destructive to the surface and increases the potential for erosion. 

Compaction and erosion also create surface disturbances and change soil properties, favoring reinvasion by invasive 

plants. These in turn adversely affect soil chemistry and stability when compared to soils populated with native 

plants. A major benefit of using herbicides is that they can often avoid or minimize reinvasions associated with 

surface disturbances (see Reference Analysis in the Soils Resources section in Chapter 4, and others).

170. Comment: The EIS should explain which invasive plants would be targeted with a prescribed fire treatment. 

For the follow-up restoration, when treating by seeding, range drills should not be used in areas of intact 

biological crusts.

Response: As described in the Fire and Fuels, Air Quality, and other sections in Chapter 4, prescribed fire would 

be used primarily east of the Cascades, in a three-step treatment regimen for preventing or controlling invasive 

annual grasses. A determination regarding the most appropriate seeding method would be made during sitespecific analysis that would consider the existence and sensitivity of soil crusts. 

171. Comment: A detailed analysis of the effects on killing or weakening biological crusts (microbiotic crusts) 

should be included in the EIS. Biological crusts are increasingly recognized as providing natural benefits in 

reducing climate change processes.

Response: The Soil Resources section describes biological crusts and outlines the major components of 

biological crusts and where these crusts are expected to be located on BLM managed lands. This section has been 

expanded to note that the application of herbicides could be considered a disturbance event that could result in 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

decreased soil organism diversity, nutrient cycling, soil stability, and organic matter. Individual components of 

the crusts can be reduced by herbicide applications, causing the crusts to lose some ability to function as a soil 

protection and a nutrient cycling mechanism. 

A section on the potential impact of the alternatives on the carbon storage capacity of biological soil crusts has 

been added to the Climate Change section as well.

172. Comment: In the Additional Information about the Fate and Effects of Herbicides subsection, changing 

the wording to note that chlorsulfuron is “more stable” in neutral soils is suggested. This would be more correct, 

as well as more consistent with the information on tables in the Soil Resources section, than the current wording 

indicating it “is relatively stable” in neutral soils.

Response: The wording regarding chlorsulfuron in the Soil Resources section has been changed to state that it is 

more stable in neutral soils. 

173. Comment: The EIS should include the following information relative to clopyralid in the EIS: Clopyralid 

has an inability to bind with soils; therefore, it can be highly mobile and a contamination threat to water and nontarget plants. It is considered persistent in soil, water, and plants. When applied to cold dry soils or waterlogged 

soils the residues may persist for years. This herbicide may leach to 180 cm in 20 days and move to streams when 

placed directly on soil. Direct application to soil may also prevent germinating plants from emerging from the 

soil. Clopyralid can also present problems for organic farmers as the herbicide can be transferred to other nontarget crop plants through compost, plant residues, soil residue, runoff, or leaching. 

Response: In the Soil Resources section, the characteristics of clopyralid are addressed. Clopyralid is disclosed 

in the EIS as being unstable in soil and is considered moderately persistent based on its half-life. It will leach 

under favorable conditions such as in wet, sandy soils like Inceptisols or Andisols as it does not bind to soil 

tightly. However, biodegradation is rapid in soil and thus the potential for leaching or runoff is low. Clopyralid 

can persist in plants and, therefore, can be introduced into the soil when plants die and kill other plants. This 

chemical is not expected to be applied to cold dry soils, as the method of application is to be foliar, it is not 

approved for wetland or riparian areas, and thus no applications would be expected on waterlogged soils. 

According to the study by Elliott et al. (1998), the leaching to 180 cm occurred on worst-case experimental 

conditions (application to a harvested, cultivated field followed by irrigation). These conditions or any such 

conditions that resemble this level of disturbance would not be encountered during the application of clopyralid 

on BLM lands. Movement of plant material, soil residue, or compost is not expected under any alternative and 

thus contamination of secondary crops would not occur. The potential for leaching and runoff are low due to the 

rapid biodegradation of the active chemicals. 

174. Comment: The EIS should address what organisms 3, 4-DCA (diuron’s breakdown product) affects, and to 

what extent. 

Response: The effects described for diuron are attributable to the 3,4-DCA. More specifically, according to one 

study in a Risk Assessment report of the substance 3, 4-dichloroaniline, bacteria, fungi, and red wiggler worms 

were affected by the application of this chemical to soil (EINECS 2006). Growth inhibition and rate of anaerobic 

nitrate respiration were reduced for the bacteria and fungi. Reductions of 80 to 40 percent depending on the 

organism and concentration of the chemical were noted. 
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Final Environmental Impact Statement: Appendix 10

A radiorespirometric3 technique was used to examine the effect of 100 ppm diuron and 3, 4-DCA on respiration of 

fresh sandy loam soil. Pseudomonas putida (a soil bacterium) was inoculated to the sterilized soil and incubated 

for 18 hours at 25oC. The results show that diuron had no inhibitory effect on P. putida or soil microbial activity. 

For 3,4-DCA, an inhibition of about 50% could be found. A growth test in vitro showed no inhibition by 3,4-

DCA, leading the authors to conclude an influence of physical properties of the soil were the cause for the 

reduction by 3,4-DCA.

In a second study (also reported in EINECS 2006), nitrification was inhibited with a lag phase of 1, 2, and 17 

days by the application of 2.5, 5, and 25 mg/kg of soil of 3,4-DCA, but the eventual appearance of nitrate was 

almost identical with that of the control. For worms, no effects on mortality and body weight of adults and the 

number of offspring were observed for the test concentrations of 1 to 100 mg/kg dry weight soil for fresh (2 hrs 

after application) and aged (5 weeks after chemical application) soil variants. The highest test concentration of 

320 mg/kg provided significant effects on mortality and body weight of adults in the freshly contaminated soil, 

and no offspring were found. In aged soil, some reduction in offspring numbers has been observed at 320 mg/kg 

dry weight soil only. These findings indicate that the bioavailability of the test substance decreased in the 5 week 

aged soil.

According to the European Food Safety Authority’s Conclusion on the Peer Review of Diuron (EFSA 2005) for 

bees, non-target arthropods, and soil micro- and macro-organisms including earthworms, the risk is considered 

low for the representative uses with regard to diuron and metabolites. The above paragraphs are consistent with 

the information summarized for diuron. This last summary paragraph has been added to the Soils Resources text 

in Chapter 4.

175. Comment: The Additional Information about the Fate and Effects of Herbicides subsection states that 

diuron is a highly persistent herbicide. To be consistent with tables in the Soil Resources section, this should be 

changed to moderately persistent.

Response: The wording regarding diuron in the Soil Resources section has been changed to state that diuron is 

moderately persistent. 

176. Comment: The EIS should describe what other soil organisms and other life might be affected by dicamba’s 

breakdown product 3,6-dichlorosalicylic acid in addition to earthworms, and describe its persistence time in soil.

Response: As noted in the EIS, dicamba breaks down in soil to very simple substances like carbon dioxide and 

water. The soil bacterium Pseudomonas maltophilia (strain DI-6) converts dicamba to 3,6-dichlorosalicylic acid 

(3,6-DCSA), which is adsorbed to soil much more strongly than is dicamba and lacks herbicidal activity. Very 

little information is available on the toxicity of these breakdown intermediates. According to Smith (1974), the 

degradation product 3,6-dichlorosalicylic acid built up during the three weeks of degradation of dicamba and was 

followed by a slow loss that was complete within nine weeks. 

177. Comment: The non-persistent rating in tables in the Soil Resources section conflicts with the text that states 

that fluridone may last up to a year on dry soils and is moderately persistent. 

Response: Fluridone is an aquatic herbicide for the control of vascular aquatic plants and not proposed for 

treatments outside lakes, ponds, canals and reservoirs (see the Water Resources section). However, information 

3 Respirometric: of, relating to, or being a study of metabolism by the measurement of carbon dioxide labeled with 

carbon 14 from the carbohydrate substrate.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

for this herbicide exists for application on soil. In field studies using different soil types, less than10 percent of 

the originally applied fluridone was found after 220 days in Miller clay, and 20 percent was found remaining after 

385 days in Lufkin fine sandy loam soil. In laboratory studies, fluridone persistence in non-sterilized soils after 

210 days was 62, 44, 10, and 5% in Lufkin fine sandy loam, Miller clay, Hidalgo sandy clay loam, and Brennan 

fine sandy loam, respectively (Banks 1979).

The wording in the Soil Resources section has been clarified to say fluridone would be used in an aquatic 

environment. The persistence rating has been footnoted to show it applies to aquatic applications. Fluridone 

would not be applied to a dry soil environment for weed control on BLM lands in Oregon. 

178. Comment: The EIS should explain how, for imazapyr, it can know that “the potential for longer-term effects 

on soil organisms exists but little is known if the effects would be positive or not.”

Response: The Soil Resources section notes that studies have reported that imazapyr may be actively exuded 

from the roots of legumes (such as mesquite). This exudate and the ability of imazapyr to move via intertwined 

root grafts may therefore adversely affect the surrounding desirable vegetation (SERA 2004d, Tu et al. 2001). 

SERA (2004d) also describes the lack of known effects to soil microorganisms. Based on the persistence time 

of the herbicide in soil and the ability of it to be taken up by other vegetation, there may be the potential for soil 

organisms to be affected, either positively or negatively. In the Forest Service Final EIS Appendix U (USDA 

2005), the chemicals are individually assessed for effects and the following statements reflect the knowledge of 

imazapyr. No other literature searches have yielded new or contradictory information. 

•	 There are no studies on the effects of imazapyr on soil invertebrates, and incomplete information on the 

effects on soil microorganisms. 

•	 One study indicates cellulose decomposition, a function of soil microorganisms, can be decreased by soil 

concentrations higher than concentrations expected from [BLM] applications. 

•	 There is no basis for asserting adverse effects to soil microorganisms. 

•	 Imazapyr degrades in soil, with a half-life of 25 to 180 days.

•	 Degradation rates are highly dependent on microbial action. 

•	 Anaerobic conditions slow degradation. 

•	 Adsorption increases with time as soil dries and is reversible. 

•	 Field studies indicate that imazapyr remains in the top 20 inches of soil and do not indicate any potential 

for imazapyr to move with surface water.

•	 In forest field studies, imazapyr did not runoff and there was no evidence of lateral movement.

•	 Modeling results indicate imazapyr runoff is highest in clay and loam soils with peaks after the first 

rainfall. 

•	 Imazapyr percolation is highest in sandy soils

This or corresponding relevant information has been included in the discussion of imazapyr in the Soil Resources

section, and the sentence cited in the comment has been changed to show there are no studies on the effects of 

imazapyr on soil invertebrates, and there is incomplete information on the effects on soil microorganisms.

179. Comment: The conclusion of no effects to soil quality from herbicide use is contradictory given the stated 

picloram effects to soil organisms and persistence.

Response: The statement for soil quality degradation has been revised to show that of the four potential 

herbicides available for use in Alternative 2 (No Action), 2,4-D, dicamba, and glyphosate would not reduce soil 

quality when used to control noxious weeds under this alternative. Picloram effects may reduce soil organisms 

for up to a year. 
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Final Environmental Impact Statement: Appendix 10

180. Comment: The discussion of sulfometuron methyl in the Soil Resources section says that sulfometuron 

methyl is broken down through hydrolysis and biodegradation and moves readily through coarse textured soils. 

This is true for laboratory studies but field studies show it to be immobile under field conditions. The EIS should 

be edited to state that the mobility and persistence of sulfometuron methyl in soil is low.

Response: Field studies by Trubey et al. (1998) determined the persistence of sulfometuron methyl in soils is 

low. The degradation and mobility of sulfometuron methyl and potential degradates in the Trubey et al. field 

studies were evaluated under actual field conditions in the United States following application of Oust® herbicide 

to bare ground at the maximum-labeled rate. Sulfometuron methyl degraded rapidly at the four test sites; 

calculated half-life values ranged from 12 to 25 days. Sulfometuron methyl and its degradates were immobile 

under field conditions.

Information from the Extoxnet Pesticide Information Profile cites that the information on the rapid disappearance 

of sulfometuron methyl and the slight potential to move through soils indicates that the compound does not pose a 

threat to groundwater (Extoxnet 1996c). 

Based on this supporting and new information, the mention of coarse textured soils and mobility within them 

has been supplemented in the Soil Resources section to note that the half-life of sulfometuron methyl is short, 

and that it has been found to move readily through coarse textured soils such as sand and sandy loams under 

laboratory conditions but that in field studies it has been demonstrated to be immobile and does not pose a threat 

to groundwater.

181. Comment: How toxic is triclopyr acid and how long does it persist in soils? 

Response: As noted in the Soil Resources section, triclopyr is manufactured in two forms: a triethyamine salt 

(TEA) and a butoxyethyl ester (BEE). Both forms degrade readily in sunlight to the parent compound, triclopyr 

acid, which is also photodegradable. No information is available for toxicity of the degraded form, triclopyr acid, 

in soil. The Soil Resources section has been expanded to include the following information regarding its half-life: 

A study of photolysis found the half-life of triclopyr acid on soil under midsummer sun was two hours (McCall 

and Gavit 1986). Photodegradation can be particularly important in water. Johnson et al. (1995) found triclopyr 

acid dissolved in water had a half-life due to photolysis of one to 12 hours. They also found that sunlight plays a 

role in the rate of microbial metabolism of triclopyr, as microbial metabolism slowed when soil was deprived of 

light. The average half-life of triclopyr acid in soil is 30 days (Tu et al. 2001). 

Water Resources

182. Comment: The Summary does not mention the potential for contamination of ground or well water.

Response: Although not in the Draft EIS Summary, known groundwater contaminates (those herbicides detected in 

groundwater regardless of the amount) were identified in the Water Resources section of the EIS in Chapter 4, and 

were listed in the short summary of Water Resources information in the Additional Effects by Resource section in 

Chapter 2. In the Final EIS, the Summary has been combined with the Final EIS so a complete effects analysis is 

within one document. The Additional Effects by Resource section in Chapter 2 has been replaced with a Comparison 

of the Effects of the Alternatives table, which continues to include a list of known groundwater contaminates.

183. Comment: The Clean Water Act declares a National goal that the “discharge of pollutants into the 

navigable waters be eliminated.” The Act defines pollutants as “chemical waste” and “biological materials,” 

which includes herbicides.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Response: Standard Operating Procedures, PEIS Mitigation Measures, and other measures are designed to keep 

non-aquatic BLM herbicides from getting into waters. For aquatic herbicides used to control invasive plants 

in and near water, site-specific analysis would demonstrate that benefits outweigh the risks before projects are 

authorized. For these cases, the EPA (in 2006) defined label-specified herbicide applications as not constituting 

a discharge of a pollutant under the Clean Water Act. The EPA’s decision was subsequently overturned by the 

United States Court of Appeals for the Sixth Circuit, but the EPA was given until April 11, 2011 to prepare a 

general National Pollutant Discharge Elimination System (NPDES) permit for label-applied herbicides into or 

near water. The general permit, once issued, would have the effect of certifying compliance with the National 

goal. The BLM would comply with the provisions of the general permit, but the permit would not necessarily 

result in any changes to the applications described in the EIS.

184. Comment: More than 2,000 miles of BLM streams in Oregon are already listed on the Clean Water Act’s 

303(d) list as impaired for water quality, and 1,711 of those miles are impaired for temperature violations. The 

BLM has not adequately examined the effect of herbicide use on temperature-impaired streams. 

Response: Both the Fish and Water Resources sections describe how invasive plants generally provide less 

stream shading and are less effective at providing bank stability than native, site appropriate, vegetation. In 

addition, total maximum daily loads (of sediments) are identified for each 303(d)-listed stream, and these 

include identification of “system potential vegetation” as the target (native) vegetation to meet water temperature 

standards. Slowing the spread of invasive species and removing invasive species from the riparian areas along 

streams, allows for the improvement of riparian vegetation important for stream shading and the maintenance 

of bank stability, both helpful in meeting temperature and other Clean Water Act objectives. Treatments along 

rights-of-way might have little effect on stream temperatures because of required buffers, and because acres 

proposed for herbicide use are already being managed using mowers and other non-herbicide methods. In any 

case, treatments would be analyzed in site-specific analysis that would consider potential effects to specific listed 

streams.

185. Comment: Oregon Department of Environmental Quality recommends that BLM establish direct 

communication with the Public Water System (PWS) operators or community liaisons downstream of the BLM 

treatment areas. Oregon Department of Environmental Quality generally recommends 100 or 200 feet buffers 

within 500 to 1,000 feet of a PWS intake and that BLM’s management in municipal watersheds and aquifers 

management should support the overall goal of providing the highest quality water possible downstream at intakes 

and wells.

Response: These Oregon Department of Environmental Quality recommendations have been included in the 

Water Resources section in Chapter 4.

186. Comment: The EIS is defective because it fails to disclose the increasing frequency of pesticide detections 

over time for watersheds affected by the EIS. For example, the EIS fails to disclose that the [Reference Analysis]4

(no herbicides) would result in the least number of pesticide detections in streams, whereas, Alternative 5 could 

have up to 18 additional pesticide detections.

Response: The EIS variously reports actual levels of herbicides currently found in water bodies and groundwater, 

or the percentage of samples in which herbicides were detected, most notably in the Water Resources and the 

revised Cumulative Impacts sections early in Chapter 4. The Water Resources section goes on to discuss specific 

4 This was “Alternative 1” in the Draft EIS and in the public comment. The title “Reference Analysis” is used in this 

Appendix to conform to the rest of the Final EIS.
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Final Environmental Impact Statement: Appendix 10

herbicides in State waters, routes of delivery, and fate. That same section concludes that the Reference Analysis 

“would not have the potential to contaminate water with herbicides,” while Alternative 5 says “the higher number 

of acres treated would add to the risk of herbicides impacting water quality ...” The potential effects described in 

the comment are fully disclosed.

187. Comment: The EIS is defective because it fails to provide baseline conditions of potentially affected 

streams (existing detections of pesticides).

Response: The EIS variously notes the results of State, the EPA, and other herbicide-related water monitoring 

efforts. Recent monitoring results for the Willamette Basin have been added to the Water Resources section. 

This section also describes incidences and sample results for surface and groundwater. The EIS is programmatic 

however; no site-specific treatments are proposed, so no specific streams are directly affected by the Record of 

Decision. Water quality monitoring could occur on a subset of herbicide application projects, particularly where 

there are Federally Listed fish or where the project is considered higher risk (see Appendix 3). Monitoring is 

described in the BLM’s Chemical Pest Control Handbook (USDI 1992c). The handbook says no set criteria for 

when to monitor are prescribed, but that a toxic chemical proposed for use in a susceptible areas such as near a 

residential area, or domestic water supply, must be monitored. Where water quality monitoring occurs, a baseline 

sample is collected before application of herbicides.

188. Comment: In 2008, the Oregon Department of Environmental Quality initiated a long-term program to 

monitor surface waters for toxic pollutants. Monitoring objectives were to collect data on pollutants known 

to present a substantial threat to human health or aquatic life and to gather information about the occurrence 

of chemicals of emerging concern in the Willamette River Basin. Water samples and fish were collected from 

mainstem and tributary locations throughout the basin and analyzed for a wide range of organic pollutants and 

metals. Herbicides were the class of pesticides most commonly found in water samples. Of the herbicides 

addressed in this EIS, diuron was found in many samples collected at locations throughout the basin. 

Response: A discussion of this Oregon Department of Environmental Quality water monitoring has been added 

to the Water Resources section. Diuron was the 13th most commonly used herbicide in the State of Oregon in 

2008. Diuron was found at low concentrations, less than 1 microgram per liter, which is 10 to 100 times less than 

the EPA benchmark for fish and invertebrates. There is no numeric water quality criteria established for diuron at 

this time (ODEQ 2008). 

BLM would use diuron only under Alternative 4 (the Proposed Action) and Alternative 5. The estimated use 

west of the Cascades would be approximately 100 acres per year (800 acres for the whole State), a small fraction 

of the total acres treated in Oregon (see the Cumulative Impacts section early in Chapter 4). Standard Operating 

Procedures and PEIS Mitigation Measures include minimum buffers for use of upland labeled herbicides near 

water, based on application method (Appendix 2). In addition, for project level analysis, Standard Operating 

Procedures include the guidance to develop further refined buffer widths based on herbicide properties and sitespecific conditions, to minimize impacts to water qualities. Buffers limit the transport of herbicide from upland 

treatments to water (Water Resources, Berg 2004, Dent and Robben 2000, Rashin and Graber 1993).

189. Comment: The Oregon Department of Forestry (ODF) encourages the BLM to share any water quality 

effectiveness monitoring data collected in support of this EIS with the State of Oregon’s Water Quality Pesticide 

Management Team (WQPMT). Initiated and led by the Oregon Department of Agriculture, the inter-agency 

WQPMT acts to review and respond to pesticide detections in Oregon’s ground and surface water as described in 

the Pesticide Management Plan for Water Quality Protection. As a Team member, the ODF is keenly interested in 

expanding the knowledge base regarding pesticides use and water quality on forestlands.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Response: Appendix 3 (Monitoring), has been revised to show that the BLM would share effectiveness 

monitoring data with the Oregon Department of Forestry’s Water Quality Pesticide Management Team. 

190. Comment: BLM should consider the EPA list of Pesticides of Interest and Oregon’s Pesticides of Concern 

as well as other water protection methods when developing and implementing projects under NEPA.

Response: A subsection addressing Pesticides of Interest and Pesticides of Concern has been added to the Water 

Resources section in Chapter 4. 

191. Comment: Many of the herbicides addressed by the EIS were detected in surface or groundwater in the 

1992-95 USGS National Ambient Water Quality Assessment (NAWQA) studies in the Willamette Basin. These 

include 2,4-D, bromacil, dicamba, diuron, glyphosate, and triclopyr (Wentz et al. 1998). These data suggest that 

standard application practices may result in measurable concentrations of these compounds in surface waters near 

application areas, sometimes above water quality standards. These results emphasize the need to limit use of 

chemical herbicide controls whenever feasible.

Response: A discussion of the NAWQA study was added to the Water Resources section in Chapter 4.

The herbicides listed in the comment are all commonly used by agriculture, where herbicides are applied at 

regular intervals to large acreages following label requirements. Of the 18 herbicides addressed in this EIS, the 

1992-95 data showed diuron in 53 percent of surface water samples, sometimes in levels exceeding drinking 

water standards. The BLM manages 25 percent of the land in Oregon but would use less than one percent of 

the herbicide under any alternative. Standard Operating Procedure-required buffers lessen the risk of herbicides 

entering water when compared to label requirements. Standard Operating Procedures also require that additional 

buffer widths be developed based on herbicide-specific and site-specific conditions, to minimize impacts to water 

quality. The Water Resources section includes information about the effectiveness of buffers at limiting the 

transport of herbicide from upland treatments to water (Berg 2004, Dent and Robben 2000, Rashin and Graber 

1993). Diuron use west of the Cascades is estimated at 100 acres per year. The herbicide-specific information 

added to the Final EIS in Appendix 9 indicates diuron would be used for nursery-bed site preparation, and weed 

control around cell phone, radio, and television towers and electrical substations well away from water. Given 

the relatively small amount of herbicide used and the buffers required, it is unlikely that herbicides used by BLM 

would add measurably to the herbicide levels in surface waters. 

192. Comment: While no National Pollutant Discharge Elimination System (NPDES) permit is required by 

Oregon Department of Environmental Quality at this time, a general NPDES permit for pesticide applications will 

be required starting in April 2011. The NPDES general permit will include conditions that must be followed by 

the applicant.

Response: The EPA has until April 2011 to prepare a general NPDES permit for label-applied herbicides into or 

near water. Such a permit is required by the Clean Water Act for the discharge of “pollutants.” The general permit 

would not necessarily result in any restrictions other than those already required by EPA-approved labels. The BLM 

would meet all regulatory requirements and obtain required permits as needed, before project implementation.

193. Comment: There are hundreds of domestic water supplies on or adjacent to BLM checkerboard lands, many 

predating BLM permitting requirements, which are unknown to the BLM. Several of the proposed new herbicide 

applications could introduce toxic chemicals to people’s drinking water. The EIS does not appear to consider this. 

The USGS report “Pesticides in the Nation’s Streams and Ground Water, 1992-2001” confirmed that commonly 

used pesticides (including herbicides) show in domestic water supplies.
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Final Environmental Impact Statement: Appendix 10

Response: To protect human health and safety a minimum buffer of 1⁄4 mi for aerial application and 100 feet for 

ground applications would be used between treatment areas and human residences, unless a written waiver is 

granted (Appendix 2). Where water sources are on BLM or away from the residence, an additional mitigation 

measure to protect wells and springs used for domestic water supplies has been suggested by the analysis in this 

EIS (see Potential Mitigation in Chapter 2). Analyses for most herbicide use west of the Cascades also consider 

that almost all streams are in community source water protection areas. Buffers limit the transport of herbicide 

from upland treatments to water (Water Resources, Berg 2004, Dent and Robben 2000, Rashin and Graber 1993). 

Domestic water intakes on BLM lands would be considered if their location were known through required land 

use permitting processes. Intakes cannot be buffered if their location is unknown. However, the application 

of normal water buffers could be expected to minimize herbicides getting into nearby water bodies. The Water 

Resources section describes the incidence of herbicides in ground and other waters, and notes that the EPA has set 

tolerances for several of the herbicides addressed in this EIS. Herbicide use proposed with this EIS could, but is 

unlikely to, contribute to herbicides within domestic water supplies. 

The referenced USGS report focused on agriculture and urban areas. The report indicates detections occurred 

most frequently in shallow ground water beneath agricultural and urban areas, where more than 50 percent of 

wells contained one or more pesticide compounds. About one-third of the deeper wells sampled, which tap major 

aquifers used for water supply, contained one or more pesticides or degradates. The findings show that streams 

are most vulnerable to pesticide contamination, but ground water also merits careful monitoring—especially in 

agricultural and urban areas. Shallow ground water in some of these areas is used for drinking water and groundwater contamination is difficult to reverse once it occurs (USGS 2008). 

194. Comment: Herbicides should not be used in the Mt. Hood watershed. Instead, a CCC5-type group could be 

created to assist local efforts in eradicating invasive plants.

Response: It is not clear what area is referenced by “Mt. Hood watershed,” but analysis of proposed herbicide 

use within source water areas for communities would normally involve the potentially affected water district. 

In any application, potential effects to domestic uses are taken into account. The difficulties of relying on 

government-employed work-crews range from the costs of transport, supervision, and housing to non-herbicide 

methods simply not working for many types of invasive plants. As described in Chapter 1, non-herbicide 

vegetation management methods are already available and being used to the extent practicable.

195. Comment: The EIS cites Austin et al. (1991) in saying glyphosate may stimulate algal growth at low 

concentrations, contributing to eutrophication of waterways, yet the effects of the proposed use of glyphosate on 

eutrophication and resultant cynobacterial blooms has not been analyzed on a site-specific or cumulative level.

Response: Austin et al. (1991) cultured periphyton6 on glass plates suspended in artificial “stream-troughs” 

which were supplied with flowing water pumped from natural streams in British Columbia. The stream water was 

low in phosphorus and flowed out of an oligotrophic lake. Glyphosate was added to give nominal concentrations 

in the troughs of between 0.001 and 0.3 mg/liter. A further series of treatments added nutrients to troughs. The 

herbicide was not toxic to the periphyton. A transitory decrease in growth was followed by a stimulation of 

biomass in the glyphosate-treated troughs. Similar effects were seen with added nutrient. The authors considered 

the effect to be the result of algae using glyphosate as a phosphate source (WHO 1994). 

5 Civilian Conservation Corps (CCC) was a public work relief program for unemployed men, providing vocational 

training through the performance of useful work related to conservation and development of natural resources in the 

United States from 1933 to 1942.

6 Periphyton is a complex matrix of algae and heterotrophic microbes attached to submerged substrata in almost all 

aquatic ecosystems
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The EIS has been edited to note that the study has more implications in streams flowing through agricultural 

and urban areas where glyphosate is shown to be relatively common, although additional phosphates from those 

same areas might mask the effect. The amount of glyphosate expected to reach streams from BLM terrestrial 

applications would be expected to have no noticeable effect on eutrophication. Aquatic formulations could 

conceivably affect waterborne algae, and this possibility is noted in the analysis. Studies by the Washington 

Department of Ecology showed that out of five treatments, three had no detection of herbicide within one hour 

of treatment, and the two treatments with herbicide detected 1 hour later also had low levels 24 hours after 

treatment (see Water Resources section). However, the spread of riparian or submerged invasive plants is a much 

higher risk for eutropication than glyphosate. Glyphosate is generally used on small patches of plants, and where 

herbicide-killed aquatic vegetation is a concern, the plants are removed from the water after treatment. 

196. Comment: The Water Resources section states that sulfometuron methyl degrades quickly by hydrolysis 

in acidic water but is stable in neutral water, and that biodegradation and photolyosis are major loss pathways in 

aquatic systems where hydrolysis rates are generally slow. A more accurate statement would be “Biodegradation 

is a major loss pathway in aquatic systems, where hydrolysis rates are generally slow.”

Response: The statement has been changed to read as suggested.

197. Comment: The EIS does not adequately acknowledge and address the fact that the way BLM’s road 

drainage system has been engineered, roadsides are really an extension of the stream network. Therefore, 

anything that BLM sprays along roadways has a high chance of polluting streams. This is a powerful argument in 

favor of alternative treatment methods.

Response: The Water Resources section in Chapter 4 addresses this issue with “Roads often parallel streams 

or have stream crossings. Roads can act as extensions of stream networks with roadside ditches having low but 

measurable herbicide concentrations months after treatment (Wood 2001). Since vehicles are a major invasive 

weed vector, a high percentage of invasive weed treatments are along roadsides. Herbicides used in these areas 

could reach streams even when buffers to the actual stream are applied. Standard Operating Procedures such 

as stream buffers reduce potential impacts to water quality from herbicide applications but do not specifically 

address ditches.” Some of this same wording is included in the Special Status Fish section. Appendix 2 includes 

a PEIS Mitigation Measure to “Consider the proximity of application areas to salmonid habitat and the possible 

effects of herbicides on riparian and aquatic vegetation. Maintain appropriate buffer zones around salmonidbearing streams.” The Potential Mitigation section in Chapter 2 of the EIS now includes a requirement that 

“site-specific analysis for road-side treatments should specifically consider that drainage structures lead to streams 

and that normal buffer distances, herbicide selection, and treatment method selection may need to be changed 

accordingly, particularly where those ditches are connected to streams with Federally Listed or other Special 

Status species.” 

The concern expressed in this comment is one reason bromacil and tebuthiuron are absent, and diuron nearly so, 

west of the Cascades under Alternative 4 (the Proposed Action).

198. Comment: The EIS gives a misleading impression that streams are particularly adversely affected by 

western juniper expansion and would especially improve if we apply chemical treatments to western juniper. 

The EIS lacks a clear bigger picture of all the things that degrade streams and the many more effective means of 

improving stream conditions by, for instance, removing or reducing roads, livestock, OHVs, logging, and mining.

Response: There are many factors and management actions that can either degrade or improve riparian areas or 

stream function and water quality. Discussion of most of these factors or changes in their management is outside 

the scope of this analysis. 
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Final Environmental Impact Statement: Appendix 10

The EIS provides a cumulative effects analysis for a proposal (and alternatives) to increase the number of 

herbicides, and their uses, on BLM lands in Oregon. The treatment acres are estimates for analysis purposes, 

and are provided in enough detail to provide background for effects analysis. The EIS does not propose to make 

decisions about western juniper removal. That said, district herbicide use estimates are based on known or likely 

vegetation management needs. The analysis sets the context and basis for one likely future use by describing that 

western juniper expansion has led to to decreasing stream flow (Effects of Invasive Plants on Water Resources). 

The use of herbicides to control western juniper expansion could occur under Alternative 4 (the Proposed Action) 

and Alternative 5. Localized improvements in stream flows and riparian vegetation would be expected with 

restoration activities that include western juniper removal. Reducing western juniper cover has been shown to 

increase understory vegetation and infiltration and reduce erosion (Miller et al. 2005, Pierson et al. 2007, Peterson 

and Stringham 2008). Removal of western juniper has been the focus of several projects in the Prineville area to 

increase stream flows (Wetlands and Riparian Areas). 

199. Comment: The EIS should explain how [the Reference Analysis] can lead to a decrease in water quality, 

compared with the alternatives, or why “invasive plants have the potential to adversely affect water resources 

more than herbicides.”

Response: There are five reasons described in the Water Resources section that support the conclusion that the 

Reference Analysis could lead to localized impairments in water quality compared to the alternatives. 

1) Some non-herbicide methods of removing plants disturb more ground than the use of herbicides. While 

mowing leaves groundcover in place, pulling or digging plants such as Himalayan blackberry or English 

ivy can disturb more soil, leaving more area vulnerable to erosion and runoff. The Reference Analysis 

would use directed livestock on 8,800 acres annually, a threefold increase from the No Action Alternative 

(Alternative 2). Livestock can also affect water quality by trampling banks, increasing sediment and 

contributing fecal coliform.

2) Noxious weeds are predicted to spread faster under the Reference Analysis, and many invasive plants 

provide poor erosion control compared to native plants. Japanese knotweed is an example of an invasive 

plant providing poor erosion control compared to native plants. Knotweeds spread rapidly downstream 

and out-compete native vegetation.

3) Large patches of certain plants cannot be treated effectively without herbicides. Although there are 

potentially successful mechanical or manual control options for small patches of knotweed, landscapelevel projects and large sites would almost certainly require integrating herbicide use into a control 

strategy (Sol 2004). 

4) Many aquatic species lead to decreased oxygen in the water and herbicides are an important method of 

control. For example, Eurasian watermilfoil accelerates eutrophication and lowers amounts of oxygen in 

the water (also described in the Fish section).

5) Invasive plants exclude native plants, typically reducing shade and detritus needed by stream organisms.

Comparing these weed effects against the comparatively small potential for the proposed herbicide treatments to 

adversely affect water quality, leads to the conclusion questioned in the comment.

200. Comment: The EIS fails to address the cumulative impact of herbicide on oceanic phytoplankton. There 

are already dead zones in the ocean off the coast of Oregon and at the mouth of the Mississippi.

Response: The low oxygen conditions (hypoxia) found in some summers off the Oregon coast has been linked to 

changes in surface winds. During normal years, cold water rich in nutrients but low in oxygen upwells from the 

deep ocean off Oregon, mixes with oxygen-rich water near the surface, causes some phytoplankton growth, and 

provides the basis for a thriving fishery and healthy marine food chain. During dead zone periods, some of the 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

normal processes (including wind and current conditions) can change. This allows huge masses of plant growth 

to die, decay and in the process consume even more of the available oxygen near the sea floor, causing hypoxic 

conditions for marine life. This is a different process than in the Gulf of Mexico where agriculture runoff high in 

fertilizers is implicated in the Gulf dead zone.

Regarding BLM activity affecting ocean phytoplankton, BLM manages 25 percent of the land in Oregon while 

proposing to use less than 1 percent of the herbicides. Use of Standard Operating Procedures and PEIS Mitigation 

Measures, site-specific mitigations decided at the project level, and the generally limited uses proposed, would 

provide protection for water. Given the relatively small amount of herbicide used and the buffers required, it is 

unlikely that herbicides used by BLM would add measurably to the herbicide levels in the ocean off the Oregon coast.

Wetlands and Riparian Areas

201. Comment: The EIS fails to explain how using or drifting herbicides into riparian areas would meet the 

Land and Resource Management Plan’s Aquatic Conservation Strategy (ACS) objectives west of the Cascades. 

Herbicides that harm aquatic species including native aquatic plants, and native plants within the riparian areas 

such as those in campgrounds, would not meet the ACS. 

Response: The Aquatic Conservation Strategy is a requirement of the Northwest Forest Plan and affects districts 

west of the Cascades and a portion of the Klamath Falls Resource Area, although similar requirements have been 

made a part of some plans east of the Cascades as well. The important phrases in the ACS standards and guidelines 

are “meet Aquatic Conservation Strategy objectives,” “does not retard or prevent attainment of Aquatic Conservation 

Strategy objectives,” and “attain Aquatic Conservation Strategy objectives.” These phrases, coupled with the phrase 

“maintain and restore” within each of the nine Aquatic Conservation Strategy objectives, define the context for 

agency review and implementation of management activities. Complying with the Aquatic Conservation Strategy 

objectives means that an agency must manage the riparian-dependent resources to maintain the existing condition 

or implement actions to restore conditions. The standards and guidelines focus on “meeting” and “not preventing 

attainment” of Aquatic Conservation Strategy objectives. Management actions that do not maintain the existing 

condition or lead to improved conditions in the long term would not “meet” the intent of the Aquatic Conservation 

Strategy and thus, should not be implemented (USDA, USDI 1994b:B-9-10). Of the nine ACS objectives listed in 

the standards and guidelines, those most pertinent to herbicide use are probably: 

2) .... network connections must provide chemically and physically unobstructed routes to areas critical for 

fulfilling life history requirements of aquatic and riparian-dependent species.

3) Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom 

configurations.

4) Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. 

Water quality must remain within the range that maintains the biological, physical, and chemical integrity 

of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic 

and riparian communities.

5) Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport.

8) Maintain and restore the species composition and structural diversity of plant communities in riparian 

areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions 

of coarse woody debris sufficient to sustain physical complexity and stability.

9) Maintain and restore habitat to support well-distributed populations of native plant, invertebrate, and vertebrate riparian-dependent species.
721

Final Environmental Impact Statement: Appendix 10

Slowing the spread of invasive plant and protecting native ecosystems, particularly within the riparian areas and 

in water, would contribute to most of these objectives. The question, then, is whether treatments (including those 

for native plants along rights-of-way or in developed sites), would lead to degradation. 

Potential negative effects from getting herbicides in water are avoided through the use of Standard Operating 

Procedures and PEIS Mitigation Measures that include the PEIS Biological Opinion (NMFS 2007) Protection 

Measures, as well as through other site-specific design features and practices. Stream buffers are one effective 

method of keeping herbicides out of water. Most of the herbicide applications proposed in the EIS are directed, 

not broadcast, sprays. Aerial applications are excluded from Alternatives 3 and 4 (the Proposed Action) west of 

the Cascades, in part to avoid drift into undetected waters.

Application of aquatic herbicides to control aquatic invasive plants would be done only where the overall impact 

on present and future water body conditions would be positive, where collateral mortality of native plants or the 

effect of the killed plants on water quality are neutral or better when considered in context with the effects of the 

invasive plants themselves. 

However, findings of ACS consistency are made during project-level planning and are based on project design, 

Watershed Analysis specific to the watershed in which treatments are proposed, and other site-specific factors.

202. Comment: The problem of aquatic invasive plants appears to be very limited in Oregon. This suggests 

that manual and mechanical control would be feasible, and does not require 2,4 D, diquat, and glyphosate 

herbicide treatment.

Response: Riparian and wetland invasive plants have not been inventoried intensively. Acres shown on Table 

A7-1 are small because aquatic habitats are limited. Elodea, parrot’s feather, Bohemian knotweed, Japanese 

knotweed, yellow flag iris, and purple loosestrife have been treated by the BLM in the past. Other weeds getting 

treatment in riparian areas for restoration projects in the recent years are Himalayan blackberry, saltcedar, Russian 

olive, perennial pepperweed, and butterfly bush. Any State listed noxious weed in a wetland or riparian area can 

inhibit habitat functions that only these areas can provide. On the east side of the Cascades in particular, the East 

Side Riparian Biome description explains that these areas provide benefits that greatly outweigh the acres they 

cover, so basing treatment on acres alone would lead to improper treatment priorities. Manual and mechanical 

means are often more disturbing to wet areas than an herbicide application by hand. Manually removing weeds 

from water can be impractical, since not all material can be collected. 

All three herbicides listed above are labeled for use in the wetland or riparian environment and are thus 

appropriate for treating undesirable vegetation in these areas. Treatments are generally in conjunction with other 

landowners (private or as part of a watershed council project) so entire stream systems are treated. Methods that 

would miss some plants would reduce the treatment effectiveness for all sections, since streams could quickly 

transport seeds and other vegetative material to other areas.

Fish

203. Comment: What is the basis for the Chapter 2 Comparison of the Effects of the Alternatives statement that 

benefits to fish from Alternatives 2 through 5 would outweigh the impacts from toxic herbicide use? There is no 

clear cost/benefit analysis in the EIS to justify this repeated assumption.

Response: The Comparison of the Effects of the Alternative section in Chapter 2 of the Draft EIS summarized the 

key conclusions from the more detailed resource sections in Chapter 4. The Chapter 4 resource sections indicate 
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that the amount and types of herbicide uses proposed by the BLM, using required site-specific analyses, Standard 

Operating Procedures and PEIS Mitigation Measures, and Endangered Species Act consultation, are expected to 

result in little to no adverse effects to fish. On the other hand, invasive plants displace native plant communities 

and expose watersheds and stream banks to erosion, increase runoff temperatures, reduce stream shading and 

native food sources, and have other adverse effects to fish. Any significant reduction or slowing of invasive 

plants is thus predicted to benefit fish, and this benefit is predicted to be well beyond the potential for adverse 

herbicide effects arising from the uses proposed under the alternatives. While both sides of this comparison 

include qualitative judgments, various estimates of the economic impact of invasive plants, and the quantitative 

risk calculations made in the Risk Assessments and reflected on the “Risk Categories” tables in Chapter 3, tend to 

support this conclusion.

204. Comment: There is no quantified or clear analysis supporting the assumption under Alternative 4 (the 

Proposed Action) that the benefits of invasive plant control would outweigh herbicide risks to fish.

Response: The risks to fish from herbicides are well studied and quantified, but only to the degree exposure is 

known. At the scale of this EIS, the BLM cannot conclude with certainty that herbicides could not potentially 

reach fish-bearing streams and cause adverse effects. However, site-specific analysis and application of Standard 

Operating Procedure-required buffers and other measures minimize the likelihood of exposures, and reduce the 

actual risk to fish to extremely low levels. The presence of certain herbicides in some of the State’s rivers, for 

example, does not indicate that BLM applications are implicated, or that BLM applications would contribute 

measurably or at all. BLM herbicide use under the Proposed Action would be less than one percent of the 

pesticides used in Oregon (Table 4-1). Required buffers, typical rates, spot treatments, and other measures mean 

that BLM contributions to adverse fish effects in Oregon would be orders of magnitude lower than even the one 

percent that might be inferred from these numbers.

The spread of invasive plants, however, is predictable and observable. Effects of this spread on stream shading, 

food sources, and stream-bank stability are known and discussed under Invasive Plant Effects in the Fish section. 

Although the actual spread reduction that would be accomplished under each alternative is a calculated estimate, 

rendering a portion of the conclusion qualitative rather than quantitative, the Alternative 4 (the Proposed Action) 

conclusion that the weed spread reduction would be more beneficial than the risk from herbicides is well founded 

and clear.

205. Comment: A recent study (Baldwin et al. 2009) examined the effects of exposure to sub-lethal amounts of 

various pesticides (including herbicides) on salmon. Major efforts are currently underway to restore Pacific salmon 

habitats in an effort to recover depressed populations. However, not much research has been done to determine the 

importance of pollution as a limiting factor of Federally Listed species. Pesticide exposure lasting only four days can 

change the freshwater growth and, by extension, the subsequent survival of sub yearling salmon.

Response: The study by Baldwin et al. (2009) used a modeling approach to link short-term, sub-lethal exposures 

of organophosphate and carbamate insecticides to chinook salmon. They did not consider herbicides. Because 

insecticides and herbicides work so differently it is difficult to compare the sub-lethal effects to fish between the 

two pesticides. However, the analysis shows that some of the herbicides analyzed in this EIS could harm fish 

if they were exposed. The amount of herbicides expected to reach water are expected to be very low under the 

alternatives in this EIS, and site-specific treatment design and required Endangered Species Act consultation 

would attempt to prevent adverse effects to Federally Listed species, including sub-lethal effects. At the scale of 

this EIS, the BLM cannot conclude with certainty that herbicides could not potentially reach fish-bearing streams 

and cause adverse effects. Herbicide use at the local or project scale, conducted under the Standard Operating 

Procedures and PEIS Mitigation Measures, and following site-specific analysis and appropriate consultation, is 

unlikely to contribute substantially to downstream effects.
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Final Environmental Impact Statement: Appendix 10

206. Comment: The EIS fails to consider the synergistic effects to salmon from herbicides proposed to be 

applied by the BLM and those pesticides already present in the streams from other users.

Response: There is no sound way to estimate background levels of contaminants in the environment and 

incorporate that information into a quantitative Risk Assessment. It is impractical and beyond the scope of this 

EIS to evaluate the potential effect of all possible pesticide contaminants in all surface water bodies of Oregon.

The BLM has done extensive analysis to study the effects of all of the proposed herbicides, and has adopted 

Standard Operating Procedures and PEIS Mitigation Measures (Appendix 2) to prevent or limit translocation to 

surface waters and effects to non-target species. These include using appropriate herbicide-free buffer zones for 

herbicides not labeled for aquatic use based on Risk Assessment guidance, with minimum widths from water 

of 100 feet for aerial, 25 feet for vehicle, and 10 feet for hand spray applications. Additional herbicide-specific 

buffer zones may be established for water bodies, habitats, and fish or other aquatic species of interest based on 

Endangered Species Act consultation requirements and site-specific analysis.

A discussion of Synergistic Toxicity of Mixtures in the Aquatic Environment has been added to the Fish section in 

Chapter 4.

207. Comment: New information since the PEIS Biological Opinion (NMFS 2007) indicates mixtures of 

pesticides that have been commonly reported in salmon habitats may pose a more important challenge for 

species’ recovery than previously anticipated (Laetz et al. 2009:348). Although Laetz et al. (2009) did not test the 

herbicides proposed for use by the BLM, the fact remains that pesticides found to be not lethal singly may become 

lethal when mixed (Laetz et al. 2009:348) and with toxicity that greatly exceeds what would be expected from 

merely additive effects (i.e. synergistic effects). 

Response: At the scale of this EIS, the BLM cannot conclude with certainty that herbicides could not potentially 

reach fish-bearing streams and cause adverse effects. However, the amount of herbicides expected to reach water 

is expected to be very low under the alternatives in this EIS, and site-specific treatment design would attempt to 

prevent adverse effects to aquatic species, including synergistic effects. 

Laetz et al. (2009) studied the synergistic effects of multiple insecticides on fish. Cumulative adverse effects to 

humans or other elements of the environment are most likely when two pesticides share a common mechanism 

of toxicity. That is, they both affect an organism the same way. Cumulative effects assessments conducted by 

the EPA typically begin by grouping pesticides by mechanism of toxicity (EPA 2002). Because insecticides 

and herbicides work so differently, even a concurrent application would be unlikely to result in significant 

environmental effects when both products are applied within label limits. As a group, insecticides are far more 

likely to adversely affect fish than herbicides, because insects and fish share most biological processes. 

The potential for synergistic effects to fish was examined in the Risk Assessments (Appendix 8). The information 

reported by Laetz et al. (2009) has been incorporated into the Fish section. 

208. Comment: The PEIS Biological Opinion (NMFS 2007) cannot be used for herbicide proposals/decisions in 

the EIS because of new scientific information about unexpected synergistic (lethal) effects to Coho salmon from 

pesticide combinations.

Response: The analysis provided in this programmatic EIS adequately addresses the potential impacts to 

Federally Listed species and critical habitat when considered as a supplement to the Biological Assessment 

completed for the PEIS as described in Appendix 5. Appendix 5 of the EIS provides information concerning 
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Federally Listed species known to occur in Oregon and is provided as a supplement to the Biological Assessment 

which is incorporated by reference in accordance with 50 C.F.R. 402.12 (g). The EIS is programmatic by design 

and does not identify or authorize site-specific vegetation treatments or amend Land and Resource Management 

Plans. As a programmatic analysis, the EIS contains the appropriate level of Endangered Species Act analysis at 

the scale for which it was intended. To minimize potential impacts to Federally Listed species and critical habitat, 

all Standard Operating Procedures and PEIS Mitigation Measures indentified in Appendix 2 of the EIS, as well as 

the protective measures in the PEIS Biological Opinion (NMFS 2007) are applicable unless otherwise modified 

by subsequent site-specific analysis and Endangered Species Act consultation. The EIS states that site-specific 

analysis, as well as Endangered Species Act consultation, must be completed prior to any project approval for 

vegetation treatments with herbicides. It is at the site-specific level that potential impacts to specific Federally 

Listed species are best analyzed and the most effective Conservation Measures are developed.

The local Biological Assessment and supporting documentation must include relevant reports, including EISs, 

Environmental Assessments, Biological Assessments, or other analyses prepared on the proposal and other 

relevant studies or other information available on the action, the affected Federally Listed species, or critical 

habitat. In other words, new scientific information about unexpected synergistic effects to Coho salmon from 

pesticide combinations would be used to develop the site-specific Biological Assessment.

There does not appear to be any significant new information indicating the PEIS consultation conclusions are 

flawed. Recent studies showing synergism of two insecticides, with resultant effects on salmonids, are neither 

unexpected nor necessarily relevant. The Risk Assessment examined the potential for synergistic effects of 

herbicides, and no new information indicates the Risk Assessment conclusions are wrong or inadequate.

209. Comment: The discussion of herbicides in the Fish section states that diuron has a low to moderate 

tendency to bioaccumulate. Based on research done on fathead minnows by Call et al. (1987), that statement 

should be changed to “diuron has a low tendency to bioaccumulate.”

Response: Carp (Cyprinus carpio) exposed for 6 weeks to diuron had experimental bioconcentration factor 

(BCF) values from two trials ranging from 3.4 to 4.9 (0.5 mg/l exposure) and <3 to 74 (0.05 mg/l exposure)7

(Chemicals Evaluation Research Institute 2000). According to (Franke et al. 1994), these BCF values suggest the 

potential for bioconcentration in aquatic organisms is low-to-moderate. Based on these references the original 

language has been retained, but a statement has been added that diuron has a low tendency to bioaccumulate in 

fathead minnows.

Wildlife Resources

210. Comment: BLM fails to address the inherent complexity and complex interspersion of vegetation across the 

landscape, and instead claims that “treatments” are necessary to create more of a mosaic, or for greater diversity.

Response: The Wildlife Resources section reports on literature that suggests mosaics of habitat, rather than large 

monocultures, benefit many species. Some wildlife in some areas will benefit from the creation of mosaics; 

the examples in the EIS are mostly the facilitation of habitat improvement projects already identified in sage 

grouse Conservation Strategies. Conversely, some wildlife could be adversely affected by large-scale habitat 

improvement; hence, a potential mitigation measure is included in Chapter 2 suggesting such treatments mimic 

natural disturbance mosaics. However, the EIS does not attempt to fully describe or justify vegetation treatment 

7 Bioconcentration factor is the concentration of a particular chemical in a tissue per concentration of chemical in water.
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Final Environmental Impact Statement: Appendix 10

prescriptions. Actual habitat improvement and other vegetation treatment needs are identified in the districts’ 

Land and Resource Management Plan, species management plans, and other planning documents. Treatment 

acres used in the EIS are simply program estimates made by the districts based on knowledge of existing plans 

and site-specific needs. These estimates provide a basis for the statewide herbicide cumulative effects analysis, 

and are not a commitment to conduct projects. 

211. Comment: Landscape-level fragmentation, cheatgrass presence, livestock facilities, and other information 

about degraded sage grouse habitat (USGS 2009) should be considered in the cumulative impact analysis of 

herbicide use where there is potential for native vegetation (required by sagebrush-associated species) to be killed. 

Response: Both the Sage Grouse Conservation Assessment (Connelly et al. 2004) and Ecology and Conservation 

of Greater Sage-Grouse: A Landscape Species and Its Habitats (USGS 2009) were reviewed and considered 

in preparation of the EIS and would be considered again when actual treatments are proposed. Invasive plant 

treatments in infested sage grouse habitats would normally be spot treatments or would be a part of restoration 

projects carefully designed to benefit sage grouse. Standard Operating Procedures and PEIS Mitigation Measures 

included in Appendix 2 would help prevent the treatment of vegetation needed by wildlife species during an 

herbicide application. Hence, the BLM does not anticipate any significant adverse cumulative impacts to native 

wildlife from the treatment of noxious weeds and other invasive plants. However, invasive weed and habitatimprovement treatment estimates in the EIS are for herbicide cumulative effects analysis, and actual vegetation 

treatment decisions would follow local direction and be subject to site-specific analysis.

According to Connelly et al. (2004), use of herbicides on private land was historically used to improve forage 

for livestock grazing and this was often done at the expense of native species. This EIS does not propose the use 

of herbicides for livestock forage production. The Proposed Action (Alternative 4) is designed in part to protect 

native ecosystems and the flora and fauna that depend on them; provide sustainable habitats for wildlife, fish, and 

native plants; and prevent herbicide control treatments from having unacceptable adverse effects to desirable flora 

and fauna. 

The EIS found that the differences between the alternatives regarding noxious weed spread are more detrimental 

than the risks from herbicides proposed under those alternatives.

212. Comment: The EIS needs to explain the anticipated effects of herbicide use on fragmented sagebrush 

habitats and sagebrush dependent species such as the sage grouse, pygmy rabbits, Brewer’s sparrow, sage 

sparrow, and sage thrasher.

Response: Sagebrush habitats and the species that depend on them have been negatively impacted by the 

spread of noxious weeds and other invasive plants. A significant portion of the Proposed Action (Alternative 4) 

endeavors to reduce the rate of invasive plant spread and help reduce further degradation of imperiled habitats 

such as those associated with sagebrush steppe ecosystems. No treatment is entirely risk free, but the herbicides 

proposed in this EIS were chosen to have minimal toxic impacts to native plant and wildlife species. Prior to any 

specific herbicide treatment, site-specific analyses would be conducted; the action alternatives in this EIS would 

add several herbicides to the choices available, so the best combination of mechanical and herbicide treatments 

for the wildlife and plants in their area would be used. In many cases, herbicide treatments would provide a 

means to restore habitat for these species that is not available with currently approved herbicides and mechanical 

treatments. Habitat improvement projects permitted under Alternative 4 (the Proposed Action) and Alternative 

5 could specifically improve or protect sage grouse and other wildlife habitats. Standard Operating Procedures, 

PEIS Mitigation Measures, and Conservation Measures for Special Status species (identified in Appendix 2 of this 

EIS) would help to reduce or avoid adverse treatment effects. 
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213. Comment: Shrubland and grassland birds such as Brewer’s sparrow, sage sparrow, and sage thrasher are 

declining faster than any other group of species in North America (Saab and Rich 1997, Paige and Ritter 1999, 

Dobkin and Sauder 2004) and may be important predictors of ecological collapse.

Response: Although these bird species are not Special Status species, they are Fish and Wildlife Service Birds 

of Conservation Concern. As such, they are evaluated in project planning (USDI 2008c, 2009x). The references 

cited in the comment are consistent with the Habitat Change Resulting from Invasive Plants subsection in the 

Wildlife Resources section, which states that exotic invasive species are contributing to habitat declines. Effects 

on Brewer’s sparrow from invasive grasses adversely affecting sagebrush habitats, for example, are specifically 

mentioned. Restoration of healthy sagebrush communities for native plants and animals (including the rare birds 

mentioned in the comment) is one of purposes of the EIS. The Proposed Action (Alternative 4) incorporates 

Standard Operating Procedures and PEIS Mitigation Measures to allow restoration to occur while minimizing 

adverse effects to native wildlife species. Additional information on the Brewer’s sparrow, sage sparrow, and sage 

thrasher has been incorporated into the Wildlife Resources section. 

214. Comment: Juniper birds are of high conservation concern, yet western juniper habitats are among the most 

consistently under-represented habitat types in biological and ecological survey efforts.

Response: The BLM seeks to maintain native species and habitats in a sustainable way. Any rare birds 

dependent upon western juniper habitats would be focal species where those habitats are rare (such as in the 

agriculturally dominated landscapes where western juniper were once more common). However, western 

juniper treatment projects would most likely occur in areas where western juniper has expanded into sagebrush 

communities, and are affecting native wildlife in those communities. Western juniper would not be treated where 

they have not become out of balance with historic and sustainable communities. The western juniper control 

referenced in the EIS is an estimate made by the districts based on local vegetation management issues and 

priorities. The EIS does not propose or approve actual projects; decisions to control western juniper would be 

made following site-specific analysis.

215. Comment: The EIS fails to adequately display the effects of increased herbicide use on birds. The EIS 

should address the potential impacts to birds using the Partners in Flight Assessment factors, which include 

population size, breeding distribution, non-breeding distribution, threats to breeding, threats to non-breeding, and 

population trend (Rich et al. 2005). 

Response: BLM is a partner in the Partner in Flight program, and reference to the BLM’s participation in this 

program has been added to the Wildlife Resources section. The factors listed in the comment would be considered 

when identifying potential impacts at the project level. Impacts related to breeding and specific population trends 

vary depending on the ecosystem affected, species’ occurrence, pre-project habitat condition, the objective of 

the treatment proposed, and the timing, dosage, and application method of the treatment, all of which cannot be 

accurately identified or analyzed in a statewide, programmatic EIS. The EIS predicts the potential effects under 

proposed dosages and scenarios, and identifies Standard Operating Procedures and PEIS Mitigation Measures 

designed to reduce impacts to the extent possible at this programmatic scale. These analyses would identify 

the potential effects of specific herbicide treatments to the wildlife species and habitats within a defined project 

area. Site-specific analysis would utilize the factors identified by Partners in Flight and many other wildlife 

and resource parameters in their analysis of applicable effects of a specific project in order to choose the most 

effective treatment to meet the objective while having the least impact to wildlife and other resource values.

216. Comment: Direct exposure and indirect ingestion of chemicals by birds and grazing or insectivorous 

mammals through food or water have caused skin and eye irritation, respiratory distress, organ malfunction, 

suppressed immune response, reproductive problems and behavioral changes leading to reduced vigor or survival. 
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Final Environmental Impact Statement: Appendix 10

Response: The Wildlife Resources section discloses that the use of chemicals can have deleterious effects to 

wildlife, and no chemical treatment is entirely risk free. Direct effects to wildlife from herbicides would depend 

on the dose (how much herbicide), exposure (whether direct contact or ingestion of contaminated food or water), 

and the toxicity or LOAEL of that level of dosage (if any). The Ecological Risk Assessments (Appendix 8) that 

form the basis of the Wildlife Resources effects discussion determine the possibility of having the effects noted in 

the comment at plausible exposure scenarios. The resultant risk levels for plausible scenarios are shown on the 

“Risk Categories” tables at the end of Chapter 3 and are considered in the Wildlife Resources effects discussions. 

Many of the adverse effects reported in the literature are from dosages hundreds of times higher than plausible 

BLM spray scenario exposures. 

217. Comment: A literature review (including Bernanke and Kohler (2008)) suggests a link between endocrine 

disrupting chemicals and the reproductive system of birds and other vertebrates. The EIS should include and 

address this research. 

Response: The potential for any of the herbicides included in this EIS to be endocrine disrupters is discussed 

in the Effects Common to All Alternatives section within the Wildlife Resources section, and in the Human 

Health and Safety section. The EPA reports that endocrine disruption effects can include abnormal thyroid, 

decreased fertility, decreased hatching success and demasculinization, and feminization of birds. The EPA is 

in the process of evaluating all pesticides for these potential effects, but to date, there is no confirmation that 

any of the herbicides proposed in the EIS are known endocrine disruptors of wildlife in field situations. Many 

papers, including Bernanke and Kohler (2008) summarize the effects of several different chemicals (including 

PCBs, DDT/DDE, and organochlorines) into an EDC (endocrine disrupting chemical) group. PCB’s, DDT/DDE 

insecticides and organochlorines all have documented adverse effects to wildlife, but are not proposed for use by 

this EIS. The herbicides proposed in this EIS were chosen to have minimal adverse impacts to non-target species. 

218. Comment: Although Roundup is not registered for aquatic uses and studies of its effects on amphibians 

indicate it is toxic to them, scientists have found that it may wind up in small wetlands anyway due to 

inadvertent spraying during its application. Studies found that even at concentrations one-third of the maximum 

concentrations expected in nature, Roundup still killed up to 71 percent of tadpoles raised in outdoor tanks.

Response: Herbicide formulations like Roundup® that are not registered for aquatic use would not be applied by 

the BLM near water. The surfactant POEA (a surfactant in most Roundup formulations) is associated with risk to 

aquatic organisms and amphibians and thus would also not be used near water. Standard Operating Procedures 

prescribe minimum buffers between water and treatments with non-aquatic herbicides to lessen the risk of 

herbicides entering water. These also require that additional buffer widths be developed based on herbicidespecific and site-specific conditions to minimize impacts to water quality. Buffers limit the transport of herbicide 

from upland treatments to water (Water Resources, Berg 2004, Dent and Robben 2000, Rashin and Graber 

1993). The Standard Operating Procedures and PEIS Mitigation Measures are designed to minimize the risk of 

inadvertent overspray and the site-specific potential for inadvertent overspray would be evaluated and addressed 

in project level analysis. 

219. Comment: The EIS does not adequately address the potential effects of herbicide use on amphibians, 

reptiles, and mollusks. Although the EIS mentions that some herbicides have low toxicity to mollusks, no further 

analysis is provided. Recent research suggests that triclopyr and hexazinone have adverse effects to amphibians 

(Relyea et al (2005), Bernanke and Kohler (2008)), and that diuron inhibits ovulation in frogs (Orton et al 2009). 

Research by Relyea (2005) suggests adverse effects of the herbicide glyphosate on amphibians. 

Response: The Effects Common to all Alternatives subsection of the Wildlife Resources section discusses 

potential impacts to amphibians, reptiles, and mollusks. Relyea (2005) and Relyea et al (2005) both describe 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

effects of glyphosate formulations that include the surfactant POEA on amphibians and laboratory communities of 

aquatic organisms. The surfactant POEA is identified in both papers as adverse to amphibians.

Bernanke and Kohler (2008) summarize the effects of several pesticides (including insecticides and herbicides 

not proposed for use on BLM lands). Two herbicides being proposed for use are mentioned in their summary: 

triclopyr and hexazinone, which were evaluated by Berrill et al (1994). The study by Berrill et al. (1994) 

evaluated dose levels likely to occur in commercial forestry applications, a much different application than 

proposed by BLM. Even in the studied application, Berrill et al. (1994:658) noted that field level dosages of 

hexazinone were unlikely to affect invertebrates, resident animals, tadpoles, and embryos. Laboratory studies 

reported in Orton (2009) suggest some minor changes to testosterone levels in frogs due to diuron, but it was not 

clear that such effects rose to a level that caused adverse effects to the animals. No estrogenic effects were noted. 

Local project planners would evaluate habitat for rare species and incorporate appropriate buffers around wetlands 

and ponds. Appendix 2 details Standard Operating Procedures and PEIS Mitigation Measures specifically 

designed to reduce the chance of wildlife exposures. These include avoiding the use of glyphosate with POEA to 

avoid risks to amphibians.

220. Comment: The spraying of roadsides, rights-of-way, campgrounds, and around BLM offices and buildings 

would deprive butterflies of much of their current territory, as those are places where sun-loving native plants 

often grow. 

Response: Rights-of-ways and other developed areas require safety and maintenance treatments specific to 

their objectives, and wildlife habitat may be a secondary objective. It is assumed that in these areas, vegetation 

is currently being maintained primarily with mechanical methods, such as mowing (see Chapter 3). However, 

prior to any specific herbicide treatment, site-specific analyses would be conducted that would include wildlife 

surveys and other efforts to identify particularly important wildlife habitat. Such information can be used to 

design mitigation measures, make a treatment method selection, and design habitat restoration projects to protect, 

conserve, or develop alternate habitat for potentially impacted species if appropriate. It is BLM policy to maintain 

natural conditions that support sustainable populations of native wildlife, particularly rare species.

221. Comment: The EIS lacks specificity in describing the actual effects of herbicides on wildlife. 

Response: The effects of herbicide use on wildlife discussed in the Wildlife Resource section are summaries 

of the detailed BLM and Forest Service Risk Assessments. These Risk Assessments are based both on models 

and surrogate species, as well as on wildlife (the EPA does not require the testing of herbicides on wildlife, 

and allows the use of surrogate species for Risk Assessments). The EIS also evaluated recent literature on the 

effects of herbicides on wildlife that have been published since the Risk Assessments were completed. The Risk 

Assessments are discussed in Chapter 3 and are included in Appendix 8. 

Effects are summarized in terms of expected dose (Risk quotient, or RQ; or Hazard Quotient, or HQ) of the 

herbicide and whether that exposure level exceeds the level of concern (LOC) for each wildlife group tested. 

BLM’s evaluated herbicide risk categories summarize the High, Moderate, or Low chance that the RQ would 

exceed the LOC for the scenario and exposure method discussed. The risks vary by application scenario, the 

animals tested, whether typical or maximum dosage is applied, and many other factors. The actual nature of 

the adverse effects varies; the LOC is based on the first observable adverse effect. This is often eye irritation; 

the LOC does not usually mean mortality. Actual field risks are likely to be less than analyzed in the Risk 

Assessments because of the low likelihood that native wildlife would actually be in contact with the herbicide 

or with food/water sprayed by herbicide, at the modeled doses, or would be exposed to such a level that adverse 

effects might occur. Most herbicide treatments would be highly focused to treat invasive species and to reduce 

chances of non-target species being affected.
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Final Environmental Impact Statement: Appendix 10

The Wildlife Resources section also describes the potential effects to wildlife food, behavior, and interspecific 

reactions that may occur from the treatment methods. Effects to wildlife would vary widely by species, timing, 

treatment method and treatment herbicide, extent and other factors that cannot be evaluated at a programmatic 

level. The EIS predicts the potential effects under proposed dosages and scenarios, and identifies Standard 

Operating Procedures and PEIS Mitigation Measures (Appendix 2) designed to reduce impacts to the extent 

possible at this programmatic scale. Prior to any specific herbicide treatment, site-specific analyses would be 

conducted, and these analyses would identify the potential effects of specific herbicide treatments to the wildlife 

species and habitats within a defined project area. These site-specific analyses would allow for the incorporation 

of such things as buffers, seasonal restrictions, partial treatments of occupied habitat, and other appropriate 

application methods to reduce potential risks to wildlife. Until actual projects are proposed, it is impossible to say 

what site-specific effects would be.

Livestock

222. Comment: The Draft EIS states in Chapter 1 that it “does not propose the use of herbicides specifically 

for commodity production such as projects to improve ... livestock forage.” This statement is not reflected in 

the rest of the rest of the EIS. For instance, the EIS describes how ranching on lands adjacent to BLM would 

commercially benefit by the BLM using herbicides. 

Response: The word “commodity” in the description of the Alternatives in Chapter 2 has been replaced with 

“specifically for livestock forage or timber production,” to remove confusion about other economic effects. 

Noxious weeds adversely affect commodity and non-commodity resource values statewide. These effects are 

one reason weeds are listed as “noxious” by the State. The Livestock section, therefore, displays the effects of the 

various alternatives on livestock use, the same as the Recreation section, Fish section, and so forth. Examination 

of the effects of the alternatives on resource values such as livestock use is a requirement of NEPA, and does not 

infer herbicides would be proposed specifically to improve livestock forage production. This point is discussed in 

more detail in the first two paragraphs of the Livestock section.

223. Comment: There is no summary of acres of disturbance by livestock, or of range improvement projects such 

as pipelines, troughs, livestock facility roads, and fences that are or may become infested and serve as weed conduits.

Response: The Noxious Weeds and Other Invasive Plants section notes that numerous vectors and events 

contribute to invasive weed spread including grazing and its appurtenant developments. However, an examination 

of the factors contributing to weed spread is outside the scope of the EIS; they are mentioned only to support a 

better understanding of the effects of the alternatives. Grazing is authorized by the FLPMA, Public Rangeland 

Improvement Act, O& C Act, and the Taylor Grazing Act, and a reconsideration of grazing or its effect on the 

spread of invasive plants is beyond the scope of this analysis. The potential for grazing and related activities to 

spread weeds is analyzed during district planning processes and in the analyses for site-specific ground disturbing 

projects such as fences and pipelines, forage enhancements, and other projects that have the potential to alter plant 

communities. These analyses must include an assessment of the risk of introducing noxious weeds and other 

invasive plants. 

224. Comment: The EIS needs to recognize livestock grazing exacerbates any climate change-related vegetation 

shifts that may be occurring, particularly in areas facing increased heat and aridity due to climate change.

Response: A consideration of grazing, or any possible interaction between grazing and climate change, is outside 

the scope of this EIS.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

225. Comment: The EIS should address the effects of intensified grazing as livestock are shifted away from 

sprayed areas. The EIS should mandate livestock removal from treated areas.

Response: Livestock exclusion times are short, most treatment areas under this EIS would be small, and 

livestock are already frequently moved to accommodate range conditions. Required herbicide exclusions are not 

likely to result in adverse grazing effects to alternative grazing sites. Site-specific planning for larger control or 

restoration projects such as those involving imazapic over thousands of acres would include consideration of the 

effects on alternate grazing sites.

Wild Horses and Burros

226. Comment: The discussion of wild horses and burros in the Comparison of the Effects of the Alternatives

section in Chapter 2 does not acknowledge greater risk to grazing animals from herbicides.

Response: The referenced section in the EIS noted that risks to wild horses and burros from herbicides are 

similar to those for livestock, where herbicide risks were discussed. Additional detail can be found in the 

corresponding sections in Chapter 4. The Comparison of the Effects of the Alternatives section in Chapter 2 has 

been reformatted and rewritten, and the Livestock and Wild Horses and Burros sections have been combined.

Fire and Fuels

227. Comment: Fire suppression has increased unwanted vegetation that the BLM now proposes to kill with 

herbicides, instead of considering the reintroduction of a more natural fire regime. For instance, the EIS notes in 

Chapter 1, Purpose 3, that fire suppression has resulted in a many fold increase in the number of western juniper 

east of the Cascades when compared with historic levels, and that herbicides could facilitate restoration of habitats 

for nesting sage grouse and other species.

Response: As identified in the EIS, herbicides would be used as part of an integrated vegetation management 

approach. The Proposed Action (Alternative 4) would constrain western juniper or sagebrush treatments to 

objectives specified in Conservation Strategies. The use of prescribed burning would be used to meet multiple 

hazardous fuels reduction objectives across Oregon as part of the State fuels program. A full examination of the 

use of fire for ecosystem restoration or fuels reduction is outside the scope of this EIS. Herbicides would be one 

tool for habitat manipulation and invasive grass fuels treatments; implementation decisions would be the result of 

site-specific analysis. 

228. Comment: A recent study by Dodson and Fielder (2006) and a recent master’s thesis by Dodson (2004) 

indicate a synergistic relationship between fuels treatment, fire, and increased invasion of exotic and undesirable 

species, with the greatest increases occurring with thinning followed by prescribed burning, versus no treatment at 

all. Current fuels treatments in sagebrush habitats often encourage cheatgrass invasion.

Response: The BLM recognizes that hazardous fuels treatments, like any other site-disturbing management 

activity, can contribute to the introduction and spread of noxious weeds and other invasive plants. However, as 

noted in the Fire and Fuels section, wildfire suppression activities can also introduce or spread invasive plants, 

so thinning and burning are fuels reduction tools that may be used. Decisions about if and how to conduct these 

and other activities include consideration of their potential to spread noxious weeds. Their reconsideration is 

outside the scope of this analysis; these are ongoing programs already covered in part by Integrated Vegetation 
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Final Environmental Impact Statement: Appendix 10

Management policies designed to prevent and control weed spread. For example, a management activity with 

a moderate or high risk of spreading noxious weeds is required to have a noxious weed risk assessment that

identifies actions to be taken to reduce or prevent the spread of noxious weeds. 

229. Comment: The EIS does not clearly identify vegetation to be targeted for hazardous fuels treatment using 

herbicides and appears only to identify old growth and mature native sagebrush steppe vegetation. 

Response: In the Sagebrush Steppe biome, herbicides would be used for the treatment of invasive annual grasses, 

such as medusahead and cheatgrass, which have altered the historic fire regime. In these areas, as described in the 

Fire and Fuels section, herbicides would be used to help achieve fuels reduction goals in a number of different ways: 

•	 As a standalone treatment or in combination with other vegetation treatments to change the vegetation 

structure and composition to reduce fire behavior characteristics (rate of spread, fire line intensities) and 

facilitate suppression actions;

•	 As a follow up or maintenance treatment to mechanical or prescribed fire treatments or post wildfire 

rehabilitation treatments, to either further reduce the fuels hazard or to help control new or existing 

invasions. (The EIS has been edited to help clarify the use of herbicides in conjunction with nonherbicide hazardous fuels reduction treatments.); and,

•	 To create strategically placed breaks in vegetation (fuel) continuity adjacent to wildland urban interface 

(WUI) communities or where treatment of the entire affected area would be either impractical or too 

expensive.

However, these are general estimates for programmatic analysis purposes, not a commitment to conduct 

treatments. An evaluation of treatment need and a determination of the most appropriate tools for meeting that 

need are the subject of site-specific analysis. Such treatments are normally implemented based upon vegetation 

management priorities set in Land and Resource Management Plans or other plans and policies. An examination 

of the applicability of any particular tool for meeting any particular vegetation management objective is outside 

the scope of this EIS.

230. Comment: The EIS is not clear how the BLM’s existing fuels control program of brushing, controlled 

burns, thinning, and other activities would be affected by herbicide use.

Response: A noted in the Fire and Fuels section, only Alternative 5 would permit herbicides to be used to control 

native plants contributing to high fuel loading. An example might be a treatment to desiccate vegetation so a 

subsequent prescribed burn can be conducted more safely and under less intense burning conditions. The analysis 

states that such treatments would be rare in Oregon; fuels issues in the State do not normally lend themselves to 

those types of treatment.

Alternatives 3 through 5, however, would permit the use of herbicides on noxious weeds and invasive annual 

grasses currently invading susceptible sagebrush habitats and increasing the risk of hot fast wildfires in some 

unban interface areas. Herbicides, such as imazapic, could be used alone or in combination with prescribed 

fire to reduce these fuels in the wildland-urban interface, or to create protection zones through important 

sagebrush steppe habitats. These herbicide treatments would be in the range of one to five percent of the total 

fuels treatments done by the BLM in Oregon annually. Herbicides would also be used to prevent reinvasion 

of some wildfire areas with invasive annual grasses. These uses are described in detail in the Fire and Fuels

section in Chapter 4.
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Timber

231. Comment: The Draft EIS states in Chapter 1 that it “does not propose the use of herbicides specifically for 

commodity production such as projects to improve timber growth...” This statement is not reflected in the rest of 

the rest of the EIS. For instance, the EIS describes how logging on lands adjacent to BLM would commercially 

benefit by the BLM using herbicides. 

Response: The word “commodity” has been replaced with “specifically for livestock forage or timber 

production,” to remove confusion about other economic effects. That said, noxious weeds adversely affect 

commodity and non-commodity resource values statewide. These effects are one reason weeds are listed as 

“noxious” by the State. The Timber section, therefore, displays the effects of the various alternatives on timber 

production, the same as for the Recreation section, Fish section, and so forth. Examination of the effects of 

the alternatives on resource values, such as timber production, is a requirement of NEPA, and does not infer 

herbicides would be proposed specifically for timber production. This point is discussed in more detail in the first 

two paragraphs of the Timber section.

Paleontological and Cultural Resources

232. Comment: Herbicides should not be applied in areas of American Indian traditional use and subsistence 

activities.

Response: The Standard Operating Procedures implemented for weed treatment include provisions for reducing 

risks to traditional use areas from herbicide treatments. Included in the Standard Operating Procedures is a 

provision for consulting and working with tribes to minimize impacts from herbicide treatments to areas of 

vegetation considered significant by the tribes. Implementation of the Standard Operating Procedures with 

cultural resource review, and inventory and consultation with American Indian tribes in areas likely to include 

cultural resources and traditional cultural values prior to vegetation treatments, would reduce potential adverse 

effects to native plants species and wildlife utilized in traditional American Indian activities. Treatments 

potentially affecting the public would also be signed per Standard Operating Procedures and label requirements.

Traditional use and subsistence activities are adversely affected by the spread of invasive plants and displacement 

of plants and animals of traditional importance. Because only about 1/3 of the noxious weeds on BLM lands 

can be effectively controlled with non-herbicide methods, the ability to respond to specific weed problems in 

traditional tribal use areas would be reduced. Without the ability to use herbicides, weeds and other invasive 

vegetation would continue to displace native species desirable to traditional American Indian activities and would 

adversely affect the quality of forage and cover for wildlife utilized by tribes. 

Visual Resources

233. Comment: It seems implausible that people would prefer the appearance of vegetation that has been treated 

with herbicides to the appearance of vegetation that has been mowed as stated in the Summary of the Major 

Effects of Each Alternative section in the Summary.

Response: The language in the Summary of the Major Effects of Each Alternative in the Summary (and similar 

language in Chapter 2) did not accurately reflect the discussion of visual effects found in Chapter 4, and the 

verbiage related to the visual effects of mowing and herbicide use has been removed. The Visual Resources
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Final Environmental Impact Statement: Appendix 10

section notes that mowing has the short-term visual effect of cut and browned vegetation and that the visual 

effect of using herbicides to treat vegetation varies depending on which herbicide is applied and how it is applied. 

When herbicides are applied directly to the invasive plant using a backpack sprayer or wicking method, the shortterm visual impact is browned and dead vegetation mixed with green native vegetation. When non-selective 

herbicides are applied aerially or with a boom sprayer, the resulting short-term visual effect is one of an open, 

browned landscape. If herbicides are used in areas in place of mowing (such as along roadsides) the short-term 

visual effect would be a swath of browned and dead vegetation. 

Wilderness and Other Special Areas

234. Comment: The EIS proposes to increase the use of herbicides in such areas as Wilderness Areas, National 

Monuments, and Wild and Scenic Rivers and does not adequately estimate the number of people likely to be 

exposed to the herbicides or the effects of this exposure on the visitors to these areas. 

Response: With a greater variety of herbicides available to treat noxious weeds and other invasive plants under 

Alternatives 3, 4 and 5, the EIS assumes there would be increased use of herbicides across all BLM administered 

lands including Wilderness Areas, National Monuments, and Wild and Scenic Rivers. With increased use of 

herbicides, there is an increased likelihood of human exposure. This programmatic EIS does not identify where 

specific herbicide treatments would take place, therefore, it does not attempt to quantify the likelihood of visitor 

exposure to herbicides. The Risk Assessments, summarized on the “Risk Categories” tables at the end of Chapter 

3, include recreational users such as hiker/hunters, anglers, berry pickers, swimmers, and subsistence users of 

plant materials. The categories for most of the herbicides likely to be used within special areas indicate no risk 

for these activities. Whether or not an herbicide might pose a risk to one of these user groups would be a sitespecific consideration in the selection of which herbicide to use and the timing of the application. Prior to any 

specific herbicide treatment, site-specific analyses would be conducted that would include public notification and 

opportunity for public comment and involvement. 

In order to help protect public land visitors from herbicide exposure, access to treatment sites is restricted for a 

short time. During these closures, the BLM posts signs noting the exclusion area and the duration of the exclusion. 

Wording explaining this closure procedure has been added to the Wilderness and Other Special Areas section. 

235. Comment: The Western Rivers Conservancy is in the process of purchasing Wildwood Park and associated 

properties along the Wild and Scenic Salmon River near Welches, Oregon. The purpose is to resell to the BLM 

to protect the Salmon River Watershed. Use of herbicides in this area would appear to be in conflict with the 

watershed protection efforts being done in the Salmon River watershed, and would likely not be supported by the 

local community.

Response: Herbicide treatment within Wild and Scenic River corridors are only permitted if they are conducted 

in an effort to protect and enhance the outstandingly remarkable values identified in the legislation establishing 

the river designation. If those values involve public access developments, herbicides might be used for their 

maintenance. The analysis in the Water Resources and Fish sections of the EIS indicates proposed herbicide 

uses are not likely to compromise water and watershed protection objectives including those in Wild and Scenic 

Rivers. Watershed values would be best protected by controlling invasive plants. Permitting invasive plants to 

displace native ecosystems within donated Wild and Scenic River corridors would be poor land stewardship. An 

example of herbicide treatments getting wide public support is the ongoing interagency effort to control Japanese 

knotweed along the Clackamas and Sandy Rivers (CRBC 2008). Prior to any specific herbicide treatment, sitespecific analyses would be conducted that would include public notification and opportunity for public comment 

and involvement. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Recreation/Interpretive Sites

236. Comment: BLM should require, not simply encourage, weed-free feed for grazing and recreational pack 

animals on BLM administered lands, and should provide strong inspection and enforcement measures to ensure 

the requirement is followed. 

Response: BLM’s Integrated Vegetation Management policy emphasizes the prevention of noxious weeds and 

other invasive plants and identifies a variety of prevention measures including requiring weed-free seed and 

mulch in restoration and other re-vegetation projects, and promoting the use of weed-free hay for grazing and 

recreational pack animals. The BLM in Oregon encourages the use of weed-free hay for grazing and recreational 

pack animals, because in general, enforcement of stronger measures is not feasible in Oregon at this time. BLM 

National policy on weed free forage encourages BLM state offices to work cooperatively with state and local 

agencies to implement a weed free forage plan. The Oregon Department of Agriculture has developed a pilot 

weed-free forage certification program. This is a voluntary pilot program with the intent of certifying weed 

forage as a part of overall weed prevention effort. In 2003, Wallowa County adopted the North American Weed 

Management Association certification standards and now has certified hay and straw products available. The 

BLM in Oregon will continue to work towards weed free forage as it becomes available, and will implement 

BLM National policy as it evolves. However, consideration of this policy is ongoing and outside the scope of 

this EIS. Its disposition would not affect the analysis of the alternatives because it would not materially affect the 

Need, and because a reexamination of all of the BLM policies that might change the noxious weed spread rate is 

outside the scope of this analysis. There is currently no statewide certification program in Oregon for weed-free 

hay. If weed-free hay is not available, enforcement is unlikely.

237. Comment: Posting of signs for at least two weeks following an herbicide application in a recreation area 

may not be sufficient due to herbicide persistence (e.g. picloram).

Response: The Recreation/Interpretive Sites section erroneously stated that signs would be posted for at least 

two weeks following an herbicide treatment in a recreation area. The language in this section has been edited to 

accurately reflect the procedure BLM follows when applying herbicides in recreation areas or other public access 

areas. The label requirement of the herbicide being used determines how long an area would be closed to visitor 

use following an herbicide treatment. Access to a site treated with an herbicide is usually restricted for a few 

hours or days, depending on the requirements on the herbicide label. During these closures, the BLM posts signs 

noting the exclusion area and the duration of the exclusion. An herbicide with no demonstrated risk to human 

health may have a very short exclusion time.

Administrative Sites, Roads, and Rights-of-Way

238. Comment: The EIS has correctly identified rights-of-way as a primary vector for the spread of noxious 

weeds. Control of roadside vegetation would not only greatly reduce the spread of these plants, it would provide 

the additional benefit of improving sight distance and subsequently the safety of its road systems.

Response: The Administrative Sites, Roads, and Rights-of-Way section includes sight distance as one of the 

safety and maintenance objectives for vegetation treatments along roadsides. This objective could be met in part 

by using herbicides under Alternative 4 (the Proposed Action) and Alternative 5. Such use could be particularly 

advantageous in checkerboard lands where private timber companies share road ownership and maintenance 

responsibilities. Under Alternatives 4 and 5, herbicide availability could allow shared owners to accomplish 

safety-related maintenance of entire haul routes in a single treatment. The EIS has been edited to note this benefit.
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Final Environmental Impact Statement: Appendix 10

239. Comment: Invasive weed concerns should be a priority during transportation planning on BLM lands. All 

motorized travel should be limited to designated routes, cross-country motorized use should be prohibited, and all 

unnecessary roads should be closed.

Response: Invasive weeds are one element considered during transportation planning on BLM lands, both at the 

plan and project scale. Transportation planning is beyond the scope of this EIS.

240. Comment: Public funds should not be used to pay for maintenance and protection of private and corporate 

infrastructure such as under power line rights-of-way.

Response: The EIS notes that in general, vegetation management around developments is the responsibility 

of the development owner, using methods approved by the BLM. Except for noxious weed control using one 

of the four currently approved herbicides, herbicide use is not currently approved for vegetation management 

in or around these sites. Information has been added to this section pointing out that invasive plant control on 

developed sites is also (usually) a permit-required responsibility of the development owner. Any of the action 

alternatives would provide more tools so development owners could better meet this permit requirement.

241. Comment: The National Park Service routinely uses herbicides to control noxious and non-native weeds on 

public lands, but is careful to not begin spraying in areas that do not truly need spraying. Aren’t there other cost 

effective ways to limit weed growth on roadways and in campgrounds? Rather than expose the public, wildlife, 

and native flora, aren’t there less intrusive ways to control unwanted weeds in these public area? Mowing, flame 

treatments, public education, public weed pulls, and even spot spraying of the worst weeds to control spread are 

sometime more effective, less expensive, and less harmful/toxic to the watershed and to the humans and wildlife 

that utilize these areas.

Response: BLM practices are similar to those described in the comment. Like the National Park Service, BLM 

is guided by Department of the Interior policy. That policy calls for accomplishment of pest management through 

cost-effective means that pose the least risk to humans, natural and cultural resources, and the environment, 

and requires bureaus to establish site management objectives and then choose the lowest risk, most effective 

approach that is feasible for each pest management project (Chapter 3, USDI 2007e). The BLM also has no 

wish to unnecessarily close recreation sites, or to post herbicide warning signs that discourage public use. These 

considerations help guide local decision-makers to use non-herbicide methods in such sites wherever feasible. 

Popular recreation sites are also the locations most likely to enlist volunteers to help remove infestations. Finally, 

because high public use areas are highly susceptible to invasive weeds, BLM personnel attempt to watch these 

areas so they can treat new infestations when they are small and might more easily be removed with non-herbicide 

methods. The vast majority of invasive weed (and native plant) control treatments within developed recreation 

sites are done with non-herbicide methods.

In some instances, herbicides are the most appropriate treatment method in developed sites. Many invasive plants 

cannot be reasonably controlled with non-herbicide methods; BLM dispersed sites are potentially more likely to 

become infested with invasive plants because of a broader array of seed-carrying recreational equipment use the 

area, including horses and OHVs.

Along roadways, most herbicide treatments of invasive plants are spot treatments posing little risk to the traveling 

public. A high percentage of the invasive plant treatments are along roadways because roads serve as weed spread 

corridors. The Reference Analysis shows that relying exclusively on non-herbicide methods in some areas would 

cost nearly three times more than under the Proposed Action (Alternative 4) when calculated on an effectively 

treated acre basis (Implementation Costs section in Chapter 4). Assuming fixed budgets, this would translate to 

two-thirds fewer weeds controlled.
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242. Comment: Lane County is also concerned about the pollution from herbicides and does not conduct 

roadside spraying. In addition, in April 2009, the Board of Commissioners adopted a resolution inviting the 

Oregon Department of Transportation (ODOT) to form a partnership with the County to ensure implementation 

of an effective plan to prevent roadside spraying on State roads in the County. The resolution states the board 

“finds that persistent long-term herbicide exposure is now recognized as hazardous.” The Board relied on a) a 

U.S. Geological Survey study on the prevalence in water quality samples of herbicides commonly used on roads 

and rights-of-way, b) the likelihood of the herbicides sprayed entering the water during and after rains, and c) 

scientific evidence that even small amounts of herbicides can damage aquatic life. The BLM now proposes to do 

something counter to the Board’s resolution that “persistent long-term herbicide exposure is now recognized as 

hazardous” and the intent of the County to reduce herbicide use.

Response: The BLM believes the Board’s position is more accurately interpreted as follows: The resolution 

(#09-4-8-16) indicates that Lane County has adopted a Roadside Vegetation and Last Resort Policy in which the 

Board has offered to collaborate with ODOT and share resources to assist in pesticide use reduction. The Board 

resolved as a matter of pesticide-use reduction that persistent herbicide exposure is now recognized as hazardous 

and recommends a reconsideration of routine and “residual” herbicides sprays as a roadside maintenance practice. 

The Board also resolved, in December of 2009, to support ODOTs Last Resort Herbicide Spray Pilot Project for 

Highway 36.

The EIS does not dispute that “persistent long-term herbicide exposure” would likely be hazardous. The uses 

proposed in the EIS would not result in persistent nor long-term herbicide exposures. Herbicides proposed for 

roadside use west of the Cascades would almost all be applied to foliage, where they would be absorbed and 

metabolized. Soil-applied herbicides used east of the Cascades are not particularly subject to leaching and 

washing to streams because of the dry conditions and lower steam densities. The EIS agrees that “residual” 

(persistent) herbicides used in roadside drainage ditches can find their way into streams where they can harm fish 

(see Water Resources and Fish sections). This is why the projected acres of bromacil, tebuthiuron, and diuron 

are so low west of the Cascades (100 acres per year under the Proposed Action, Alternative 4), and why there is 

a proposed mitigation measure requiring project planners to consider that roadside ditches connect directly to 

streams and conventional buffers would not apply. BLM policy regarding the selection of treatment methods 

prevents herbicide applications from being considered “routine.” Although the BLM does not refer to its decision 

process as a last resort policy, it requires a hard look. The EIS does not dispute the cited research. For example, it 

is true that small amounts of certain herbicides can damage aquatic life, and that herbicides are found in Oregon’s 

streams. BLM’s Standard Operating Procedures and PEIS Mitigation Measures, application measures, and sitespecific planning are designed to minimize or eliminate negative effects from herbicide treatments.

243. Comment: The Administrative Sites, Roads, and Rights-of-Way section might benefit from examples that 

are more specific. For instance, Idaho Power uses a diuron/tebuthiuron herbicide to treat vegetation around 

wooden power poles on BLM lands in Idaho, to reduce the risk of wildfire burning down the poles. Such 

treatments could be undertaken on BLM lands east of the Cascades under Alternative 4 (the Proposed Action) and 

Alternative 5.

Response: This example has been added to the Administrative Sites, Roads, and Rights-of-Way section. 

244. Comment: Saving money, noted in the Implementation Costs section for roadside spraying, is not an 

acceptable reason to further expose the public to chemicals while they are enjoying and recreating on public lands.

Response: As indicated in the Social and Economic Values section, there is a part of the population that does not 

consider cost savings to be a legitimate reason for potentially increasing public herbicide exposure. That position 

is described in the EIS and would be considered by the decision-maker in formulating the Record of Decision. 
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Final Environmental Impact Statement: Appendix 10

That said, it is equally appropriate to display implementation costs in order to inform the decision-maker of the 

potential for cost savings. BLM toxicologists also detail in the EIS that treatments constitute a negligible effect 

on human health risks, even if the public is exposed, which is highly unlikely. The analysis indicates that under 

Alternative 4 (the Proposed Action) and Alternative 5, current road and rights-of-way maintenance budgets would 

see cost savings of approximately $1 million which would then be available to meet other types of maintenance 

and improvement needs, or be available to reduce utility customer’s costs.

Social and Economic Values

245. Comment: The EIS states there is “higher public acceptance” of herbicide risks east of the Cascades. 

Whom did you query on this? The Oregon State Extension Service and the County Soil and Water districts, who 

work almost exclusively with ranchers? Were fish and wildlife biologists from the Oregon Department of Fish 

and Wildlife and the Forest Service included? Were the Warm Springs, Paiute, and Umatilla Tribes included? 

Were the environmental communities such as The Nature Conservancy consulted? Were the Native Plant Society 

and various birding groups east of the Cascades encouraged to comment? We can hardly fathom that people 

concerned with native plants and insects, recovery of aquatic habitat and fish populations, bird numbers and 

habitat, etc. east of the Cascades are by nature more receptive to intensive toxic herbicide use than those west of 

the Cascades.

Response: All of the groups named in the comment are included on the EIS mailing list, most submitted 

comments, and most comments were supportive of Alternative 3 or Alternative 4 (the Proposed Action). The 

Oregon Department of Fish and Wildlife submitted a comment letter in favor of Alternative 4 (the Proposed 

Action). Oregon Department of Environmental Quality “realizes that herbicides will be needed in certain 

situations to control invasive species.” The Nature Conservancy “supports efforts by the BLM to treat noxious 

weeds and non-native invasive plants that negatively impact biodiversity, natural communities, rare and 

endangered species, plant communities and habitats, and ecosystem processes. We support BLM using an 

expanded list of herbicides for vegetation treatments on public lands...” Oregon State Extension and County 

Soil and Water districts are highly concerned with the long-term sustainability of all county resources including 

soil and water, as well as with the quality of life for county residents, and many wrote in support of the proposed 

herbicide increase during scoping and during the public comment period for the Draft EIS. This support tended 

to come more from east of the Cascades where, for a variety of reasons, public awareness of the scope and effects 

of invasive plants is higher than west of the Cascades. BLM lands make up a higher percentage of lands east 

of the Cascades, and the flat, open terrain means invasive weeds are more visible. Scoping meetings east of the 

Cascades were attended by at least five county supervisors, all of whom were supportive of increasing the number 

of herbicides available to the BLM for invasive plant control. Tribes received personal contacts as well as specific 

scoping letters; those responding said they would save comments for site-specific proposals; one noted the need 

to protect ethnobotany resources in the West Eugene Wetlands. The Forest Service provided internal review 

comments and other information for the BLM analysis. The EPA gave the Draft EIS its highest grade, “lack of 

objection,” meaning they did not identify any potential environmental impacts requiring changes to the proposal.

The BLM and all of its resource specialists involved with preparation of the EIS are preeminently concerned 

with the resources and habitats mentioned in the comment. However, nearly every resource section in Chapter 4 

concludes that while there is some increased risk to resources because of using herbicides, the effects of invasive 

plants are far worse.

More herbicide use may be proposed for east of the Cascades in part because 85 percent of the BLM lands in 

Oregon are east of the Cascades (Table 4-2). Although it is probably also true in a larger sense, the “higher social 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

acceptance” comment was made only in reference to the likely public acceptability of a 4,000 to 5,000 acre per 

year increase in wildlife habitat improvement projects using herbicides that would occur east of the Cascades 

under Alternative 5 (when compared to Alternative 4, the Proposed Action), two-thirds of which would be new 

opportunities that would not happen with non-herbicide methods. 

246. Comment: The EIS does not explain the basis for the conclusion in the Comparison of the Effects of the 

Alternatives section in Chapter 2, that on both sides of the Cascades, people believe that invasive plants are more 

harmful than herbicide use. 

Response: While a breadth of perceptions exist on the effects of herbicide use and continued invasive plant 

spread, many voiced concerns for the threat to resource values from invasive species. These concerns do not 

overshadow concerns expressed regarding the threat to resource values from herbicide use, and thus the statement 

may have over generalized the degree of social consensus. The statement does not occur in the reformatted 

Comparison of the Effects of the Alternatives section in Chapter 2. 

247. Comment: The Summary statement that states that social acceptance of the Reference Analysis is likely to 

be low, ignores public concerns about the use of herbicides.

Response: This phrase appeared in the Summary as well as in Chapter 2 in the Summary of the Major Effects of 

Each Alternative, and was followed by “Although some scoping comments expressed a desire for no herbicide 

use, most communities are concerned with the resource damage caused by invasive plants and are aware of the 

higher costs and lower practicality of non-herbicide control methods.” The statement has been modified to better 

state the conclusions in Chapter 4.

248. Comment: The Social and Economic Values section states “there is a perception of unguarded exposure 

and the possibility of direct contact or ingestion ...” The EIS needs to state there is a real threat and not just a 

perception.

Response: Threats are described in this section as they relate to perceptions instead of actual threats since 

perceptions vary between individuals, groups, or communities. Thus, while actual threats to specific resources 

or to human health are discussed in other sections of the EIS, the Social and Economic Values section uses 

perceptions as an indicator since individuals, groups, or communities are of interest. 

249. Comment: The EIS should consider the effects on tourism from invasive plants spread. Specifically, effects 

on wildlife habitat could decrease opportunities for wildlife viewing in certain areas. 

Response: That point was addressed in the EIS. The first paragraph of the Environmental Consequences

subsection of the Social and Economic Values section explains, “Invasive plants can have a negative effect on 

observation-based tourism, as the wildlife and wildflowers that people come to enjoy and photograph are crowded 

out by invasive plants (Westbrooks 1998). Consequently, recreation dependent communities in Oregon may be 

more susceptible to the effects of invasive weed spread than more economically diversified communities.”

250. Comment: The EIS should consider that the effects of controlling the spread of noxious weeds include a 

reduced need for control on lands adjacent to BLM.

Response: In the subsection The Spread of Invasive Plants from Adjacent BLM Lands, under Effects by 

Alternative, this benefit is discussed. Specific points include “future costs to neighboring private and public 

lands would decrease” (Alternative 3); “wildland fire-related costs in these communities...could be reduced...” 

(Alternative 3); and “benefits to adjacent landowners would particularly accrue from the roadside herbicide 
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Final Environmental Impact Statement: Appendix 10

treatments indirectly reducing noxious weeds and other invasive plants in locations where they are most likely to 

be spread to their lands” (Alternative 4). A subsection discussing the possibility that herbicide use on BLM lands 

could result in an overall reduction of herbicide use on adjacent non-BLM lands has been added to the Cumulative 

Impacts section near the beginning of Chapter 4. 

251. Comment: The Social and Economic Values section should acknowledge the widespread public concern 

over the use of herbicides in its Cumulative Effects subsection.

Response: Language under the Cumulative Impacts heading early in Chapter 4 explains that “because this 

is a statewide programmatic document covering the estimated level of future herbicide use in Oregon, ...this 

entire analysis is itself a cumulative effects analysis.” Thus, the Cumulative Effects subsection in the Social and 

Economic Values section does not summarize, but adds to, the “cumulative” effects already discussed in the rest 

of the section. 

Environmental Justice

252. Comment: Consider including ranchers in the analysis of Environmental Justice and acknowledge that 

ranchers are poor and their income is affected by increasing commodity prices. In addition, acknowledge that 

weeds decrease farm income when forage resources are affected. 

Response: The Environmental Justice Principles in BLM’s Land Use Planning Handbook requires the BLM 

to “determine if its proposed actions will adversely and disproportionately impact minority populations, lowincome communities, and Tribes and consider aggregate, cumulative, and synergistic effects, including results of 

actions taken by other parties” (USDI 2005f). Per this definition, ranchers are not a defined environmental justice 

population. However, the handbook encourages consideration of “all potential social and economic effects, 

positive and negative, on any distinct group.” Consequently, the EIS describes loss incurred from the spread of 

invasive plants in the second paragraph of the Environmental Consequences section of the Social and Economic 

Values section stating: 

“Similarly, the Livestock section in this Chapter identifies reductions in livestock carrying capacity of thirtyfive to ninety percent from weed infestations. Invasive weeds affect the livestock industry by lowering yield 

and quality of forage, poisoning animals, increasing the costs of managing and producing livestock, and 

reducing land value (DiTomaso 2000). A 1993 economic study in Grant County showed the annual economic 

impact to livestock grazing was $326,000 and losses would climb to over $3.96 million [2009 dollars] without 

increased weed management (Test 1993).”

Losses to ranch values are also included under the subsection on Concerns Raised During Oregon Scoping in the 

Social and Economic Values section. In order to provide additional detail suggested by this comment, the text 

of the EIS has been augmented with the example given in a public comment letter. The text under the section on 

Concerns Raised During Oregon Scoping now includes the sentence: 

“Incomes in ranching dependent communities are also affected by weed spread since weeds decrease the 

nutritional value and availability of forage in pastures. These effects are compounded by increasing commodity 

prices which further decrease profitability.” 

253. Comment: Please clarify the sentence “While the percentage of the population living below poverty was 

slightly greater east of the Cascades, its percentage of total population decreased by a greater degree than west of 

the Cascades.”
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Response: The sentence has been changed to “In 1999 the percentage of the population living below poverty 

was slightly greater east of the Cascades (13.1 percent) than west of the Cascades (11.4 percent). In addition, the 

percentage of the total population east of the Cascades decreased by a greater degree than west of the Cascades 

over the period from 1989 and 1999 - decreasing by 1.6 and 0.7 percent, respectively.”

254. Comment: The EIS should consider effects to wild mushrooms as a commercial resource and not only in an 

environmental justice context. 

Response: The EIS describes the concern for loss from herbicide use in the Herbicide as a Threat to Resource 

Values and Human Health subsection of the Social and Economic Values section, stating: “Many comments 

proposed that the potential damage to resource values from treatments does not justify the use of herbicides. 

Many suggested herbicides threaten non-target native, rare, Federally Listed and other Special Status species.”

However, concern on potential effects to the commercial value of other forest products was not specifically 

mentioned in the Draft EIS. Consequently, the text under the Social and Economic Values section now goes on to 

include: “Some noted effects to other forest products collected for their subsistence, cultural or commercial value 

such as chanterelle or matsutake mushrooms.”

Specificity on commercial value of these specific resources is not added to the analysis of the alternatives, as they 

are included in the Effects by Alternative section on Herbicide as a Threat to Resource Values and Human Health

section in Chapter 3. The topic is also addressed under Native and Other Non-Invasive Vegetation section in 

Chapter 4, and will be considered during site-specific analysis.

255. Comment: The EIS fails to consider the effects of general herbicide use on those who collect native species 

and “other forest products” such as mushrooms, manzanita, medicinal plants, and greenery for wreaths.

Response: There is a potential for herbicides to contact mushrooms and other forest products. Some native 

special forest products species could be targeted under Alternative 4 (the Proposed Action) and Alternative 5. The 

potential for exposure to people who collect or use these products is discussed in the Environmental Justice and 

Human Health and Safety sections. 

Under the Environmental Justice section of Alternative 4 (the Proposed Action), the EIS notes “under Alternative 

4, [native species within a few feet of the road edge] would be deliberately targeted, increasing the potential to 

affect plants and other products (which include other forest products such as mushrooms, manzanita, and greenery 

for wreaths) utilized by under-represented groups.” Corresponding language under Alternative 5 has also been 

similarly edited. 

The Environmental Justice section under all the alternatives also notes that site-specific analysis prior to 

treatments, and Standard Operating Procedures that reduce drift, would help minimize exposure of non-target food 

and water sources. The Risk Assessments evaluated people who gather and use large amounts of range and forest 

products and generally found no risk (see “Risk Categories” tables at the end of Chapter 3). Standard Operating 

Procedures require consultation with tribes to locate any areas of vegetation that are significant to the tribes and 

that might be affected by herbicide treatments. In addition, when herbicides are used, the application site would 

be signed to inform the public what herbicides had been used in the area and what precautions to take. To the 

degree any risk remains, the document notes under all action alternatives that the potential for disproportionate or 

adverse impacts to minority or low-income groups would still exist.

Regarding the collection of forest products that are classified as noxious weeds, Oregon law does not permit 

the sale, purchase, propagation, or transport of noxious weeds. Therefore, the BLM does not issue permits for 

collection of noxious weeds even when they have medicinal uses such as milk thistle and St. John’s wort. 
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Final Environmental Impact Statement: Appendix 10

256. Comment: The Environmental Justice section indicates minorities, American Indians, and low-income 

people will be disproportionately affected by herbicides. Why are these people sacrificed? Why is there no 

alternative or provision to better protect these groups?

Response: The comment assumes “risk” equals “effects,” which is not the case. The entire analysis is about 

variations in risk, while in reality Standard Operating Procedures and PEIS Mitigation Measures, and the nature 

of the proposed treatments, make risk negligible. No actual human health incidents are predicted, and adverse 

wildlife and other effects would be extremely limited, short-term, and localized. 

American Indian tribes were specifically contacted during scoping for this EIS. Those responding indicated 

support of the Proposed Action (Alternative 4) because improved invasive plant control would help protect 

traditional uses valuable to the tribes. Tribes are also directly involved with site-specific planning through 

government-to-government consultation in order to minimize adverse effects and identify safety concerns with 

regard to traditional gathering areas. Hispanics were identified as potentially adversely affected because language 

differences could lead to poorer understanding of label and other instructions. State-licensing requirements, 

however, are aimed at reducing this particular effect. Lower income people and minorities are simply more 

likely to be gathering food including mushrooms; thus, the analysis identifies them as potentially more exposed. 

The Risk Assessments, however, examined this potential exposure and found risks to be very low (see Human 

Health and Safety section), and identification of these groups as potentially more exposed does not infer that 

their exposure would change that. Executive Order 12898 simply requires agencies to identify and address 

disproportionately high and adverse human health or environmental effects of its decisions on minority and low 

income populations. This section of the EIS examines that potential. 

Implementation Costs

257. Comment: The EIS should consider the effect on employment from mechanical and herbicide treatments 

that includes potential effects from unemployment. In addition, it should consider updating 2005 data with most 

recent available information considering effects from the economic downturn. 

Response: The programmatic scale of this analysis makes assumption of site-specific project planning 

speculative; thus, information on anticipated treatments is not available and employment impact estimation is not 

feasible. Site-specific analysis prior to treatment would include employment effects if public scoping reveals a 

community concern related to employment impacts. In regards to the need for more current information beyond 

2005, the EIS used 2009 cost information and other sources more recent than 2005 for all data except population 

growth and density, where 2005 is the most recent available data. While additional slight changes in population 

density and growth over the period from 1970 to the present could have occurred - demographics are discussed 

in the EIS at a broad regional scale and not affected by the EIS at this scale. Thus, some change in population or 

demography could occur at the site-specific level, but as stated above, the programmatic nature of this document 

makes the assumption of site-specific effects infeasible.

258. Comment: The herbicide application cost estimates should have included the cost of monitoring surface 

water effects from herbicide treatments.

Response: Districts provided their experienced project-level costs, so these costs included existing monitoring. 

259. Comment: The EIS should display costs and benefits, showing the true costs of invasive plants (in terms of 

resources and income losses). It should also show the cost/benefit of treating an infestation early, in order to more 

clearly support increased budget requests.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Response: Non-market components of wildland resources affected by invasive species are notoriously difficult 

to quantify, and information about invasive species’ economic effects is unavailable specific to BLM lands. These 

factors make estimates at this scale of analysis speculative; effects might be more discernable at the site and 

weed-specific scale. BLM-specific data is simply insufficient for any such display to be meaningful. Regardless, 

the EIS considered much of the identified literature regarding economic losses statewide and for specific sites. 

Where these losses are relevant, they have been cited in the Social and Economic Values section, the Noxious 

Weeds and Other Invasive Plants section, or elsewhere. In addition, despite our inability to quantify non-market 

values, such values are discussed qualitatively in the Social and Economic Values section and in other sections of 

the EIS. In general, these serve only as examples, and the portion of such numbers that are applicable to BLM 

lands can only be estimated. 

That said, there is little doubt that invasive plants are having a significant economic impact on resource values on 

BLM lands in Oregon. Effects, and resultant weed control emphasis, is a part of district land management plans. 

The idea that cost information would justify early treatment seems to be well supported by laws and policy at all 

levels. As the available number of herbicides increase, the cost information presented in Chapter 4 demonstrates 

the effectiveness of increased treatment on the rate of spread and resulting cost decreases. In effect, this shows 

cost savings of early treatment. 

260. Comment: The EIS should consider that loss to non-commodity resources and non-market values (such 

as the cost to human health, native plants, water quality, fish, soils, Federally Listed species, grazing mammals, 

scavengers, neotropical songbirds, amphibian, etc) are not compensated by monetary savings to Federal Agencies 

from using herbicides. 

Response: In the Environmental Consequences portion of the Social and Economic Values section the document 

notes that Concerns Raised During Public Scoping included “understanding the value of non-commodity 

resources and non-market values was important, since without estimates, these resources may be undervalued 

and decisions regarding their use may not accurately reflect their true value to society.” The document then notes 

that while there have been many studies on the impacts of invasive species in localized settings, few take into 

account non-market impacts of invasive species, which “might be due to the difficulty in preparing estimates and 

the controversy over available methods” [Cusack and Harte 2008]. In the absence of quantitative information for 

these goods, they are discussed qualitatively where indicated below.” 

Under the subsection Herbicide as a Threat to Resource Values and Human Health in the section Effects by 

Alternative, the document now notes, “comments expressed concerns that herbicides would unacceptably damage 

non-target plants and other non-commodity resources and non-market values” to include those values of concern 

stated in the public comment. The same paragraph of this section then addresses effects by alternative, stating, 

“Alternative 2 may be more acceptable because of the fewer acres treated with herbicides, but Alternative 3 

would use 35 percent fewer total pounds ... and provides more herbicides to accomplish control objectives while 

decreasing environmental risk.” In addition, any risks to these values are discussed implicitly in the specific 

resource sections of this EIS.

While losses to non-commodity and non-market values from herbicide use could occur as recognized above, the 

document also notes in the Environmental Consequences portion of the Social and Economic Values section, 

under Effects Common to All Alternatives that “treatments under the action alternatives would variously result in 

improvements in the condition of BLM resources and would lead to increases in commodity, non-commodity, and 

non-market values.”

261. Comment: The EIS should consider the merits of manual removal beyond just cost. It should consider the 

environmental and health costs of using herbicides. Studies showing the impacts of pesticides on human health 
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Final Environmental Impact Statement: Appendix 10

have been published by the Oregon Environmental Council (see, e.g., The Price of Pollution: Cost Estimates of 

Environmentally-Related Disease in Oregon, OEC 2008).

Response: Treatment effects from manual and other non-herbicide methods are described in most of the resource 

sections in Chapter 4.

The Social and Economic Values section acknowledges concerns related to human health in the subsection titled 

Herbicide as a Threat to Resource Values and Human Health and examines human health concerns by alternative. 

While the Oregon Environmental Council study provides an estimate of the cost associated with environmentally 

attributable disease and disability in Oregon it is not specific to pesticides and does not provide cost estimates 

specific to pesticide related illness. Hence, use of this information would thus overstate the cost of pesticide 

related illness in Oregon. In addition, the paper states “the purpose of this study is to estimate how much money 

is spent in Oregon annually to pay for environmentally attributable diseases, which are largely preventable” and is 

thus limited to just cost estimates represented by monetary transactions. 

The EIS acknowledges that the cost of pesticide related disease is important and does not limit the discussion 

to just quantifiable costs of pesticide related illness and disease treatment. In the Environmental Consequences

subsection of the Social and Economic Values section, the document notes that Concerns Raised during Public 

Scoping included “concerns about adverse effects on human health. These comments noted the increased human 

health threat to users of BLM lands, adjacent landowners, herbicide applicators, and BLM personnel who work 

in the field.” Rather than a quantitative assessment using the incurred cost of disease, the EIS qualitatively 

recognizes the risks to human health may be greater under some alternatives than others based on levels of 

treatment. 

In this manner, the analysis of cost effectiveness is not a cost-benefit analysis and thus does not claim to cover 

pesticide related costs associated with illness or resource damage. These costs are discussed qualitatively in the 

Social and Economic Values section (where noted above). This qualitative assessment of non-market transactions 

is valuable and appropriate given limitations discussed in the EIS, “Understanding the value of non-commodity 

resources and non-market values was important, since without estimates, these resources may be undervalued 

and decisions regarding their use may not accurately reflect their true value to society.” The EIS then notes the 

difficulty in preparing estimates of non-market values due to controversy over available methods (Cusack and 

Harte 2008). 

Human Health and Safety

262. Comment: The EIS needs to explain that pesticides cause birth defects and miscarriages.

Response: The herbicides proposed for use in the EIS, used in the manner described, would not cause birth 

defects of miscarriages. This conclusion is based on the Human Health Risk Assessments and the body of 

scientific evidence that are the basis for the EIS analysis.

263. Comment: BLM did not analyze effects to recreational users and the young and elderly.

Response: The Risk Assessments, summarized in the “Risk Categories” tables at the end of Chapter 3, include 

recreational users such as hiker/hunters, angler, berry pickers, swimmers, and subsistence users of plant materials. 

Both children and adults were also evaluated. In addition, the reference doses used for the acceptable dose contain 

uncertainty factors for extrapolating to humans including susceptible sub-populations like subsistence users.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

264. Comment: The EIS does not discuss that violations of the Rehabilitation Act of 1973 would occur when 

the BLM disparately harms disabled people by forcing people to endure non-consensual herbicide exposures 

when they are on BLM lands, or near enough to them to receive drift or vapors, runoff into surface waters, or 

ground water contamination, or contact via other means of transport. If people suffer from disabilities that render 

them unable to detoxify the chemicals that BLM proposes to use, they will be disparately harmed by the BLM’s 

massive spray program.

Response: BLM herbicide treatments would not be a violation of the Rehabilitation Act. Under Section 

504 of the Rehabilitation Act of 1973, as amended (29 USC 794), no person can be denied participation in a 

Federal program that is available to all other people solely because of his or her disability. The purpose of this 

is specifically to allow all people access to services and benefits of a program; it does not protect the public 

from programs (such as the Integrated Vegetation Management program) potentially denying people access 

to something else (public lands). In addition, agencies are not required to take any action to facilitate such 

participation if such action would result in a fundamental alteration in the nature of a program or activity (7 C.F.R. 

15(e) 103) (for example, Wilderness does not have to be wheelchair accessible). It should also be noted that no 

court has found chemical sensitivities to be a disability. 

However, herbicide use under the Proposed Action (Alternative 4) would be scattered and infrequent, and not 

comparable to industrial uses on farms or timberlands. Standard Operating Procedures and PEIS Mitigation 

Measures require signing and/or other notification when herbicides are applied, and require buffer distances 

around residences to limit risks to people. In addition, the calculation of human health risk categories used in the 

EIS included uncertainty factors for extrapolating to humans including susceptible sub-populations.

265. Comment: Private homeowners suffer from negative health conditions because of the BLM and private 

timber companies’ herbicide use.

Response: The Pesticide Analytical Response Center (PARC), a division of the Oregon Department of 

Agriculture, prepares an annual report to the State Legislature, detailing all suspected or confirmed cases of 

pesticide poisoning. Physicians are required by State law to report suspected or confirmed pesticide poisoning, 

and all cases are followed up on. PARC investigated 89 reports in their 2006-2007 report, 84 reports in their 

2005-2006 reports, and 213 reports in their 2001 reports (PARC did not receive funding to produce annual reports 

between 2002-2004, nor have they produced their 2008 or 2009 reports yet). Out of these 386 reports, 28 were 

herbicide specific. The majority of the reports were occupational incidents, and employers were cited by OSHA 

for lack of training and lack of safety measures. There were a few reports of drift, where herbicide application 

(on agricultural lands) blew onto nearby lands and killed non-target plants. There were some reports from 

homeowners who misapplied herbicides, and some reports of accidental consumption. However, there was only 

one report of homeowners being affected by long-term herbicide exposure because they live near forested land 

where herbicides were being applied.

That report occurred in 2001; four residents in Polk County reported human illness and ill horses (cancer and 

blindness) after long-term exposure to clopyralid, sulfometuron methyl, and 2,4-D used on agricultural and 

forestry lands. PARC found insufficient information to pursue the case. It should be noted that the lands in 

question were not BLM lands. The BLM is not proposing to use herbicides for commodity production, and hence 

application is target specific and not likely to drift to non-target species (including humans). 

People who suspect that they have been poisoned by any pesticide should report the incident to their doctor (and/

or the Pesticide Analytical Response Center) as soon as possible.
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Final Environmental Impact Statement: Appendix 10

266. Comment: All of the potential public exposures are non-consensual. Unlawful testing of herbicides on 

humans is in violation of the labels and of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 

Section 12 (unlawful testing on humans).

Response: The herbicides addressed in this EIS have been tested and registered for the proposed uses. While 

analysis of any application contributes information to future adaptive management decisions, the proposed 

applications are not tests. The FIFRA Section 12 refers to testing of the pesticide for registration, not to 

application under labeled uses.

267. Comment: The proposed roadside spraying forces the public to endure non-consensual exposures and 

violates their right to safety at home and during travel.

Response: The proposed herbicides are registered for roadside use, and Risk Assessments indicate those uses 

are highly unlikely to affect road users. Standard Operating Procedures and PEIS Mitigation Measures further 

limit exposures.

The BLM is aware of no health issues to the public or workers originating from BLM herbicide applications in 

Oregon during the past 25 years. Recognizing that current BLM herbicide use is far less than one percent of 

such use in the State, the BLM chose to examine a larger sample and reviewed the annual Oregon Department 

of Agriculture Pesticide Analytical Response Center’s pesticide incident reports for three different years. The 

Oregon Department of Agriculture is required to investigate all reported injuries to people or property, as well as 

reported violations of pesticide application rules. Further, doctors are required to report to the Oregon Department 

of Agriculture every incident where a patient alleges pesticide poisoning, or the doctor suspects it. Therefore, the 

Oregon Department of Agriculture reports should represent a good summary of verified herbicide injuries. The 

Oregon wide reports generally contain two to four herbicide-related illnesses statewide per year (no deaths were 

found) (PARC 2001, 2006, 2007). These included illnesses from home use, from untrained operators without 

required safety equipment, and from applications during wind conditions well beyond those permitted by BLM 

Standard Operating Procedures. Although there were not enough injuries to indicate a statistical trend, it appeared 

injuries are most likely to occur to incidental operators. Few of the injuries were to trained agricultural or forestry 

workers or to landowners adjacent to these types of uses. The intent of this examination was to determine if 

herbicides were inherently risky and if the BLM Standard Operating Procedures were barely keeping us from 

harm, or if these are reasonable industrial and home-use tools that might be compared to using ladders or radial 

arm saws, and good work practices would reasonably eliminate most risk. The latter seems most true.

268. Comment: Native plants along roads and other areas can be treated under Alternative 4 (the Proposed 

Action) and Alternative 5. Herbicides could be applied to forest products such as mushrooms, manzanita, and 

greenery for wreaths, and species like milk thistle and pennyroyal that are used as medicinal herbs. How does the 

analysis address effects to those who gather and use these forest products?

Response: The Risk Assessments evaluated human subsistence use (Native American) of those who gather and 

use large amounts of range and forest products exposed to direct sprays or drift, and generally found no risk (see 

“Risk Categories” tables at the end of Chapter 3). When an herbicide is used, the potential for exposure would be 

reduced by posting the spray site to inform the public of herbicide use.

269. Comment: The Human Health and Safety section states that the EPA has not developed toxicity categories 

for sulfometuron methyl. However, they are provided in the Reregistration Eligibility Decision in 2008 (all 

endpoints are either IV or III)
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Response: Toxicity categories III and IV are not endpoints used in Risk Assessment per se. They are simply 

label categories of the level of caution or danger associated with acute effects associated with handling the 

herbicide. The Risk Assessments use actual acute and chronic toxicity data for dermal and oral exposure. 

Sulfometuron methyl does not have any oral toxicity data, but the dermal data were used.

270. Comment: A recent article in Scientific American had an article on Roundup titled: Weed-Whacking 

Herbicide Proves Deadly to Human Cells. The summary says: 

Used in yards, farms and parks throughout world, Roundup has long been a top-selling weed killer. But now 

researchers have found that one of Roundup’s inert ingredients can kill human cells, particularly embryonic, 

placental and umbilical cord cells... Glyphosate, Roundup’s active ingredient, is the most widely used 

herbicide in the United States. About 100 million pounds are applied to U.S. farms and lawns every year, 

according to the EPA. Until now, most health studies have focused on the safety of glyphosate, rather than 

the mixture of ingredients found in Roundup. However, in the new study, scientists found that Roundup’s 

inert ingredients amplified the toxic effect on human cells - even at concentrations much more diluted than 

those used on farms and lawns. One specific inert ingredient, polyethoxylated tallowamine, or POEA, was 

more deadly to human embryonic, placental and umbilical cord cells than the herbicide itself -- a finding the 

researchers call “astonishing.” “This clearly confirms that the [inert ingredients] in Roundup formulations are 

not inert,” wrote the study authors from France’s University of Caen. “Moreover, the proprietary mixtures 

available on the market could cause cell damage and even death [at the] residual levels” found on Rounduptreated crops, as soybeans, alfalfa and corn, or lawns and gardens. The research team suspects that Roundup 

might cause pregnancy problems by interfering with hormone production, possibly leading to abnormal fetal 

development, low birth weights, or miscarriages.

Response: POEA was specifically evaluated for the PEIS (Appendix D) and found to be toxic for aquatic life, but 

non-toxic to humans. The Benachour and Seralini (2008) study referenced in Scientific American was published 

in the Journal of Chemical Research in Toxicology, and shows potential endocrine disruption, DNA damage, and 

toxicity of glyphosate with and without POEA in human cell cultures. This is a new finding (since the PEIS) 

based on laboratory tests with cells, and needs to be confirmed by other studies and possible dose implications 

considered. The Final EIS has been changed to report these findings. 

271. Comment: The BLM should not be using 2,4-D because of health risks including the presence of deadly 

dioxins in about 60 percent of 2,4-D formulations.

Response: The EPA’s 2005 Reregistration Eligibility Decision for 2,4-D has concluded 2,4-D is not associated 

with lymphoma or any cancer, that the dioxins present are of no toxicological concern, and reports that the dioxin/

furan contaminant concentration was always low in 2,4-D in the 1980s and the industry has since further reduced 

these contaminants. Using 1987 data, the EPA found cancer and non-cancer effects from these contaminants to be 

of no toxicological concern. Additional studies requested by the EPA based on the 2005 Reregistration Eligibility 

Decision document, are nearing completion (EPA 2005a).

272. Comment: 2,4-D is persistent and has high, not moderate, risks to public and applicators.

Response: The EIS evaluation of the risk is based on the 2006 Forest Service Risk Assessment, which the PEIS 

analysis did not use. The new Risk Assessment actually reduced risks shown in the EIS when compared to the 

PEIS. (In addition, errors on Draft EIS Risk Category Tables for 2,4-D have been corrected.) Risks for typical or 

central exposures average from none to low with moderate risks for only 2 of 21 categories. Risks for maximum 

exposures average low to moderate with 5 moderate risk categories for 21 categories. According to the EPA’s 
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Final Environmental Impact Statement: Appendix 10

2005 Reregistration Eligibility Decision document, the degradation of 2,4-D was rapid (half-life= 6.2 days ) in 

aerobic mineral soils. The half-life of 2,4-D in aerobic aquatic environments was 15 days (EPA 2005a). These 

findings demonstrate that 2,4-D is not persistent.

273. Comment: California is listing 2,4-D as a developmental toxicant.

Response: California listed 2,4-D as a developmental toxicant under Proposition 65 several years ago, based on 

indicators described in the EPA’s 2005 2,4-D Reregistration Eligibility Decision document. The Risk Assessment 

prepared by the EPA as part of that process, and the Forest Service Risk Assessment, both indicate the cited 

information is inconclusive. The EPA has requested registrants to provide additional information about these 

apparent effects. The indicators, and the uncertainty associated with them, are discussed under 2,4-D in the 

Human Health and Safety section. Listing by California’s Office of Environmental Health Hazard Assessment 

does not represent a toxicity interpretation by an authoritative source, only that they believed the evidence met 

Proposition 65’s criteria for listing. 

274. Comment: The EIS should consider various draft EPA documents on dioxin and restrict 2,4-D containing 

the dioxins 2,4,7,8 TCDD and 1,2,4,7,8,PCDD.

Response: It is not clear what draft documents are referred to nor would it be scientifically defensible to take 

action based on draft EPA documents. The EPA’s 2005 Reregistration Eligibility Decision for 2,4-D concluded 

2,4-D is not associated with lymphoma or any cancer, and reports that the dioxin/furan contaminant concentration 

was always low in 2,4-D in the 1980s and the industry has since further reduced these contaminants. Using 1987 

data, the EPA found cancer and non-cancer effects from these contaminants to be of no toxicological concern 

(EPA 2005a). The EPA has not restricted its use nor required any identification of dioxin constituents. The EPA 

continues to require testing to ensure dioxin contamination continues to decline. 

275. Comment: The statement in the Human Health and Safety section that eye and skin irritation are the only 

overt effects of mishandling chlorsulfuron should be deleted. Chlorsulfuron is in toxicity category IV (labeled 

with “Caution”) for skin and eye effects (only slight effects were seen in the studies). 

Response: The text properly states that eye and skin irritation are the only overt effects of mishandling of 

chlorsulfuron because the Risk Assessment did not find any other risks.

276. Comment: Clopyralid can cause severe eye damage, including permanent loss of vision if splashed into the 

eyes by, for example, a worker accident.

Response: The potential for clopyralid to cause eye irritation and damage is described in the Human Health and 

Safety section of the EIS, under Human Health Risks Associated with Herbicides Evaluated in the 2005 Forest 

Service EIS. That section notes “irritation and damage to the skin and eyes can result from direct exposure to 

relatively high levels of clopyralid.....as a consequence of mishandling clopyralid (SERA 2004b).” “Severe” 

effects are not quantified, but study results included in the Risk Assessment show slight to marked conjunctival8

redness, diffuse to marked corneal opacity, and slight to marked chemosis9, sometimes lasting longer than 21 days 

in rabbits treated with high doses. The Risk Assessment does not suggest permanent loss of vision. 

8 Conjunctiva: A delicate mucous membrane that covers the internal part of the eyelid and is attached to the cornea.

9 Chemosis: Swelling of eye whites; an inflammatory collection of fluid under the membrane covering the white of the 

eye so that it swells. It indicates conjunctivitis, often of allergic origin.
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

277. Comment: Glyphosate has been demonstrated to cause genetic damage in lab tests with human cells and 

tested animals. Farmers see increased risk of non-Hodgkin’s lymphoma. Glyphosate contamination has been 

demonstrated in all six of King County urban streams tested. The USGS Hydrology Program survey of Midwest 

Streams (2002) found over one-third of stream samples contained glyphosate, while two-thirds contained primary 

breakdown products. 

Response: No references were provided for the genetic damage portion of this comment. Glyphosate does not 

cause mutations (EPA 1993). Regarding non-Hodgkin’s lymphoma, the glyphosate Risk Assessment (Appendix 

8) discusses the available evidence and concludes: 

“Given the marginal mutagenic activity of glyphosate and the failure of several chronic feeding studies to 

demonstrate a dose-response relationship for carcinogenicity and the limitations in the available epidemiology 

study, the Group E classification given by the U.S. EPA/OPP (1993a, 3-18 2002) appears to be reasonable. As 

with any compound that has been studied for a long period and tested in a large number of different systems, 

some equivocal evidence of carcinogenic potential is apparent and may remain a cause of concern, at least in 

terms of risk perception (e.g., Cox 2002). While these concerns are understandable, there is no compelling 

basis for challenging the position taken by the U.S. EPA and no quantitative risk assessment for cancer is 

conducted as part of the current analysis” (SERA 2003a).

Regarding King County urban streams, it would not be surprising to find glyphosate in urban streams, given the 

apparent quantities sold in home and garden stores. The USGS publication Pesticides Detected in Urban Streams 

in Kings County, Washington 1998-2003 (USGS 2004) identifies lawn and shrub care as the potential source. 

Wildland use by Federal Agencies following Standard Operating Procedures and PEIS Mitigation Measures is not 

comparable. USGS has detected glyphosate in Midwest streams but at levels more than 100 times lower than the 

allowable drinking water standards. The USGS study contributes information that would help guide the future 

use of glyphosate, but these specific results are not a health concern per se. Glyphosate is the world’s best selling 

herbicide, used in more than 90 countries on 150 crops as well as along roadsides and other locations (USGS 

2002). The USGS findings do not indicate BLM uses are inherently dangerous.

278. Comment: The BLM should not be using diuron because it is carcinogenic.

Response: Diuron has been characterized as a “known/likely” human carcinogen; however, risk assessments by EPA 

shows a lifetime risk estimate of 1.68 cases per million exposed (EPA 2003b). The EPA considers this a low risk.

279. Comment: The Human Health and Safety section states that diuron is a “suspected carcinogen, and 

possible endocrine disruptor.” Both of these endpoints have been recently assessed by the EPA. The EPA’s 2003 

Reregistration Eligibility Decision document for diuron states, “At this time, neither the available submitted 

studies on diuron or the literature show any indication of endocrine disruption effects” (EPA 2003b). In the 

Reregistration Eligibility Decision, diuron was classified as a known/likely carcinogen. We suggest the EIS be 

changed to reflect the EPA’s assessment.

Response: The diuron sentence has been changed as suggested.

280. Comment: One of the stated Purposes for increasing the number of herbicides is the benefit of the use of 

“newer, less toxic herbicides” (Chapter 1). However, in all of the action alternatives, the use of at least one of the 

four older, more toxic herbicides already in use would increase (“Risks to Worker and Public Health” table in the 

Human Health and Safety section). Under the Proposed Action (Alternative 4) the use of herbicides “would more 

than double the use of moderate risk herbicides (when compared to Alternative 3).” Alternative 3 is designated as 
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having “higher risk” than the No Action Alternative (Alternative 2). In would seem that the action alternatives do 

not, in fact, meet the stated purpose of “minimizing the effects to non-target plants and other species” and lead “to 

lower human and ecosystem risk” as suggested in Purpose number 6.

Response: The statewide acres treated totals for all four of the currently used herbicides would go down under 

all of the action alternatives, even though total estimated acres treated (with all herbicides) would triple under 

Alternative 5 (“Estimated Annual Treatment Acres...” table in Chapter 3). The “Risk to Workers and Public 

Health” table in the Human Health and Safety section displays only those herbicides registering at least one 

moderate or low human health risk category (as opposed to zero), and not counting accidental exposure scenarios. 

Since 2,4-D is the only moderate risk herbicide in Alternative 2 (No Action) and Alternative 3 (the legitimate 

comparison since any increases between Alternatives 3 and 4 (the Proposed Action) come from the addition of 

other treatment objectives), there is projected to be a slight increase annually west of the Cascades (shown in the 

top half of the referenced table), and a 4,800 acre decrease annually east of the Cascades, for a 4,500 acre reduction 

statewide. Low risk herbicides would be added by Alternative 3, but those 2,400 acres do not negate the gain.

For Alternative 4 (the Proposed Action), the addition of soil active herbicides for use around certain rights-ofway and developments doubles the moderate risk acres when compared with Alternative 3, but the total acres of 

moderate risk herbicides are still 1,200 acres below those of Alternative 2 (No Action). Even with its expanded 

objectives, the acres of moderate risk herbicides are lower under the Proposed Action (Alternative 4) than under 

the No Action Alternative (Alternative 2). With respect to human health, it would appear that the objectives of 

Purpose 6 would be furthered by the Proposed Action.

Third, these numbers only address human health risk. Changes in ecosystem risks are best extrapolated from 

the individual resource sections in Chapter 4. Thus, in the Comparison of the Effects of the Alternatives section 

in Chapter 2, the Final EIS includes a numerical summary of the acres by risk categories by resource. These 

numbers are only indicators, because several parameters were rated for each resource. However, they indicate a 

reduction in overall ecosystem risk between the No Action Alternative (Alternative 2) and Alternative 3. 

Other Environmental Consequences

281. Comment: The section on the Relationship Between Short-Term Uses of the Human Environment and 

Maintenance of Long-term Productivity is inadequate because it does not address the potential long-term effects 

of herbicides.

Response: The potential for long-term effects is addressed in the discussion of half-lives of the herbicides 

under various conditions in the Soil Quality and Water Resources sections. BLM applications are not expected 

to significantly contribute to cumulative downstream effects to fish. BLM-applied herbicides will break down 

at or near the point of application. The analysis indicates there would be no herbicide-related effects to longterm productivity. These conclusions, inferred or stated by the environmental effects discussions in the pertinent 

resource sections in this chapter, have been added to this section in the Final EIS. 

282. Comment: The section on Irreversible or Irretrievable Impacts does not include a discussion of the 

irretrievable health problems for workers of the public; potential irreversible contamination of waterways, soils, or 

change to ecological diversity, or loss of vulnerable species such as amphibians.

Response: The potential for such effects is addressed in their respective sections in this chapter. The analysis 

indicates no such permanent effects are likely under BLM treatment scenarios. 
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References

283. Comment: An up-to-date search of scientific literature should be undertaken to better inform the BLM 

in their use of pesticides. There is a lack of references addressing certain issues in the otherwise extensive 

references section.

Response: The comment does not suggest specific missing references, or name the issues lacking references. To 

help inform the BLM of the risks associated with their proposed herbicide use, this EIS relies on BLM or Forest 

Service-prepared Human Health and Ecological Risk Assessments for each of the 18 herbicides. These Risk 

Assessments are included in this EIS as Appendix 8, and each Risk Assessment itself includes a very extensive 

references section. The references section at the end of Chapter 4 is also very extensive but generally only 

includes references that made it into the main body of the EIS. The summaries of the herbicide risk that occur 

in Chapter 4 are necessarily brief, and often cite the Risk Assessment as the reference rather than the primary 

source. Pertinent new information published since compilation of the Risk Assessments is included in Chapter 4 

and its references section. Additional references have been added based on public comments and resultant new 

information added between the Draft and Final EISs.

Distribution List

284. Comment: The BLM failed to notify the public of this planning process. Local community leaders and 

parties that had no vested economic interest in removing invasive weeds or using herbicides should have been 

informed.

Response: In June of 2008, the Oregon BLM sent out 17,200 postcards and 2,000 emails notifying individuals 

and organizations that the Oregon BLM was going to begin preparation of an EIS. The postcards and emails 

advised recipients how to get on the mailing list and when scoping meetings would be held. Those notified 

included: State and Federal elected officials; American Indian Tribes and Nations; lessees of BLM land; Soil and 

Water Conservation Districts and Oregon State University Extension Boards, as well as other interested parties 

identified by the Oregon Department of Agriculture; and, mailing lists from other planning efforts including the 

BLM Western Oregon Plan Revisions, the Forest Service Pacific Northwest Region Invasive plant program: 

Preventing and Managing Invasive Plants (2005), the PEIS, and all Oregon BLM districts’ mailing lists of persons 

having expressed an interest in being kept informed about local BLM planning efforts.

Approximately 400 press releases were sent to media outlets throughout the State. Newspapers do not have to 

publish news releases, but articles were published in several papers, including the Oregonian and the Ontario 

Argus Observer, and the issue received airtime on KEX and KCBY.

In addition, a Notice of Intent was published in the Federal Register on June 23, 2008. The Federal Register 

notice, news releases, and the postcards all announced the twelve scoping meetings, subsequently held throughout 

the State in July 2008.

About 1,300 interested parties were on the mailing list to receive the Draft EIS and about 2,000 interested parties are 

on the mailing list to receive the Final EIS. Per NEPA regulations, a distribution list is included in both the Draft and 

the Final EIS, which includes the names and/or organizations of all parties who are on the mailing list. An introduction 

paragraph has been added to the start of the distribution list to clarify how the distribution list was compiled.
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Final Environmental Impact Statement: Appendix 10

285. Comment: Do form letters count as multiple responses?

Response: The Dear Reader letter in the Draft EIS states that the purpose of the public comment period is to 

ensure that the appropriate range of reasonable alternatives is presented, that the analysis of effects is complete, 

appropriately presenting and interpreting the available published information. Comments on the Draft EIS should 

be as specific as possible and should address the adequacy of the Draft EIS and the merits of the alternatives 

discussed (40 C.F.R. 1503.3). Comments meeting this standard were identified as “substantive” comments. One 

letter might have several substantive comments, and another may have none. Receiving the same substantive 

comment several times has no additional effect on the Final EIS; the deficiency is corrected one time, and no 

tally or “vote” is otherwise kept. All letters were treated equally and were not given weight by number received, 

organizational affiliation, or other status of the respondents. 

Letters sent during the public comment period process were read by a public comment coding team who found 

the substantive comments and compiled them into comment statements. All of these comment statements are 

included in this Appendix, all have written responses, and many resulted in changes to the Final EIS. 

Comments received are part of the public record on the Draft EIS and are available for public inspection. 

Individuals or organizations that submitted comment letters (including form letters) have been added to the 

distribution list, and would receive or be notified about the Final EIS and the Record of Decision.

Appendix 2 – Standard Operating Procedures 

and Mitigation Measures from the PEIS

286. Comment: The EIS never mentions or discusses buffer zones.

Response: Non-spray “buffer” zones are mentioned more than 50 times in the body of the EIS, with particular 

emphasis in the Water Resources section. Buffer zones are also specified or emphasized in 20 of the Standard 

Operating Procedures and PEIS Mitigation Measures in Appendix 2, variously requiring non-spray buffers up to 

1500 feet. Four tables in Appendix 2 are titled “Buffer Distances to Minimize Risk to....” As with other Standard 

Operating Procedures and PEIS Mitigation Measures, effects discussions in Chapter 4 are predicated on the 

application of these required no-spray buffers.

287. Comment: Loopholes, such as language like “where practicable” and “for the most part” in Appendix 

2 (Standard Operating Procedures and PEIS Mitigation Measures) would allow the BLM to avoid using these 

protective measures. Thus, assurance of few or no effects is weak.

Response: Neither of these phrases appears in Appendix 2. “Where feasible” appears, and denotes a requirement 

to seek an alternative way of meeting the objective (including reconsideration of whether the control is necessary) 

and infers that the extra risk of the higher dose be a part of the analysis. However, pending that analysis, the 

action may be selected. The entire section also has language that would allow departures if the adverse effects 

they seek to avoid are unlikely to occur. This is one reason measures are duplicated in two or more sections, so 

users can understand (and achieve) all of the objectives of specific measures. BLM field offices would tailor 

these Standard Operating Procedures and PEIS Mitigation Measures based on local conditions and site-specific 

analysis. Such “tailoring” would normally be described in the site-specific analysis documents that would be 

subject to public involvement and comment. 
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Appendix 3 – Monitoring

288. Comment: Appendix 3 (Monitoring) should include additional information on Oregon BLM’s vision of an 

adaptive management framework.

Response: The Oregon and Washington BLM State Office follows the Bureau’s Adaptive Management 

Implementation Policy (USDI 2008d). Guidance for implementation of this policy is contained in the US 

Department of the Interior’s Adaptive Management Technical Guide (USDI 2009). The adaptive management 

framework employed by the State Office includes developing stated management objectives to guide decisions 

about what actions to take and identifying explicit assumptions about expected outcomes that are then compared 

against actual outcomes. This framework acknowledges uncertainty about how natural resources systems 

function and how they would respond to management actions, and it makes use of management intervention 

and monitoring to improve subsequent decision-making. This information has been added to Appendix 3 as 

suggested.

289. Comment: Appendix 3 states that Pesticide Application Records are kept for 10 years. What are the 

implications of that for long term monitoring? Appendix 7 and the Noxious Weeds and Other Invasive Plants

section both discuss weed spread in the next 15 years; how will Pesticide Application Records kept for only 10 

years be sufficient to facilitate meaningful measurement of the control strategy in the Record of Decision?

Response: Pesticide Application Records are retained in project files for a minimum of 10 years as per Bureau 

Manual 9011 (USDI 1992c). Even if Pesticide Application Records are not kept, district summary records 

typically include weed treatment information from previous decades. With the deployment of the BLM’s National 

Invasive Species Information Management System (NISIMS) in 2010, Pesticide Application Records would be 

entered electronically and maintained indefinitely, which would better facilitate long-term data retention. This 

point has been clarified in Appendix 3.

The 15 year projected weed spread discussed in Appendix 7 and the Noxious Weeds and Other Invasive Plants

section is a statewide estimate (based on available literature) for analysis purposes, and Appendix 3 does not 

suggest those should be used as a basis for any sort of monitoring. Potential and existing monitoring indentified 

in Appendix 3 is generally at a smaller scale than statewide. The 15-year weed spread rate is to show an 

indication of the size of the problem; individual species, populations, and ecosystems would have varying rates of 

weed spread, and varying responses to the alternatives.

290. Comment: The EPA recommends monitoring include a description of how BLM’s data retention guidelines 

will facilitate long-term effectiveness monitoring. 

Response: Appendix 3 in the Draft EIS failed to describe the BLM’s new National Invasive Species Information 

Management System (NISIMS), which would help address this monitoring need. A description of the system and 

of the components that would facilitate effectiveness monitoring has been added to Appendix 3 in the Final EIS.

291. Comment: The EPA recommends that Part II of Appendix 3, Potential Monitoring be incorporated into 

all action alternatives in order to help avoid adverse environmental impacts from herbicide use. The EPA also 

recommends the proposal be amended to explicitly identify minimum site-specific requirements of monitoring. 

These requirements should provide guidance on how site-specific project planning and NEPA analysis would 

consider the costs and benefits of monitoring impacts on air, vegetation, soil, and water. Descriptions such as 

“water quality monitoring would be conducted at discretion of the district” and “there might also be a need to 
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Final Environmental Impact Statement: Appendix 10

determine if the standards and protection measures were effective at reducing potential effects to Federally Listed 

species and/or designated critical habitat” do not sufficiently disclose how districts will develop and implement 

adequate effectiveness monitoring for environmental and human health concerns.

Response: The Appendix has been edited to better describe existing BLM policy direction directing that 

monitoring should be dictated by the nature of the critical components of the environment in the treatment area. 

The action alternatives do not propose a new program; they propose to add additional herbicides to an existing 

BLM program that has been conducted without a significant incident for decades, and operates under BLM-wide 

guidance developed from BLM’s experience with herbicides. This monitoring ideas presented in this section 

of Appendix 3 could apply to any or all of the action alternatives; the decision-maker would determine which 

monitoring to adopt, based on concerns raised in the analysis or concerns the decision-maker may have about the 

selected alternative. Adoption of all monitoring in this section is probably not feasible or necessary. The Standard 

Operating Procedures and PEIS Mitigation Measures are designed to reduce treatment risks to acceptable levels. 

Departures from these measures might be a reason to add project-specific implementation monitoring. 

292. Comment: The “Five-year Examination of Weed Spread” should be incorporated into the action alternatives 

because it - or something similar - would provide a mechanism to measure the effectiveness of the chosen control 

strategy relative to EIS weed spread projections. Coordinating large-scale evaluations with relevant State and 

Federal Agencies and publishing the results would greatly increase their relevance.

Response: This monitoring is not automatically included in the action alternatives because it would be 

complicated, and its ability to accomplish the stated objectives unclear or expensive to fine-tune. If selected by 

the decision-maker, the BLM and relevant cooperators would need to determine its design and what objectives it 

could achieve. One problem is that the current 12 percent spread rate is an estimate, and BLM actions under the 

action alternatives are, according to the analysis presented in Appendix 7, will reduce the current rate over the 

next 10 to 15 years. It is not clear a significant change in weed spread rate would be discernable in five years.

This is not to suggest these issues are insurmountable, but that like other potential monitoring, a decision would 

have to consider whether the likelihood of meaningful monitoring results would justify the deferral of funds from 

direct weed control efforts.

293. Comment: Monitoring Specific Concerns Identified in the EIS should be incorporated into all action 

alternatives because it would help to ensure that adverse impacts on non-target resources have been effectively 

avoided or mitigated. Please also consider a more operational title for this effectiveness monitoring proposal, e.g., 

“Effectiveness Monitoring on the Avoidance and Mitigation of Adverse Impacts to Non-target Resources.”

Response: A new title for this potential monitoring item, similar to that suggested by this comment, has been 

incorporated into Appendix 3. This monitoring is not automatically adopted because the decision-maker needs to 

determine if there are any significant concerns remaining after one of the alternatives and potential mitigation are 

selected. PEIS Mitigation Measures were designed to eliminate all significant effects at the west-wide analysis 

level, and the Oregon EIS may not have identified adverse effects deemed by the decision-maker to need, or 

significantly benefit from, monitoring.

294. Comment: The EPA recommends Appendix 3 explicitly identify different potential monitoring as either 

implementation or effectiveness monitoring. For example, “Monitoring for Concerns Identified in the EIS” 

might be more broadly understood as statewide implementation monitoring. The EIS describes two major 

effectiveness monitoring proposals – “Five-year Examination of Weed Spread” and “Monitoring Specific 

Concerns Identified in the EIS.”
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Response: The potential monitoring listed in Part II of Appendix 3 has been categorized into new Implementation

and Effectiveness monitoring sections, as suggested.

295. Comment: The Oregon Department of Environmental Quality requests that the BLM coordinate with 

them when sending data electronically for potential entry into Oregon Department of Environmental Quality’s 

Laboratory Analytical Storage and Retrieval Database (LASAR). In addition, the Oregon Department of 

Environmental Quality requests copies of any monitoring reports of herbicide effectiveness and impacts on 

water quality and ecological conditions are shared with Oregon’s Water Quality Pesticide Management Team 

(WQPMT).

Response: These requests have been forwarded to the BLM State Office restoration coordinator. A discussion of 

the request to coordinate LASAR entries with Oregon Department of Environmental Quality has been added to 

Appendix 3 in the Potential Monitoring section. The request to share any water quality effectiveness monitoring 

data collected in support of this EIS with Oregon’s WQPMT is also described in Appendix 3. The multi-agency 

WQPMT acts to review and respond to pesticide detections in Oregon’s ground and surface water.

Appendix 5 – Federally Listed and other Special 

Status Species

296. Comment: The Endangered Species Act analysis in the EIS is insufficient and does not adequately address 

potential impacts to Federally Listed species and Critical Habitat. 

Response: The Endangered Species Act analysis provided in this programmatic EIS adequately addresses 

the potential impacts to Federally Listed species and Critical Habitat when considered as a supplement to the 

Biological Assessment completed for the PEIS, as described in Appendix 5. Appendix 5 of the EIS provides 

information concerning Federally Listed species known to occur in Oregon, and is provided as a supplement 

to the Biological Assessment which is incorporated by reference in accordance with 50 CFR 402.12 (g). The 

EIS is programmatic by design and does not identify or authorize site-specific vegetation treatments or amend 

Land and Resource Management Plans, and as a programmatic analysis, it contains the appropriate level of 

Endangered Species Act analysis at the scale for which it was intended. To minimize potential impacts to 

Federally Listed species and critical habitat, all Standard Operating Procedures and PEIS Mitigation Measures 

indentified in Appendix 2, as well as the Protective Measures in the PEIS Biological Opinion (NMFS 2007) 

and the Conservation Measures listed in the Biological Assessment are applicable unless otherwise modified 

by subsequent site-specific analysis and Endangered Species Act consultation. The EIS states that site-specific 

analysis, as well as Endangered Species Act consultation, must be completed prior to any project approval for 

vegetation treatment with herbicides. It is at the site-specific level that potential impacts to specific Federally 

Listed species are best analyzed and the most effective Conservation Measures are developed. 

297. Comment: The entire Biological Assessment from the PEIS should have been provided as part of the EIS 

for easier reference.

Response: The Biological Assessment for the PEIS includes information on almost 300 species, of which only a 

small subset occur in Oregon and are therefore not affected by the Proposed Action (Alternative 4). Some parts of 

the PEIS Biological Assessment covered non-herbicide treatments addressed in the PER, but outside of the scope 

of this EIS. The relevant information concerning those species that do occur in Oregon is provided in Appendix 
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Final Environmental Impact Statement: Appendix 10

5 of the EIS. At over 530 pages, printing the entire Biological Assessment for distribution was not practical. The 

Biological Assessment is available on the EIS website, and has been included on CD versions of the Final EIS.

298. Comment: The EIS does not adequately address the effects that 2,4-D, diuron, and triclopyr BEE may have 

on Federally Listed fish species. The EPA found that current labeled uses of these three herbicides are likely to 

adversely affect Oregon’s Threatened and Endangered salmon and steelhead. The BLM should not propose their 

use until the National Marine Fisheries Service completes final Biological Opinions for these herbicides.

Response: Near the end of Chapter 1, the EIS notes that 37 pesticides including three of the herbicides included 

in the Proposed Action (Alternative 4) in this EIS are part of a July 2008 settlement agreement reached in 

Northwest Coalition for Alternatives to Pesticides et al. v. National Marine Fisheries Service, which requires 

National Marine Fisheries Service to complete consultation on the registration of these pesticides. That settlement 

agreement stems from a 2002 decision by the District Court for the Western District of Washington finding that 

the EPA had not consulted with National Marine Fisheries Service regarding the potential affects to Federally 

Listed salmon for 55 pesticides. That consultation has not been completed. 

In January 2004, in response to the EPA consultations having not been completed, the same court ordered buffer 

zones be applied to salmon supporting waters, noting pesticide application buffer zones are a common, simple, 

and effective strategy for avoiding jeopardy for Threatened and Endangered salmonids. The court, however, 

exempted applications by Federal Agencies for which National Marine Fisheries Service consultation had been 

conducted, perhaps because such uses already meet one of the “termination events” applicable to the courtordered buffer requirements, that is, the issuance of a National Marine Fisheries Service Biological Opinion. 

As noted in the EIS, the BLM would conform to any future EPA label restrictions resulting from the EPA and 

National Marine Fisheries Service consultation on these pesticides, but there is certainly nothing to indicate the 

BLM’s use should be stopped pending completion of that consultation, or indeed that BLM’s uses do not already 

meet the resolution sought in the original case.

That said, the potential effects that herbicides, including; 2,4-D, diuron and triclopyr BEE, pose to Federally 

Listed fish species are addressed in the EIS and Biological Assessment and are consistent with the results 

of NEPA analysis and Endangered Species Act consultation conducted for the PEIS. To further minimize the 

potential effects to Federally Listed fish species, the PEIS Biological Opinion (NMFS 2007) contains Protective 

Measures to be followed in addition to the Standard Operating Procedures identified in Appendix 2 of the EIS. 

The EIS states that site-specific analysis, as well as Endangered Species Act consultation, as appropriate, must be 

completed prior to any project approval for vegetation treatment. 

299. Comment: The BLM cannot assure compliance with the Endangered Species Act if approving herbicides 

with undisclosed ingredients that are likely harmful to Federally Listed species such as Coho salmon.

Response: Additional information about inert ingredients and adjuvants has been added to the Final EIS. The 

additional information documents BLM and Forest Service reviews of confidential business information and 

other information that indicates a very low likelihood that any undisclosed ingredients would have toxic effects 

on any resource beyond those already described in the Risk Assessments for the herbicides themselves. A list of 

herbicide products approved for use by the BLM at the National level is included in Appendix 9. Many inerts 

have been found to have high toxicity levels, and inclusion of one or more of those toxic inerts would preclude the 

formulation from being approved by the BLM for use.

300. Comment: The list of Endangered, Threatened and Bureau Sensitive species provided in the EIS is not 

complete based on information contained in Butterflies and Moths of Pacific Northwest Forests and Woodlands: 

Rare, Endangered, and Management-Sensitive Species (USDA 2007x). 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Response: The EIS list is complete. Tables A5-1 and A5-2 of the EIS accurately reflect the current list of 

butterflies in the BLM’s Special Status Species Program, which includes Threatened, Endangered, proposed, and 

Bureau Sensitive species. It appears that the referenced text is using the term “management-sensitive,” which is 

not a category of species considered by the BLM. 

Appendix 8 – Human Health and Ecological Risk 

Assessments

301. Comment: Appendix 8 states that the courts have found that the Federal Insecticide, Fungicide and 

Rodenticide Act does not require the same examination of the impacts that the BLM is required to undertake 

under NEPA. What courts?

Response: The United States Court of Appeals for the Ninth Circuit found this in their 1983/84 rulings. This 

point has been clarified in the text.

Appendix 9 – Additional Information About the 

18 Herbicides

302. Comment: Appendix 9 lists a number of important native species and the herbicides that would target them. 

It is not clear when herbicides would be used to target these species.

Response: Herbicides could be used under Alternative 3 on native plants only to control the spread of pests and 

diseases in State-identified control areas, such as the one for Sudden Oak Death in Curry County. Herbicides 

could be sprayed on native species under Alternative 4 (the Proposed Action), to accomplish safety and 

maintenance objectives in administrative sites, rights-of-way, and recreation sites, or to achieve habitat goals 

specified in Conservation Strategies for Federally Listed or other Special Status species. Herbicides could be used 

on any undesired vegetation under Alternative 5, provided that the objective was not to grow timber or livestock 

forage.

Native species were also included in Appendix 9 because it is important to know what desired species might 

be harmed if the species were to be exposed to one of the proposed herbicides. An explanation of this has been 

added to Appendix 9.

303. Comment: The Oregon Institute of Applied Ecology in Corvallis Oregon has helped conduct research 

on biology, management, and recovery of native plant species; studied and performed habitat management and 

restoration; and, conducted research on effective control techniques for invasive weeds. Our studies indicate 

herbicides are needed as follows:

1) The only non-herbicide method that is effective in removing meadow knapweed is hand-grubbing which 

is relatively expensive. Herbicides have been effectively used to control this species.

2) After eight years of studying various control techniques for false-brome, we found that herbicides could 

successfully be used to control this invasive species, while avoiding negative impacts to native species, 

including the Threatened Kincaid’s lupine, Nelson’s checkermallow, and the Endangered Fender’s blue 

butterfly. Although manual techniques can be used to control false-brome in small areas, those areas are 

re-invaded within a year or two and manual techniques are not cost effective on large infestations. 
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Final Environmental Impact Statement: Appendix 10

3) Each year, rare native prairie habitat is lost to invasive species since the current control methods are not 

effective at killing priority invasive species such as Canada thistle, Himalayan blackberry, annual grasses, 

and reed canarygrass. Judicious use of herbicides would restore these areas.

4) In a five-year study of restoration methods in Willamette Valley upland prairies, a combination of burning 

and treatment with both a broad-spectrum and grass-specific herbicide was the most successful restoration 

method. When timed correctly, this treatment had minimal effects on established native species, but 

caused a significant decline in the cover of non-native species. In contrast, treatments without herbicides 

were ineffective in reducing the cover of non-native species or increasing the cover of native species.

Response: The control of invasive plants to restore native plant communities is a primary purpose for BLM’s 

proposal to increase the number of herbicides available for use. Native plant communities contain the primary 

resources that comprise wildlife habitat and forage. The herbicides being proposed were selected for their 

efficiency in controlling weeds and the ability to use them in a manner that prevents or minimizes impact to nontarget species. Table A9-2 lists the recommended herbicides for various species. It also lists the alternative where 

effective control becomes available. The information in this table applies to established infestations that are 

more difficult and costly to control than new or small infestations. Many species may be effectively controlled 

with non-herbicide methods such as hand pulling or digging; however, on a larger scale, these treatments are not 

practical. For example, the Oregon Institute of Applied Ecology noted that hand pulling was effective on Meadow 

knapweed. While this is true, hand pulling may be too expensive to be feasible on larger infestations. Therefore, 

there is no conflict in the findings of the Oregon Institute of Applied Ecology and the information summarized in 

Table A9-2.

304. Comment: Numerous field studies done by The Nature Conservancy, the Institute for Applied Ecology, and 

a wide variety of local organizations have shown that the only cost/time/resource-effective method for managing 

Garlic mustard, false brome, Knotweed, False Indigo and yellow archangel is through the use of herbicide 

treatments.

Response: Treatment recommendations for these species have been added to Appendix 9.

Miscellaneous

305. Comment: Tables should clearly identify the No Action (Alternative 2) and the Proposed Action 

(Alternative 4) in the headers, so as not to confuse or mislead the reader.

Response: This issue has been corrected in the Final EIS.

306. Comment: The EIS format is confusing. For example, Affected Environment and Environmental 

Consequences have been combined for no apparent benefit; Comparison of Alternatives should be in the 

Environmental Consequences chapter; subjects are hard to find without footers or being placed alphabetically; 

Incomplete and Unavailable Information should be in Chapter 3; Conflicts with Other Plans should be in Chapter 

1; and Cumulative Impacts should be at the end of the Environmental Consequences chapter. 

Response: Although the CEQ regulations at 40 CFR 1502.15 and 16 address the requirements of the Affected 

Environment and Environmental Consequences separately, they do not require they be separated in the analysis. 

In this case, we believe the reader is better served to have the description of the resource presented immediately 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

prior to addressing the effects of the alternative on that resource. This approach has been used by other EISs, 

notably the Northwest Forest Plan (USDA, USDI 1994a) and its subsequent amendments. It was also used in 

the 2004 EIS for amending National Forest and BLM District Plans for the management of Port-Orford-cedar 

(USDA, USDI 2004). This approach prevents needing to summarize the affected environment section before 

starting the environmental consequences section.

The BLM discovered during preparation that the narrow focus of the analysis required a significant discussion 

of setting and assumptions; hence, Chapter 3 is long and detailed. Nothing in Chapter 3 is effects per se, but 

assumptions for the effects analysis. Thus, Incomplete and Unavailable Information and other sections correctly 

addressing affected environment and/or environmental consequences have been left in Chapter 4. 

The Comparison of Alternatives section has been rewritten and left in Chapter 2. This is consistent with 40 

CFR 1502.14, Alternatives Including the Proposed Action. This regulation states, “This section is the heart of 

the environmental impact statement. Based on the information and analysis presented in the sections on the 

Affected Environment (Sec. 1502.15) and the Environmental Consequences (Sec. 1502.16), it should present the 

environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues 

and providing a clear basis for choice among options by the decision-maker and the public.” The separation is 

elucidated in CEQs Forty Most Asked Questions, question number 7, Difference Between Sections of EIS on 

Alternatives and Environmental Consequences (CEQ 1981). The discussion builds on the regulation with:

In order to avoid duplication between these two sections, most of the “alternatives” section should be devoted 

to describing and comparing the alternatives. Discussion of the environmental impacts of these alternatives 

should be limited to a concise descriptive summary of such impacts in a comparative form, including charts 

or tables, thus sharply defining the issues and providing a clear basis for choice among options (Section 

1502.14). The “environmental consequences” section should be devoted largely to a scientific analysis of the 

direct and indirect environmental effects of the proposed action and of each of the alternatives. It forms the 

analytic basis for the concise comparison in the “alternatives” section.

The Chapter 2 Comparison of the Effects of the Alternatives section in the Final EIS has been converted mostly to 

table form to better contrast the differences between the alternatives, as suggested by the CEQ direction.

The resource sections in Chapter 4 are sequenced to match the PEIS upon which they are tiered. Consideration 

was given to alphabetizing, but the titles are not necessarily intuitive enough for an alphabetical arrangement to 

be very helpful. However, a) the EIS chapters are now separated by colored card stock; b) a table of contents 

has been added to the start of each chapter immediately following the colored chapter separators; and c) resource 

section headers now include the name of the section. 

The Conflicts with Other Plans has been moved to Chapter 1 as suggested. 

Finally, since the entire programmatic analysis is essentially a cumulative effects analysis, miscellaneous 

information applicable to more than one section were presented early in Chapter 4 to help provide context to 

individual sections, particularly as some of those sections refer to those actions. Some of the ongoing actions 

described in the Draft EIS in the Cumulative Impacts section, however, are not impacts. These have been moved 

to the end of Chapter 1.
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Final Environmental Impact Statement: Appendix 10

References

Austin et al. 1991

Austin, A.P., G.E. Harris, and W.P. Lucey. 1991. Impact of an Organophosphate 

Herbicide (Glyphosate) on Periphyton Communities Developed in Experimental 

Streams. Bulletin of Environmental Contamination and Toxicology 41:29-35.

Baldwin et al. 2009

Baldwin, David H, Julann A. Spromberg, Tracy K. Collier, Nathaniel L. Scholz 

(2009) A fish of many scales. Extrapolating sublethal pesticide exposures to the 

productivity of wild salmon populations. Ecological Applications. 19(8)2004-2015

Banks 1979

Banks P. A.; M. L. Ketchersid; M. G. Merkle. The Persistence of Fluridone in 

Various Soils under Field and Controlled Conditions. Weed Science, Vol. 27, No. 6 

(Nov., 1979), pp. 631-633

Bedell et al. 1993

Bedell, T.E.; L.E. Eddleman; T. Deboodt; C. Jacks.1993. Western Juniper-Its 

Impact and Management in Oregon Rangelands. Oregon State University Extension 

Service, EC 1417. pp15.

Benachour and Seralini 

2008 

Benachour, N. and Seralini, G-E. 2008. Glyphosate Formulations Induce Apoptosis 

and Necrosis in Human Umbilical, Embryonic, and Placental Cells Chemical 

Research in Toxicology, DOI:10.1021/tx800218n. December 23, 2008. Available at 

http://pubs.acs.org/doi/abs/10.1021/tx800218n

Berg 2004

Berg, Neil, 2004, Assessment of Herbicide Best Management Practices: Status of 

Our Knowledge of BMP Effectiveness, Pacific Southwest Research Station, USDA 

Forest Service, Albany, CA.

Bernanke and Kohler 2008

Bernanke Julie, and Heinz-R Kohler. 2008. The Impact of Environmental 

Chemicals on Wildlife Vertebrates. Reviews of Environmental Contamination and 

Toxicology. 198:1-47

Berrill et al 1994

Berrill, M., S. Betram, L. McGillivray, M. Kolohan, and B. Pauli. 1994. Effects 

of low concentrations of forest-use pesticides on frog embryos and tadpoles. 

Environmental Toxicology and Chemistry 13:657-664.

Brown 2009 Brown, Gay. 2009. Oregon Grasshopper and Mormon Cricket Summary for 2009. 

United States Department of Agriculture, APHIS

Busse et al. 2003

Busse, M.; G. Fiddler; and N. Gillette. 2003. Are herbicides detrimental to 

ectomycorrhizae? In: Cooper, S.L. (comp.) Proceedings, 24th Ann. Forest 

Vegetation Management Conference, Jan. 14-16, 2003; Redding, CA. Univ. 

California Coop. Exten., Redding, CA. pp. 46-53.

Call et al. 1987, 

Call, D.J, L. T. Brooke, R. J. Kent, M. L. Knuth, S. H. Poirier, J. M. Huot, and A. 

R. Lima. 1987. Bromacil and Diuron Herbicides: Toxicity, Uptake, and Elimination 

in Freshwater Fish. Archives of Environmental Contamination and Toxicology. 16, 

607-613.

CEQ 1981 Council of Environmental Equality. 1981. Forty Most Asked Questions. 46 Fed. 

Reg. 18026. Available at http://ceq.hss.doe.gov/nepa/regs/40/40p1.htm

Connelly et al. 2004

Connelly, J.W., S.T. Knick, M.A. Scrhoeder and S.J. Stiver. 2004. Conservation 

Assessment of Greater Sage-grouse and Sagebrush Habitats. Western Association of 

Fish and Wildlife Agencies. Unpublished Report. Cheyenne, Wyoming

Cooperrider 1995

Cooperider, A., et. al. 1995. In, State of the Biome Uniqueness, Biodiversity, 

Threats and the Adequacy of Protection in the Sonoran Bioregion. The Wildland 

Project. March 1998,Tucson, Arizona
 760

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Cornell University 2008

Cornell University. 2008. Evaluation of acetic acid based herbicides for use in 

broad-spectrum turfgrass and weed control. Available at http://www.ccerensselaer.

org/Horticulture-Program/Turfgrass-Research/Vinegar-Herbicide.aspx

CRBC 2008 Clackamas River Basin Council. 2008. History of Knotweed Control in Clackamas 

County. Available at http://www.clackamasriver.org/misc/knotweed_history.htm

Cusack and Harte 2008 Cusack, C., and Harte, M. 2008. The Economics of Invasive Species. Prepared for 

the Oregon Invasive Species Council. July 2008

Dent and Robben 2000

Dent, Liz and Joshua Robben, 2000, Aerial Pesticide Application Monitoring Final 

Report, Oregon Department of Forestry, Forest Practices Monitoring Program, 

Technical Report 7.

DiTomaso 2000 DiTomaso, Joseph. 2000. Invasive weeds in rangelands: Species, impacts, and 

management. Weed Science, Volume 48 pages 255-266. March – April, 2000.

DiTomaso and Healy 2007

DiTomaso, J.M. and E.A. Healy. 2007. Weeds of California and other Western 

States. UC

DANR Publ. #3488. 1808 pp.

Dobkin and Sauder 2004

Dobkin, D. S. and J. D. Sauder. 2004. Shrubsteppe landscapes in jeopardy. 

Distributions, abundances and the uncertain future of birds and mammals in the 

Intermountain West. High Desert Ecological Research Institute. Bend, OR.

EFSA 2005 EFSA (2005). Conclusion on the peer review of diuron. EFSA Scientific Report 25. 

European Food Safety Organisation.

Elliott et al. 1998

Elliott, J.A. et al. 1998. Leaching and preferential flow of clopyralid under 

irrigation: Field observations and simulation modeling. J. Environ. Qual. 27: 124-

131.

ENSR 2005j

ENSR. 2005j. Vegetation Treatments Programmatic EIS – Sulfometuron Methyl 

Ecological Risk Assessment Final Report. Prepared for the U.S. Department of 

the Interior Bureau of Land Management, Nevada State Office, Reno, Nevada. 

Westford, Massachusetts.

EPA 1993

Environmental Protection Agency. 1993. Reregistration Eligibility Decision (RED). 

U.S. EPA Publication Glyphosate. Office of Prevention, Pesticides and Toxic 

Substances.

EPA 2001 Environmental Protection Agency. 2001. Pesticide Registration (PR) Notice 2001-x 

Draft: Spray and Dust Drift Label Statements for Pesticide Products

EPA 2002 see Branda

EPA 2003b

Environmental Protection Agency. 2003b. Reregistration Eligibility Decision for 

Diuron. Washington D.C. Available at http://www.epa.gov/pesticides/reregistration/

REDs/diuron_red.pdf

EPA 2005a

Environmental Protection Agency. 2005a. Reregistration Eligibility Decision for 

2,4-D. EPA 738-R-05-002, Washington D.C. Available at http://epa.gov/oppsrrd1/

REDs/24d_red.pdf

EPA 2008b Environmental Protection Agency. 2008b. Reregistration Eligibility Decision for 

Sulfumeturon methyl, Washington D.C. 

EPA 2010 Endocrine disruptor screening program
761

Final Environmental Impact Statement: Appendix 10

Extoxnet 1996c

Extension Toxicology Network (Extoxnet). 1996c Sulfometuron Methyl. Pesticide 

Information Profiles. Extension Toxicology Network. Available at: http://extoxnet.

orst.edu/pips/sulfomet.htm.

Franke et al. 1994

Franke, C., G. Studinger, G. Berger, S. Bohling, U. Bruckmann, D. CohorsFresenborg, and U. Johncke. 1994. The Assessment of Bioaccumulation. 

Chemosphere. 29, 1501-14. 

Health Canada 2009

Health Canada. 2009. Questions and Answers - Final Decision on the Re-evaluation 

of 2,4-D. Available at http://www.hc-sc.gc.ca/cps-spc/pest/part/protect-proteger/useutiliser/_24d/24d-faq-eng.php#dogs

Houston et al. 1998

Houston, A.P.C.; S. Visser; R.A. Lautenschlager. 1998. Response of microbial 

processes and fungal community structure to vegetation management in mixed 

wood forest soils. Canadian Journal of Botany 76: 2002-2010.

IUCN 2008

International Union for Conservation of Nature. 2008. Wildlife in a Changing 

World. Ana Analysis of the 2008 IUCN Red List of Threatened Species. Edited by 

Jean-Christophe Vie, Craig Hilton-Taylor and Simon N Stuart.

Johnson et al. 1995 Johnson, W.G., T.L. Lavy, and E.E. Gbur. 1995. Persistence of Triclopyr and 2,4-D 

in Flooded and Non-flooded Soils. Journal of Environmental Quality 24:493-497.

JPR 1998 Journal For Pesticide Reform. 1998. Herbicide Gact Sheet: Clopyralid. Winter 

1998, Vol 18, No 4.

Kao et al. 1995

L.M. Kao, C.F. Wilkinson, L.B. Brattsten, In vivo effects of 2,4-D and atrazine on 

cytochrome P450 and insecticide

toxicity in southern armyworm (Spodoptera eridania) larvae, Pestic. Sci. 45 (1995) 

331–334.

Laetz et al. 2009

Laetz, Cathy A David H. Baldwin, Tracy K. Collier, Vincent Hebert, John D. Stark, 

and Nathaniel L. Scholz. 2009. The Synergistic Toxicity of Pesticide Mixtures: 

Implications for Risk Assessment and the Conservation of Endangered Pacific 

Salmon. Environmental Health Perspectives. Volume 117, Number 3.

McCall and Gavit 1986

McCall, P. J. and P. D. Gavit. 1986. Aqueous photolysis of triclopyr and its 

butoxyethyl ester and calculated environmental photodecomposition rates. Environ. 

Toxic. Chem. 5:879-885.

Miller et al. 2005

Miller, R.F., Bates, J.D., Svejcar, A.J., Pierson Jr, F.B., Eddleman, L.E. 2005. 

Biology, ecology, and management of western juniper (juniperus occidentalis). 

Oregon State University Agricultural Experiment Station. Technical Bulletin 152. 

77 p. Available at http://juniper.oregonstate.edu/bibliography/article.php?article_

id=53

NMFS 2007

National Marine Fisheries Service. 2007. Biological Opinion on the 2007 

Vegetation Treatments Using Herbicides on BLM Lands in 17 Western States Final 

Environmental Impact Statement. Available as an Appendix to the 2007 Vegetation 

Treatments Using Herbicides on BLM Lands in 17 Western States Record of 

Decision at http://www.blm.gov/wo/st/en/prog/more/veg_eis.html

ODEQ 2008

Oregon Department of Environmental Quality. 2008. Oregon Toxics Monitoring 

Program Willamette River Basin Year One (2008) Summary Report DRAFT. 

http://www.deq.state.or.us/about/eqc/agendas/attachments/2009oct/E-AttAToxicsMonitoring.pdf
 762

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

OSU 2009

Oregon State University. 2009. Pacific Northwest Weed Management Handbook. 

Editor: Ed Peachey. Available at http://weeds.ippc.orst.edu/pnw/weeds?01W_

INTR06.dat

Paige and Ritter 1999 Paige, C. and S. Ritter. 1999. Birds in a sagebrush sea. Partners in Flight, Western 

Working Group. Boise, ID.

PARC 2001, 2006, 2007 Pesticide Analytical and Response Center (Oregon Department of Agriculture) 

2001 Annual Report. Available at http://www.oregon.gov/ODA/PEST/parc.shtml

Peterson and Stringham 

2008

Peterson S. L. and Stringham T.K. 2008. Infiltration, Runoff and Sediment Yield 

in Response to Western Juniper Encroachment in Southeast Oregon. Rangeland 

Ecology and Management 61(1) 24-81

Pierson et al. 2007

Pierson, Frederick B., Jon D. Bates, Tony J. Svejcar, and Stuart P. Hardegree. 

2007. Runoff and Erosion after cutting western juniper. Rangeland Ecology and 

Management. 60(3)285-292

Radke and Davis 2000

Radke, Hans D. and Shannon W. Davis. 2000. Economic Analysis of Containment 

Programs, Damages, and Production Losses From Noxious Weeds in Oregon. 

Oregon Department of Agriculture, Plant Division, Noxious Weed Control Program. 

Rashin and Graber 1993

Rashin, Ed and Craig Graber, 1993, Effectiveness of Best Management Practices 

For Aerial Application Of Herbicides, Washington State Department of Ecology 

Publication 93-81.

Relyea 2005

Relyea, R. A. 2005. The lethal impact of Roundup® on aquatic and terrestrial 

amphibians. Ecological Applications 15:1118-1124. Available at http://www.pitt.

edu/~relyea/Site/Publications.html

Relyea et al 2005

Relyea, R.A., N.M. Schoeppner, and J.T. Hoverman. 2005. Pesticides and 

amphibians: The importance of community context. Ecological Application. 

15:1124-1134

SERA 2003a

Syracuse Environmental Research Associates, Inc. (SERA). 2003a. Glyphosate 

– Human Health and Ecological Risk Assessment Final Report. SERA TR 02-43-

09-04a. Prepared for the U.S. Department of Agriculture Forest Service, Arlington, 

Virginia. Fayetteville, New York.

SERA 2004b

Syracuse Environmental Research Associates, Inc. (SERA). 2004b. Clopyralid 

(Transline) – Human Health and Ecological Risk Assessment Final Report. SERA 

TR 04 43-17-03c. Prepared for the U.S. Department of Agriculture Forest Service, 

Arlington, Virginia. Fayetteville, New York.

SERA 2004d

Syracuse Environmental Research Associates, Inc. (SERA). 2004d. Imazapyr – 

Human Health and Ecological Risk Assessment Final Report. SERA TR 04-43-17-

05b. Prepared for the U.S. Department of Agriculture Forest Service, Arlington, 

Virginia. Fayetteville, New York.

Sheley and Petroff 1999 Sheley, Roger L and Janet K Petroff. 1999. Biology and Management of Noxious 

Rangeland Weeds. Oregon State University Press.

Smith 1974

Smith, Allan E. 1974. Breakdown of the herbicide dicamba and its degradation 

product 3,6-dichlorosalicylic acid in prairie soils. Journal of Agricultural and Food 

Chemistry. 22 (4), pp 601–605

Theodoropoulos 2003 Theodoropoulos, David. 2003. Invasion Biology: Critique of A Pseudoscience. 

Avatar Books. Blythe, CA
763

Final Environmental Impact Statement: Appendix 10

TNC 2009 The Nature Conservancy. 2009. The Nature Conservancy Element Stewardship 

Abstracts. Avaliable at http://www.imapinvasives.org/GIST/ESA/index.html

Trubey et al. 1998 

Truby, R.K., Bethem, R.A., and Peterson, B. (1989). Degradation and Mobility of 

Sulfometuron-methyl (Oust Herbicide) in Field Soil. J. of Agricultural and Food 

Chem. 46:2360-2367.

Tu et al. 2001

Tu, M., C. Hurd, and J. M. Randall. 2001. Weed Control Methods Handbook: Tools 

& Techniques for Natural Areas. The Nature Conservancy, http://www.invasive.org/

gist/handbook.html, version. June 2001.

USDA 2005

USDA Forest Service. 2005. Pacific Northwest Region Invasive Plant Program: 

Preventing and Managing Invasive Plants. Final Environmental Impact Statement. 

Available at http://www.fs.fed.us/r6/invasiveplant-eis/

USDA, USDI 1994a

USDA Forest Service and USDI Bureau of Land Management. 1994a. Final 

Supplemental Environmental Impact Statement on management of habitat for latesuccessional and old-growth species within the range of the Northern Spotted Owl.

USDA, USDI 1994b

USDA Forest Service and USDI Bureau of Land Management. 1994b. Record of 

Decision on management of habitat for late-successional and old-growth species 

within the range of the Northern Spotted Owl.

USDA, USDI 2004 USDA Forest Service and USDI Bureau of Land Management. 2004. Management 

of Port-Orford Cedar in Southern Oregon. Final Environmental Impact Statement.

USDI 1989 USDI Bureau of Land Management. 1989. Western Oregon – Management of 

Competing Vegetation Final Environmental Impact Statement. Washington D.C.

USDI 1992a USDI Bureau of Land Management. 1992a. BLM Manual 1745. Introduction, 

Transplant, Augmentation, and Reestablishment of Fish, Wildlife, and Plants. 14pp.

USDI 1992b

USDI Bureau of Land Management. 1992b. Manual 9015. 2-Dec-92. Integrated 

Weed Management. Release 9-321. Available at http://www.blm.gov/ca/st/en/prog/

weeds/9015.html

USDI 1992c USDI Bureau of Land Management. 1992c. Chemical Pest Control Handbook 

(BLM Manual 9011)

USDI 2005f USDI Bureau of Land Management. 2005f Land Use Planning. Manual Handbook 

Number 1601-1. Washington D.C.

USDI 2005g south deer landscape EA

USDI 2006d Columbia White tailed deer

USDI 2007e USDI. 2007e. Department of the Interior Departmental Manual. Part 517. 

Pesticides.

USDI 2008a USDI Bureau of Land Management. 2008a. Integrated Vegetation Management. 

Manual Handbook Number H1740-2. Washington D.C. March 2008.

USDI 2008b

USDI Fish and Wildlife Service. 2008b. Biological opinion for SOD eradication 

activities scheduled to occur on federal lands administered by the Rogue River–

Siskiyou National Forest (Forest) and the Coos Bay District Bureau of Land 

Management (District), FWS Reference Number 13420-2008-F-0041. FWS 

Roseburg Field Office. Roseburg, OR. 113 pp. 

USDI 2008d USDI Bureau of Land Management.. 2008d. 522 Department Manual 1; Adaptive 

Management. Washington D.C. 3 pp.
 764

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

USDI 2009 USDI Bureau of Land Management. 2009. IM No OR-2009-018 

USGS 2002

U.S. Geological Survey. 2002. Glyphosate Herbicide Found in Many Midwestern 

Streams, Antibiotics Not Common. Toxic Substances Hydrology Program. 

Available at http://toxics.usgs.gov/highlights/glyphosate02.html

Vencill et al. 2002 Vencill, W. K. (ed.). 2002. Herbicide Handbook, 8th ed. Weed Science Society of 

America, Lawrence, KS. pp. 155-157.

Wentz et al. 1998

Wentz, Dennis A., Bernadine A. Bonn, Kurt D. Carpenter, Stephen R. Hinkle, Mary 

L. Janet, Frank A. Rinella, Mark A. Uhrich, Ian R. Waite, Antonius Laenen, and 

Kenneth E. Bencala. 1998. Water Quality in the Willamette Basin, Oregon, 1991–

95. US Department of the Interior and US Geographical Survey

Westbrooks 1998

Westbrooks, R. 1998. Invasive plants, changing the landscape of America: Fact 

book. Federal Interagency Committee for the Management of Noxious and Exotic 

Weeds (FICMNEW), Washington, D.C. 109 pp.

Wood 2001

Wood, Tamara, 2001, Herbicide Use in the Management of Roadside Vegetation, 

Western Oregon, 1999–2000: Effects on the Water Quality of Nearby Streams, 

USGS, Water-Resources Investigations Report 01–4065.

Woodward et al. 1997

Woodrow J. E., Seiber J. N., and Baker L. W. (1997) Correlation techniques for 

estimating pesticide volatilization flux and downwind concentrations. Environ. Sci. 

Technol. 31(2), 523–529.
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Appendix 11 - 

Comment Letters from Federal, State, 

and Local Government Agencies on the 

2009 Draft EIS

This appendix contains comment letters from Federal, State, and local government agencies. The 

Environmental Protection Agency (EPA) has a legal obligation under Section 309 of the Clean Air Act to 

review and comment on environmental impact statements. Their letter reviewing the Draft EIS appears at 

the beginning of this appendix.
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Appendix 12 - 

2,4-D 

Introduction

Because of public concern over the use of 2,4-D, the BLM has focused particular attention on whether or not 

to continue to include 2,4-D in one or more of the action alternatives. Following the July 2008 scoping period, 

while the EIS team was seeking herbicide use estimates from the nine BLM districts in Oregon, districts were 

specifically asked to identify what their program would look like without 2,4-D. The Steering Committee 

considered this and other preliminary information and decided to include 2,4-D in the action alternatives in 

the Draft EIS. Again in January of 2010 in response to the Draft EIS analysis and over 800 public comments 

specifically mentioning concerns with 2,4-D, the districts and others were again asked about the implications of 

managing invasive plants and other vegetation without 2,4-D. The Steering Committee examined the responses 

along with the other available information about 2,4-D and decided to retain it within the action alternatives in 

the Final EIS. This appendix includes much of the information considered by the Steering Committee in 2010 

(updated to Final EIS language), in the hopes that it will facilitate public and decision-maker understanding of the 

risks and the value associated with this product.

2,4-D is a widely used, selective, broad-leaf herbicide first registered for use in 1944, and extensively studied 

since that time. It is inexpensive, effective on a broad range of noxious weeds and other plants either alone and 

in tank mixes, one with which BLM and other applicators are well familiar, and non-carcinogenic. BLM Weed 

Coordinators, permit and rights-of-way holders, and cooperators all report serious implications to their programs 

if its use on BLM lands is discontinued.

However, its association with Agent Orange, with timber spraying in the 1980s, and potential human and 

environmental risks when compared with some of the other herbicides being proposed, continue to raise public 

controversy. Of the 1050 public letters received on the DEIS, 821 (including form letters) specifically mentioned 

2,4-D as something they opposed. A few writers were opposed to 2,4-D in spite of being in favor of the remainder 

of the Proposed Action.

Uses and Importance

District Query 2008

Scoping comments in 2008 led the BLM to consider removing 2,4-D during formulation of the alternatives in late 

2008. The districts reported heavy reliance on 2,4-D, particularly in tank mixes to reduce the quantity of other 

herbicides needed, and to make other herbicides more effective. It was noted that BLM permit/rights-of-way 

holders and cooperators also rely on 2,4-D when spraying on BLM lands. Wind farms, solar, and transmission 

corridors are increasing rapidly, contributing to a continuing need for such reliance.

District Query 2010

In January 2010, the districts were asked again if there were reasonable substitutes for 2,4-D, and specifically, 

would removing 2,4-D reduce the BLM’s ability to meet Purpose 6, to cooperatively control invasive plants so 

they do not infest or re-infest adjacent non-BLM lands. Districts were encouraged to contact cooperators and ask 
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specifically what the loss of 2,4-D would mean to cross-boundary control efforts. The districts were also asked 

why 2,4-D use was not projected to decrease on the west side between Alternatives 2 and 3, when eight more 

herbicides become available but only invasive weeds are added to the control objectives. (East side projections 

dropped 72 percent.) District and Oregon State Office (OSO) staff responses included the following:

Effectiveness

• 2,4-D increases the effectiveness of other herbicides thereby reducing the pounds of herbicide applied per 

acre, reducing the need for multiple applications, reducing cost, and reducing weed population resistance 

development. 

• The development of weed resistance to 2,4-D has been minor.

• 2,4-D provides a burn-down that effectively stops the plants’ progress towards seed ripening, even at 

advance phenological stages, that cannot be duplicated with other herbicides. This extends the control 

window so crews can reach multiple control locations.

• 2,4-D in tank mixes similarly extends the spray season for many weeds (e.g. knapweed).

• ALS-inhibitor herbicides are more likely to result in herbicide resistance than 2,4-D.

• One of the few effective treatments for rush skeletonweed is 2,4-D early in the season, followed by 

picloram in the late season. 2,4-D and sulfometuron methyl is effective on difficult-to-control whitetop 

and perennial pepperweed. 

• Aquatic formulations of 2,4-D can be used in riparian areas and are less damaging to other vegetation than 

the use of glyphosate. 

• 2,4-D is selective for woody vegetation that encroaches on roads, but does not kill grass important to 

maintaining road cut and ditch stability.

Cooperator Implications

• Oregon Department of Agriculture and Oregon Department of Transportation use 2,4-D as a component 

of 85 percent of their roadside noxious weed spraying. Heavier reliance on glyphosate could lead to weed 

resistance. 

• The lower cost of 2,4-D when compared to other herbicides makes it commonly used by BLM 

cooperators.

• 2,4-D is commonly used by BLM cooperators such as Counties and timber companies due in part because 

it was one of only four herbicides available for use on BLM lands and there was a desire to develop 

compatible weed control strategies and applications. 

Target Species: 2,4-D is one recommended herbicide for 91 of the 230 invasive and native target plants listed 

on Table A9-2 in Appendix 9, and is the only herbicide available under the proposed action for the control of 

three of the invasive plant species (see 2,4-D entries in Attachment 1). However, dropping 2,4-D because other 

herbicides would control most target plants means decreasing the options for site-specific selection of the most 

effective, least impacting herbicide. For example, loss of 2,4-D and restrictions on picloram use (it is persistent 

and leachable) mean only one other herbicide is available for diffuse and spotted knapweeds, Mediterranean 

sage, puncturevine, St. Johnswort, Swainsonpea, velvetleaf, European centaury, sowthistles, and rabbit brush – 

which could lead to herbicide resistance. 2,4-D is effective on Scotch and Portuguese brooms and gorse at low 

rates. (Triclopyr is effective on brooms as well, but it has various risks for wildlife.) West side districts reported 

needing it as a tank mix component for most of their spraying. 

The “newer, more target-specific” herbicides are an advantage for specific target weeds located where avoiding 

collateral damage is necessary, but those herbicides have few general uses and thus are not used for most weed 
785

Final Environmental Impact Statement: Appendix 12

control. Time, equipment costs, and worker health risks are all reduced when one, multiple-species herbicide mix 

can be used on many different target plants. 

Acres and Trends

Estimated use by alternative shows 2,4-D dropping statewide:

Alt 2 Alt 3 Alt 4 Alt5

West side 1800 2100 2300 2300

East side 6700 1900 3100 5200

Total 8500 4000 5400 7500

West side use is projected to increase across all alternatives 

While the additional uses added by Alternatives 4 and 5 would increase herbicide use when compared to 

Alternative 3, the reason for the west side increase between Alternatives 2 and 3 is that, because of the nature of 

the weeds on the west side, 2,4-D is a part of almost all tank mixes. Perhaps the pounds of 2,4-D will go down, 

but the 2008 query to the districts was not specific enough to reflect that.

Worker and Public Health

2,4-D enjoys widespread home and commercial use. It is the second-most commonly used herbicide in Oregon, 

and the BLM use would be .73% (less than 1%) of the 2,4-D used commercially in the State. The districts have 

used 2,4-D for more than 25 years without incident. It has been registered for use for over 60 years, and been the 

subject of extensive study. It was reregistered in 2005 with no uses dropped and two more added. Label changes 

in 2007 removed most grazing restrictions and tightened mixing instructions to reduce worker exposures. The 

EPA has set food and water tolerances; tolerance for drinking water is 70 ppb. It is not carcinogenic and is only 

remotely implicated in development abnormalities at extremely high doses. (These implications are currently 

being retested.) 2,4-D has a half-life in the body of 12 hours, does not metabolize or transform, is excreted 

unchanged, and does not accumulate.

The label rate for 2,4-D is 4 lbs/ac, and until recently, many BLM uses were at that rate. The current (PEIS) 

BLM maximum rate is 1.9 lbs, with a PEIS Mitigation Measure limiting applications to typical rate (1.0 lbs/ac, 

or 1/4 of label rates) where feasible, to reduce risk to workers and the public. Average application rates on BLM 

lands have been 1.66, 1.50, and 1.05 lbs/ac for 2006, 2007, and 2008 respectively, and they are still trending 

down in response to the new (lower) PEIS rates. Tank mixes normally include about 1/2 lb of 2/4-d per acre, but 

tank mixes raise additional health risks identified in the risk assessment (see Attachment 2). The risk ratings for 

maximum rate are based on the 4.0 pound label rate.

Although the BLM in Oregon has not had an incident with 2,4-D in 25 years, BLM use is less than one percent 

of state use. Therefore, the BLM queried three years of statewide Oregon Department of Agriculture pesticide 

incident reports and found relatively minor incidents at the rate of 3 or 4 a year, mostly home users drifting it onto 

neighbor’s plants. BLM uses SOPs and PEIS Mitigation Measures, certification, training, good equipment, and 

other standards to reduce the likelihood of incidents.
 786

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

The Final EIS analysis and associated 2006 2,4-D Risk Assessment shows moderate risk to workers and the public 

under two accidental exposure scenarios (Attachment 3, EIS Tables 3-18 and 19). It is responsible for about 67 

percent of the treatment acres posing a moderate or high risks to workers and public resulting from the proposed 

action, not counting spill scenarios (Table 4-36). The persistent soil-applied bromacil, diuron, and tebuthiuron 

herbicides are the only ones higher. (Attachment 2 contains the 2,4-D-related human health and safety excerpts 

from the Final EIS.)

The Risk Assessment Executive Summary recommends 2,4-D be used only as a last resort. The Forest 

Service decided not to include 2,4-D in their 2005 selected alternative for invasive plant control in Oregon and 

Washington, at least at the programmatic scale (see Attachment 4 for further discussion).

The Northwest Coalition for Alternatives to Pesticides (NCAP) has petitioned the EPA to drop 2,4-D registration 

and all food and water tolerances (see Non-BLM Actions Potentially Affecting the Use of Herbicides on BLM 

Lands in Oregon near the end of Chapter 1). EPA initiated a public comment period on the petition, and the 

Industry Task Forest II on 2,4-D Research Data submitted illustrative comments (project record; available upon 

request). The Industry Task Force is made up of several herbicide manufacturers for the purpose of funding (not 

directing) any registration research requested by the EPA or the Canadian Pest Management Regulatory Agency.

Environmental Effects

The risk table ratings for wildlife, fish, and aquatic species are included in Attachment 5, along with the 2,4-

D discussion extracted from each of the various resource sections in the EIS. 2,4-D poses some of the higher 

risk scenarios in the EIS but that is relative, and the analysis indicates Standard Operating Procedures and PEIS 

Mitigation Measures (like buffers, wind limitations, etc.) would virtually negate adverse effects, at least at the 

community and population level. 

2,4-D is bound tightly to organic matter, and breaks down quickly in wildland settings. It has a half-life of 10 

days; the shortest of the 18 herbicides addressed in the EIS. It is one of the herbicides found in the Columbia 

River, and can be moderately toxic to fish. All resource sections including Water Quality indicated that slowing 

noxious weed spread would more than make up for any risks from the proposed herbicide use.

2,4-D is important enough to noxious weed control that if it is dropped, the estimated weed spread-rate projections 

for the alternatives would need to be increased. Alts 3, and 4 are projected to reduce the spread of noxious weeds 

on BLM from the current 12% annually to 7% and 6% respectively. Not having 2,4-D would raise those rates at 

least to 8% and 7%. This would be consistent with the Forest Service 2005 analysis.

DEIS Public Comments

The BLM received 1050 public comment letters on the Vegetation Treatments Using Herbicides on BLM Lands in 

Oregon DEIS, with 821 of these specifically mentioning 2,4-D

From the letters mentioning 2,4-D, 18 unique substantive comments statements were created. These and their 

responses are in Appendix 10, numbers 19-22, 24, 35, 37, 38, 52, 75, 116-117, 191, 271-274, and 298. The 

Proposed Action would reduce the use of 2,4-D about 50 percent when compared to the No Action Alternative. 
787

Final Environmental Impact Statement: Appendix 12

Attachment 1 - 2,4-D Vegetation Control

(Source: Table A9-2)

Common Name

2,4-D

Clopyralid

Dicamba

Fluridone

Glyphosate

Hexazinone

Imazapic

Imazapyr

Metsulfuron

Picloram

Sulfometuron

Triclopyr

Chlorsulfuron

Diflufenzopyr+

Diquat

Diuron

Tebuthiuron

Bromacil

Vegetation that can only be controlled with 2,4-D

Creeping buttercup √

European Water chestnut √

Western water hemlock √

Vegetation that can only be controlled with 2,4-D under Alts 2-4

Parrot’s feather √ √

Vegetation that is especially well controlled with 2,4-D and another herbicide

Burdock, common √2 √3 √2 √ √2 √3

Knapweed, Diffuse √2 √2 √

Thistle, Bull √2 √ √2,3 √ √ √ √3

Thistle, Musk √2 √ √2 √ √ √3

Vegetation that is especially well controlled with 2,4-D, and not with any other herbicide

Kochia √2 √ √ √

Vegetation where 2,4-D is one of many tools that can be used for control

Babysbreath √ √

Big sagebrush √ √ √ √

Bur buttercup √ √ √ √ √

Chicory √ √ √2 √ √2

Cocklebur, spiny √ √ √ √ √

Common bugloss √ √ √ √ √

Dyers woad √ √ √ √

European centaury √ √

Field bindweed √ √ √

Field mustard √ √ √

Field sowthistle √ √ √

Garden cornflower or bachelor 

buttons √ √ √ √ √ √ √3

Garden vetch √ √ √ √

Goatsrue √ √ √

Halogeton √ √ √ √

Hawkweed, common √ √ √ √ √

Hawkweed, Yellow √ √ √ √ √

Horehound √ √ √3 √3

Hounds-tongue √ √ √2 √

Knapweed, Meadow √ √ √ √ √2 √ √3
 788

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Common Name

2,4-D

Clopyralid

Dicamba

Fluridone

Glyphosate

Hexazinone

Imazapic

Imazapyr

Metsulfuron

Picloram

Sulfometuron

Triclopyr

Chlorsulfuron

Diflufenzopyr+

Diquat

Diuron

Tebuthiuron

Bromacil

Knapweed, spotted √ √ √2

Madrone √ √ √ √

Mediterranean sage √ √ √

narrowleaf plantain √ √ √

Oblong spurge √ √ √ √ √ √

Paterson’s curse √ √ √ √ √

Paterson’s curse √ √ √ √ √

Poison hemlock √ √ √ √ √

Policemans helmet √ √ √

Prickly sowthistle √ √ √

Puncturevine √ √ √

Purple foxglove √ √ √ √ √

Rabbitbrush √ √ √

Rush skeletonweed √ √ √ √2

Spurge, Myrtle √ √ √ √ √

St. Johnswort √ √ √

Sulfur cinquefoil √ √2 √ √ √2

Swainsonpea √ √

sweet fennel √ √

Syrian bean-caper √ √ √ √3 √3

Tansy ragwort √ √ √ √ √

Teasel, common √ √ √3 √ √ √ √ √3

Thistle, Italian √ √ √ √

Thistle, Milk √ √ √3 √ √ √ √ √3

Thistle, Plumeless √ √ √3 √2 √ √ √ √ √3

Thistle, Russian √ √ √

Thistle, Slender flowered √ √ √ √

Thistle, Taurian or bull 

cottonthistle √ √ √

Thistle, wavyleaf √ √ √3 √ √ √ √ √3

Toadflax, Dalmation √ √ √ √

Tumbleweed or Prickly Russian 

thistle √ √ √ √ √ √

Velvetleaf √ √2 √

Whitetop, (Hoary cress) √ √ √ √ √ √ √

whitetop, Lens-podded √ √ √ √ √

Whitetop, Hairy √ √ √ √ √
789

Final Environmental Impact Statement: Appendix 12

Common Name

2,4-D

Clopyralid

Dicamba

Fluridone

Glyphosate

Hexazinone

Imazapic

Imazapyr

Metsulfuron

Picloram

Sulfometuron

Triclopyr

Chlorsulfuron

Diflufenzopyr+

Diquat

Diuron

Tebuthiuron

Bromacil

Willow √ √ √ √ √ √

Yellow Flag Iris √ √ √ √ √

Yellow glandweed √ √ √ √ √

Vegetation where 2,4-D would be used as part of a tank mix

Blackberry, Evergreen √3 √ √ √ √

Blackberry, Himalayan √3 √ √ √ √ √

Broom, French √3 √ √ √ √3 √

Broom, Portugese √3 √ √ √ √3 √

Broom, Scotch √3 √ √ √ √3 √

Broom, Spanish √3 √ √ √ √3 √

Common cruprina √3 √ √3 √ √

Gorse √3 √ √ √ √3 √

Hawkweed, King-devil √3 √ √3 √ √3

Hawkweed, Meadow √3 √ √3 √ √

Hawkweed, Mouse-eared √3 √ √3 √ √3

Hawkweed, Orange √3 √ √3 √ √

Hawkweed, Yellow √3 √ √3 √ √

Mutiflora rose √3 √ √3 √

Poison ivy √3 √ √ √3

Poison Oak √3 √ √ √ √3

Ragweed √3 √ √ √

Skeletonleaf bursage √3 √3 √

Spanish heath √3 √3 √

Starthistle, Iberian √3 √3 √ √ √

Starthistle, Purple √3 √3 √ √3 √

Thistle, Scotch √3 √ √3 √ √ √ √

Tree-of-heaven √3 √3 √ √ √ √ √

White Bryonia √3 √ √ √ √3

2

 Excellent control, recommended from multiple sources.

3 Used in combination with another herbicide (tank mix)

Based on the experience of District Weed Specialists and various references, primarily the Pacific Northwest Weed 

Management Handbook (Oregon State University 2008 and 2009), the Weed Control Methods Handbook (Tu et al. 2001), 

DiTomaso, Joseph M., Evelyn A.Healy. Weeds of California and other Western States (DiTomaso et al. 2007), Biology 

and Management of Noxious Rangeland Weeds (Shelly and Petroff 1999), The Nature Conservancy Element Stewardship 

Abstracts (http://www.imapinvasives.org/GIST/ESA/index.html updated 2009)
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Attachment 2 - Worker and Public Health

Selected Citations from the Final EIS

Risk Assessment (Final EIS Appendix 8) – Risk ratings used in the Final EIS are based on a Forest Service Risk 

Assessment completed in 2006 (new since the PEIS, see Appendix 8). The Overview in the Executive Summary

of the 2,4-D Risk Assessment includes the following:

Potential exposures to 2,4-D are developed based on the anticipated use patterns and a number of 

relatively standard exposure scenarios used in most Forest Service risk assessments. Estimates of risk 

are presented in terms of a hazard quotient. A hazard quotient is simply the quotient of an estimate of 

exposure divided by the appropriate toxicity value. Concern for the development of adverse effects 

increases as the value of the as hazard quotient increases. For 2,4-D, substantial concern is evident for 

workers, members of the general public, as well as several groups of organisms covered in the ecological 

risk assessment.

For many pesticides, including 2,4-D, accidental exposure scenarios, some of which are extremely 

conservative and perhaps implausible, lead to risk quotients that exceed the level of concern. 2,4-D 

is, however, somewhat atypical because many non-accidental exposure scenarios – i.e., exposures that 

are plausible under normal conditions of use – also exceed the level of concern and often by a very 

substantial margin.

Unless steps are taken to mitigate risks, workers involved in the application of 2,4-D and members of the 

general public who consume vegetation contaminated with 2,4-D could be exposed to 2,4-D levels greater 

than those which are generally regarded as acceptable. In some cases, the exceedances are substantial. 

Similarly, adverse effects in the normal use of 2,4-D salts or esters could occur in groups of non-target 

organisms including terrestrial and aquatic plants, mammals, and possibly birds. Adverse effects 

on aquatic animals are not likely with formulations of 2,4-D salts except for accidental and extreme 

exposures at the upper ranges of application rates. The ester formulations of 2,4-D are much more toxic 

to aquatic animals and adverse effects are plausible in sensitive species and sometimes in relatively 

tolerant species. The results of this risk assessment suggest that consideration should be given to alternate 

herbicides and that the use of 2,4-D should be limited to situations where other herbicides are ineffective 

or to situations in which the risks posed by 2,4-D can be mitigated. [There is a potential mitigation 

measure to that effect in Chapter 2.]

The Risk Assessment also suggests that reduced application rates in tank mixes do not necessarily reduce, and in 

fact may increase, the potential for human health risks. Risk Assessment section 3.1.1 says:

“Based on recent studies published in the open literature, 2,4-D is toxic to the immune system and 

developing immune system, especially when used in combination with other herbicides. The mechanism 

of action of 2,4-D toxicity is disruption of the cell membrane and cellular metabolic processes. The 

molecular basis for 2,4-D toxicity to human lymphocytes and nerve tissue is likely the induction of 

programmed cellular death known as apoptosis” (p. 3-2). 

The Risk Assessment later expands on this risk saying: 

“That 2,4-D can induce programmed cell death (apoptosis), as discussed in section 3.1.2, suggests a 

potential for additive, synergistic, or inhibitory effects on other apoptic agents, depending upon the nature 

of the agent and it’s mechanism for induction of the apoptic cascade of events. As discussed in Section 
791

Final Environmental Impact Statement: Appendix 12

3.1.2 (Mechanism of Action) 2,4-D disrupts the cell at a fundamental level; therefore, interactions are 

likely to occur between 2,4-D and any of the many other chemicals that affect cell membranes and cell 

metabolism” (p. 3-48).

In 2003, the Forest Practices Branch, British Columbia Ministry of Forests published Toxicology and Potential 

Health Risk of Chemicals that May Be Encountered by Workers Using Forest Vegetation Management Options, 

Part III: Risk to Workers Using 2,4-D Formulations (Author Frank N. Dost), from which the Abstract reads:

2,4-D is possibly the most extensively researched of all pesticides, and the data have been examined by an 

unusual number of advisory committees and work groups.

2,4-D is slowly absorbed from the skin, and is rapidly excreted unchanged by the kidneys. It is not stored 

in the body. Mutagenic activity of 2,4-D is negligible or absent, nor is there evidence of carcinogenicity 

in animal assays. It does not cause significant reproductive effects except at doses high enough to cause 

general intoxication. Its ability to cause birth defects is very limited.

The large number of epidemiology studies seeking evidence of a relation between phenoxy herbicides and 

human cancer has been inconsistent and conflicting. Review panels, including that convened by United 

States Environmental Protection Agency (USEPA) in April 1993 have consistently concluded that the 

evidence is at best weakly suggestive and does not warrant change in regulatory policy.

A number of cases of human intoxication from either careless handling or suicide attempts have been 

reported in the medical literature, almost all in the fifties and sixties. The pattern of effects has been 

inconsistent but a few individuals have experienced neurologic problems in the extremities.

There is extensive data on exposure of forest workers to 2,4-D, showing that careless work habits increase 

exposure. The primary concern is skin and eye irritation from certain formulations. Simple protective 

clothing and work discipline reduce exposure to very low levels. 

2,4-D excerpts from the Human Health and Safety section of the Final EIS include: 

2,4-D: PEIS Mitigation Measures (Appendix 2) limit the use of 2,4-D to typical application rates, where 

feasible. At the typical and maximum application rates, workers involved in backpack spray, boom spray, 

and aerial application face low to moderate risk from 2,4-D exposure. Workers also face moderate risk from 

wearing contaminated gloves for 1 hour and no risk from exposure to a spill on lower legs for one hour 

or from exposure to spill on the hands for one hour. Based on upper bound hazard quotients that exceed 

1, adverse health outcomes are possible for workers exposed repeatedly over a longer period. The public 

faces zero risk from most modeled scenarios at the typical and maximum application rates. Consumption 

of contaminated vegetation (fruit) over a period of several months would have a low risk to the public and a 

moderate risk to subsistence populations. Other chronic exposures to the public have no risk.

Based on recent studies reviewed by SERA, 2,4-D is toxic to the immune system and developing immune 

system, especially when used in combination with other herbicides (tank mixes). The mechanism of 

action of 2,4-D toxicity is cell membrane disruption and cellular metabolic processes. 2,4-D toxicity 

affects human lymphocytes and nerve tissue. Therefore, interactions are likely to occur when 2,4-D is 

mixed with other chemicals that affect cell membranes and cell metabolism (SERA 2006).

SERA (2006) suggests that 2,4-D may cause endocrine disruption in male workers applying large 

amounts of this herbicide; however, the study was inconclusive. Based on currently available toxicity 

information that demonstrate effects on the thyroid and gonads following exposure to 2,4-D, there are 
 792

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

some data supporting its endocrine disruption potential and EPA is studying this further (EPA 2005a). In 

the Human Health Risk Assessment conducted to support the reregistration of 2,4-D (EPA 2004), the EPA 

concluded that there is not sufficient evidence that 2,4-D is an endocrine disrupting chemical. 

Human Health Risks by Application Method

Ground applications ... spot rather than boom/broadcast applications are less likely to result in health 

risks to people downwind. However, these spot applications could present an increased risk [compared 

to aerial application] to the workers charged with applying the herbicide because they are more likely to 

come into contact with the herbicide (their exposure doses is higher). In particular, workers applying ... 

2,4-D by backpack and horseback would be at low to moderate risk for health risks from exposure to the 

herbicide. Ground boom spray applicators of 2,4-D would have low to moderate risk...

Typical Application Rate

PEIS Mitigation Measures limit the use of [2,4-D] to the typical application rate, where feasible. 2,4-

D applications at the typical application rate would pose a low to moderate risk to plane and helicopter 

pilots and mixer/loaders, backpack applicator/mixer/loaders, horseback applicators and applicator /mixer /

loaders, and consumers of contaminated fruit/vegetation. 

Accidental Direct Spray and Spill Scenarios

Accidental direct spray and spill scenarios for many herbicides pose a risk to workers and the public 

(accidental scenarios for diflufenzopyr, imazapic, and sulfometuron methyl were not evaluated because 

these herbicides are not considered toxic through short-term dermal exposure). These scenarios are 

unlikely, and can be minimized by following Standard Operating Procedures. However, these scenarios 

are included on Table 4-36, Estimated Annual Acres of Treatments with Risk to Human Health.

Human Health Risks

Worker: 2,4-D, .... pose risks to workers when applied at both typical and maximum application rates. 

For 2,4-D, ... people working with aerial applications would be at low to moderate risk for applications 

at the typical application rate, and most workers would be at risk when applying these herbicides at 

maximum application rates. 2,4-D, also poses risks to ground applicators, particularly during applications 

at the maximum application rate.

Public: In general, there are lower risks to the public than occupational workers. However, within this 

category, there is higher risk to children than adults. 2,4-D....pose[s] a risk to the public under one or 

more maximum application rate accidental exposure scenarios (e.g., exposure resulting from the spill of 

an herbicide into a small pond). [R]isk to the public can be minimized or avoided by using the typical 

application rate, including other proposed mitigation measures, and following Standard Operating 

Procedures that greatly reduce the likelihood of accidents.

Summary of Highest Human Health Risks

... 2,4-D has possible endocrine disruption abilities in workers applying large amounts of 2,4-D and poses 

moderate risks to workers performing ground-based boom spraying at maximum rates and under some 

accidental exposure scenarios.
793

Final Environmental Impact Statement: Appendix 12

Treatment Method

Risk Categories

2,4-D1

Typ2 Max4

General Exposures

Directed foliar and spot 

treatments (backpack) L3 M

Broadcast ground spray 

(boom spray) L M

Aerial applications (pilots 

and mixer/loaders) L M

Accidental/Incidental Exposures

Immersion of hands 0 0

Wearing contaminated 

gloves M M

Spill on hands 0 0

Spill on lower legs 0 0

1

 Where different formulations exist, risks reported are 

the most conservative.

2

 Typ = Typical application rate; and Max = Maximum 

application rate.

3

 Risk categories: 0 = No risk (majority of HQs < 1); 

L = Low risk (majority of HQs >1 but < 10); M = 

Moderate risk (majority of HQs > 10 but < 100); H 

= High risk (majority of HQs > 100); and NE = Not 

evaluated. Risk categories are based on typical and 

upper HQ estimates. To determine risk for lower or 

central HQ estimates, see the individual herbicide 

risk assessments (SERA 2005b). Risk categories are 

based on comparison to the HQ of 1 for typical and 

maximum application rates.

4

 The 2,4-D Risk Assessment used a maximum rate of 

4 lbs/acre. However, at the National level, BLM is 

limited to 1.9 lbs/acre. PEIS Mitigation Measures limit 

2,4-D to typical application rates where feasible.

FS-Evaluated Herbicide Risk Categories for

Workers (Source: Table 3-18)

FS-Evaluated Herbicide Risk Categories for the

Public (Source: Table 3-19)

Attachment 3 – Forest Service Risk Tables

Treatment Method

Hazard Quotient

2,4-D1

Typ2 Max4

Acute/Accidental Exposures

Direct spray - child, entire 

body 03 L

Direct spray - woman, lower 

legs 0 0

Dermal - contaminated 

vegetation, woman 0 0

Consumption of 

contaminated fruit 0 L

Consumption of 

contaminated water - pond, 

spill

M M

Consumption of 

contaminated water - stream, 

ambient

0 0

Consumption of 

contaminated fish - general 

public

0 L

Consumption of 

contaminated fish - 

subsistence populations

L L

Chronic/Longer-term Exposures

Consumption of 

contaminated fruit 0 L

Consumption of 

contaminated water 0 0

Consumption of 

contaminated fish - general 

public

0 0

Consumption of 

contaminated fish - 

subsistence populations

0 0
 794

Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Attachment 4 – 2005 Forest Service Decision

2,4-D was included in the Forest Service’s proposed action in 2005. They de-selected it six months later in their 

Record of Decision. Their EIS analysis indicates its loss compromises their weed control ability and projections.

Record of Decision-stated reasons for de-selection of 2,4-D were fairly brief: At the regional scale, there 

were no invasive plants identified that could not be treated with another of their selected herbicides. (They 

specifically left the door open for site-specific proposals however.) Also 2,4-D (and dicamba) were inherently 

more risky than the ten herbicides approved for use – being in higher risk categories for humans, large 

mammals, and birds (FS ROD:25). Finally, the FS analysis indicated 2,4-D and dicamba gave no advantage in 

terms of avoiding herbicide resistance. 

The decision recognized that higher prices for replacement herbicides would reduce acres treated in the 

neighborhood of 25 percent. (The BLM cannot link this rationale to this EIS. Early in the EIS process, the BLM 

did a cost per acre comparison of the 18 herbicides in this EIS and decided the herbicide costs were close enough 

on a per acre basis that there was no reason to track them separately in the EIS cost analysis.) 

Effects to cooperators are not mentioned in the Forest Service’s Record of Decision. The Forest Service objective 

is to totally remove invasive weeds, so the decision officially just slows accomplishment of that because it 

increases cost. Effects to adjacent landowners are not discussed in the Record of Decision, nor would they be the 

same issue as they are on BLM lands. It may be that BLM lands are crossed by more permitted road and utility 

rights-of-way, and there are more checkerboard ownership and other adjacent private lands. These would imply 

that weed and vegetation control by cooperators is more applicable to the BLM than to the Forest Service.

Short-Term Implications for National Forests and, Potentially, the BLM

The Forest Service 2,4-D decision means National Forests have been reduced to (variously) three herbicides since 

2005, until they can complete and implement their step-down Forest NEPA documents. 

BLM units have expressed a concern that a similar thing could happen to the BLM; if the BLM Record of 

Decision chooses to drop 2,4-D in favor of other herbicides, and then part of the decision is enjoined, districts 

could be reduced to three herbicides indefinitely.
795

Final Environmental Impact Statement: Appendix 12

Attachment 5 - Environmental Effects

Selected Citations from the Final EIS

Risk Ratings for Wildlife, Fish, and Aquatic Species (Source: Table 3-15)

2,4-D

Application Scenario Typ5 Max1

Acute/Accidental Exposures

Direct spray, small mammal, 1st order absorption 06 L

Direct spray, small animal, 100% absorption L M

Direct spray, bee, 100% absorption L L

Consumption of contaminated fruit, small mammal L L

Consumption of contaminated grass, large mammal M M

Consumption of contaminated grass, large bird L L

Consumption of contaminated water, small mammal, spill L L

Consumption of contaminated water, small mammal, stream 0 0

Consumption of contaminated insects, small mammal M H

Consumption of contaminated insects, small bird L M

Consumption of contaminated small mammal, predatory 

mammal M M

Consumption of contaminated small mammal, predatory bird 0 0

Consumption of contaminated fish, predatory bird, spill 0 0

Fish (susceptible species) – accidental spill H H

Fish (tolerant species) – accidental spill M M

Fish (susceptible species) – acute exposure, peak EEC M M

Fish (tolerant species) – acute exposure, peak EEC 0 0

Aquatic Invertebrates – accidental spill L M

Aquatic Invertebrates – acute exposure, peak EEC 0 0

Chronic Exposures

Consumption of contaminated vegetation, small mammal, 

on- site 0 0

Consumption of contaminated vegetation, small mammal, 

off- site 0 0

Consumption of contaminated vegetation, large mammal, 

on- site L L

Consumption of contaminated vegetation, large mammal, off 

-site 0 0

Consumption of contaminated vegetation, large bird, on-site 0 0

Consumption of contaminated vegetation, large bird, off-site 0 0

Consumption of contaminated water, small mammal 0 0

Consumption of contaminated fish, predatory bird 0 0

Fish – chronic exposure 0 0

Aquatic invertebrates – chronic exposure 0 0

Shading denotes herbicides that are limited by PEIS Mitigation Measures to typical application rates where feasible. 

1

 The 2,4-D Risk Assessment used a maximum rate of 4 lbs/acre. However, at the National level, BLM is limited to 1.9 lbs/acre.

5

 Typ = typical application rate; and Max = maximum application rate.

6

 Risk categories: 0 = No risk (HQ < LOC); L = Low risk (HQ = 1 to 10 x LOC); M = Moderate risk (HQ = 10 to 100 x LOC); H = High 

risk (HQ > 100 LOC); and NE = Not evaluated. Risk categories are based on upper estimates of hazard quotients and the BLM LOCs 

of 0.1 for acute scenarios and 1.0 for chronic scenarios. The reader should consult the text of this section of the individual Forest 

Service Risk Assessments to evaluate risks at central estimates of hazard quotients. 

Fish susceptible species include coldwater fish, such as trout, salmon, and Federally Listed species. Fish tolerant species include warm 

water fish, such as fathead minnows.
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2,4-D Summaries From Resource Effects Sections in Chapter 4, Final EIS

Native and Other Non-Invasive Vegetation - 2,4-D (salts and esters) is a selective herbicide that kills broadleaf 

plants, but not grasses. It has a long history of use and is relatively inexpensive. Direct spraying of non-target 

plant species is the highest potential for damage due to 2,4-D application. Drift could damage non-target species 

close to the application site (much less than 100 feet) although some species such as grapes are more susceptible. 

One study determined that 2,4-D could affect three species of ectomycorrhizal fungi in laboratory experiments 

(Estok et al. 1989).

Soils - 2,4-D has a very short half-life that averages 10 days in moist soil. Its fate is dependent on soil acidity or 

alkalinity (pH). A soil pH of 7.0 is neutral. Acid soils measure between 1 and 7 on the pH scale whereas alkaline 

soils measure between 7 and 14. 2,4-D on a Spodosols would resist to degradation, but on a Mollisols, it would 

readily degrade in a warm and moist environment. 2,4-D is readily broken into simpler components in alkaline 

soils but the break-down is slower in acidic soils. Temperature affects degradation as well, with slower breakdown in cold or dry soils or where microbial organisms are not present. Warm, moist soils previously treated 

with 2,4-D have been shown to dissipate the herbicide more rapidly due to the presence of bacteria that degrade it 

(Oh and Tuovinen 1991, Smith and Aubin 1994, Shaw and Burns 1998, all cited in Tu et al. 2001). Furthermore, 

most studies of the effects of 2,4-D on microorganisms concluded that the quantity of 2,4-D reaching the soil from 

typical applications would probably not have a serious negative effect on most soil microorganisms (Bovey 2001).

Water Resources - 2,4-D: Some salt forms of 2,4-D are registered for use in aquatic systems. 2,4-D is a known 

groundwater contaminant1 although potential for leaching into groundwater is moderate by its being bound to 

organic matter and its short half-life. Concentrations of up to 61 mg/L have been reported immediately following 

direct application to water. Concentrations as low as 0.22 mg/L can damage susceptible plants (Que Hee and 

Sutherland 1981 cited in Tu et al. 2001).

In terrestrial applications, most formulations of 2,4-D do not bind tightly with soils, and therefore have a moderate 

potential to leach into the soil column and to move off site in surface or subsurface water flows (Johnson et al. 

1995 cited in Tu et al. 2001). In a study on groundwater in small shallow aquifers in Canadian prairies, 2,4-D was 

detected in 7 percent of 27 samples (Wood and Anthony 1997).

[According to EPAs 2005 Reregistration Eligibility Decision document, the EPA Office of Water has established a 

Maximum Contaminant Level (MCL) of 0.07 ppm for 2,4-D in drinking water.]

Wetlands and Riparian Areas - 2,4-D: The principle hazard is unintended spraying or drift to non-target plants; 

spot treatments applied according to the labeled rate do not substantially affect native aquatic vegetation or 

significantly change species’ diversity (USDA 2005a, WA Dept of Ecology c). Kuhlmann et al. (1995) found no 

biodegradation of 2,4-D under anaerobic (sulfate reducing) conditions in a laboratory experiment of sediments 

and groundwater. In aerobic riparian soils that have a high content of organic material, an active microbial 

community, high pH values, and high temperatures, toxic effects are limited because of rapid degradation of 2,4-

D. 2,4-D may inhibit shoot and/or root growth of macrophytes in aquatic systems (Roshon et al. 1999).

Fish - 2,4-D has formulations that are registered for use on aquatic vegetation, including water hyacinth and 

Eurasian watermilfoil, and as a tank mix partner to control purple loosestrife. The toxicity of 2,4-D to fish 

is relatively low (Norris et al. 1991). Risk is greater under scenarios of direct application to water bodies or 

1 Has been detected in groundwater. Does not necessarily mean levels have exceeded any established health standard or 

allowance.
797

Final Environmental Impact Statement: Appendix 12

accidental direct spills. The ester forms of 2,4-D (including the BEEs found in Aqua-Kleen) are approximately 

200 to 1,000 times more toxic to fish than the amine forms, when toxicity is measured by acute (24- to 48-hour) 

LC-50 values. While these esters are chemically stable, they are short-lived in natural water because of biological 

degradation. At the typical application rate, 2,4-D poses a low risk to fish, while at the maximum application 

rate, 2,4-D poses a moderate risk to fish under scenarios of accidental direct spray or spill to a stream and pond. 

Routine (non-spill) acute and chronic exposure scenarios do not pose a risk to fish.

Wildlife Resources - 2,4-D is a possible endocrine disrupter (see Endocrine Disrupters) and is one of the more 

toxic herbicides for wildlife of the foliar-use herbicides considered in this EIS. The ester form is more toxic to 

wildlife than the salt form. Ingestion of treated vegetation is a concern for mammals, particularly since 2,4-D 

can increase palatability of treated plants (USDA 2006b) for up to a month following treatment (Farm Service 

Genetics 2008). Mammals are more susceptible to toxic effects from 2,4-D, and the sub-lethal effects to pregnant 

mammals were noted at acute rates below LD50. Birds are less susceptible to 2,4-D than mammals, and the 

greatest risk is ingestion of contaminated insects or plants. The salt form is practically non-toxic to amphibians, 

but the ester form is highly toxic. It can be neurotoxic to amphibians; although not all amphibians respond 

the same (e.g., toads were more susceptible than leopard frogs). There is little information on reptile toxicity, 

although one study noted no sexual development abnormalities. It presents low risk to honeybees (Table 3-15), 

but little information is available for other terrestrial invertebrates. Parasitic wasps may be affected, which could 

result in changes to community structure by favoring damaging insects controlled by parasitic wasps.

Livestock and Wild Horses and Burros - 2,4-D presents a low to moderate acute risk to livestock under several 

of the direct spray, ingestion, and spill scenarios, and a moderate chronic risk for large mammals for consumption 

of on-site contaminated vegetation under both typical and maximum rate (SERA 2006). The Risk Assessment 

suggests that because large livestock eating large quantities of grass and other vegetation are at risk from routine 

exposure to 2,4-D and because 2,4-D is considered for use in rangeland, it should not be applied over large 

application areas where livestock would only consume contaminated food. According to label directions for 

one formulation, dairy animals should be kept out of areas treated with 2,4-D for 7 days. Grass for hay should 

not be harvested for 30 days after treatment. Meat animals should be removed from treated areas 3 days prior to 

slaughter. Similar restrictions may be in place for other formulations.

Industry Task Force

The chairman of the Industry Task Force II on 2,4-D Research Data responded to our request for 2,4-D 

information from cooperators, taking issue with most of the negative effects (risks) described in the DEIS. He 

also said relabeling in 2007 removed all grazing restrictions except mowing hay. (The Industry Task Force is 

made up of several herbicide manufacturers for the purpose of funding (not directing) any registration research 

requested by the EPA or the Canadian Pest Management Regulatory Agency.) [The letter was coded and specific 

EIS citations were checked and corrected where appropriate.]
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon
799

Final Environmental Impact Statement: Appendix 13

Appendix 13 - 

EPA Pesticide Registration and 

Reregistration and BLM/FS Risk 

Assessment Processes

This appendix contains an overview of the EPA pesticide registration process, reregistration eligibility decisions 

(REDs), and overviews of the BLM and Forest Service Ecological and Human Health Risk Assessments 

conducted to support effects analysis under the NEPA process. The information is provided to help clarify the 

parameters and intensity of safety analyses conducted for all herbicides before they can be used on federal lands. 

This appendix also includes the Uncertainty Analysis in Risk Assessments from Appendix C in the PEIS. 

Table of Contents

Data Requirements for EPA Pesticide Registration ...................................................................................800

EPA Reregistration Eligibility Decision (RED) Documents......................................................................803

BLM Ecological Risk Assessments...........................................................................................................804

BLM Human Health Risk Assessment (HHRA) .......................................................................................805

Forest Service Human Health and Environmental Risk Assessment.........................................................808

Uncertainty Analysis in Risk Assessments................................................................................................817
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Data Requirements for EPA Pesticide 

Registration

The primary reference for this section is: Environmental Protection Agency. 2007. Data Requirements for EPA 

Pesticide Registration. Available at http://www.epa.gov/pesticides/regulating/data_requirements.htm. References 

cited in this section are internal to the above-referenced document. 

In 2007, the Agency revised the data requirements that pertain to conventional pesticides. The following 

information is current as of October 26, 2007. 

Before manufacturers can sell pesticides in the United States, EPA must evaluate the pesticides thoroughly 

to ensure that they meet federal safety standards to protect human health and the environment. EPA grants a 

“registration” or license that permits a pesticide’s distribution, sale, and use only after the company meets the 

scientific and regulatory requirements. These data requirements apply to anyone or any company that registers 

pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) or seeks a tolerance or tolerance 

exemption for a pesticide under the Federal Food, Drug, and Cosmetic Act (FFDCA). 

In evaluating a pesticide registration application, EPA assesses a wide variety of potential human health and 

environmental effects associated with use of the product. Potential registrants must generate scientific data 

necessary to address concerns pertaining to the identity, composition, potential adverse effects, and environmental 

fate of each pesticide. The data allow EPA to evaluate whether a pesticide has the potential to cause harmful 

effects on certain nontarget organisms and endangered species that include: 

• Humans

• Wildlife

• Plants

• Surface water or ground water

EPA recommends the pesticide registrant provide data from tests conducted according to published EPA test 

guidelines. 

Types of Studies Required 

The following sections describe the reasons for each type of test and the kind of information EPA obtains from the 

results of each test. 

Product Performance

Requirements to develop data on product performance provide a mechanism to ensure that pesticide products will 

control the pests listed on the label and that unnecessary pesticide exposure to the environment will not occur as 

a result of the use of ineffective products. Specific performance standards are used to validate the efficacy data in 

the public health areas, including disinfectants used to control microorganisms infectious to humans in any area 

of the inanimate environment and those pesticides used to control vertebrates (such as rodents, birds, bats, and 

skunks) and invertebrates (ticks, mosquitoes, etc.) that may directly or indirectly transmit diseases to humans. 
801

Final Environmental Impact Statement: Appendix 13

Data from Studies that Determine Hazard to Humans and Domestic Animals

Data required to assess hazards to humans and domestic animals are derived from a variety of acute, subchronic, 

and chronic toxicity tests, and tests to assess mutagenicity and pesticide metabolism. 

Acute Studies

Determination of acute oral, dermal, and inhalation toxicity is usually the initial step in the assessment and 

evaluation of the toxic characteristics of a pesticide. These data provide information on health hazards likely to arise 

soon after, and as a result of, short-term exposure. Data from acute studies serve as a basis for classification and 

precautionary labeling. For example, acute toxicity data are used to calculate farm worker reentry intervals and to 

develop precautionary label statements pertaining to protective clothing requirements for applicators. They also: 

• provide information used in establishing the appropriate dose levels in subchronic and other studies; 

• provide initial information on the mode of toxic action(s) of a substance; 

• determine the need for child-resistant packaging; and 

• determine the need to restrict use of the pesticide to trained applicators or in other ways to minimize 

human and environmental hazards. 

Information derived from primary eye and primary dermal irritation studies serves to identify possible hazards 

from exposure of the eyes, associated mucous membranes, and skin. 

Subchronic Studies

Subchronic tests provide information on health hazards that may arise from repeated exposures over a limited 

period of time. They provide information on target organs and accumulation potential. The resulting data are 

also useful in selecting dose levels for chronic studies and for establishing safety criteria for human exposure. 

These tests are not capable of detecting those effects that have a long latency period for expression (e.g., 

carcinogenicity). 

Chronic Studies

Chronic toxicity (usually conducted by feeding the test substance to the test species) studies are intended to 

determine the effects of a substance in a mammalian species following prolonged and repeated exposure. 

Under the conditions of this test, effects that have a long latency period or are cumulative should be detected. 

The purpose of long-term carcinogenicity studies is to observe test animals over most of their life span for the 

development of neoplastic lesions during or after exposure to various doses of a test substance by an appropriate 

route of administration. 

Data from Studies that Determine Hazard to Non-target Organisms

The information required to assess hazards to nontarget organisms are derived from tests to determine pesticidal 

effects on birds, mammals, fish, terrestrial and aquatic invertebrates, and plants. These tests include short-term 

acute, subacute, reproduction, simulated field, and full field studies arranged in a hierarchical or tier system 

that progresses from the basic laboratory tests to the applied field tests. The results of each tier of tests must be 

evaluated to determine the potential of the pesticide to cause harmful effects and to determine whether further 

testing is required. A purpose common to all data requirements is to help determine the need for (and appropriate 

wording for) precautionary label statements to minimize the potential harm to nontarget organisms. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Acute and Subacute Studies

The short-term acute and subacute laboratory studies provide basic toxicity information that serves as a starting 

point for the hazard assessment. These data are used to: 

• establish acute toxicity levels of the active ingredient to the test organisms; 

• compare toxicity information with measured or estimated pesticide residues in the environment in order to 

assess potential effects on fish, wildlife, plants, and other nontarget organisms; and 

• indicate whether further laboratory and/or field studies are needed. 

Chronic and Field Studies

Additional studies (i.e., avian, fish, and invertebrate reproduction; life cycle studies; and plant field studies) may 

be required when basic data and environmental conditions suggest possible problems. Data from these studies are 

used to: 

• estimate the potential for chronic effects, taking into account the measured or estimated residues in the 

environment; and 

• determine if additional field or laboratory data are necessary to further evaluate hazards. 

Simulated field and/or field data are used to examine acute and chronic adverse effects on captive or monitored 

fish and wildlife populations under natural or near-natural environments. Such studies are required only when 

predictions as to possible adverse effects in less extensive studies cannot be made, or when the potential for 

harmful effects is high. 

Post-Application Exposure Studies

Data required to assess hazard to farm employees resulting from reentry into areas treated with pesticides are 

derived from studies on toxicity, residue dissipation, and human exposure. Monitoring data generated during 

exposure studies are used to determine how much pesticide people may be exposed to after application and to 

establish how long workers must wait before reentering a treated area. 

Applicator/User Exposure Studies

EPA requires applicator/user exposure data for all pesticides to evaluate the potential risks to people applying the 

pesticide, i.e., those who may be exposed to higher concentrations of the pesticide through handling, including 

mixing or applying. 

Pesticide Spray Drift Evaluation

Data required to evaluate pesticide spray drift are derived from studies on the range of droplet sizes and spray 

drift field evaluations. These data contribute to development of the overall exposure estimate. Along with data on 

toxicity for humans, fish, and wildlife, or plants, data on spray drift are used to assess the potential exposure of 

these organisms to pesticides. A purpose common to all these tests is to provide data to help determine the need 

(and appropriate wording) for precautionary labeling to minimize the potential harm to nontarget organisms. 
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Final Environmental Impact Statement: Appendix 13

Environmental Fate

EPA uses the data generated by environmental fate studies to: 

• assess the presence of widely distributed and persistent pesticides in the environment that may result in 

loss of usable land, surface water, ground water, and wildlife resources; 

• assess the potential environmental exposure of other nontarget organisms, such as fish, wildlife, and 

plants, to pesticides; and 

• help estimate expected environmental concentrations of pesticides in specific habitats where threatened or 

endangered species or other wildlife populations at risk are found. 

Residue Chemistry

EPA uses residue chemistry data to estimate the exposure of the general population to pesticide residues in food 

and for setting and enforcing tolerances for pesticide residues in food or feed. The Agency can estimate the 

amount and nature of residues likely to be present in food or animal feed because of a proposed pesticide usage by 

evaluating information on: 

• the chemical identity and composition of the pesticide product; 

• the amounts, frequency, and time of pesticide application; and 

• test results on the amount of residues remaining on or in the treated food or feed. 

EPA Reregistration Eligibility Decision (RED) 

Documents

The primary reference for this section is: Environmental Protection Agency. 2008. Pesticide Reregistration Facts. 

Available at http://www.epa.gov/pesticides/reregistration/reregistration_facts.htm. References cited in this section 

are internal to the above-referenced document. 

The 1988 amendments to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) authorized EPA 

to conduct a comprehensive pesticide reregistration program - a complete review of the human health and 

environmental effects of pesticides first registered before November 1, 1984, to make decisions about these 

pesticides’ future use. The goal of the reregistration program is to mitigate risks associated with the use of older 

pesticides while preserving their benefits. Pesticides that meet today’s scientific and regulatory standards may be 

declared “eligible” for reregistration. The results of EPA’s reviews are summarized in Reregistration Eligibility 

Decision (RED) documents.

Risk Reduction through REDs

The reregistration program is bringing about improvements in pesticide safety. Most REDs include at least some 

of the following risk reduction requirements: 

• Voluntary cancellation; 

• Some uses not eligible or not yet eligible; 

• Limit amount, frequency or timing of applications; 

• Other application restrictions; 

• “Restricted Use Pesticide” classification; 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

• Personal Protective Equipment (PPE); 

• Restricted Entry Intervals (REIs); 

• User safety requirements and recommendations; 

• Improved use directions and precautions; 

• Special or tamper-resistant packaging; 

• Engineering or production controls; 

• Ground or surface water safeguards; 

• Spray drift labeling; 

• Ecological safeguards; 

• Special programs to better protect young children. 

Product Reregistration

After EPA has issued a RED and declared a pesticide eligible for reregistration, individual end-use products that 

contain the pesticide active ingredient still must be reregistered. Through this concluding part of the process, 

known as “product reregistration,” the Agency makes sure that the risk reduction measures called for in REDs 

are reflected on individual pesticide product labels. In some cases, the Agency uses Memoranda of Agreement 

or other measures to include risk reduction measures on pesticide labels sooner, before product reregistration is 

completed. EPA plans to complete the last product reregistration decisions by 2014, several years after the last 

REDs are signed.

Registration Review

Even before the reregistration program was completed, EPA began implementing registration review starting 

in early 2007. This new program ensures that, as the ability to assess risk evolves and as policies and practices 

change, all registered pesticides will continue to meet the statutory standard of no unreasonable adverse effects.

BLM Ecological Risk Assessments 

The primary reference for this section is: ENSR. 2004. Vegetation Treatments Programmatic EIS Ecological Risk 

Assessment Protocol. Pages 2-1 & 2-2. Prepared for the BLM. Westford Massachusetts. Available at http://www.

blm.gov/or/plans/vegtreatmentseis/riskassessments/. References cited in this section are internal to the abovereferenced document. 

For the PEIS, ecological risk assessments (ERAs) were produced for ten herbicides: bromacil, chlorsulfuron, 

dicamba, diflufenzopyr, diquat, diuron, fluridone, imazapic, sulfometuron methyl, and tebuthiuron (see Appendix 

8). The ERAs for each of the herbicides were produced as separate documents. While the risk assessments have 

been tailored to address the potential usage of each particular herbicide, they follow the same essential format and 

methodology, which is described below. Each ERA includes the following sections: 

• Introduction – covers general concepts and document overview. 

• BLM Herbicide Program Description – describes BLM-specific uses of the product, statistics of use to 

date, and incident reports compiled by the USEPA. 

• Herbicide Toxicology, Environmental Fate, and Physical-Chemical Properties – discusses the review 

of toxicity literature and its results, environmental fate of the herbicide, and specific physical-chemical 

properties used in the ERA. 
805

Final Environmental Impact Statement: Appendix 13

• Ecological Risk Assessment – evaluates potential risk to ecological receptors resulting from exposure to 

the herbicide in a number of different scenarios (discussed in more detail in this section). 

• Sensitivity Analysis – discusses the sensitivity of predicted exposure concentrations to variation in 

environmental processes and the models used to represent them. This analysis is provided in order to 

verify that most predicted concentrations are overestimates, and to identify situations where the general 

assumptions of the models might be relaxed or should be made more stringent. 

• Rare, Threatened, and Endangered (RTE) Species – discusses potential direct and indirect impacts to RTE 

species, including consideration of taxa for which ecotoxicological data are not available. 

• Uncertainty in the Ecological Risk Assessment – describes data gaps, assumptions, and uncertainties of 

the risk assessment. 

• Summary – summarizes the overall implications of the risk assessment. 

• References – presents references considered in the document. 

The following appendices are also included in each ERA: 

• Summary of Available and Relevant Toxicity Data/Ecological Risk Assessment Literature Review 

• Ecological Risk Assessment Worksheets 

• Species Listed Under the Endangered Species Act for 17 BLM States 

• Review of Confidential Business Information Memo 

• Summary of Tank Mix Risk Quotients 

Transport via surface runoff and wind-blown dust, and the resulting exposure concentrations, are not included in 

the ERAs for the aquatic herbicides (diquat and fluridone). Therefore, exposure scenarios and appendices relating 

to GLEAMS and CALPUFF are not included in the risk assessment documents for these herbicides. 

The overall goal of the ERAs is to facilitate risk management decisions for the PEIS and support development 

of the Biological Assessment (BA) for the PEIS. An additional goal of this process is to provide risk managers 

with a tool that presents a range of generic risk estimates that vary as a function of site conditions. The tool to 

accomplish this primarily consists of the Excel spreadsheets (presented in the ERA Worksheets) that may be used 

to calculate exposure concentrations and evaluate potential risks provided in the risk assessment. For further sitespecific evaluation of a particular herbicide, BLM land managers can modify specific variables in the worksheets. 

The general approach and analytical methods for conducting the ERAs were based on U.S. Environmental 

Protection Agency’s (USEPA) Guidelines for Ecological Risk Assessment (hereafter referred to as the 

“Guidelines” [USEPA 1998]). The ERA is a structured evaluation of all currently available scientific data 

(exposure chemistry, fate and transport, toxicity, etc.) that leads to quantitative estimates of risk from 

environmental stressors to non-human organisms and ecosystems. The current Guidelines for conducting ERAs 

include three primary phases: problem formulation, analysis, and risk characterization.

BLM Human Health Risk Assessments (HHRA)

The primary reference for this section is: ENSR. 2004. Vegetation Treatments Programmatic EIS Human 

Health Risk Assessment Protocol. Pages ES1-ES3. Prepared for the BLM. Westford Massachusetts. Available 

at http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/veis.Par.82009.File.dat/

Risk%20Assessment%20(November%202005).pdf. References cited in this section are internal to the abovereferenced document. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

For the PEIS, the BLM convened an inter-agency work group from May through October of 2002 to reach 

consensus on updated risk assessment methods to ensure that the risk assessment methodology is scientifically 

defensible, is consistent with currently available guidance where appropriate, and meets the needs of the BLM 

vegetation treatment program. 

For the HHRA methods discussion, the inter-agency work group consisted of representatives from the BLM, 

USEPA, and ENSR International, the contractor who prepared the HHRA for the BLM. The resultant HHRA 

complies with USEPA guidance for conducting risk assessments for pesticides including, but not limited to, the 

following documents: 

• The Role of Use-related Information in Pesticide Risk Assessment and Risk Management (USEPA 2000a) 

• Guidance for Performing Aggregate Exposure and Risk Assessments (USEPA 1999a) 

• Exposure Factors Handbook (EFH; USEPA 1997a) 

In 1983, the National Research Council of the National Academy of Sciences (NAS 1983) recommended a basic 

approach for risk assessments that are conducted by or for groups within the federal government. NAS (1983) 

recommended a four step process: hazard identification, exposure assessment, dose-response assessment, and 

risk characterization. For risks to be quantified, a hazard must be identified, exposures must be quantitatively 

estimated, and a dose-response relationship must be expressed quantitatively. A description of the four st.

Hazard Identification 

The Hazard Identification section provides information on the herbicide active ingredient (a.i.) characteristics 

and usage, and toxicity profiles. The toxicity profiles include information on acute, subchronic, and chronic 

toxicity studies, reproductive and developmental toxicity studies, results of cancer bioassays, mutagenesis, and 

metabolism. The USEPA’s acute toxicity categories are I, II, III, and IV representing severe, moderate, slight, 

and very slight toxicity. The criteria considered are oral, inhalation, and dermal acute toxicity, eye irritation, 

skin irritation, and dermal sensitization. For most of the criteria, the herbicide a.i. evaluated in this HHRA are 

in toxicity categories III and IV. Dicamba is in toxicity category III for acute oral and acute dermal effects, in 

toxicity category IV for acute inhalation effects, and in toxicity category II for primary eye and primary skin 

effects. Diquat is in toxicity category II for acute dermal and eye irritation, and fluridone is in toxicity category II 

for eye irritation. The USEPA has not developed acute toxicity categories for sulfometuron methyl. None of the 

six herbicide a.i. are designated as potential carcinogens by the USEPA. 

Dose-response Assessment 

For pesticide risk assessments, noncarcinogenic effects are evaluated differently depending on whether the exposure 

is dietary or non-dietary. Dietary exposures are evaluated by dividing site-specific herbicide a.i. intakes by a 

Population Adjusted Dose (PAD). The results are expressed as %PADs. The %PAD approach was used to evaluate 

public receptor ingestion of drinking water, berries, and fish. Non-dietary exposures are evaluated by dividing a No 

Observable Adverse Effects Level (NOAEL) by the site-specific intake to calculate a Margin of Exposure (MOE). 

The MOEs are typically compared to a target MOE of 100, unless specified otherwise. NOAELs are available for 

a variety of exposure durations and exposure routes. The NOAEL approach is used to evaluate the occupational 

receptors and the public receptors for the following scenarios: dermal contact with spray, dermal contact with foliage, 

dermal contact with water while swimming, and incidental ingestion of water while swimming. 

For each of the six herbicide a.i. evaluated in this HHRA, the USEPA has developed NOAELs for a majority but 

not all of exposure durations and exposure routes. 

Exposure Assessment 

The exposure assessment involves identifying receptors and exposure scenarios and quantifying exposures. To 
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Final Environmental Impact Statement: Appendix 13

understand how humans may be exposed to herbicide a.i. as a result of the BLM vegetation treatment program, it 

is necessary to understand herbicide use within the BLM. Within the BLM vegetation treatment program, public 

lands are classified into various land programs (rangeland, public domain forestland, energy and minerals sites, 

rights-of-way, recreation and cultural sites, and aquatic sites). Within each program, aerial-, ground-, or boatbased applications may be used. Various application vehicles can be used for each application type, and for each 

vehicle, there are different application methods. Similarly, there are different BLM job descriptions associated 

with each application method. It is assumed that occupational receptors may be incidentally exposed to the 

herbicide a.i. through dermal contact and inhalation exposure routes. In addition, an accidental spill scenario was 

evaluated for the occupational receptors, assuming a direct spill of herbicide a.i. on the skin. 

Members of the public may also be incidentally exposed to herbicide a.i. used on public lands. Such receptors 

include hikers, hunters, berry pickers, swimmers, anglers, area residents, and Native Americans using natural 

resources on public lands. Although there are many different exposure scenarios and receptors that could be 

evaluated, these receptors cover a range of potential exposures that could occur under worst case conditions on BLM 

lands. It is assumed that these receptors could be exposed through one or more of the following exposure pathways: 

• Dermal contact with spray 

• Dermal contact with foliage 

• Dermal contact with water while swimming 

• Ingestion of drinking water or incidental ingestion of water while swimming 

• Ingestion of berries 

• Ingestion of fish 

Although all public receptor exposures to herbicide a.i. used on public lands are considered to be accidental, 

public receptor exposures are evaluated under two scenarios. Routine-use exposures are assumed to occur when 

public receptors come into contact with environmental media that have been impacted by spray drift. Accidental 

exposures are assumed to occur when public receptors come into contact with environmental media that have 

been subject to direct spray or spills. Under the direct spray scenarios, it is assumed that a receptor enters a 

foliated area or a pond (for the aquatic herbicide a.i.) that has recently been treated, even though the area is posted 

with warning signs. The direct spray pathway for terrestrial herbicide a.i. onto ponds assumes that the herbicide 

a.i. are accidentally sprayed on the pond. 

To quantify exposures, it is necessary to estimate the herbicide a.i. concentrations to which receptors could be 

exposed. For the occupational receptors, routine exposures were calculated using unit exposure (UE) values 

developed by USEPA combined with the herbicide a.i. application rates (ARs) and the acres treated (AT) per day. 

Accidental exposures were calculated using the undiluted herbicide a.i. concentrations for liquid formulations and 

application-ready concentrations for solid formulations, and assuming a certain amount of spill and absorption 

through the skin. 

For the public receptors, routine exposures from spray drift were calculated using exposure point concentrations 

(EPCs) developed using computer models. The AgDriftmodel was used to estimate deposition of herbicide 

a.i. drift onto the receptor, foliage, berries, and pond. The GLEAMS model was used to calculate herbicide a.i. 

concentrations in the pond resulting from runoff (short-, intermediate-, and long-term exposure durations). For the 

terrestrial herbicide a.i., pond concentrations calculated in AgDrift were added to the highest pond concentrations 

calculated in GLEAMS. Accidental exposures were calculated assuming direct spray of the herbicide a.i. at the 

maximum ARs onto the receptor, foliage, berries, and pond. In addition, an accidental spill scenario was evaluated 

for the pond assuming that the entire contents of a truck or helicopter could spill into the pond. 
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Risk Characterization 

The risk characterization section provides quantitative risk estimates for each of the herbicide a.i. for the various 

receptors and exposure scenarios. USEPA’s Office of Pesticide Programs (OPP) has developed an Aggregate Risk 

Index (ARI) approach that combines risks calculated using the %PAD and MOE methods. As with the MOE, 

potential risk increases as the ARI decreases. The ARI is compared against a target value of 1. Values greater than 

1 do not exceed the USEPA’s level of concern. 

Diquat results in ARIs less than 1 for a majority of the occupational receptors and public receptors, indicating a 

level of concern. Fluridone results in ARIs less than 1 for several of the occupational and public receptors under 

the maximum AR scenarios. Dicamba, diquat, and fluridone result in ARIs less than one for the occupational 

accidental spill scenario (spill to worker skin). The other three herbicide a.i. (diflufenzopyr, imazapic, and 

sulfometuron methyl) do not result in ARIs below 1 for any scenario, indicating no level of concern with use of 

these three herbicide a.i.

Forest Service Human Health and 

Environmental Risk Assessments 

The primary reference for this section is: Syracuse Environmental Research Associates, Inc. (SERA). 2007. 

Preparation of Environemnatl Documentation and Risk Assessments. Pages 1-2 to 1-13. Prepared for the U.S. 

Department of Agriculture Forest Service. Arlington, Virginia. Fayetteville, New York. Available at http://www.

fs.fed.us/foresthealth/pesticide/pdfs/PrepEnvirmentalDoc_01-07.pdf. References cited in this section are internal 

to the above-referenced document. 

The Forest Service Risk Assessments contain both human health and environmental risk assessments sections. 

Each section follows the four-step process recommended the National Research Council of the National Academy 

of Sciences (NRC 1983) and used in the BLM Human Health Risk Assessments. For risks to be quantified, a 

hazard must be identified, exposures must be quantitatively estimated, and a dose-response relationship must be 

expressed quantitatively. Each of these four basic steps are summarized as follows:

Hazard Identification

Hazard identification is the process of identifying what, if any, effects a compound is likely to have on an 

exposed population. Hazard identification is the first and most critical step in any risk assessment. Unless some 

plausible biological effect can be demonstrated, the nature of the subsequent dose-response assessment and risk 

characterization is extremely limited. Both the human health and ecological risk assessments are prepared using 

in vivo and in vitro data from experimental animal studies. Additional sources of information like epidemiology 

studies, case reports, and clinical investigations are used to prepare human health risk assessment. Studies 

on various model nontarget test species (e.g., ducks, quail, fish, aquatic invertebrates, plants, and terrestrial 

invertebrates) are commonly available to strengthen an ecological risk assessment. In addition, available field 

studies on nontarget species are used in ecological risk assessments in much the same way epidemiology studies 

are used in human health risk assessments. The hazard identification is based on a review of the toxicological and 

pharmacokinetics data and is arranged to focus on the dose-response and dose-severity relationships. Of these two 

relationships, the dose-severity relationship is generally more relevant for non-carcinogenic effects in humans and 

nontarget species. The severity scale used to conduct the risk assessment typically employs four levels of severity, 

which are defined in Table 1-1. 
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Final Environmental Impact Statement: Appendix 13

Table 1-1: Severity definitions used in human health risk assessment (HHRA) and ecological

risk assessment (ERA)

Acronym

HHRA ERA Definition

NOEL NOEC No-observed-effect level (concentration): No biologically or statistically significant effects attributable to 

treatment.

NOAEL NOAEC No-observed-adverse-effect level (concentration): Effects that are attributable to treatment but do not 

appear to impair the organism’s ability to function and clearly do not lead to such an impairment.

LOEL LOEC Lowest-observed-effect level (concentration): The lowest exposure level associated with an adverse effect.

AEL Adverse-effect level: Signs of toxicity that must be detected by invasive methods, external monitoring 

devices, or prolonged systematic observations. Symptoms that are not accompanied by grossly observable 

signs of toxicity.

FEL Frank-effect level: Gross and immediately observable signs of toxicity.

The terminology used in human health and ecological risk assessments is somewhat different, but the concepts 

are virtually identical. In human health risk assessment, severity is typically defined by the consequences of 

different levels of exposure. These include the no-observed-effect level (NOEL), no-observed-adverse-effect level 

(NOAEL), adverse-effect level (AEL), and frank-effect level (FEL). An additional term, lowest-observedadverseeffect level (LOAEL) is sometimes used to designate the lowest AEL. This scale, with minor differences in 

nomenclature, is used by many government agencies to classify the toxicological effects observed in experimental 

or epidemiology studies. In the ecotoxicology literature, the term NOEC—no observed effect concentration—is 

sometimes used rather than the term NOEL. As indicated in Table 1-1, these terms as well as their variations are 

synonymous. The hazard identification process involves making judgments about which effects are most relevant 

to the assessment of human health or nontarget species. During this process, studies may be eliminated from 

consideration because they are inherently flawed, or because they are grossly inconsistent with the preponderance 

of other studies.

Although hazard identification results in a qualitative determination, quantitative methods are usually required 

as in most other assessments of causality. For instance, the process of hazard identification often hinges on a 

statistical assessment of exposure-response or dose-response relationships. Furthermore, hazard identification 

must also consider fundamental and qualitative differences among species. Depending on the chemical of concern, 

hazard identification also may include the use of quantitative or qualitative structure activity relationships or 

differences in pharmacokinetics.

Exposure Assessment

The exposure scenarios considered in a risk assessment involving pesticide exposure are determined by the 

application method and the chemical and toxicological properties of the compound. Depending on the properties 

of the chemical and the application method, the risk assessment may consider acute, subchronic, or chronic 

durations of oral, dermal, inhalation or combined exposure to the pesticide.

Human Health

Exposure scenarios are developed for workers and members of the general public. For each group, two types of 

exposure scenarios are generally taken into consideration: general exposure and accidental/incidental exposure. 

The term general exposure refers to human exposure resulting from the normal use of the chemical. For workers, 

general exposure involves the handling and application of the compound. These general exposure scenarios 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

can be interpreted relatively easily and objectively. The exposure estimates are calculated from the amount of 

the chemical handled/day and the exposure rates for the worker group. Although each of the specific exposure 

assessments for workers involves degrees of uncertainty, the exposure estimates are objective in that they are 

based on empirical relationships of absorbed dose to pesticide use. For the general public the general exposure 

scenarios are somewhat more arbitrary and may be less plausible. For each pesticide, at least three general 

exposure scenarios are considered, including walking through a contaminated area shortly after treatment, the 

consumption of ambient water from a contaminated watershed, and the consumption of contaminated vegetation. 

These three scenarios are consistently used because one of them usually leads to the highest estimates of 

exposure. Additional scenarios discussed below may be considered for each of the individual compounds as 

warranted by the available data and the nature of the program activities.

Some, if not all, of these general exposure scenarios for the general public may seem implausible or at least 

extremely conservative. For example, in many cases compounds are applied in relatively remote areas and so it 

is not likely that members of the general public would be exposed to plants shortly after treatment. Similarly, the 

estimates of longer-term consumption of contaminated water are based on estimated application rates (lbs a.i./

acre) and monitoring studies that can be used to relate levels in ambient water to treatment rates in a watershed; 

however, in most pesticide applications, substantial portions of a watershed are not likely to be treated. Finally, the 

exposure scenarios based on longer-term consumption of contaminated vegetation assume that an area of edible 

plants is inadvertently sprayed and that these plants are consumed by an individual over a 90-day period. While 

such inadvertent contamination might occur, it is extremely unlikely to happen as a result of directed applications 

(e.g., backpack applications). Even in the case of boom spray operations, the spray is directed at target vegetation 

and the possibility of inadvertent contamination of cultivated or edible vegetation would be low. In addition, for 

herbicides and other phytotoxic compounds, it is likely that the contaminated plants would show obvious signs of 

damage over a relatively short period of time and would therefore not be consumed.

All of the factors discussed above concerning general exposure scenarios for the general public have merit and 

must be considered in the interpretation of the risk characterization (Section 3.4). Thus, the typical hazard to the 

general public may often be negligible because significant levels of exposure are not likely. For the general public, 

the general exposures may be regarded as extreme in that they are based on very conservative exposure assessments 

and/or very implausible events. Nonetheless, these general exposure assessments are included because the risk 

assessment is intended to be extremely conservative with respect to potential effects on the general public, and to 

provide estimates regarding the likelihood and nature of effects after human exposure to pesticides.

Accidental/incidental exposure scenarios describe specific examples of gross over-exposure associated with 

mischance or mishandling of a chemical. All of these exposure scenarios are arbitrary in that the nature and duration 

of the exposure is fixed. For example, the worker exposure scenario involving immersion of the hands is based on 

a 1-minute period of exposure but could just as easily be based on an exposure period of 5 seconds or 5 minutes. 

Similarly, the consequences of wearing contaminated gloves could be evaluated at 4 hours rather than at 1 hour.

These scenarios are intended to provide an indication of relative hazard among different pesticides and different 

events in a manner that facilitates conversion or extrapolation to other exposure conditions.

Like the general exposure scenarios, the accidental exposures for the general public may be regarded as more 

extreme than those for workers. Three scenarios are included in each exposure assessment. They include 

direct spray, the consumption of contaminated water shortly after a spill, and the consumption of contaminated 

vegetation shortly after treatment. The direct spray scenario is clearly extreme. It assumes that a naked child is 

sprayed directly with a pesticide as it is being applied and that no steps are taken to remove the pesticide from 

the child for 1 hour. There are no reports of such incidents in the literature, and the likelihood of such an incident 
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Final Environmental Impact Statement: Appendix 13

occurring appears to be remote. Nonetheless, this scenario and others like it are useful not only as a uniform 

comparison among pesticides but also as a simplifying step in the risk assessment. If the ‘naked child’ scenario 

indicates no basis for concern, other dermal spray scenarios will not suggest a potential hazard and need not be 

explored. If there is a potential hazard, other more plausible exposure scenarios may need to be considered. The 

other two accidental scenarios are similarly intended to serve as uniform comparisons among chemicals as well as 

a means of evaluating the need to explore additional exposure scenarios.

In all cases, the level of exposure is directly proportional to the exposure parameters. The exposure associated 

with wearing gloves for 4 hours is 4 times the exposure associated with wearing contaminated gloves for 1 hour. 

Similarly, the general exposure scenarios for workers are based on an 8-hour work day. If a 4-hour application 

period were used, the hazard indices would be reduced by a factor of two. As another example, general exposure 

scenarios for both workers and the general public are linearly related to the application rate. Consequently, if the 

application rate were to double or vary by some other factor, the estimated exposure would double or vary by the 

same factor. Thus, the specific exposure parameters used in the risk assessment are selected to allow for relatively 

simple extrapolation to greater or lesser degrees of exposure.

Additional variability is taken into consideration by estimating exposure doses or absorbed doses for individuals 

of different age groups (i.e., adults, young children, toddlers, and infants). Children may behave in ways that 

increase their exposure to applied pesticides (e.g., long periods of outdoor play, pica, or imprudent consumption 

of contaminated media or materials). In addition, anatomical and physiological factors, such as body surface 

area, and breathing rates and consumption rates for food and water, are not linearly related to body weight and 

age. Consequently, the models used to estimate the exposure dose (e.g., mg/kg body weight/day) based on 

chemical concentrations in environmental media (e.g., ppm in air, water, or food) indicate that children, compared 

with individuals of different age groups, are generally exposed to the highest doses of chemicals for a given 

environmental concentration.

Ecological Effects

The exposure assessments for ecological effects are conceptually similar to those conducted in the human health 

risk assessment, and for many terrestrial organisms the exposure assessments are parallel to those used in the 

human health risk assessment. Similarly, exposures of aquatic species are typically based on the same estimates 

of concentrations of the chemical in water that are used in the human health risk assessment. Terrestrial animals 

might be exposed to any applied pesticide from direct spray, the ingestion of contaminated media (vegetation, 

prey species, or water), grooming activities, or indirect contact with contaminated vegetation. Estimates of oral 

exposure are expressed in the same units as the available toxicity data. As in the human health risk assessment, 

these units are usually expressed as mg of agent per kg of body weight and abbreviated as mg/kg body weight. 

For dermal exposure, the units of measure usually are expressed in mg of agent per cm2 of surface area of the 

organism and abbreviated as mg/cm2. In estimating dose, however, a distinction is made between the exposure 

dose and the absorbed dose. The exposure dose is the amount of material on the organism (i.e., the product of 

the residue level in mg/cm2 and the amount of surface area exposed), which can be expressed either as mg/

organism or mg/kg body weight. The absorbed dose is the proportion of the exposure dose that is actually taken 

in or absorbed by the animal. For the exposure assessments discussed below, general allometric relationships are 

used to model exposure (e.g., Boxenbaum and D’Souza 1990). These relationships dictate that for a fixed level of 

exposure (e.g., concentrations of a chemical in food or water), small animals will receive a higher dose, in terms 

of mg/kg body weight, than large animals will receive. Based on allometric relationships, it would be possible to 

model exposure in a very large number of nontarget terrestrial animals. This approach has been used in some past 

USDA assessments. This approach is no longer used because highly species-specific exposure assessments are of 

little use in the absence of species-specific dose-response assessments. Thus, if the pesticidespecific information 

indicates that large mammals may be more sensitive than smaller mammals ( i.e., in contrast to the more general 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

relationship noted above), both large and small mammals are modeled separately. Similarly, if the available 

information suggests that the compound under review may be more toxic to birds than to mammals, separate 

exposure assessments are conducted for both birds (large and small) and mammals. The basic philosophy behind 

this approach is that the exposure assessment should not be more complicated than the dose-response assessment.

Generic estimates of exposure are always given for a small mammal. A body weight of 20 g is used for a small 

mammal, which approximates the body weight of small mammals like mice, voles, shrews, and bats. Other body 

weights, food consumption, and caloric requirements for mammals and birds are taken from U.S. EPA (1993). The 

computational details for each exposure assessment presented in this section are provided in standard worksheets 

(see Appendix 3). Depending on the available toxicity data and the uses of the chemical under review, exposure 

assessments may be made for larger mammals, birds, various terrestrial invertebrates, and terrestrial plants. The 

specific scenarios most often considered are detailed in Section 4.2.

Dose-Response Assessment

The purpose of the dose-response assessment is to describe the degree or severity of risk as a function of dose. In 

classical toxicology, doseresponse assessments are usually expressed as linear or non-linear equations, such as probit 

analysis and the multistage model, respectively. Using these methods, the prevalence or magnitude of a response can 

be estimated for any dose level. In regulatory toxicology, this approach is the exception rather than the rule.

Most dose-response assessments in regulatory toxicology, as discussed below, result in point estimates. Although 

some methods in regulatory toxicology use dose-response models, the regulatory value used is a point estimate. For 

example, U.S. EPA cancer risk assessments usually employ a form of the multistage model or some other linear 

dose-response relationship that provide measures of variability or error. The estimate used in setting exposure 

criteria, however, is typically a point estimate that is a single value rather than a range of values. The results of 

other commonly used dose-response assessments, such as RfDs, and RfCs, are point estimates of doses that are not 

believed to be associated with any adverse effect and that are not directly related to a dose-response model.

The practice of relying on point estimates in regulatory toxicology is grounded in the history of this discipline 

(Dourson and Stara 1983). From its inception, the focus of regulatory toxicology has been the development of 

criteria (i.e., levels of exposure that are defined as safe). Consequently, the methods used in regulatory toxicology 

are conservative.

Consistent with the recommendation of NRC (1983) that various groups within the federal government adopt 

common risk assessment methodologies, standard dose-response assessments are generally based on reference 

values, like RfDs, derived by other government agencies. This approach avoids a duplication of effort, capitalizes 

on the expertise of other organizations, and decreases the size, complexity, and cost of risk assessments.

In cases for which these standard approaches yield evidence of potential risk, other statistical methods such as 

categorical regression may be used to characterize the likelihood and severity of the risk. Categorical regression 

analysis is used as a tool to supplement RfDs and analogous values. The method defines a relationship between 

responses that can be categorized according to exposure dose and duration (factors that may influence the 

response), and estimates the probability that a group of animals subjected to a given exposure will be classified 

into a particular category (Dourson et al. 1997, Durkin et al. 1992, Guth et al. 1997). Categorical regression as 

well as other methods (quantitative and semi-quantitative) are discussed further in Section 3.3.5.

In most respects, dose-response assessments for ecological effects are conceptually similar to the methods 

employed in the human health risk assessments, with one major exception. Human health risk assessments focus 

on protecting the individual. This is why uncertainty factors (sometimes very large) are used to derive RfD values 
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Final Environmental Impact Statement: Appendix 13

and why cancer risk is estimated using very conservative assumptions. In ecological risk assessment, the focus is 

on a population or community rather than an individual. Thus, the use of uncertainty factors is less common and 

the general methods for dose-response assessment are less conservative.

For terrestrial mammals, the dose-response assessment generally is based on the same data used to derive the 

RfD in the human health risk assessment: an NOAEL from a chronic exposure study. The data on other terrestrial 

animals, both birds and invertebrates, are often not as detailed as the available information on experimental 

mammals. Fewer toxicological endpoints are examined, and, at least for vertebrates, lifetime or chronic studies 

are seldom available.

For some terrestrial plants as well as some aquatic species, sensitive life-stage studies are often available. Such 

studies include egg-and-fry studies in fish, life-cycle toxicity studies in Daphnia magna, and seed germination and 

growth studies in plants, all of which are required by the U.S. EPA for the registration of herbicides. The studies 

are obtained and assessed following the same criteria applied to studies for the human health risk assessment. 

The principal difference is that NOEL, NOEC, or LD or LC values are used directly rather than RfD values that 

involve the application of uncertainty factors.

Nonetheless, dose-response assessments for some nontarget species considered in a risk assessment can be 

complicated (Section 4.3). As in the human health dose-response assessment, the nature of the available data as 

well as the potential risk may dictate the use of relatively complex dose-response analyses.

Risk Characterization

Conceptually, risk characterization is simply the process of comparing the exposure assessment to the doseresponse assessment. In this process, risk is characterized quantitatively either as a ratio or as an incidence of 

response or a defined risk level – i.e., a risk of 5%.

Because the risk characterization flows directly from the exposure and dose-response assessments, the complexity 

and clarity of the risk characterization will be dependent on complexity and clarity of both the exposure and 

dose-response assessments. In most cases, risk will be quantitatively characterized as a ratio: a level of exposure 

divided by some defined effect level. In the human health risk assessment, the defined effect level is almost 

always the reference dose (RfD), and the ratio of the exposure to the reference dose is referred to as the hazard 

quotient (HQ). In the ecological risk assessments, the defined effect level is may be an NOEC or a risk level. 

The risk level, in turn, may be a lethal dose (e.g., LD50 or some other response level such as an LD25) or a dose 

causing some risk of a non-lethal effect (e.g., an ED50 or ED25). For aquatic organisms and for some terrestrial 

organisms for which exposure is characterized by a concentration rather than a dose, the defined risk levels may 

be expressed as a lethal concentration (LC50 or some other response level) or a sublethal concentration that leads 

to some effect (e.g., an EC50). In general, the Forest Service prefers to use NOAEL or NOEC values in risk 

characterizations. If NOAEL or NOEC values are not available, a sublethal effective dose at some response rate 

(e.g., EDX or ECX where X is some level of response) is generally preferred over a lethal response rate (e.g., 

LDX or LCX). While these ratios are sometimes referred to as HQs, more suitable terms are risk quotients (RQs).

If sufficient data are available and if the simple HQs or RQs suggest some level of concern, doseresponse or doseseverity relationships may be used to characterize risk. Dose-response relationships most often involve explicit 

dose-response functions that lead to an explicit estimate of risk (e.g., a response rate of 13.2% for some effect 

or an 8% decrease in some biological function). Dose-severity relationships are typically less quantitative and 

lead to some assessment of what effects might be observed in a population at various levels of exposure. A fuller 

discussion of the quotient methods (HQs and RQs) as well as the dose-response and doseseverity relationships are 

given in Section 3.4 (Human Health Effects) and Section 4.4 (Ecological Effects).
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Elaborations

Probabilistic Risk Assessment

Variability and uncertainty may be dominant factors in any risk assessment, and these factors should be expressed. 

Within the context of a risk assessment, the terms variability and uncertainty signify different conditions. In 

general, variability and uncertainty can be distinguished from each other depending on the state of knowledge 

or information. Variability reflects the knowledge of how things may change. By acquiring more knowledge or 

information, better estimates of variability may be obtained but the variability itself will not decrease – i.e., it is 

inherent in the population or system being considered. Differences in human body weights are a good example 

of variability. Uncertainty reflects a lack of knowledge and uncertainty can be reduced by acquiring information. 

For example, while the toxicity of herbicides has been tested in the honey bee, very little information is available 

on the toxicity of most herbicides to other nontarget terrestrial insects. This leads to uncertainty (in terms of how 

representative the honey bee is for other insects) but this uncertainty can be reduced by conducting experiments 

on the toxicity of the herbicide to other insects.

Variability may take several forms. For this risk assessment, three types of variability are distinguished: statistical, 

situational, and arbitrary. Statistical variability reflects apparently random patterns in data. For example, various 

types of estimates used in this risk assessment involve relationships of certain physical properties to certain 

biological properties. In such cases, best or maximum likelihood estimates can be calculated, as well as upper 

and lower confidence intervals that reflect the statistical variability in the relationships. Situational variability 

describes variations depending on known circumstances. For example, the application rate or the applied 

concentration of an herbicide will vary according to local conditions and goals. As discussed in the following 

section, the limits on this variability are known and there is some information to indicate what the variations are. 

In other words, situational variability is not random. Arbitrary variability, as the name implies, represents an 

attempt to describe changes that cannot be characterized statistically or by a given set of conditions that cannot 

be well defined. This type of variability dominates some spill scenarios involving either a spill of a chemical on 

to the surface of the skin or a spill of a chemical into water. In either case, exposure depends on the amount of 

chemical spilled and the area of skin or volume of water that is contaminated.

In order to quantitatively address both variability and uncertainty, risk assessment methods generically referred to 

as probabilistic risk assessment have been and continue to be developed. The general approach for probabilistic 

risk assessment, particularly with respect to ecological species, has been articulated by Ecological Committee on 

FIFRA Risk Assessment Methods (ECOFRAM 1999). The basic approach given in ECOFRAM (1999) involves a 

tiered risk assessment process:

Tier 1: Very conservative screening methods involving worse case assumptions in terms of both exposure 

and dose-response. Risk is typically expressed as a point estimate such as an HQ or RQ. 

Tier 2: Typically elaborates or refines the exposure assessment to include more realistic estimates of 

exposures and may elaborate the dose-response assessment to include the use of full dose-response 

curves. Risk may be expressed in terms of probabilities rather than point estimates. 

Tier 3: An extension of a Tier 2 approach that may involve the inclusion of data on additional species 

(e.g., species sensitivity distributions) and more sophisticated exposure models. 

Tier 4: Is the most complex risk assessment and may involve experimental or monitoring programs 

designed to definitively characterize either exposure and toxicity and the use of all available data 

including microcosm, mesocosm, and field studies.
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Final Environmental Impact Statement: Appendix 13

As implied by the term Tier, probabilistic risk assessments under the general ECOFRAM model are designed 

to be conducted in stages going from the most conservative or worst-case approach (Tier 1) to less extreme 

and presumably more realistic assessments. Because this staged approach typically results in progressively 

lessened perceptions of risk, probabilistic risk assessments have been criticized as simply mechanisms to make 

risk disappear by mathematical manipulations. This criticism is addressed in ECOFRAM (1999) and is largely 

unfounded. While any risk assessment, probabilistic or otherwise, can be manipulated to distort risk (either 

upward or downward), the proper application of probabilistic risk assessment typically results not in conflicting 

risk characterizations at the different tiers but rather in more fully elaborated and refined risk assessments.

The nomenclature of probabilistic risk assessments, particularly as embodied in ECOFRAM (1999) is somewhat 

different from that of NAS (1983) but the concepts are essentially the same. The first stage of a probabilistic 

risk assessment is typically referred to as the Problem Formulation. This is similar to the Hazard Identification 

as defined by NAS (1983) but focuses on identifying which organisms are likely to be at greatest risk. The 

other stages of the risk assessment process defined by ECOFRAM (1999) are exposure characterization, effects 

characterization, and risk characterization and correspond closely to more general definitions given by NAS 

(1983) for the exposure assessment, dose-response assessment, and risk characterization.

In the higher tiered risk assessments, the probabilistic approach is based on more sophisticated methods of 

handling data and expressing both variability and uncertainty. A central feature of many higher tiered probabilistic 

risk assessments is Monte Carlo Analysis. Monte Carlo Analysis is a general term for any simulation that uses 

probability distributions rather than point estimates to represent and approximate the variability in a system 

model. The method was originally developed in the 1940’s, shortly after the development of computers, to make 

probabilistic approximations to the solutions of mathematical equations or models that could not be solved 

analytically (U.S. EPA/Risk Assessment Forum, 1997).

Monte Carlo Analyses can be relatively simple or very complicated depending on the simplicity or complexity 

of the model. As a simple example, take a situation in which we knew that a population of individuals will be 

exposed each day to up to 200 mg of a chemical. In this population, the smallest individual will have a body 

weight of about 52 kg. Thus, the maximum daily dose is about 3.8 mg/kg body weight. In addition, we knew that 

the RfD for the general population is 3.5 mg/kg. Taking a standard ratio approach using point estimates (Section 

1.2.1.4), the hazard quotient would be about 1.1, somewhat above the level of concern. This would be a standard 

point-estimate worst-case approach and the risk assessment would conclude that some unspecified number of 

individuals could be subject to exposures that would not be generally considered acceptable.

Suppose, however, that the average body weight was 70 kg and the body weights in the population evidenced a 

normal distribution with a standard deviation of 10 kg. In addition, suppose that we knew that not all individuals 

would be exposed to the same amount of the chemical but that the amount could vary from 50 mg/day to 200 mg/

day. Lastly, while the RfD was 3.5 mg/kg/day, we also knew that some individuals could be more sensitive and 

might respond with an adverse effect at a dose above 2 mg/kg/day, but that other individuals would not respond 

adversely until the dose reached 10 mg/kg/day. This sort of variability could be modeled in a Monte Carlo 

Analysis with the following assumptions:

Parameter Distribution

Body weight Normal distribution with a mean of 70 kg and a standard deviation of 10 kg

Exposure Uniform distribution with a range of 50 mg/day to 200 mg/day.

RfD Triangular with a mode of 3.5 mg/kg/day, a lower limit of 2 mg/kg/day and an upper limit of 10 g/kg/day
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

An illustration of the results of a Monte Carlo Analysis of this simple model is given in Figure 1-2. Under 

the conditions of the simulation, the hazard quotient would be greater than unity (the level of concern for this 

scenario) for about 5% of the population. Note that the use of a Monte Carlo simulation does not necessarily 

change the conclusions risk assessment. In the above example, the simulation is consistent with the worst-case 

point estimate approach: some people will be at risk. The Monte Carlo simulation, however, does incorporate 

more information into the assessment and allows the risk assessor to better characterize the consequences – i.e., 

about 5% of the individuals may be exposed to more of the agent than would be generally considered acceptable.

Most practical Monte Carlo simulations are much more complicated and may involve quantitative considerations 

of differences in sensitivity among different species (e.g., Posthuma et al. 2002) as well as very complex 

applications of environmental fate models (e.g., Randall et al. 2003). Also, although elementary Monte Carlo 

Analyses can be conducted in commonly available software programs like EXCEL, most Monte Carlo analyses 

require relatively specialized software. The above example was conducted using an EXCEL add-in called 

Crystal Ball (Decisioneering 2004) that is commonly used in probabilistic risk assessments conducted by or for 

the U.S. EPA’s Office of Pesticides, Environmental Fate and Effects Division. Other packages capable of more 

sophisticated modeling include acslXtreme (AEgis Technologies Group 2004), ModelMaker (Cherwell Scientific 

2000), and Mathematica (Wolfram Research 2004).

Extreme Value Risk Assessment

The USDA Forest Service has not adopted probabilistic risk assessment methods. Historically, the Forest Service 

has developed different scenarios that have been referred to as typical and worst-case (e.g., USDA/FS 1989a,b,c). 

With the advent of the SERA risk assessments, a somewhat different approach was taken in which almost no 

values used in a risk estimate are presented as a single number. Instead, most numbers used in calculating risk 

values are expressed as a central estimate and a range, which is sometimes very large. The central estimate would 

generally correspond to the typical value and the upper value in the range (or more specifically the upper or lower 

bound that leads to the highest estimate of risk) would generally correspond to what used to be called the “worstcase” value. The other end of the range (the upper or lower bound that leads to the lowest estimate of risk) might 

be termed the “best case” value. The best case assessment is made simply because an unacceptable level of risk 

from a best case would lead to the clear conclusion that the use of the agent under any circumstances would likely 

result in some adverse effect.

As with a probabilistic risk assessment, an attempt is often made to apply the extreme value approach both to 

the exposure assessment as well as to the dose-response assessment. Applications of the exposure assessment 

are relatively simple and may involve various assumptions concerning animal weight, food consumption, water 

consumption, rainfall and so forth. Many of the specific assumptions are detailed in Section 3.2 (Human Health) 

and Section 4.2 (Ecological Effects). In terms of the dose-response assessment, the extreme value approach most 

often involves the identification of both tolerant and sensitive species, typically in the ecological risk assessment 

(Section 4.3). In the human health risk assessment (Section 3.3), different RfD values may be derived for sensitive 

subgroups – e.g., children or women of childbearing age.

The extreme value approach has some but not all of the benefits of probabilistic risk assessment. For example, 

it can and often does indicate that a particular use of an agent might not cause any adverse effects under some 

circumstances but could cause adverse effects under other circumstances. To the extent that the circumstances 

are clearly defined, this may serve as a guide to using the agent in a manner that will minimize the potential for 

adverse effects. While probabilistic risk assessments may be used by the Forest Service at some point in the 

future, probabilistic risk assessments generally take longer to conduct (because of the tiered nature of the risk 

assessment process) and involve the commitment of greater resources.
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Final Environmental Impact Statement: Appendix 13

Uncertainty Analysis in Risk Assessments 

The primary reference for this section is: USDI Bureau of Land Management. 2007. Vegetation Treatments using 

Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact 

Statement (PEIS). Appendix C, PEIS C-78 to C-86. Available at http://www.blm.gov/wo/st/en/prog/more/veg_eis.

html. References cited in this section are internal to the above-referenced document. 

For any ERA, a thorough description of uncertainties is a key component that serves to identify possible weaknesses 

in the analysis and to elucidate what impact such weaknesses might have on the final risk conclusions. The 

uncertainties of this risk assessment are discussed below (also see Table 7-1 in the herbicide ERAs [ENSR 2005a-j]). 

Toxicity Data Availability 

The majority of the available toxicity data was obtained from studies conducted as part of the USEPA pesticide 

registration process. There are a number of uncertainties related to the use of this limited data set in the risk 

assessment. In general, it would be preferable to base any ecological risk analysis on reliable field studies 

that clearly identify and quantify the amount of potential risk from particular exposure concentrations of the 

chemical of concern. However, in most risk assessments it is more common to extrapolate the results obtained 

in the laboratory to the receptors found in the field. It should be noted, however, that laboratory studies often 

overestimate risk relative to field studies (Fairbrother and Kapustka 1996). 

Species for which toxicity data are available may not necessarily be the most sensitive species to a particular 

herbicide. These species have been selected as laboratory test organisms because they are generally sensitive 

to stressors and can also be maintained under laboratory conditions. Toxicity values for the most appropriate 

sensitive surrogate species for each receptor were selected by qualified toxicologists based on a thorough review 

of the available toxicity data; however, there is a possibility that some non-tested receptors in a given receptor 

group would be more sensitive. 

Furthermore, the surrogate species used in the registration testing are not an exact match to the wildlife receptors 

included in the ERA. For example, avian data are only available for two primarily herbivorous birds: the 

mallard duck and the bobwhite quail. However, TRVs based on these receptors were also used to evaluate risk to 

insectivorous and piscivorous birds. Species with alternative feeding habits may be more or less sensitive to the 

herbicide than those species tested in the laboratory (see Tables C-3 and C-4 for a list of surrogate species and 

their receptor groups). 

In general, the most sensitive available endpoint for the appropriate surrogate test species was used to derive 

TRVs. This approach is conservative as there may be a wide range of data and effects for different species. For 

example, the EC50s available for aquatic invertebrates exposed to bromacil ranged from 65 mg a.i./L to >1,000 mg 

a.i./L. Accordingly, 65 mg a.i./L was selected as the aquatic invertebrate TRV, even though the majority of results 

were well above this value. In general, this selection criterion for TRVs has the potential to overestimate risk 

within the ERA. 

In addition, several of the toxicity tests conducted during the registration process did not use herbicide formulations 

with 100% a.i. The assumption has been made that any toxicity observed in the tests is due to the herbicide a.i.; 

however, it is possible that the additional ingredients in the different formulations also had an effect. For purposes 

of TRV derivation and the ERA, it was assumed that all toxicity data applies to the a.i. itself and not the particular 

product formulation tested. This may result in an overestimate of risk to certain receptors and species guilds. 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

Degradates, Inert Ingredients, Adjuvants, and Tank Mixtures 

In a detailed herbicide risk assessment, it is preferable to estimate risks not just from the a.i. of an herbicide, but 

also from the cumulative risks of degradates, inert ingredients (inerts), and adjuvants. Other pesticides may also 

factor into the risk estimates, as herbicides can be tank mixed to expand the level of control and to accomplish 

multiple identified tasks (the BLM usually only tank mixes herbicides with other herbicides). However, using 

currently available models (e.g., GLEAMS), it is only practical to make deterministic risk calculations (i.e., 

exposure modeling, effects assessment, and RQ derivations) for a single a.i. 

In addition, information on inerts, adjuvants, and degradates is often limited by the availability of, and access to, 

reliable toxicity data for these constituents. The sections below present a qualitative evaluation of the potential 

risks from degradates, inert ingredients, adjuvants, and tank mixtures. 

Degradates 

The potential toxicity of degradates should be considered when selecting an herbicide. However, it is beyond the 

scope of this risk assessment to evaluate all of the possible degradates of the various herbicide formulations of the 

10 herbicides. Degradates may be more or less mobile and more or less toxic in the environment than their source 

herbicides (Battaglin et al. 2003). Differences in environmental behavior (e.g., mobility) and toxicity between parent 

herbicides and degradates makes prediction of potential impacts challenging. For example, a less toxic, but more 

mobile bioaccumulative, or persistent degradate may have a greater adverse impact due to residual concentrations 

in the environment. A recent study indicated that 70% of degradates had either similar or reduced toxicity to 

fish, daphnids, and algae than the parent pesticide. However, 4.2% of the degradates were more than an order of 

magnitude more toxic than the parent pesticide, with a few instances of acute toxicity values below 1 mg/L (Sinclair 

and Boxall 2003). No evaluations of impacts to terrestrial species were conducted in the study. The lack of data on 

the toxicity of degradates of the specific herbicides represents a source of uncertainty in the risk assessment. 

Inerts 

Pesticide products contain both active and inert ingredients. The terms “active ingredient” (a.i.) and “inert 

ingredient” have been defined by federal law—the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA)—since 1947. An a.i. is one that prevents, destroys, repels, or mitigates the effects of a pest, or is a plant 

regulator, defoliant, desiccant, or nitrogen stabilizer. By law, the a.i. must be identified by name on the label, 

together with its percentage by weight. An inert ingredient is simply any ingredient in the product that is not 

intended to affect a target pest. For example, isopropyl alcohol may be an a.i. and antimicrobial pesticide in some 

products; however, in other products, it is used as a solvent and may be considered an inert ingredient. The law 

does not require inert ingredients to be identified by name and percentage on the label, but the total percentage of 

such ingredients must be declared. Because neither the federal law nor the regulations define the term “inert” on 

the basis of toxicity, hazard or risk to humans, non-target species, or the environment, it should not be assumed 

that all inert ingredients are non-toxic. 

The USEPA has a listing of regulated inert ingredients at http://www.epa.gov/opprd001/inerts/index.html. This 

listing divides inert ingredients into four lists. The number of inert ingredients found in the nine herbicides 

evaluated in the ERAs for each category is shown below (nine inerts were not found on the USEPA lists): 

List 1 - Inert Ingredients of Toxicological Concern: None. 

List 2 - Potentially Toxic Inert Ingredients: None. 

List 3 - Inerts of Unknown Toxicity: 12. 

List 4 - Inerts of Minimal Toxicity. List 4 is subdivided into List 4A (minimal risk inert ingredients) and List 

4B (inerts that have sufficient data to substantiate that they can be used safely in pesticide products): Over 50. 
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Final Environmental Impact Statement: Appendix 13

Toxicity information was also searched in the following sources: 

• TOMES (a proprietary toxicological database including USEPA’s IRIS, the Hazardous Substance Data 

Bank, and the Registry of Toxic Effects of Chemical Substances (RTEC). 

• USEPA’s ECOTOX database which includes AQUIRE (a database containing scientific papers published 

on the toxic effects of chemicals to aquatic organisms). 

• TOXLINE (a literature searching tool). 

• Material Safety Data Sheets from suppliers. 

• Other sources, such as the Farm Chemicals Handbook. 

• Other cited literature sources. 

Relatively little toxicity information was found. A few acute studies on aquatic or terrestrial species were reported. 

No chronic data, no cumulative effects data, and almost no indirect effects data (food chain species) were found 

for the inerts in the 10 herbicides. 

A number of the List 4 compounds (Inerts of Minimal Toxicity) are naturally-occurring earthen materials (e.g., 

clay materials or simple salts) that would produce no toxicity at applied concentrations. However, some of the 

inerts, particularly the List 3 compounds and unlisted compounds, may have moderate to high potential toxicity to 

aquatic species based on information in Material Safety Data Sheets or on published data. 

As a tool to evaluate List 3 and unlisted inerts in the ecological risk assessment, the exposure concentration of the 

inert compound was calculated and compared to toxicity information. As described in more detail in Appendix 

D of the ERAs, the GLEAMS model was set up to simulate the effects of a generalized inert compound in the 

base-case watershed (annual precipitation rate of 50 inches per year, application area of 10 acres, slope of 0.05, 

surface roughness of 0.015, erodibility of 0.401 tons per acre, and vegetation type of weeds) with a sand soil type. 

The chemical characteristics of the generalized inert compound were set at either extremely high or low values to 

describe it as either a very mobile or stable compound. The application rate of the inert/adjuvant compound was 

fixed at 1 lb a.i./acre. Under these conditions, the maximum predicted ratio of inert concentration to herbicide 

application rate was 0.69 mg/L per lb a.i./acre (3 day maximum in the pond), and in every case (acute and chronic, 

pond and stream scenarios) the inert concentrations exceeded herbicide a.i. concentrations. 

In general, higher application rates resulted in higher exposure concentrations of surfactant inerts, exceeding 1 

mg/L for the maximum pond scenario. This suggests that inerts associated with the application of herbicides may 

contribute to acute toxicity to aquatic organisms if they reach the aquatic environment. However, due to the lack 

of specific inert toxicity data, this may be an overestimate of the potential toxicity. It is assumed that toxic inerts 

would not represent a substantial percentage of the herbicide and that minimal impacts to the environment would 

result from these inert ingredients. 

Adjuvants and Tank Mixtures 

Evaluating the potential additional/cumulative risks from mixtures and adjuvants of pesticides is substantially 

more difficult than evaluating the inerts in the herbicide composition. While many herbicides are present in the 

natural environment along with other pesticides and toxic chemicals, it is extremely difficult to estimate the 

potential cumulative risks of such mixtures. The composition of such mixtures is highly site-specific, and thus 

nearly impossible to address at the programmatic level of the EIS. 

Herbicide label information indicates whether a particular herbicide can be tank mixed with other pesticides. 

Adjuvants (e.g., surfactants, crop oil concentrates, fertilizers) may also be added to the spray mixture to improve 

the herbicide efficacy when mixed and applied to according to the label. Without product specific toxicity data, 
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Vegetation Treatments Using Herbicides on BLM Lands in Oregon

it is impossible to quantify the potential impacts of these mixtures. In addition, a quantitative analysis could only 

be conducted if reliable scientific evidence allowed a determination of whether the joint action of the mixture was 

additive, synergistic, or antagonistic. Such evidence is not likely to exist unless the mode of action is common 

among the chemicals and receptors. 

Adjuvants 

Adjuvants generally function to enhance or prolong the activity of an a.i. For terrestrial herbicides, adjuvants 

aid in proper wetting of foliage and absorption of the a.i. into plant tissue. Adjuvant is a broad term that includes 

surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, compatibility agents, 

stickers, and spreaders. Adjuvants are not under the same registration guidelines as pesticides; the USEPA does 

not register or approve the labeling of spray adjuvants. Individual herbicide labels contain lists with “labelapproved” adjuvants for use with a particular herbicide under specific conditions. 

Following the same procedure used to address inerts in Appendix D of the ERAs, the GLEAMS model was 

used to estimate the potential portion of an adjuvant that might reach an adjacent waterbody via surface runoff. 

In addition, sources (Muller 1980; Lewis 1991; Dorn et al. 1997; Wong et al. 1997) generally suggest that the 

acute toxicity of surfactants and anti-foam agents to aquatic life ranges from 1 to 10 mg/L, and that chronic 

toxicity ranges as low as 0.1 mg/L. This evaluation indicates that, for herbicides with high application rates, 

adjuvants have the potential to cause acute, and potentially chronic, risk to aquatic species. However, more 

specific modeling and toxicity data would be necessary to define the level of uncertainty. Selection of adjuvants is 

under the control of BLM land managers, and it is recommended that land managers follow all label instructions 

and abide by any warnings. In general, adjuvants compose a relatively small portion of the volume of herbicide 

applied; however, selection of adjuvants with limited toxicity and low volumes is recommended to reduce the 

potential for the adjuvant to influence the toxicity of the herbicide. 

Tank Mixtures 

The use of tank mixtures of labeled herbicides, along with the addition of an adjuvant (when stated on the label), 

may be an efficient use of equipment and personnel; however, knowledge of both products and their interactions 

is necessary to avoid unintended negative effects. In general, herbicide interactions can be classified as additive, 

synergistic, or antagonistic: 

• Additive effects occur when mixing two herbicides produces the same response as the combined effects of 

each herbicide applied alone. The products neither hurt nor enhance each other. 

• Synergistic responses occur when two herbicides provide a greater response than the added effects of each 

herbicide applied separately. 

• Antagonistic responses occur when two herbicides applied together produce less control than if you 

applied each herbicide separately. 

While a quantitative evaluation of all of these mixtures is beyond the scope of this ERA, a qualitative evaluation 

may be made if the assumption is made that the products in the tank mix will act in an additive manner. The 

predicted RQs for two active ingredients can be summed for each individual exposure scenario to see if the 

combined impacts result in additional RQs elevated above the corresponding LOCs.

The RQs for any two herbicides in a tank mix were combined to simulate a tank mix in Appendix E of each 

ERA (diquat, fluridone, and tebuthiuron are not generally tank mixed by the BLM and were not included in this 

analysis). The application rates within the tank mix are not necessarily the same as each individual a.i. applied 

alone. See Table 7-2 in each ERA (ENSR 2005a-j) for a comparison of the percent of RQs exceeding LOCs for 

each of the 10 herbicide active ingredients applied alone and in a tank mix. 
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Final Environmental Impact Statement: Appendix 13

These comparisons indicate that tank mixes for bromacil (with sulfometuron methyl) and imazapic with 

diflufenzopyr do not result in more RQs above the associated LOCs for birds, mammals, fish, and invertebrates 

(and aquatic plants for imazapic), than were predicted for bromacil, imazapic, or diflufenzopyr alone. Additional 

elevated RQs are predicted for both aquatic and RTE terrestrial plants when tank mixes of bromacil with 

sulfometuron methyl, and imazapic with diflufenzopyr, are applied (aquatic plant risk is not elevated versus 

imazapic applied alone). This suggests that in some cases plant species may be particularly sensitive to the tank 

mix. However, when chlorsulfuron and diuron are tank mixed, all receptors are at higher risk than with application 

of chlorsulfuron alone (risks are not higher than with the application of diuron alone), and most receptors are also 

at higher risk when sulfometuron methyl is applied with bromacil versus sulfometuron methyl alone. 

The comparison of the RQs from herbicide a.i. and tank mixes of these herbicides indicate that results are specific 

to each tank mix. Aquatic plants and RTE terrestrial plants may be at greater risk from the tank mixed application 

than from the a.i. alone. However, in some cases all receptors are at greater risk and precautions (e.g., increased 

buffer zones, decreased application rates) should be taken to reduce risk. There is some uncertainty in this 

evaluation because herbicides in tank mixes may not interact in an additive manner; this may overestimate risk 

if the interaction is antagonistic, or it may underestimate risk if the interaction is synergistic. In addition, other 

products may also be included in tank mixes and may contribute to the potential risk. 

Selection of tank mixes, like adjuvants, is under the control of BLM land managers. To reduce uncertainties 

and potential negative impacts, it is required that land managers follow all label instructions and abide by any 

warnings. Labels for both tank mixed products should be thoroughly reviewed and mixtures with the least 

potential for negative effects should be selected. This is especially relevant when a mixture is applied in a 

manner that may have increased potential for risk. Use of a tank mix under these conditions increases the level of 

uncertainty in risk to the environment (PEIS C-78 to C-86).
Vegetation Treatments Using Herbicides on BLM Lands in Oregon

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